In a joint submission, CA ANZ and CPA Australia support the development, improvement and consolidation of reporting frameworks that focus on information that users need and which enable an entity to tell its whole story. However, the submission recommends the IASB defers this project until such time that the International Sustainability Standards Board (ISSB) is firmly established and operational.

In our view, there is more work that needs to be done to further inform the development of the ED. For example, as currently drafted, from a preparers’ perspective it is not intuitive how the disclosure objectives, areas of content, attributes, key matters and materiality all fit together. This gives rise to the risk of inconsistent application. We encourage a reconsideration of the structure of chapters and most importantly, the development of implementation guidance including a diagram that demonstrates the connections between the various aspects.

Given the ED presents a comprehensive revision, we recommend the IASB conducts field testing of the proposals in jurisdictions that have promoted the Practice Statement. In our view, this is critical to providing necessary insights into the practical application of the proposals. In addition to the field testing, we suggest that research on the following may also assist the project:

• the reasons why various jurisdictions have or have not adopted the 2010 Practice Statement, and  
• understanding how to effectively deliver such information given the rapid shift in how stakeholders are consuming information.

We are supportive of management commentary being subject to independent external assurance. However, there are well documented practical challenges around providing assurance over non-financial, narrative and forward-looking information. Therefore, we raise concerns in relation to the auditability of management commentary until such time that reporting systems and processes reach a level of maturity.  

If the project is not deferred, we emphasise that the proposed effective date of one year after issuance is not reasonable. For jurisdictions that mandate the Practice Statement, this revision will present a significantly different approach to management commentary. Entities will need a transition period in which to implement new data gathering systems and processes. Therefore, the effective date should provide a similar transition time as any new IFRS Standard.