Chapter 3
Chapter 3
3. The oversight role of the trustees. (Concern: Trustees should demonstrate more clearly
how they are fulfilling the oversight function.)
4. Funding of the IASC Foundation. (Concern: The funding structure of the IASC
Foundation needs to be examined.)
5. The composition of the IASB. (Concern: The geographic backgrounds of the IASB
members need to be examined.)
6. The appropriateness of the IASB’s existing formal liaison relationships. (Concern: More
guidance is needed in the constitution regarding the role that liaison relationships play.)
7. Consultation arrangements of the IASB. (Concern: Consultative arrangements need
to be improved.)
8. Voting procedures of the IASB. (Concern: For approval of a standard, the current
“simple majority” approach should be replaced with a “super majority” approach.)
9. Resources and effectiveness of the IFRIC. (Concern: Given the likely increase in
demand for IFRIC interpretations, the current arrangements are inadequate.)
10. The composition, role, and effectiveness of the SAC. (Concern: Steps should be taken
to make better use of the SAC.)
A proposal published by the trustees of the IFRS Foundation builds on governance
enhancements implemented as a result of the first Constitution Review, completed
in 2005 (these reviews take place every five years). For example, in 2005, the IASC
Foundation’s trustees changed the most important criterion for IASB membership
from “technical expertise” to “professional competence and practical experience.”
Indeed, Hans Hoogervorst, who succeeded David Tweedie as IASB chairman in July
2011, was the immediate past chairman of the Dutch securities regulator, and he did
not have an accounting background. The trustees published a report on the changes to
the Foundation’s constitution made as a result of the second part of their 2008–2010
constitution review. They launched a program to enhance investors’ participation in the
development of IFRS. In early 2009, the trustees revised the constitution to increase the
number of Board members from 14 to 16 and specified geographical quotas for member-
ship: four from North America, four from Europe, four from Asia/Oceania, one from
South America, one from Africa, and two to achieve geographical balance. Further, as
many as 3 of the 16 members could be part-timers. Further, in response to the crit-
icism that the IASB is a private-sector standard-setter and is not likely to act in the
public interest, the trustees created a Monitoring Board, which consists of leading fig-
ures from regulators in the world (namely, representatives of the SEC, Japan’s Financial
Services Agency, the European Commission, and the Emerging Markets and Technical
Committees of IOSCO) with the functions of overseeing the standard-setting activities
of the IASB and approving the appointment of trustees.
of a single set of accepted standards by several regulatory bodies. From a soft viewpoint,
it refers to diminishing differences among accounting standards issued by several regu-
lators. According to a third viewpoint, it refers to a situation where two or more jurisdic-
tions agree on a core set of common standards, allowing varying interpretations
regarding non-core issues. Similarly, in implementing the international “convergence”
process, three fundamental approaches can be adopted. First, the aim could be to merge
all standard-setting bodies into a unified “global” body. From a theoretical point of
view, it is often argued that the unified solution of a single international standard-setting
body is optimal. Second, the aim could be to recognize each of the existing standard-
setting bodies as the sole authority in its respective jurisdiction. Accordingly, it could
also be argued that discretion and flexibility in accounting standards through mutual
recognition is theoretically more desirable than uniformity and rigidity, and when the
incentive consequences and the investment effects of accounting standards are taken
into consideration, then discretion can be superior to uniformity. Third, the aim could
also be to recognize that a national standard-setting body can coexist with international
coordination bodies. The IASB’s main objective is to achieve international convergence
with its standards. In other words, the efforts of the IASB are directed toward develop-
ing a high-quality set of standards for use internationally for financial reporting pur-
poses (global standard-setting).15
According to its former chairman, the IASB’s strategy is to identify the best in
standards around the world and build a body of accounting standards that constitutes
the “highest common denominator” of financial reporting. The IASB has adopted a
principles-based approach to standard-setting and has obtained the support of U.S.
regulators (even though U.S. standard-setters historically have taken a rules-based
approach). On the other hand, the IASB’s structure is similar to that of the U.S.
standard-setter, recognizing that the FASB has the best institutional structure for devel-
oping accounting standards.
The major concerns in achieving IFRS convergence include:
• The complicated nature of particular standards, especially those related to financial
instruments and fair value accounting.
• For countries with tax-driven national accounting regimes, using IFRS as the basis for
taxation may be a problem.
• Disagreement with certain significant IFRS, especially those related to financial state-
ments and fair value accounting.
• Insufficient guidance on first-time application of IFRS.
• For countries with limited capital markets, there is little benefit to be derived from
using IFRS.
• Investor/user satisfaction with national accounting standards.
• IFRS language translation difficulties.
The IASB has taken initiatives to facilitate and enhance its role as a global standard-setter.
The issuance of IFRS 1 is one such initiative. IFRS 1 was issued in response to the concern
about a lack of guidance on first-time application of IFRS. The official language of the
IASB is English, and IFRS are written in this language. The IASB has attempted to address
the translation issue by permitting national accountancy bodies to translate IFRS into more
than 30 languages, including Chinese, French, German, Japanese, Portuguese, and Spanish.
In addition to the problem that IFRS have not yet been translated into very many languages,
15
G. Whittington, “The Adoption of International Accounting Standards in the European Union,”
European Accounting Review 14, no.1 (2005), pp. 127–53.
International Convergence of Financial Reporting 75
research has shown that translation can be problematic, as some terms in English have no
direct equivalent in other languages.16
With the increasing trend toward the adoption of IFRS in many countries, including
Australia and the EU member nations, a large number of companies now use IFRS in
preparing their financial statements. An important initiative was the IASB’s decision
to hold a series of public roundtable forums to provide opportunities for those who had
commented on an Exposure Draft to discuss their views on the proposals with members
of the IASB.
A significant number of Board members had direct liaison responsibility with national
standard-setters.17 As a result, unlike its predecessor, the IASB was formally linked to
national standard-setters in at least some countries, and the liaison Board members were
able to coordinate agendas and ensure that the IASB and those national bodies were work-
ing toward convergence.
IFAC supported the IASB’s objective of convergence. For example, at its July 2003
meeting, held in Quebec, Canada, IFAC approved a compliance program designed to pro-
vide clear benchmarks to current and potential member organizations in ensuring high-
quality performance by accountants worldwide. This program required member bodies to
implement, with appropriate investigation and disciplinary regulations, both IFAC stan-
dards and IFRS. IFAC’s Auditing and Assurance Standards Board (IAASB) also issued
new guidance clarifying when financial statements were in full compliance with IFRS. In
its 2007 annual report, the IFAC highlighted, among other things, the progress in achiev-
ing international convergence through IFRS.
As stated earlier in this chapter, the main objective of the IASB is to achieve interna-
tional convergence with IFRS. However, as Zeff points out, some obstacles to comparability
are likely to arise in areas of the business and financial culture, the accounting culture, the
auditing culture, and the regulatory culture.18 He also warns that, in addition to the obsta-
cles to convergence due to the problems of interpretation, language, and terminology, the
impact of politics could create a “catch-22” situation. He states:
The more rigorous the enforcement mechanism—that is, the more authority and the larger
budget a country gives to its securities market regulator to fortify the effort to secure
compliance with IFRS—the more lobbying pressure that will be brought on the IASB,
because companies in such countries will know that they have no “escape valve,” no way
of side-stepping the adverse consequences, as they see them, of a proposed IASB standard
or interpretation. If the auditor is strict and the regulator is strict, political lobbying of the
standard setter, IASB, may become more intense. If a powerful company or group of com-
panies do not like a draft standard, they will have an incentive to engage in politicking of
the standard-setting body. Hence it becomes a Catch-22.
16
T. S. Doupnik and M. Richter, “Interpretation of Uncertainty Expressions: A Cross-National Study,”
Accounting, Organizations and Society 28, no. 1 (2003), pp. 15–35. These researchers found, for
example, that German speakers do not view the English word “remote” (used in the context of the
probability that a loss will occur) and its German translation “Wahrscheinlichkeit äußerst gering” as
being equivalent.
17
The IASB initially had official liaison with national standard-setters from Australia, Canada, France,
Germany, Japan, New Zealand, the United Kingdom, and the United States.
18
S. Zeff, “Political Lobbying on Proposed Standards: A Challenge to the IASB,” Accounting Horizons 16,
no. 1 (2002), pp. 43–54.
76 Chapter Three
EXHIBIT 3.2
IFRS not permitted 23 jurisdictions (e.g., Argentina, Thailand, Tobago, Tunisia,
Use of IFRS in 175
and Uzbekistan)
jurisdictions*
IFRS permitted 25 jurisdictions (e.g., American Samoa, Dominican Republic,
Note: 21 jurisdictions have no Mexico, Moldova, Maldives, and Nepal)
stock exchange (e.g., Albania IFRS required for some 10 jurisdictions (e.g., Belarus, Belgium, Botswana, Dubai-UAE,
and Afghanistan).
Fiji, and Kazakhstan)
IFRS required for all 96 jurisdictions (e.g., some EU countries, Australia, Hong Kong,
(with some variations) Turkey, and Canada)
20
Excerpt from a speech delivered before the Committee on Banking, Housing and Urban Affairs of the
United States Senate, Washington, DC, February 14, 2002.
78 Chapter Three
Further, it pointed out that the volume of rules would hinder the translation into different
languages and cultures. The Global Accounting Alliance (GAA) supported a single set of
globally accepted and principles-based accounting standards that focused on transparency
and capital market needs and would be ideal for all stakeholders.21 In February 2010, the
IOSCO, in a report entitled “Principles for Periodic Disclosure by Listed Entities,” pro-
vided securities regulators with a framework for establishing or reviewing their periodic
disclosure regimes. According to the report, its principles-based format allows for a wide
range of application and adaptation by securities regulators.
21
The Global Accounting Alliance was an alliance of 11 leading professional accounting bodies in the
United States, the United Kingdom, Canada, Hong Kong, Australia, Germany, Japan, New Zealand, and
South Africa formed in November 2005 to promote quality services, share information, and collaborate
on important international issues.
22
David Illigworth, president of the Institute of Chartered Accountants in England and Wales, in a
speech at the China Economic Summit 2004 of the 7th China Beijing International High-Tech Expo,
May 21, 2004.
International Convergence of Financial Reporting 79
satisfy all of the parties involved throughout the world seems an almost impossible task.
Not only would convergence be difficult to achieve, but the need for such standards is not
universally accepted. A well-developed global capital market exists already. It has evolved
without uniform accounting standards. Opponents of convergence argue that it is unneces-
sary to force all companies worldwide to follow a common set of rules. They also point out
that this would lead to a situation of “standards overload” as a result of requiring some
enterprises to comply with a set of standards not relevant to them. The international capital
market will force those companies that can benefit from accessing the market to provide
the required accounting information without convergence. Yet another argument against
convergence is that because of different environmental influences, differences in account-
ing across countries might be appropriate and necessary. For example, countries that are at
different stages of economic development or that rely on different sources of financing
perhaps should have differently oriented accounting systems. Professor Frederick Choi
refers to this as the dilemma of global harmonization. According to him, the dilemma is
that the thesis of environmentally stimulated and justified differences in accounting runs
directly counter to efforts at the worldwide harmonization of accounting.23
23
See F. D. S. Choi, “A Cluster Approach to Harmonization.” Management Accounting, August 1981 , pp.
27–31.
24
Gresham’s law is named after Sir Thomas Gresham (1519–1579), an English financier in Tudor times.
It means, briefly, “Bad money drives out good.”
80 Chapter Three
customers, government agencies, and the general public as potential users of financial
statements but concludes that financial statements that are designed to meet the needs of
investors will also meet most of the information needs of other users. This is an important
conclusion because it sets the tone for the nature of individual IFRS, that is, that their
application will result in a set of financial statements that is useful for making investment
decisions.
than through distributions to owners. Equity is defined as assets minus liabilities. Income
should be recognized when the increase in an asset or decrease in a liability can be measured
reliably. The Framework does not provide more specific guidance with respect to income
recognition. (This topic is covered in IAS 18, Revenue.) Expenses are recognized when the
related decrease in assets or increase in liabilities can be measured reliably. The Framework
acknowledges the use of the matching principle in recognizing liabilities but specifically
precludes use of the matching principle to recognize expenses and a related liability when
it does not meet the definition of a liability. For example, it is inappropriate to recognize an
expense if a present obligation arising from a past event does not exist.
Adoption of IFRS
There are a number of different ways in which a country might adopt IFRS, including
requiring (or permitting) IFRS to be used by the following:
1. All companies; in effect, IFRS replace national GAAP.
2. Parent companies in preparing consolidated financial statements; national GAAP is
used in parent company–only financial statements.
3. Stock exchange–listed companies in preparing consolidated financial statements.
Nonlisted companies use national GAAP.
4. Foreign companies listing on domestic stock exchanges. Domestic companies use
national GAAP.
5. Domestic companies that list on foreign stock exchanges. Other domestic companies
use national GAAP.
The endorsement of IFRS for cross-listing purposes by the IOSCO and the EU’s deci-
sion to require domestic-listed companies to use IFRS for consolidated accounts beginning
in 2005 have provided a major boost to the efforts of the IASB.
The IFAC supports IASB in its efforts at global standard-setting. The IFAC 2008 annual
report highlights initiatives during the credit crisis and the need for convergence to global
standards.
The IFAC G20 accountancy summit in July 2009 issued a renewed mandate for adop-
tion of global standards in which it recommended that governments and regulators should
step up initiatives to promote convergence to global accountancy and auditing standards.