In its comment letter, EFRAG generally agrees with the IASB’s assessment of the issues and with its proposed amendments to address them as it believes that they provide practical solutions that would reduce divergences in application.

However, EFRAG provides some recommendations on how to improve the drafting of the proposed amendments in the ED.

EFRAG is also concerned that addressing more and more specific terms and conditions of different share-based plans is resulting in ever-increasing complexity in the requirements of IFRS 2. Therefore, the IASB should envisage a more general review of IFRS 2 to consider all implementation issues in a principle-based way and this could be done as part of a post-implementation review of the Standard.

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