International Accounting Standards Board
30 Cannon Street
London EC4M 6XH
United Kingdom

12 October 2017

Dear Mr Hoogervorst,

Re: Discussion Paper DP/2017/1 Disclosure Initiative - Principles of Disclosure

On behalf of the European Financial Reporting Advisory Group (EFRAG), I am writing to comment on the Discussion Paper DP/2017/1 Disclosure Initiative - Principles of Disclosure, issued by the IASB on 30 March 2017 (the ‘IASB DP).

This letter is intended to contribute to the IASB’s due process and does not necessarily indicate the conclusions that would be reached by EFRAG in its capacity as advisor to the European Commission on endorsement of definitive IFRS Standards in the European Union and European Economic Area.

General comments

EFRAG fully supports the aims of IASB’s Principles of Disclosure project and the overall Disclosure Initiative. As expressed in EFRAG’s response to the IASB’s 2015 Agenda Consultation, in EFRAG’s view the Disclosure Initiative is one of the most important of the IASB’s active projects. In its response to the 2015 IASB Agenda Consultation, EFRAG stressed the importance of having a clear, effective, coherent and comprehensive but concise package of disclosure requirements. Further, EFRAG regretted that the Disclosure Initiative has only resulted in small amendments to standards so far whereas the main project has not yet reached standards-level stage. This lack of progress is disappointing, especially in the light of the substantial research conducted by EFRAG and other regional and national accounting standards bodies related to the disclosure problem.