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IFAC Response to the IFRS for SMEs Exposure Draft

| Comment Letters

IFAC welcomes this comprehensive review of IFRS for small- and medium-sized enterprises (SMEs). In principle, we support alignment of IFRS for SMEs with full IFRS Standards. As a basic standard-setting principle we believe the concepts that underpin IFRS and IFRS for SMEs should be the same, notwithstanding that their application may need to be modified to address user needs and capacity constraints of SMEs.

We generally agree with most of the proposals in the Exposure Draft and commend the IASB for considering the cost/benefit of each new or amended requirements from the perspective of SMEs and users of their financial statements. We believe it is critical to maintain the concept of ‘undue cost or effort’ and related exemptions as this is part of the foundation on which IFRS for SMEs has been developed and is a contributing reason why it is attractive to SMEs across the world.

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