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Deloitte submission on the AASB's proposed Reduced Disclosure Regime (RDR)


Our comment letter to the AASB on ED 192 Revised Differential Reporting Framework can be downloaded below.


  • We support the introduction of a second tier of reporting requirements for the preparation of general purpose financial statements (GPFSs)
  • We generally agree with the board’s proposals for the determination of those entities required to apply ‘Tier 1’
  • We support the retention of full IFRS recognition and measurement requirements for entities applying the proposed ‘Tier 2’ Reduced Disclosure Regime.
  • We support the proposed level of disclosure under the proposed ‘Tier 2’ Reduced Disclosure Regime
  • We do not support mandatory or optional adoption of ‘IFRS for SMEs’ in Australia at this time
  • Whilst the reporting entity concept has served us well in operationalising differential reporting in Australia, we do not believe it is necessary to retain such concept within Australian Accounting Standards. Provided that the requirements of the reporting mandate are developed and established with appropriate consideration of the information needs of users of the financial statements, such approach will produce outcomes similar to the reporting entity concept (where appropriately applied).
Related links
  • Accounting alert 2010/02 – our analysis of the proposals in ED 192
  • Accounting alert 2009/11 – our summary of the key differential reporting and Corporations Act proposals
  • AASB ED 192 Revised Differential Reporting Framework (from the AASB website, PDF 529kb)
  • AASB Consultation Paper Differential Financial Reporting – Reducing Disclosure Requirements (from the AASB website, PDF 196kb)
  • AASB press release ‘AASB proposes radical regime shift to cut burden of disclosures’ (from the AASB website)


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