EFRAG publishes Feedback Statement on Post-Implementation Review of IFRS 16 Leases

EFRAG has published its Feedback Statement on the post-implementation review (PIR) of IFRS 16 Leases. The Feedback Statement summarises constituents' feedback, including responses to EFRAG’s draft comment letter and findings from outreach to different stakeholders. It explains how the feedback received was considered by EFRAG in reaching the positions reflected in the final comment letter.

Most respondents considered IFRS 16 to be broadly working as intended, improving transparency by bringing most leases onto the balance sheet. However, they highlighted significant implementation and ongoing costs, particularly for lease-intensive entities, and generally supported targeted improvements rather than fundamental changes. Key areas identified included clearer guidance on lease term, discount rates and variable lease payments, as well as concerns about the presentation of lease payments in the cash flow statement. Respondents also raised issues regarding interactions with IFRS 9 Financial Instruments and IFRS 15 Revenue from Contracts with Customers.

ABOUT PIR IFRS 16

​The IASB issued a Request for Information (RFI/2025/1) on 13 June 2025. EFRAG invited comments on its draft comment letter, published on 24 July 2025, and released its final comment letter on 23 October 2025.

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