EFRAG's final comment letter on the IASB's Exposure Draft ED/2021/8 Initial Application of IFRS 17 and IFRS 9 - Comparative Information (Proposed amendment to IFRS 17)

​EFRAG expresses its appreciation for the IASB's swift response and delivery of the Exposure Draft because this is an urgent issue. ​EFRAG welcomes and supports the IASB proposal as it will allow insurance entities to provide more useful information about their activities during the comparative period and also reduce operational challenges.

However, there are some remaining concerns that EFRAG would like the IASB to address when finalising the amendment. For example, ​EFRAG recommends that the IASB aligns the scope of the classification overlay and the temporary exemption from applying IFRS 9 (which is under IFRS 4 Insurance Contracts) due to operational complexity and presentation inconsistencies in the consolidated financial statements. 

Also, EFRAG suggests that the IASB states explicitly that the classification overlay may be applied from a date pre-dating the publication of the ED or the final amendment.

EFRAG's final comment letter is available here.​​