Consultants and auditors have given the International Accounting Standards Board (IASB) and its interpretations committee no clear sense of the way forward on proposed changes to pensions accounting under international standards.
The proposals affect International Accounting Standard 19, Employee Benefits (IAS 19) and its accompanying guidance, International Financial Reporting Interpretations Committee 14 (IFRIC 14), which addresses the IAS 19 asset-ceiling test and surplus recognition.
In a further twist, the UK audit regulator, the Financial Reporting Council (FRC), has weighed into the debate and said it expects UK-listed companies to pay heed to the guidance in the run-up to the year’s annual reporting season.
Consultant actuaries Lane Clark and Peacock (LCP) have hit out at the changes to IFRIC 14 and IAS 19.
LCP partner Tim Marklow said: “IFRIC 14 as it currently stands is a very problematic area. It is a small-print legal lottery where two very similar companies can have very different accounting positions thanks to minor differences in pension scheme rules.
“Do the proposals in the ED help with that? They clarify some areas, but they don’t address the fundamental issue with IFRIC 14, which is that it leads to very different and inconsistent treatment between companies.
“The rules are so complex I don’t think readers of the accounts and investors would be able to make sense of why companies with similar pension schemes are disclosing such different positions.”
Actuarial consultants Towers Watson, however, signalled their support for the changes.
“The proposed changes should reduce diversity in practice,” it said. “However, difficulties remain in interpreting the intent of IFRIC 14 with respect to unlikely or irrational actions that could potentially affect an entity’s unconditional right to a plan’s surplus.”
Among the Big Four audit firms, Deloitte and KPMG broadly supported the IFRIC 14 changes. PWC and EY, however, both raised substantial concerns.
In a 19 October comment letter, PWC argued: “The proposed changes to IFRIC 14 result in a mixed measurement model inconsistent with the underlying principles in lAS 19.”
It went on to argue that the basis for the IFRIC 14 amendment was incompatible with the requirements of IAS 19, the standard that it interprets.
“The proposed changes require an entity to anticipate possible future events (for example, plan amendments or a winding-up) initiated by the trustees,” it said. “IAS 19 precludes such events to be accounted for when they happen.
“These changes appear to be driven by concerns the current guidance permits an entity to recognise a surplus that is not controlled by the entity (and therefore does not meet the definition of an asset in the IASB’s Conceptual Framework).”
The IASB and its interpretations committee issued the proposed changes to IAS 19 and IFRIC 14 in June as a joint exposure draft.
The IFRIC 14 changes, if they are confirmed, will restrict the surplus a DB plan sponsor can recognise in its accounts – irrespective of how likely the plan trustees are likely to seize part or all of that surplus.
The proposals could also force sponsors to take account of statutory requirements that are substantively enacted when they determine the amount of surplus available for them to recognise as an asset.
IFRS IC developed both the amendment to IAS 19 and to IFRIC 14.
The IFRS IC’s predecessor issued IFRIC 14 in 2007 in an effort to explain the application of the standard’s asset-ceiling requirements.
Paragraph 58 of IAS 19 limits the measurement of a DB asset to the “present value of economic benefits available in the form” of refunds from the plan or reductions in future contributions to the plan.
IFRIC 14 also deals with the interaction between a minimum funding requirement and the restriction in paragraph 58 on the measurement of the DB asset or liability.
When a DB plan sponsor applies IAS 19, it must first measure the DB obligation using the projected unit credit method on the one hand, and fair value any plan assets on the other.
This calculation will produce either a DB asset or liability at the balance sheet date. Where a plan is in surplus, the sponsor recognises the lower of any surplus and the IAS 19 asset ceiling.
In addition to the amendment to IFRIC 14, the IASB has also proposed a change addressing the assumptions DB plan sponsors must use in their pensions accounting following a plan amendment, settlement or curtailment.
Meanwhile, the UK audit regulator, the FRC, has complicated the landscape and announced in its 2015 Corporate Reporting Review that it expects companies to make disclosures consistent with the requirements of the as yet unfinalised ED.
The FRC said: “Until the ED is finalised and effective, and IAS 19 and IFRIC 1421 are amended, we would expect companies to disclose any significant accounting judgements made when assessing trustees’ rights, including the extent to which their policies are consistent with the ED.”
Although the FRC has no legal basis to enforce the exposure draft’s requirements, its approach does follow the requirements of IAS 1, which requires entities to disclose critical judgements and areas where there are uncertainties affecting the reported numbers.
Alongside the furore in some quarters over the IFRIC 14 changes, the IASB’s proposed amendment to IAS 19 aimed at addressing the accounting for a plan settlement or curtailment has also received a mixed response.
LCP’s Tim Marklew said: “They are just unnecessarily tinkering. The current rules work fine, and these new rules on remeasuring pension schemes are simply unnecessary.”
Auditors KPMG, however, supports the proposal “because it would result in more useful and precise information and would not be costly to preparers, as the information is already available for the remeasurement required under paragraph 99 of IAS 19.”
The IFRS IC is likely to revisit the exposure draft and decide on the next steps on the project at its scheduled January 2016 meeting.