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In its letter, EFRAG notes that it has initiated a European field-test on the Exposure Draft Revenue from Contracts with Customers. At the time the field-test was launched, the expectation was that the Exposure Draft would be issued in September 2011. However, with the Exposure Draft published in November 2011, the comment period overlaps with constituents’ year-end financial closing and the preparation of their annual financial reports. As a result of these competing priorities many constituents are unable to dedicate much time to understanding the Exposure Draft and assess the impact of the proposals in the opening two months of 2012. The effective comment period is therefore drastically reduced.
This short effective comment period has the potential to adversely affect the quality of the input obtained through the field-test. EFRAG is therefore concerned that the IASB would not meet its (and EFRAG’s) objective of avoiding unintended consequences arising from the final standard. Accordingly, EFRAG believes that the comment period should be extended by 60 days in order to facilitate participation in field-tests and commenting activities.
In addition, EFRAG is considering to organise a field-test addressing the operationality of the proposals included in the forthcoming Review Draft on General Hedge Accounting. EFRAG would therefore also like to request the IASB to set the comment period such that constituents have three months, outside their year-end closing period, to respond to the Review Draft and to participate in field-testing activities.
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