International Financial Reporting Standards: Revised Readiness Toolkit
International Financial Reporting Standards: Revised Readiness Toolkit
This is the revised word version of the published International Financial Reporting Standards:
readiness toolkit, which is available on our website, www.nao.org.uk. This revised toolkit takes
into account the finalised IFReM produced by HM Treasury in July 2008 and details the main
IFReM developments since the first toolkit was produced: accounting for Public Private
Partnership (PPP) and Private Finance Initiatives (PFI); intangible assets; infrastructure assets;
and IFRS 8 Operating Segments.
This version has expandable word tables that will enable clients to complete the document
electronically and share the results within their organisation and with their NAO audit teams.
The questions and issues raised in the document are directly comparable to the published
version.
If you have any queries about your use of this document, then please contact the NAO.
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HELPING THE NATION SPEND WISELY
The Comptroller and Auditor General is an Office of the House of Commons. Hs is the head of the
National Audit Office, which employs some 850 staff. He, and the National Audit Office, are totally
independent of Government. He certifies the accounts of all Government departments and a wide
range of other public sector bodies; and he has statutory authority to report to Parliament on the
economy, efficiency and effectiveness with which departments and other bodies have used their
resources.
Introduction
The transition from UK Accounting standards to International Financial Reporting Standards (IFRS)
and the IFRS version of the Treasury’s Financial Reporting Manual (IFReM) is the largest change to
UK public sector financial reporting since the introduction of resource accounting. HM Treasury
set the revised timetable for the transition in FD Letter 08/12, including Trigger Point dates for
key actions in order to achieve IFRS-compliant financial statements for the year to 31 March
2010. Awareness of the key issues and a planned approach will ensure that the transition is
managed effectively and that the timetable is achieved.
The NAO have developed this ‘readiness toolkit’ to help our clients consider the work they need
to do in advance of the first set of audited IFRS accounts and establish the key financial reporting
issues for their organisation. We have also included an Annex outlining the key impacts of the
transition to Financial Instrument Standards for the 2008-09 financial year, which entities may
find useful.
The toolkit is designed to be used by client staff to assess the impact of the transition on their
business and financial statements. The toolkit:
Outlines each applicable standard, and any relevant Treasury adaptations or interpretations
for the central government sector;
Details the key areas of each of the applicable standards, where they differ from current UK
GAAP and the FREM; and
Suggests a series of questions and actions which management should consider in defining
their approach to the transition
We have designed the document to be as comprehensive as possible and to address the majority of
the issues in implementing IFRS. However, it is not intended to replace the need for detailed
knowledge of the standards and the IFReM adaptations. It is important that the issues are considered
by the business as a whole, not just finance staff in isolation, as implementation in the private sector
suggests that in many cases, the detailed knowledge required to successfully introduce IFRS lies
outside the finance function.
Section A is designed to pull together the key issues and processes that management need to
take into account;
Section B considers the individual International Financial Reporting Standards and the areas
of impact;
Section C notes some of the key lessons from the private sector from implementation of
IFRS.
Annex 1 details some of the considerations around the implementation of the financial
instrument standards for FRS, to be implemented in 2008-09.
NAO Audit teams will be available to discuss the process of transition and timetable with clients as
required and will audit the restatement of figures required by IFRS 1 – First Time Adoption of IFRS, in
line with the requirements of Treasury’s trigger points.
Note – Due to current legislative restrictions within the Charities Act, charitable NDPBs will continue
to prepare their accounts in accordance with the Charities SORP, which draws from current UK
GAAP. This checklist should therefore not be used for charities, unless IFRS-compliant consolidation
schedules are required for Resource Accounts or Whole of Government Accounts purposes.
SECTION A - OVERALL SUMMARY OF MANAGEMENT ACTIONS
Background
This section summarises the management actions that are required to implement IFRS successfully. In
completing this section you will want to draw on information gathered in Section B.
Management will need to ensure that sufficient steps are taken to successfully implement IFRS and
the IFReM. In particular, management will wish to review their activities and their organisation so
that they are aware of the impact of the transition to the new standards and that they have sufficient
resources and knowledge to ensure a successful transition.
Management will need to ensure that they are able to produce financial reporting information on an
IFRS basis to feed into restated comparatives. Until 31 March 2009 management will also need to
produce information on the current UK GAAP basis for their 2008-09 published financial statements. In
overview there is a need for organisations to:
Entities will need to consider the following standards in their first time adoption review process:
The standard also sets out a number of exemptions that may be applied when adopting IFRS.
However, for UK Government implementation Treasury have clearly stated that adjustments should
only be made if they are material.
If an entity wishes to apply either of these exemptions a full audit trail must be produced to outline
the assessment and sufficient evidence must be provided to evidence that the application of the
exemption is appropriate.
The main issues that bodies need to be aware of when adopting IFRS 1 are:
A full audit trail for all adjustments from UK GAAP to IFRS will be required;
Additional reconciliations and disclosures will need to be produced, see detailed sections
below;
A significant amount of analysis and documented evidence will be required even when
proving ‘nil’ adjustments;
Key issues need to be flagged early and discussed with auditors to ensure there is timely
agreement on accounting treatment;
The length of disclosures within the accounts as a result of IFRS will be increased;
Early engagement with Audit Committees is essential to ensure they are aware of the process
and the impact of the change to IFRS; and
Significant investments in terms of time and resources are likely to be required to ensure
that all issues with IFRS are resolved, especially for more complex accounts.
The Treasury has adapted the rules of IFRS 1 in the IFReM. This section reflects these adaptations and
interpretations.
IFRS 1 – Areas of impact Yes/No/Not applicable
Process
17. Has full consideration been given to the key
issues for applying full retrospective restatement
of IFRS required by the Treasury’s Trigger Points?
Restatement of Balances
18. Has a restatement of the Balance Sheet as at
31 March 2008 been carried out and submitted to
the NAO by 30/09/2008?
The adoption of IFRS is an opportunity for clients to revisit their accounting policies and ensure that
they comply with the guidance in all areas.
The IFReM states that the departmental boundary is different from the concept of a group under
generally accepted accounting practice: it is based on in-year budgetary control and not on strategic
control. The IFReM also gives details of bodies both inside and outside the departmental resource
accounting boundary, with NDPBs specifically excluded.
However, there may be some impact on NDPBs and Trading Funds as they will be applying the
consolidation and boundary standards in full.
IAS 27 – Subsidiaries;
IAS 28 - Associates; and
IAS 31 - Joint Ventures.
Jointly
controlled assets:
Its share of the jointly controlled assets.
Any liabilities it has incurred directly.
Its share of any liabilities incurred
jointly.
Its share of the joint venture income and
expense.
Any expenses it has incurred.
If an entity has any assets that it is planning to sell, or property that is held as an investment, then
these standards will apply.
IFRS 5 applies to a disposal group (group of assets and associated liabilities to be disposed of by sale
or otherwise together as a group in a single transaction) and non-current assets held for sale (that are
not under the scope of financial instruments or IAS 40 Investment Property).
IAS 40 defines investment property as “property held to earn rentals or for capital appreciation or
both, rather than for: use in the production or supply of goods and services; for administrative
purposes; or sale in the ordinary course of business”.
Note - There is no link between assets held for sale and discontinued operations. Discontinued
operations will not have a significant impact in the public sector as the IFReM states that machinery
of government transfers do not count as discontinued operations.
The standards that impact on the accounting for non-current assets are:
Note – These standards do not apply to assets held for sale, biological agricultural assets,
exploration and evaluation assets, mineral rights and reserves, or investment properties.
There is the opportunity for entities to revisit their accounting for non-current assets as a result of
the adoption IFRS and introduce a more component based approach. This will require material
components of non-current assets to be capitalised and depreciated separately, which will allow a
more accurate reflection of the consumption of economic benefits and the recapitalisation of
components when they are replaced. However, we advise entities to take a pragmatic approach to
the recognition of components under IAS 16 and only recognise components if there is a clear case for
doing so.
The applicability of IAS 16 to infrastructure and heritage assets is detailed in the IFReM in Chapter 6.
The Treasury have adapted the rules of IAS 38 in the IFReM and, as a result, we are not expecting
significant additions or removals from entities’ balance sheets. However, where there is a clear case
for capitalisation of intellectual property and database type assets, they should be recognised.
The IFReM states that cost of capital is outside the scope of IAS 23 and, therefore, should not be
capitalised.
Background
Under IFReM most PPP / PFI assets will come onto the public sector balance sheet.
The accounting treatment under IFRS is determined by whether the PPP arrangement, including PFI
contracts, meets the definition of a service concession arrangement under IFRIC 12 Service Concession
Arrangements. If the definition is met, the asset will be on the grantor’s balance sheet, valued in the
same way as other assets of that generic type, with the liability valued accordingly with reference to
the capital value of the contract.
The standards that apply to PPP arrangements, including PFI contracts, are:
IFRIC 12 Service Concession Arrangements
IAS 17 Leases
Comment
INVENTORIES
Background
The standards that apply to inventories are:
IAS 2 – Inventories;
IAS 11 – Construction Contracts
IAS 41 - Agricultural Assets.
Inventories are defined as “assets held for sale in the ordinary course of business; or in the process of
production for such sale; or in the form of materials or supplies to be consumed in the production
process or in the rendering of services”.
Entities that are inventory rich may need to review their accounting for their inventories against IAS 2
in detail to ensure that they are adopting the correct approach.
INVENTORIES – IAS 2 – FOR LONG TERM CONTRACT INVENTORY ISSUES SEE CONSTRUCTION
CONTRACTS BELOW. EXCLUDES AGRICULTURAL AND FOREST PRODUCTS, MINERALS AND MINERAL
COMPOUNDS.
Background
IAS 2 and SSAP 9 are similar standards in most respects though there are some minor adjustments to
the accounting and the scope of the standards.
Note – This standard applies only to entities that develop long term construction contracts for sale,
IAS 2 or IAS 16 will apply to entities that are purchasing such assets.
(Note – This is a specialist standard which will not apply to many entities. The IFReM clarifies that
this standard only applies in the government sector to activities that are undertaken for commercial
gain, which may, or may not, comprise the full entirety of a reporting entity’s operations. IAS 41
does not apply to goods held under price stabilisation programmes.)
CASH
Background
IAS 7 sets out the format and details of the Cash Flow Statement. The IFReM contains a prescribed
format for the cash flow statement that must be followed. There is, however, one additional rule
within IAS 7 which may impact on some government entities.
In addition IAS 27 states that any land and building leases should be subject to separate assessments
for the land and building elements. This is likely to lead to more buildings being included on public
sector balance sheets.
IFRIC 4 extends the scope of the lease based accounting treatment beyond the legal form or leases to
“lease type arrangements”, which will increase the disclosure and recognition requirements for some
entities.
Finance lease:
Initially recognise the asset as a
receivable at an amount equal to the
net investment in the lease (gross
investment discounted using the implicit
interest rate).
Subsequently recognise income on a
pattern reflecting a constant periodic
rate of return on the lessor’s net
investment in the finance lease.
Operating lease:
Present the asset as appropriate to its
nature.
Recognise lease income in a straight line
basis over the lease term.
Include the transaction expenses with
the asset and depreciate in line with the
entities policy.
OTHER AREAS OF IMPACT
Background
IAS 18, IAS 19, IAS 24 and IFRS 8 contain some areas of revised guidance that will impact on the
entities when adopting IFRS.
Background
The treatment under IFRS 8 is significantly different to SSAP 25 as it requires reporting of segments of
an entity’s internal reporting framework. The standard will apply to all non-department entities,
while departments will continue to produce a Statement of Net Operating Costs by Departmental Aim
and Objective, which will provide the necessary segmental information.
Comment
The introduction of IFRS in the private sector caused a number of difficulties. The standards that
created the most problems were IAS 32, 39 and IFRS 7 on Financial Instruments; IAS 27, 28 and 31 on
Subsidiaries, Associates and Joint Ventures; IFRS 2 on Share Based Payment; and IAS 12 on Income
Taxes. IFRS 2 and IAS 12 will not apply to the public sector in general, but the other standards will be
applied, as adapted by the IFReM, which will result in significant impacts for some organisations.
The key lessons from the private sector transition to IFRS are as follows:
Early preparation is essential to ensure that there is no knock-on impact on the timetables
for the first year of IFRS compliant Accounts;
The level of disclosure required under IFRS and therefore the length of accounts, increased
significantly as a result of the transition and the new standards;
For most organisations the impact assessment and understanding of the new standards took
considerably longer than was expected;
A significant investment in staff training was required;
Flagging up and discussing key issues and potential areas of difficulty with key stakeholders
early aided smooth transition;
Board and Audit Committee engagement is crucial, to ensure that they are involved in the
project and aware of the areas of impact and the potential risks involved in the transition.
The NAO believe that a number of these issues will apply equally to the central government
implementation of IFRS. Given the progress the central government entities have made in bringing
forward the laying and publication of accounts to the pre-recess period, it is important that the
process of implementation is well managed to ensure that timetables are not adversely affected.
ANNEX 1: FINANCIAL INSTRUMENTS
FINANCIAL INSTRUMENTS
Background
The financial instruments standards are long and complex and will need a significant effort in terms of
time and resources in some government entities to ensure that the categories and accounting of such
instruments is correct. Some entities may not be affected by the standards but a considerable amount
of work may still be required to ensure that this is the case. The Standards will come into effect on 1
April 2008 in the public sector.
Financial instruments are defined as, “contracts that give rise to a financial asset of one
entity and a financial liability or equity instrument of another entity”.
Financial assets are defined as “cash, or an equity instrument of another entity, or a
contractual right to receive cash or another financial asset from another entity”.
Financial liabilities are defined as “a contractual obligation to deliver cash to another entity
or to exchange financial assets or liabilities on unfavourable terms”.
The major challenge for clients will be to provide a clear audit trail of their assessment of the impact
of the financial instruments standards, which will need to include a method of review of contracts
that may contain financial instruments.
Examples of specific areas where these standards will impact on the central government sector are:
Entities should note that the Treasury has stated that prior year comparatives will not be restated on
the adoption of these Standards.