EFRAG’s main observations in its letter are:

• The main priority is the finalisation of  the Insurance Contracts Project, the revision of the Conceptual Framework and advancing on the Disclosure Initiative and the Dynamic Risk Management (Macro-hedging) Projects;
• EFRAG welcomes the evidence based standard setting approach but believes that the IASB should better explain how priorities are assigned and what objectives are pursued in each Research project. A categorisation of these projects would be helpful;
• Beyond the Disclosure Initiative and Dynamic Risk Management  (Macro-hedging), EFRAG believes that the following five Research projects should have high priority: Financial Instruments with Characteristics of Equity; Discount Rates; Equity Method; Primary Financial Statements; and Goodwill and Impairment;
• EFRAG underlines the importance of Post-implementation Reviews in helping identify what works and what is in need for improvement in current practice. The use of Reviews should be extended beyond recently issued Standards;
• EFRAG believes that the IASB in its Research activities should leverage on the substantial work of EFRAG and other regional and national accounting standards setters;
• EFRAG supports IASB’s maintenance activities but believes the IASB  needs to strike an appropriate balance with the need for stability for both preparers and users


EFRAG’s Letter