Staff paper

Agenda reference: 1C

IFRS Foundation Trustees meeting—Due Process Oversight Committee

Date June 2024

Project Post-implementation Review of IFRS 9—Impairment
Topic Summary of feedback and the IASB’s responses
Iliriana Feka ([email protected])
Contacts
Riana Wiesner ([email protected])
This document is prepared for discussion of a public meeting of the IFRS Foundation Trustees’ Due Process
Oversight Committee (DPOC). The Trustees are responsible for governance of the IFRS Foundation, oversight of
the International Accounting Standards Board (IASB) and International Sustainability Standards Board (ISSB),
and for delivery of the IFRS Foundation’s objectives as set out in the IFRS Foundation Constitution.

Introduction

1. The purpose of this paper is to report on the due process undertaken in the Post-
implementation Review of IFRS 9—Impairment (PIR of IFRS 9—Impairment)
and to seek the DPOC’s confirmation that it has been completed satisfactorily.

2. At its May 2024 meeting, the IASB decided that sufficient work had been completed
to conclude the PIR of IFRS 9—Impairment and requested the staff prepare the
Project Summary and Feedback Statement (the Report).

3. The Due Process Handbook requires the IASB to report to the DPOC when it has
completed a post-implementation review and provide the DPOC with a draft of the
Report. A draft of the Report has been circulated to the DPOC (but not as a public
paper, given that it is still draft). The IASB expects to finalise the Report in July 2024,
if the DPOC is satisfied that the IASB has completed the PIR of IFRS 9—Impairment
satisfactorily.

4. Does the DPOC agree, based on the materials provided, that the IASB has
completed the PIR of IFRS 9—Impairment satisfactorily and that the Report can
be finalised and published?
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Background

5. The Due Process Handbook states that a post-implementation review has two phases:

(a) First phase—the IASB identifies matters to be examined, drawing on

discussions with the IFRS Interpretations Committee, the IASB’s advisory
groups and other interested parties. The IASB consults publicly on the matters
identified in the form of a request for information.

(b) Second phase—the IASB considers the comments from the public consultation
along with the information it has gathered from any additional analysis and
other consultative activities. On the basis of that information, the IASB
presents its findings and sets out the steps it plans to take, if any, as a result of
the review.

6. A post-implementation review ends when the IASB presents its findings and sets out
the steps it plans to take, if any, as a result of the review.

Objective of post-implementation reviews

7. When the IASB issues a new requirement, it includes an effects analysis of the likely
benefits and costs arising from the new requirement. Costs comprise initial and
ongoing financial and other costs.

8. The objective of a post-implementation review is to assess whether the effects of

applying the new requirements on users of financial statements, preparers, auditors
and regulators are as intended when the IASB developed those new requirements.

9. A post-implementation review includes consideration of how contentious matters that

the IASB considered during development of the new requirements, and how market
developments since those new requirements were issued, are being addressed in
practice.

10. A post-implementation review concludes with a determination of whether:

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(a) overall, the new requirements are working as intended. Fundamental questions
(ie ‘fatal flaws’) about the clarity and suitability of the core objectives or
principles in the new requirements would indicate that they are not working as
intended; and

(b) there are specific questions about application of the new requirements. If there
are specific application questions, the IASB may still conclude that the new
requirements are working as intended. However, those specific application
questions would be addressed if they meet the criteria for whether the IASB
would take further action (see paragraphs 33–35 of this paper).

11. A post-implementation review is not a standard-setting project and does not

automatically lead to standard-setting. It is also not intended to lead to the resolution
of every application question.

12. However, post-implementation reviews can identify improvements that can be made
to a new requirement, to the standard-setting process or the structure of IFRS
Accounting Standards.

The IASB’s objectives when issuing IFRS 9—Impairment

13. IFRS 9 Financial Instruments was issued in 2014 and became effective for annual
periods beginning on or after 1 January 2018.

14. The IASB developed IFRS 9 with the overall objective of improving the requirements
for financial reporting of financial instruments to enhance the relevance and
understandability of information about financial instruments for users of financial
statements. IFRS 9 was issued in three discrete stages reflecting the key areas of the
requirements: classification and measurement, impairment and hedge accounting.

15. As noted in the Basis for Conclusions on IFRS 9, the IASB’s main objective in
developing the impairment requirements was to provide users of financial statements
with more useful information about expected credit losses on an entity’s credit
exposures to facilitate users’ assessment of the amount, timing and uncertainty of

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future cash flows. In the IASB’s view, to achieve this objective, the expected credit
loss model had to:

(a) address the delayed recognition of credit losses under the incurred loss model
in IAS 39 Financial Instruments: Recognition and Measurement; and

(b) reduce the complexity arising from applying multiple impairment models for
financial instruments.

16. The expected credit loss model in IFRS 9, complemented by the related disclosures in
IFRS 7 Financial Instruments: Disclosures, resulted in the following key differences
compared to the requirements in IAS 39:

(a) the same impairment model is applied to all financial instruments that are
subject to impairment accounting, removing a major source of complexity in
IAS 39;

(b) more timely recognition of expected credit losses because they are recognised
throughout the life of a financial instrument and the amount of expected credit
losses recognised is updated at each reporting date to reflect changes in credit
risk. This requirement removed the threshold for recognising credit losses only
after such losses were incurred;

(c) the impairment model is forward-looking, broadening the information required

to be considered. The measurement of expected credit losses is based on
reasonable and supportable information about past events, including historical
credit loss information for similar financial instruments, current conditions and
forecasts of future economic conditions; and

(d) improved disclosures about credit risk, requiring entities to provide

information that explains the basis for their expected credit loss calculations
and how they measure expected credit losses and assess changes in credit risk.

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How the PIR of IFRS 9—Impairment was conducted

17. In July 2022 the IASB began the first phase of the PIR of IFRS 9—Impairment and
the IASB discussed the plan for the first phase of the project at its July 2022 meeting.

18. To inform the first phase of the project and to gather evidence on application of
impairment requirements in IFRS 9, the IASB reviewed academic research and other
literature, benchmark analysis published by various stakeholders and Agenda
Decisions issued by the IFRS Interpretations Committee.

19. The IASB also considered matters that were contentious during the development of
the IFRS 9 impairment requirements (as described in the Basis for Conclusions on
IFRS 9, the Effects analysis and the Basis for Conclusions on IFRS 7). Those matters
included:

(a) the recognition of 12-month versus lifetime expected credit losses—

recognition of lifetime expected credit losses only after a significant increase
in credit risk;

(b) the principle-based assessment of significant increases in credit risk since

initial recognition. This included the approaches for determining whether a
significant increase in credit risk occurred (for example, collective versus
individual assessment, absolute versus relative assessment of changes in credit
risk);

(c) the recognition of expected credit losses for unrecognised financial

instruments such as loan commitments and financial guarantee contracts; and

(d) objective-based disclosure requirements. Considering the differences in how

entities approach credit risk management, the IASB decided to include
objective-based disclosure requirements about credit risk in IFRS 7 to allow
entities to decide how much detail to disclose and how much emphasis to place
on different aspects of the disclosure requirements.

20. In addition, the IASB members and staff held 30 outreach meetings with a wide range
of stakeholders (see Appendix B). The purpose of this outreach was to provide the

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IASB with sufficient information to identify the matters for which it would seek
further feedback through a request for information.

21. These outreach activities included consulting the IASB’s consultative bodies at their
public meetings (Capital Markets Advisory Committee, Global Preparers Forum,
Accounting Standards Advisory Forum and Islamic Finance Consultative Group), as
well as gathering detailed input through meetings with small groups of stakeholders
that have a particular interest in impairment requirements of IFRS 9 (such as analysts
of financial entities, industry groups for financial and non-financial entities,
regulators, auditors and academics).

22. As discussed in the IASB’s February 2023 meeting, the information collected during
these activities suggested that stakeholders found that applying the forward-looking
expected credit loss model results in more timely recognition of credit losses than
applying IAS 39, addressing the problem of delayed recognition of credit losses.
Stakeholders said that the impairment requirements generally work well in practice,
including in periods of increased economic uncertainty. For example, stakeholders
told the IASB that the application of the requirements during the covid-19 pandemic
demonstrated that the core objectives or principles in IFRS 9 relating impairment are
appropriate.

23. However, stakeholders identified areas of diversity in application of the requirements,

including disclosure requirements in IFRS 7 for credit risk, and identified application
challenges relating to specific requirements.

24. In April 2023 the IASB approved the publication of the Request for Information:
Post-implementation Review of IFRS 9—Impairment (the RFI). Based on the evidence
gathered in the first phase, the IASB decided to focus questions in the RFI on
particular matters relating to the impairment requirements in IFRS 9 and credit risk
disclosure requirements in IFRS 7. The RFI was published on 30 May 2023, with
comments due on 27 September 2023 (a 120-day comment period).

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25. The second phase of the PIR started after the publication of the RFI and the IASB
continued its consultation with stakeholders during the comment period, participating
in 18 events with preparers, users of financial statements, prudential and securities
regulators, auditors, national standard-setters and academics.

26. The IASB received 79 comment letters on the RFI. Although the IASB received only
one comment letter from users of financial statements, IASB members and staff
participated in seven outreach events with groups of investors and financial analysts
(see Appendix B).

27. In November 2023 the IASB discussed the summary of feedback received on the RFI.
The IASB noted that overall, the PIR feedback was positive. Almost all respondents
to the RFI said that the requirements work as intended with no fatal flaws. Feedback
in response to the RFI largely provided the same views and identified the same issues
as the feedback the IASB had received previously through its extensive consultation
with stakeholders (as described in paragraphs 22–23 of this paper). However, the
comment letters provided further details on the application of the requirements, such
as real-life examples and common practices.

28. Feedback on specific areas of the requirements was considered by the IASB between
February 2024 and May 2024 to decide what, if any, action to take in response (see
paragraphs 36–51 of this paper).

29. At its meeting in February 2024, the IASB also discussed an update to the academic
literature review. This literature review included nine papers, in addition to the
literature considered during the first phase of the project.

30. Furthermore, to supplement the feedback from stakeholders on the application of

credit risk disclosure requirements in IFRS 7 and inform its response to the feedback,
at its meeting in May 2024 the IASB also considered an academic research report
prepared by external academics and staff analysis of current practice examining how
entities disclose credit risk information applying IFRS 7.

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31. At its May 2024 meeting, the IASB decided that sufficient work has been completed
to conclude the project and requested the staff to prepare the Report. Subject to
approval from the DPOC, the IASB expects to publish the Report in July 2024.

32. Appendix A of this paper sets out the due process steps followed in this project.
Appendix B of this paper sets out the distribution of respondents to the RFI and
outreach participants by stakeholder type and by geographical region.

Reminder of the approach for assessing feedback in a post-

implementation review

33. The IASB considers whether to take any action on matters identified in post-
implementation reviews if there is evidence that:

(a) there are fundamental questions (ie ‘fatal flaws’) about the clarity and
suitability of the core objectives or principles in the new requirements; or

(b) the benefits to users of financial statements of the information arising from
applying the new requirements are significantly lower than expected (for
example, there is significant diversity in application); or

(c) the costs of applying some or all of the new requirements, or the costs of
auditing and enforcing their application, are significantly greater than expected
(or there is a significant market development since the new requirements were
issued for which it is costly to apply the new requirements consistently).

34. If the IASB decides to take any action on a particular matter, the prioritisation of a
matter as high, medium or low depends on the extent to which evidence gathered
during the post-implementation review indicates that:
(a) the matter has substantial consequences;
(b) the matter is pervasive;
(c) the matter arises from a financial reporting issue that can be addressed by the
IASB or the Interpretations Committee; and

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(d) the benefits of any action would be expected to outweigh the costs. To
determine this, the IASB would consider the extent of disruption and
operational costs from change and the importance of the matter to users of
financial statements.

35. The prioritisation of matters as high, medium or low determines when the matter is
addressed. See the IASB’s process for post-implementation reviews for further details.

Findings from the PIR of IFRS 9—Impairment

36. After analysing the evidence gathered in the PIR of IFRS 9—Impairment, the IASB
concluded that the impairment requirements in IFRS 9 are working as intended. In
particular, the IASB concluded that:

(a) there are no fundamental questions (ie ‘fatal flaws’) about the clarity or
suitability of the core objectives or principles in the requirements;

(b) in general, the requirements can be applied consistently. However, further

clarification and application guidance is needed in some areas to support
greater consistency in application;

(c) the benefits to users of financial statements from the information arising by
applying the impairment requirements in IFRS 9 are not significantly lower
than expected. However, targeted improvements to credit risk disclosures are
needed to further enhance the usefulness of information to users; and

(d) the costs of applying the impairment requirements and auditing and enforcing
their application are not greater than expected.

37. Applying the approach outlined in paragraphs 33–35 of this paper to the matters
raised in the PIR of IFRS 9—Impairment, the IASB decided:

(a) to classify as medium priority the matters identified by stakeholders relating to

credit risk disclosures. The IASB will add a project to its research pipeline to
make targeted improvements to specific disclosure requirements in IFRS 7
(paragraphs 40–44 of this paper); and

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(b) to classify as low priority the matters relating to financial guarantee contracts
and to consider these matters during the next agenda consultation
(paragraphs 45–48 of this paper).

38. The IASB decided to take no additional action on the matters raised by stakeholders
relating to the interaction of the impairment requirements with other requirements in
IFRS 9—namely, the requirements for modification, derecognition and write-off of
financial assets. The IASB had already decided in July 2022 that it will consider these
matters as part of its research pipeline project Amortised Cost Measurement
(paragraphs 49–51 of this paper).

39. The IASB decided to take no further action on other matters identified in the PIR of
IFRS 9—Impairment.

Credit risk disclosures

40. At its meeting in May 2024, the IASB discussed feedback on the application of the
credit risk disclosure requirements in IFRS 7. Most stakeholders said that there are no
fatal flaws with the credit risk disclosure objectives in IFRS 7 and that the
combination of disclosure objectives and specific requirements is the right approach
for a general purpose—rather than industry specific—Standard such as IFRS 7.

41. However, most stakeholders (including users of financial statements) reported some
diversity in how much information entities disclose about credit risk and the format in
which the information is provided. Most feedback related to specific disclosure
requirements such as information about sensitivity analysis, post-model adjustments
or management overlays, significant increases in credit risk and forward-looking
information.

42. Stakeholders further explained that the quantity, quality, and level of disaggregation
of information disclosed by different entities for these areas vary in practice. These
differences are reducing comparability between similar entities and as a result, reduce
the usefulness of information to users of financial statements.

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43. To achieve greater consistency in the information disclosed by entities, stakeholders

suggested the IASB support the disclosure objectives by adding or amending the
specific disclosure requirements, accompanied by application guidance or illustrative
examples.

44. In response to the feedback, the IASB decided to classify these matters as medium
priority and add a project to its research pipeline to make targeted improvements to
the disclosure requirements in IFRS 7 about credit risk.

Financial guarantee contracts

45. At its meeting in April 2024, the IASB discussed application questions raised by
stakeholders relating financial guarantee contracts. Those questions were:

(a) how to assess if a financial guarantee contract held qualifies for inclusion in
the measurement of expected credit losses for the related financial instrument;

(b) if a financial guarantee held does not qualify for inclusion in the measurement
of expected credit losses, how to separately account for it applying IFRS
Accounting Standards; and

(c) how to account for a financial guarantee contract issued by an entity, including
how to calculate expected credit losses, if premiums are received over time.

46. The IASB noted that some of these questions also relate to requirements of other
IFRS Accounting Standards (for example, requirements in IFRS 17 Insurance
Contracts or in IAS 37 Provisions, Contingent Liabilities and Contingent Assets). The
feedback received did not suggest that there are substantial operational or financial
reporting consequences. However, some feedback indicated that these questions arise
frequently in practice and particularly, in times of economic crisis whereby the effect
from financial guarantee contracts is more prominent.

47. In response to feedback, considering the prioritisation criteria, the IASB decided to
classify as low priority the matters about financial guarantee contracts and consider
these matters as part of the next agenda consultation.

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48. Considering the matters as part of the agenda consultation would help obtain a more
holistic view about applying the requirements in different IFRS Accounting Standards
to financial guarantee contracts. Accordingly, it would provide the IASB with better
information to assess whether actions are needed to effectively respond to such
feedback.

Application of the impairment requirements in IFRS 9 with other

requirements

49. At its meeting in April 2024, the IASB discussed the matters relating to the interaction
between the impairment requirements with other requirements in IFRS 9. The main
matters were:

(a) how to apply the impairment requirements in IFRS 9 with the requirements for
modifications, derecognition (including forgiveness of contractual cash flows)
and write-off of financial assets;

(b) how to interpret the definition of credit losses in particular circumstances; and

(c) how to account for write-offs, including recoveries from amounts previously
written off.

50. As mentioned in paragraph 38 of this paper, as a result of findings from the post-
implementation review of IFRS 9—Classification and Measurement, the IASB
decided in July 2022 to add to its research pipeline the Amortised Cost Measurement
project to consider potential clarifications to the requirements and related application
guidance in IFRS 9 for the modification, derecognition and write-off of financial
assets.

51. At the time, the IASB acknowledged that there is an interaction between impairment
requirements and these other requirements in IFRS 9. Therefore, the IASB concluded
that this project will also consider the related findings from the PIR of IFRS 9—
Impairment.

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Appendix A—Confirmation of Due Process Steps

Step Nature IASB DPOC

Determining the timeline for the Required In July 2022, the IASB discussed the objectives, activities and The DPOC was informed in
post-implementation review timeline for the first phase of the PIR of IFRS 9—Impairment. October 2022 that the work on the
first phase of the PIR of IFRS 9—
Impairment had commenced.

Determining the scope, including Required In the first phase, 30 meetings were held with stakeholders The DPOC was reminded of
identifying the important or including preparers, auditors, users of financial statements, activities being undertaken in the
contentious issues that arose national standard-setters and regulators. This included first phase of the Post-
during development of the Standard meetings with the IASB’s consultative bodies. implementation Review at its
March 2023 meeting.
The history of the development of the impairment
requirements in IFRS 9 together with matters subsequently
brought to the attention of the IASB and the IFRS
Interpretations Committee were analysed to identify the
important and contentious issues.
The IASB also performed an academic literature review to
understand empirical evidence on implementation and
application of the impairment requirements in IFRS 9.
The IASB considered the analysis of feedback from its first
phase outreach and identified matters it considered warranted
further examination at its February 2023 meeting (see Agenda
Paper 27A, Agenda Paper 27B and Agenda Paper 27C for the
IASB’s February 2023 meeting).

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Step Nature IASB DPOC

After the initial assessment, one of Required At its April 2023 meeting, the IASB approved the publication of The DPOC was informed in June
two routes may be taken: the RFI and set a 120-day comment period. 2023 that the RFI was published
with a comment period of 120
(a) a request for information
published to invite public days.
comment, with appropriate
response period; or
(b) after its initial assessment, the
IASB may decide that it would
be premature to undertake a
review at the time.

The IASB considers whether it is Optional During the second phase of the PIR of IFRS 9—Impairment Not applicable
necessary to supplement the the IASB conducted extensive and focused consultation with
responses to the request for stakeholders, including its consultative bodies.
information with other evidence,
At its February 2024 meeting, the IASB discussed an update
such as an analysis of financial
to the academic literature review conducted in the first phase
information, a review of academic
of the Post-implementation Review, including nine additional
or other related research on the
academic research papers.
implementation of the Standard
being reviewed, or consultations At its May 2024 meeting, the IASB discussed an academic
with relevant parties. research report prepared by a team of external academics and
staff analysis of current practice about the application of credit
risk disclosure requirements in IFRS 7.

Project teams analyse and Required The IASB discussed a summary of the feedback received on The DPOC was informed, at its
summarise comment letters for the the RFI at its November 2023 meeting. October 2023 meeting, that the
IASB’s consideration. The IASB staff were analysing feedback
All comment letters and summaries of the feedback were
posts all comment letters in relation from comment letters and
posted on the project page on the IFRS Foundation’s website.

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Step Nature IASB DPOC

to the request for information outreach, with plans to begin
online. discussions with the IASB at its
November 2023 meeting.

Follow up action after concluding Required The IASB discussed what action, if any, it should take at its The DPOC was informed about
the post-implementation review. meetings between February 2024 and May 2024. the high-level feedback to the RFI
and the IASB’s future plans for
The IASB’s decisions are summarised in paragraphs 36–51 of
the Post-implementation Review
this paper.
at its meeting in February 2024.

IASB meetings are held in public Required The PIR of IFRS 9—Impairment was discussed at public IASB The DPOC was informed about
and papers are publicly available. meetings held between July 2022 and April 2023 (first phase) progress on the project at its
All decisions are made in a public and November 2023 and May 2024 (second phase). meetings in October 2022, March
session. 2023, June 2023, October 2023
The project page on the IFRS Foundation’s website has been
and February 2024.
maintained throughout the project.

The IASB presents its findings in a Required The draft report has been circulated to the DPOC. The DPOC is asked to confirm
public report. that the IASB may finalise the
Report at this meeting.

Recommendations to DPOC about Optional Step performed and no changes to the IASB’s procedures Not applicable
changes to the IASB’s procedures were identified.
(such as how the effects of a
Standard should be assessed or
additional steps that should be
taken in developing a Standard).

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Appendix B—Respondents and participants by stakeholder type

and by geographical region

Public consultation through a Request for Information

B1. In May 2023, the IASB published the RFI for public comment. The RFI was open for
comment until 27 September 2023. The IASB received 79 comment letters, which are
available on the IFRS Foundation’s website. 1

B2. The data in these tables should be considered in conjunction with the stakeholder
engagement events to gather feedback during the project (paragraphs B5–B6).

B3. Respondents to the RFI represented various stakeholder groups:

Table B1—Respondents by stakeholder type

Type of respondent Number of Percentage of
respondents respondents (%)
Accounting firm 9 12
Preparer 24 30
Regulator 7 9
National standard-setter or 35 44
accountancy body
User 1 1
Other 3 4
Total 79 100
B4. Respondents to the RFI represented various geographical regions:

Table B2—Respondents by geographical region

Geographical region Number of Percentage of
respondents respondents (%)
Africa 5 6
Asia-Oceania 23 29
Europe 31 39
Latin America 4 5
North America 3 4
Global 13 17
Total 79 100

1
Included in this total is one comment letter which was received after the comment period deadline.

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Stakeholder engagement

B5. During the PIR of IFRS 9—Impairment, IASB members and technical staff met with
a wide range of stakeholders, which included participating in 30 stakeholder-
engagement events during the first phase and 18 events during the second phase of the
project. Stakeholders consulted included academics, users of financial statements,
preparers, prudential and securities regulators, auditors, national standard-setters and
the IASB’s consultative bodies (Capital Markets Advisory Committee, Global
Preparers Forum and Accounting Standards Advisory Forum). Some of the events
were facilitated by national standard-setters or professional accountancy bodies.

B6. The events included participants from various stakeholder groups:

Table B3—Participants by stakeholder type

Type of participant Number of events Percentage of
events (%)
Academics 2 4
Accounting firms 6 12
Preparers and industry 13 27
organisations
Regulators 3 6
National standard-setters 9 19
Users of financial statements 7 15
Mixed groups 8 17
Total 48 100

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