How does consultation inform our work?
We operate on the principle that wide, transparent consultation with informed stakeholders enhances the quality of IFRS Standards―IFRS Accounting Standards and IFRS Sustainability Disclosure Standards.
This consultation can be carried out through various means, including invitations to comment on a discussion paper or exposure draft, surveys, individual meetings with stakeholders and public round tables.
Comment letters play a pivotal role in collecting feedback on consultation documents such as exposure drafts and developing an IFRS Standard, because the letters provide considered, public responses to that formal consultation.
Comment letters are usually made public on the relevant project page within five working days of submission.
What makes a comment letter effective?
Comment letters are particularly effective in contributing to the development of IFRS Standards if they:
- address the specific questions asked in an invitation to comment;
- contain a clear rationale for the views expressed and provide related evidence; and
- include any alternatives that we should consider, if applicable.
Comment letters need not answer all the questions in an exposure draft to provide helpful input.
How do we analyse comment letters?
All comment letters received during a consultation period are entered into a database. We capture all comments made by a respondent. Wherever possible, comments are allocated to the specific questions asked in the consultation, and in other cases comments are allocated to broad topics. This allocation process facilitates an effective and efficient analysis of the comments received.
Comments that can be allocated to the specific questions are particularly helpful in the subsequent analysis.
Soon after the comment period ends, the comment letters are initially summarised in comment letter summaries that are discussed in public meetings and published online.
Comment letter summaries provide a general overview of the feedback, including:
- demographic information by jurisdictions and types of respondents;
- summaries of responses by question or by topic;
- explanations of how the feedback is quantified; and
- identifications of trends in feedback by jurisdiction or by respondent type.
The initial comment letter summaries are followed by detailed analysis of respondents’ feedback on particular aspects of a consultation paper. These detailed analyses, as well as final project feedback statements, are also published online.
In analysing comment letters we evaluate the respondents’ views and the explanations and evidence they provided to support those views. We place particular weight on the strength of a respondent’s analysis and substantiating (or supporting) evidence, rather than the mere frequency of a particular view.
The explanations and evidence provided by respondents informs our decision-making on whether to confirm, amend or withdraw a particular proposal, and guides us in evaluating alternative approaches, if needed, and in developing the final requirements.
