Date posted: 13/03/2026

Submission on ED 338: Application of AASB 18 by superannuation and not-for-profit entities

For entities preparing Tier 1 general purpose financial statements

When issuing AASB 18 Presentation and Disclosure in Financial Statements, the AASB agreed to undertake further work to determine how AASB 18 should apply to superannuation entities, not-for-profit (NFP) private sector entities and NFP public sector entities, which led to deferring the application date of AASB 18 for these entities to annual periods beginning on or after 1 January 2028, instead of 1 January 2027.

Overall, CA ANZ is supportive of the AASB’s proposals in ED 338 Application of AASB 18 and AASB 107 by Superannuation and Not-for-Profit Entities and Operating Cash Flow Reconciliation – For entities preparing Tier 1 general purpose financial statements. Our response is summarised as follows:

Superannuation entities

We support the AASB’s view that there is no need to amend AASB 1056 Superannuation Entities for the revised presentation and disclosure requirements of AASB 18. We have heard that the current requirements of AASB 1056 meet the needs of financial statement users in this sector in a consistent and comparable way and so making changes to align with AASB 18 would not be cost beneficial for the sector.

NFP private sector entities (including universities)

We support the AASB’s view that Tier 1 NFP private sector entities should be required to apply AASB 18. While there are mixed views on the cost-benefit of some aspects, we are of the view that, overall, the revised AASB 18 presentation and disclosure requirements will provide relevant and reliable information for users that is consistent and comparable. However, we urge the AASB to conclude its NFP revisions to the Conceptual Framework before releasing an amending standard based on these proposals.

NFP public sector entities

We also support the AASB’s decision to amend AASB 18 to provide accounting policy choices that will enable the public sector to continue its existing reporting practices. Feedback we have heard indicates that the current requirements of AASB 1049 Whole of Government and General Government Sector Financial Reporting and AASB 101 Presentation of Financial Statements meet the needs of the sector in a consistent and comparable way. Ongoing alignment with the current Government Finance Statistics Manual requirements is also important.