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Royaume-Uni - Réforme des PCGR

La période de commentaires sur les propositions initiales de l’Accounting Standards Board visant une réforme complète des PCGR du Royaume-Uni a pris fin en février 2010.

Une approche à trois volets est envisagée : les entités ayant une obligation d’information du public appliqueraient les Normes internationales d’information financière (IFRS), les entités sans obligation d’information du public pourraient appliquer les IFRS pour les PME, et les petites entités pourraient continuer d’appliquer la norme d’information financière pour les petites entités (Financial Reporting Standard for Smaller Entities).

On s'attend à ce que l’Accounting Standards Board publie cet été son projet d’information financière en cette nouvelle ère d’information fondée sur les IFRS.

Un article du Accountancy Magazine décrit quels devraient être les principes directeurs en la matière au cours des prochains mois. (Consulter l’article «Where now for UK GAAP?» ci-dessous - en anglais seulement.)

Source : Paul-Emile Roy - Canada (25 mai 2010)

Where now for UK GAAP?

Nigel Sleigh-Johnson offers a sensible route.

In February 2010, the comment period closed on the Accounting Standards Board’s initial proposals for fundamental reform of UK GAAP. A three-tier approach was envisaged. Broadly, publicly accountable entities would follow International Financial Reporting Standards (tier 1); non-publicly accountable entities would be eligible to apply the IFRS for SMEs (tier 2); and the Financial Reporting Standard for Smaller Entities would remain available to small entities (tier 3).

Over the summer, the board is expected to publish its final blueprint for this brave new world of IFRS-based financial reporting. What should be the guiding principles as it sets pen to paper in the next few months?

1. Discard existing UK GAAP
The ASB should stick to its guns and replace existing UK GAAP for large and medium-sized companies with the IFRS for SMEs as soon as practicable. UK GAAP for such entities is currently an uncomfortable mishmash of converged and non-converged standards, lacking any strong underlying cohesion. The alternative until recently was full IFRS, complex standards designed to meet the needs of investors in companies in public capital markets, with disclosure requirements more extensive than necessary for users of private company financial statements.

There is now potentially a third option – the IFRS for SMEs, published by the International Accounting Standards Board (IASB) last July. The standard is shorter and more manageable than UK GAAP, in many respects is reasonably close to current UK GAAP requirements, and is a standalone document like the FRSSE. It simplifies the accounting requirements of full IFRS, with substantially fewer disclosure requirements. Naturally, there would be drawbacks to moving to an IFRS-based regime. In particular, there would be a loss of control over the standards UK companies follow, in effect the imposition of the IASB’s one-size-fits-all solutions. As a corollary, there will be pressure for changes to the standard before it is applied in the UK. Even so, it seems likely that, overall, the benefit of ‘tier 2 companies’ moving to the IFRS for SMEs (or a close relative) would outweigh the associated costs. If this is the broad UK consensus, as appears to be the case, a date certain for the switch-over should be set at the earliest opportunity. An orderly transition as early as 2012 – or in any case 2013 – may then be achievable for such companies.

2. Safeguard the interests of small companies
Small companies are arguably the sector least likely to benefit from reform of UK GAAP, and every effort should be made to ensure that the costs of change are kept to a minimum for such entities.

The current FRSSE is widely regarded as meeting the information needs of the users of small company financial reporting at a reasonable cost, and any change to the existing regime should only follow more detailed analysis and consultation than has been undertaken to date. This should take account of recent developments in Brussels: in March, in a landmark decision, the European Parliament voted to permit EU member states to exempt ‘micro-entities’ [see box] from statutory financial reporting altogether. The passing of the proposed legislation into law is far from assured, but if it makes it to the finishing line, the UK government (whichever party wins the general election) seems likely to jump at the chance of reforming small company reporting for the better. If the exemption is enacted, a highly-simplified set of requirements should replace existing UK requirements for micros – the vast majority of small companies. The FRSSE would then be withdrawn, meaning that the small companies not classified as micros would have to move up to the mid-tier regime. If the exemption fails to be enacted, the UK should introduce a new-model FRSSE for small companies. This would retain the current ‘one-stop shop’ features and be based on the IFRS for SMEs, but should exclude any requirements that did not meet rigorous cost/benefit analysis.

What should happen to the FRSSE until such time as the shape of the new regime for small companies becomes clear? Perhaps the current FRSSE should simply be left more or less unaltered until then. This pragmatic approach would avoid costs for small companies and their advisers that would bring few or no benefits should the eventual decision be to abandon the FRSSE in its current form.

3. Add a new tier for subsidiaries
The ASB’s recent proposals would see non-publicly accountable subsidiaries of listed IFRS reporters eligible to use the IFRS for SMEs, but no special regime for subsidiaries. The ASB should think again on this issue.

When deciding whether subsidiaries should use the IFRS for SMEs, a UK parent will consider, inter alia, the practicalities of the consolidation process. The IFRS for SMEs will offer significantly reduced disclosures but, in some cases, the need to make consolidation adjustments for the effects of differing recognition and measurement policies may make it more efficient in terms of time and costs for subsidiaries of IFRS reporters to prepare financial statements under full IFRS.

Several major UK businesses have expressed concern over the implications for subsidiaries of the initial ASB proposals. Some have proposed a further tier for subsidiaries, containing the recognition and measurement requirements of full IFRS while allowing disclosure exemptions. There are arguments for and against this proposal. Much hinges on an assessment of whether exemptions that groups consider advantageous would provide cost savings without disadvantaging users of subsidiary accounts. On balance, the case for recognising business concerns in this area seems sound.

4. Retain the Statement of Recommended Practice
The use of SORPs has significantly improved the quality of financial reporting. The role of sector experts in their development has created SORPs that successfully supplement UK reporting requirements to deal with sector-specific issues. The benefits of this regime should not be discarded lightly. There is a strong and legitimate demand from particular sectors for guidance specific to the UK regulatory and legal environment. In some sectors, such as insurance, a comprehensive international standard is not expected for some time. Robust guidance in the form of a SORP or equivalent will continue to be valuable until such standards are published.

5. The need for education, guidance and training
Many UK constituents will have little knowledge or experience of IFRS or the IFRS for SMEs. Some may feel that they are being asked to respond to important questions without sufficient understanding of the issues and implications. The ASB will therefore need to reach out extensively to explain the practical implications of its blueprint for change, and seek to understand the concerns and challenges that those new to IFRS reporting will be facing.

Ultimately, ending the existence of two parallel GAAPs in the UK makes sense for everyone involved in financial reporting. For example, costs of training and updating staff in separate regimes, which could include IFRS, UK GAAP and the FRSSE, can be significant for smaller firms of accountants in particular. However, the ASB needs to look closely at how constituents would best be supported in terms of education, training and guidance over the next few years. It has not been possible in this space to touch on a number of important aspects of the debate over the future of UK GAAP, not least the implications for ‘public benefit’ entities. A transition to an IFRS-based accounting regime for such entities would present a number of particular challenges. But these should not be allowed to delay changes in the ‘for profit’ sector. It’s time to move on.

By Nigel Sleigh-Johnson (04 May 2010)
Accountancy Magazine

Mercredi 26 Mai 2010

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