The IDW notes:
"The IDW appreciates the opportunity to comment on the IASB Discussion
Paper 2013/1 ‘A Review of the Conceptual Framework for Financial Reporting.
In general, we welcome the Board’s decision to reinitiate the Conceptual
Framework project. However, we believe that the timing of the publication of the Discussion Paper is inopportune as the Board is still working on its four main standard projects (revenue recognition, leases, insurance contracts and
financial instruments). It is essential to ensure that these long-term projects are consistent with one another and completed with priority. Upon completion of these projects, the Board should use the insights gained for revising the
We agree with the Board’s decision to develop a complete set of proposals for a revised Conceptual Framework, i.e. not to continue with the phased approach.
Given the complexity as well as the interdependency of the various issues
addressed in the Conceptual Framework project, a phased approach would
necessarily result in unintended consequences and could lead to new
inconsistencies. However, we had expected the Board to undertake a
fundamental and comprehensive review of the Conceptual Framework rather
than merely ‘updating, improving and filling in gaps’. Currently it seems to us
that the IASB is only proposing a quick fix solution.
We doubt whether the proposals in the Discussion Paper reflect the significance of the Conceptual Framework appropriately. Many of the proposed approaches (e.g. to profit and loss and recycling or for the distinction between equity and liabilities) seem only ‘half-baked’. Moreover, in some cases the dividing line between the principles in the Conceptual Framework and the provisions in IAS 1 is not readily identifiable (e.g. in the case of going concern). Obviously, much more time is needed, and we urge the IASB to take the time necessary to revise the Framework in such a way that it can provide both, a consistent and sound conceptual basis for financial reporting under IFRS and be of real assistance to the IASB in developing or amending future Standards.
Although the specific provisions at the Standards level should always take
precedence over the principles of the Conceptual Framework, the Conceptual
Framework must be generally binding when the IASB develops or amends
Standards. Therefore, we recommend that – going forward – the IASB’s
adherence to the final provisions of the Conceptual Framework should be
monitored. This would also contribute to improving the accountability of the
entire IASB’s standard-setting process. A departure from the Conceptual
Framework should only be possible in rare cases."