Pensions accounting: Tactics before strategy?
Finally on 26 July, the International Accounting Standards Board launched its public consultation on the shape of its future agenda.
"In particular", it would seem, "IASB is seeking feedback on how it should balance the development of financial reporting with the maintenance of IFRSs and - with consideration of our time and resource constraints - those areas of financial reporting that should be given the highest priority for further improvement". It is perhaps the most succinct statement you will find anywhere in the consultation paperwork.
The problem with the consultation document is that it appears to be founded on an extremely poor understanding of what makes up a strategy. And given that a strategy, through tactics, is all about arriving at a goal as a consequence of the successful allocation of resources, it is, to put it mildly, disappointing that the board has made such a poor job of articulating where it wants to be.
For example, it is all well and good to explain that a research effort will guide the IASB toward its future vision for financial reporting. The problem is that the board fails to articulate what that vision is. Even IASB chairman Hans Hoogervorst notes that the consultation poses "deliberately open questions". Too open, perhaps.
Introducing at page seven its "strategy", the board explains: "We think there are three key aspects that should be reflected in our strategic approach towards a future agenda."
Those three "key aspects" are:The diversity of jurisdictions now applying international financial reporting standards Today's more complex market environment A number of changes that require implementing
Point one suggests the board has more than the EU to think about. One way of summing up the three points as a whole is to say the new strategy will take account of the real world. Those of you who might have been hoping against the odds that an IASB-originated strategy might be a relatively simple affair will hit the first of many heart-sink moments by page nine. In addition to the three points, we are told that a separate strategy review conducted by the IASB's parent body, the IFRS Foundation Trustees, has thrown up two "important tensions".
These are:The need to demonstrate the quality and relevance of the standards The risk that practices related to implementation and adoption will diverge
Quite how the latter point is supposed to guide the average reader of IPE is anyone's guess. The chances are that it is code for: if we don't add the projects that the Far Eastern jurisdictions want us to add - foreign-currency translation, real-estate tax treatment - then they will develop their own regional variants of IFRSs.
And so finally we get to the bare bones of the tentative strategy ... well almost. What we actually get are the two categories into which the five "strategic areas" that are "driving the work of the IASB" can be said to fall:
If by now you are screaming 'Just give me the damned strategy!', here it is. Broadly, the IASB plans to strengthen "the consistency of IFRSs" by finalising its work on the conceptual framework and improve the "usability of ﬁnancial reports through the development of a presentation and disclosure framework".
Strategic aim number two, coming hot on the heels of the seemingly contradictory IASB decision to dispense with its academic adviser, is "investing in research and addressing the strategic issues for ﬁnancial reporting to aid future standard-setting and to develop further the IASB's vision of the future shape of ﬁnancial reporting".
One strategic area that is unlikely ever to make it into the canon of great strategic objectives is number three: filling gaps in the IFRS literature by undertaking standards-level projects - ie developing new IFRSs or making major amendments.
The remaining two "strategic areas" are plans to follow-up implementation issues with new IFRSs by conducting post-implementation reviews, and a programme of "targeted, narrow-scope improvements".
And there's more: "In addition to seeking your views on the overall strategic direction and balance of the IASB's agenda, we also want to learn about your views on how you think we should prioritise existing and potential new projects, taking account of the resource limitations we and our stakeholders face."
As for pensions accounting, a candidate project for the board's post-2011 agenda, at page 25, the board explains that work on measurement issues surrounding deﬁned beneﬁt plans and contribution-based promise plans "has not yet commenced".
Here's the rub. If you want the IASB to address pensions, you will have to identify the strategic objective, explain why it matters and provide enough of a research base to make up for the board's past and proven deficiencies. You have until 30 November to make your views known.