EFRAG publishes final comment letter on IASB’s Exposure Draft ED/2021/8 Initial Application of IFRS 17 and IFRS 9 - Comparative Information (Proposed amendment to IFRS 17)

EFRAG has published its final comment letter in response to the IASB's Exposure Draft ED/2021/8 Initial Application of IFRS 17 and IFRS 9 - Comparative Information (Proposed amendment to IFRS 17).

In the comment letter, EFRAG has welcomed and supported the IASB’s proposal as it will allow insurance entities to provide more useful information about their activities during the comparative period and also reduce operational challenges.

However, EFRAG has raised some concerns, which include:

• EFRAG has recommended that the IASB aligns the scope of the classification overlay and the temporary exemption from applying IFRS 9 (which is under IFRS 4 Insurance Contracts) due to operational complexity and presentation inconsistencies in the consolidated financial statements. 
• EFRAG has suggested that the IASB states explicitly that the classification overlay may be applied from a date pre-dating the publication of the ED or the final amendment.
• EFRAG has suggested clarifying the wording related to expected credit loss approach of IFRS 9 not being required by stating that the expected credit loss requirements in IFRS 9 are permitted but not required to be applied.

The final comment letter may be accessed here.