Issue 49, October 2015 IFR S LSWEN RETE INSURANCE While working to address the consequences of differing effective dates, the IASB continues to make progress on participating contracts and the completion of its redeliberations appears to be near. Joachim Kölschbach, KPMG’s global IFRS MOVING TOWARDS INTERNATIONAL insurance leader INSURANCE ACCOUNTING This edition of IFRS Newsletter: Insurance highlights the IASB’s discussions in October 2015 on its insurance contracts project. Highlights Addressing the consequences of differing effective dates l The IASB agreed on a comment period of 60 days for the exposure draft to amend IFRS 4. Classifcation and measurement of fnancial assets on transition l A ‘designation approach’ would be applied to reassess the business model for managing fnancial assets on transition. l The Board confrmed the restatement of comparative information about insurance contracts and that it would not be mandatory for transition reliefs for fnancial assets. Mirroring approach l The Board decided not to proceed with the mirroring approach as proposed in the ED. Presentation and disclosure assessments l The IASB made decisions on presentation and disclosure requirements based on previous decisions made since publishing the ED. l The IASB considered the overall disclosure requirements in light of feedback received from stakeholders. © 2015 KPMG IFRG Limited, a UK company, limited by guarantee. All rights reserved. DECISIONS ON TRANSITION, PRESENTATION AND DISCLOSURE AND DIFFERING EFFECTIVE DATES What happened in October 2015? The story so far … At its cO tober meeting, the IA BS agreed on a comment period hT e current phase o f the insurance proej ct aw s launched o f 06 days of r the epx osure dratf to amend IFR S 4 Insurance in May 200,7 hw en the IA BS published a discussion Contracts and decided that r� stt- ime adopters o f IFR S ow uld be paper PD( ,) Preliminary Views on Insurance Contracts. prohibited rf om applying the deef rral and overlay approaches. More recently, the IA BS ree- px osed its revised insurance hT e IA BS had previously discussed these approaches as contracts proposals of r public comment by publishing the temporary measures to address the accounting conseuq ences epx osure dratf 2/DE 01 7/3 Insurance Contracts t( he )DE in o f applying IFR S 9 beof re the of rthcoming insurance contracts uJ ne 201.3 standard. hT e sta f f epx ect the epx osure dratf to amend IFR S 4 iS nce aJ nuary 201,4 the oB ard has been redeliberating to be issued in eD cember 2015 and any n� alised amendments issues raised through the .DE It initially of cused on the to be issued during 3Q 201.6 model of r nonp- articipating contracts and has no w turned its of cus to modic� ations of r participating contracts. Also this month, the oB ard decided that the scope applied hw en designating n� ancial assets as relating to insurance Interaction with other standards activities of r the overlay approach 3 ow uld also apply hw en hT roughout its redeliberations, the oB ard has considered assessing hw ich n� ancial assets ow uld be subej ct to hw ether the accounting of r insurance contracts ow uld transition reliesf on transition to the of rthcoming insurance be consistent iw th other eix sting or uf ture standards, contracts standard. including the ne w revenue recognition standard – IFR1�S 5 Revenue from Contracts with Customers1. Much o f the nO initial application o f the of rthcoming insurance contracts guidance contained in the DE aw s designed to align iw th standard, the oB ard decided that: the IAs’BS and the FAs’BS oj int standard on revenue • an entity ow uld be reuq ired to restate comparative recognition. inof rmation of r insurance contracts ; and hT e oB ard has also considered many o f the decisions made in the ne w n� ancial instruments standard, IFR9 �S 2 • an entity that has previously applied IFR S 9 ow uld be permitted b( ut not reuq ired ) to restate comparative – including the aw y in hw ich IFR S 9 might interact iw th the n� al insurance contracts standard – because IFR 9 �S inof rmation about n� ancial assets relating to insurance iw ll cover a large maoj rity o f an insurers’ investments. activities only i:f Additionally, the oB ard has eax mined ho w best to address – it is possible iw thout the use o f hindsight ; and the conseuq ences o f the dief f ring eef f ctive dates o f IFR 9 �S and the of rthcoming insurance contracts standard. – the entity chooses to apply the transition reliesf in the of rthcoming insurance contracts standard. 1 2 uD ring its uJ ne 2015 meeting, the oB ard had agreed to modiyf Contents the general measurement model of r participating contracts t( he v‘ ariable ef e approach.)’ It introduced the variable ef e approach to address some staek holder concerns over the approach of r participating contracts proposed in the .DE hT e oB ard thereof re decided this month not to pursue the mirroring approach proposed in the .DE hT e IA BS also considered presentation and disclosure reuq irements of r insurance contracts. It revisited various decisions that it has made since publishing the ,DE and considered ho w eef f ctive they ow uld be in responding to ef edbac k received rf om preparers and users o f n� ancials� tatements. hT e IA BS has no w completed most o f its redeliberations. hT e remainder, hw ich include evaluating the dief f rences betew en the general model and the variable ef e approach of r participating contracts, iw ll be discussed at a later meeting. An eef f ctive date iw ll not be discussed until all other 1. eS e our Issues IneD- pth : Revenue rf om oC ntracts iw th uC stomers redeliberations have been completed. eS( ptember 201.)4 In uJ ly 2015, the IA BS published targeted amendments to the ne w standard. For more detail, read our eN w on the oH rioz n. 2. eS e our First Impressions : Financial instruments –hT e complete .3 For more inof rmation, see Issue 84 o f our IFRS Newsletter: standard eS( ptember 201.)4 Insurance. 2 © 2015 KPMG IFRG Limited, a UK company, limited by guarantee. All rights reserved. ADDRESSING THE CONSEQUENCES OF DIFFERING EFFECTIVE DATES The IASB agreed What’s the issue? on a comment At its eS ptember 2015 meeting, the IA BS completed its deliberations on the proposed measures period of 60 days to address the temporary accounting conseuq ences that might arise rf om applying IFR S 9 beof re for the exposure the of rthcoming insurance contracts standard becomes eef f ctive. It agreed that the proper due process has been completed and that it can begin to ballot the epx osure dratf to amend IFR S .4 draft to amend hT e pacak ge o f temporary measures, i f it is conr� med, ow uld amend IFR S 4 to : IFRS 4. • permit a reporting entity hw ose activities are predominantly insurance a temporary eex mption rf om applying IFR S 9 until 1 aJ nuary 2021 t( he d‘ eef rral approach ;)’ and • give entities issuing insurance contracts that implement IFR S 9 the option to remove rf om prot� or loss some o f the accounting mismatches and temporary volatility that could occur beof re the of rthcoming insurance contracts standard is implemented t( he o‘ verlay approach.)’ Further, i f these changes are conr� med, both approaches ow uld be relevant of r r� stt- ime adopters in periods atf er IFR S 9 becomes eef f ctive, and the overlay approach ow uld also be relevant of r r� stt- ime adopters that early apply IFR S .9 oC nseuq ently, the oB ard needed to consider hw ether entities that are preparing their r� st IFR S n� ancial statements should be permitted to apply these tow approaches. Applicability of the approaches to frst-time adopters of IFRS hT e sta f f argued that ef w r� stt- ime adopters o f IFR S ew re liek ly to apply the overlay and deef rral approaches, even i f they ew re permitted to. hT is is because applying these approaches may be more costly than applying IFR S 9 in uf ll, because r� stt- ime adopters o f IFR S are unliek ly to have applied reuq irements that are similar or identical to IA S 93 Financial Instruments: Recognition and Measurement beof re preparing their r� st set o f IFR S n� ancial statements and the application o f either o f these approaches ow uld reuq ire an entity to provide inof rmation that ow uld result rf om applying IA S ,93 in uf ll or in part. hT e sta f f considered hw ether the deef rral and overlay approaches ow uld be relevant of r r� stt- ime adopters o f IFR,S noting that they ew re intended to address temporary accounting conseuq ences that could arise hw en an entity maek s the transition rf om IA S 93 to IFR S .9 hT is ow uld not be a concern of r r� stt- ime adopters o f IFR,S hw ich ow uld be maik ng the transition rf om their previous local n� ancial reporting reuq irements to IFR S .9 hT e sta f f also believed that prohibiting the deef rral and overlay approaches of r r� stt- ime adopters ow uld be consistent iw th IFR S 1 First-Time Adoption of International Financial Reporting Standards, hw ich reuq ires r� stt- ime adopters o f IFR S to apply the current versions o f IFR S to enhance comparability iw thin an entity over time. What did the staff recommend? hT e sta f f recommended that the IA:BS • allo w of r a comment period o f 06 days of r the epx osure dratf to amend IFR S ;4 and • prohibit r� stt- ime adopters o f IFR S rf om applying the deef rral and overlay approaches. What did the IASB discuss? hT e sta f f inof rmed the oB ard that the uD e Process vO ersight oC mmittee had approved a comment period o f no less than 06 days. © 2015 KPMG IFRG Limited, a UK company, limited by guarantee. All rights reserved. 3 What did the IASB decide? hT e IA BS agreed iw th the sta f f recommendation. KPMG insight Comment period A comment period o f 06 days ow uld epx edite the n� alisation o f any amendments to IFR S .4 Although the implementation period ow uld be compressed, the overlay and deef rral approaches ow uld not need a typical implementation period because the overlay approach builds on inof rmation that is already reported by entities in accordance iw th IA S 93 and the deef rral approach results in a temporary eex mption rf om IFR S ,9 iw th the ecx eption o f limitedd� isclosures. First-time adopters hT is decision ow uld not aef f ct a r� stt- ime adopter o f IFR S that prepares its r� st IFR S n� ancial statements using IA S 93 of r reporting periods that end beof re 1 aJ nuary 201.8 In other ow rds, a r� stt- ime adopter o f IFR S that prepares its r� st IFR S n� ancial statements under IA 93 �S ow uld be alloew d to use the deef rral and overlay approaches hw en it prepares n� ancial statements in subseuq ent periods. Firstt- ime adopters o f IFR S that intend to adopt IFR S 9 in their r� st IFR S n� ancial statements beof re implementing the of rthcoming insurance contracts standard ow uld consider hw ether any accounting mismatches iw ll arise rf om the dief f ring eef f ctive dates o f the tow standards, given that they ow uld be prohibited rf om using the deef rral and overlay approaches. In place o f these approaches, these entities could consider using accounting policies that are consistent iw th the reuq irements o f the of rthcoming insurance contracts standard or early adopting the of rthcoming insurance contracts standard, once it is available. hT e transition reliesf available on adopting the of rthcoming insurance contracts standard ow uld also be available to thesee� ntities. 4 © 2015 KPMG IFRG Limited, a UK company, limited by guarantee. All rights reserved. CLASSIFICATION AND MEASUREMENT OF FINANCIAL ASSETS ON TRANSITION A ‘designation Scope for reassessment of the business model approach’ would What’s the issue? be applied to reassess the At its aJ nuary 2015 meeting, the oB ard decided to conr� m the transition relie f proposed in the ,DE hw ich ow uld mean that, on initial application o f the of rthcoming insurance contracts standard, an business model entity that has previously applied IFR S 9 ow uld be: for managing • permitted to designate n� ancial assets under the af ir value option F( )O V as measured at af ir fnancial assets value through prot� or loss F( PTV L ) to eliminate or signic� antly reduce accounting mismatches; on transition. • reuq ired to revoek previous F O V designations i f the accounting mismatch that led to the previous designation no longer eix sts ; and • permitted to designate an investment in an euq ity instrument as measured at af ir value through other comprehensive income F( ICO V ) and to revoek previous designations. hT e oB ard decided to consider providing uf rther transition relie f to permit or reuq ire an entity to reassess the business model of r n� ancial assets designated as relating to insurance activities, at the date o f initial application o f the of rthcoming insurance contracts standard. hT is ow uld be based on the conditions that eix st at that date. In maik ng these decisions, the IA BS noted that it ow uld need to consider the of lloiw ng: • the n� ancial assets to hw ich the uf rther transition relie f should apply ; and • i f the classic� ation ando/ r measurement o f n� ancial assets changes as a result o f applying the uf rther transition relie:f – hw ether the c hange should be applied prospectively or retrospectively, and ho w any resulting gains or losses should be treated ; and – hw at inf ormation should be disclosed. What did the staff recommend? Topic Staff recommendations and considerations Financial assets What did the staff recommend? designated oC nsistent iw th the approach to identiyf ing n� ancial assets that relate to as relating insurance activities under the overlay approach, the sta f f recommended that to insurance the reassessment o f the business model of r managing n� ancial assets on activities transition to the of rthcoming insurance contracts standard apply to n� ancial to which assets that an entity designates as related to insurance activities. the further transition relief should apply © 2015 KPMG IFRG Limited, a UK company, limited by guarantee. All rights reserved. 5 Topic Staff recommendations and considerations Financial assets What else did the staff consider? designated hT e sta f f believed that introducing another approach of r identiyf ing as relating n� ancial assets that relate to insurance activities ow uld increase the to insurance compleix ty o f n� ancial reporting of r preparers and users. activities to which oC nsistent iw th the designation under the overlay approach, the the further designation o f n� ancial assets of r the purposes o f the reassessment o f transition relief the business model ow uld apply to both : should apply • n� ancial assets that the entity holds to uf nd the settlement o f liabilities (continued) arising rf om epx ected levels o f insurance claims and epx enses ; and • additional o( r surplus ) assets that an entity needs to hold in case insured events are more rf euq ent or more severe, or reuq ire settlement sooner than epx ected. Using an approach consistent iw th the designation under the overlay approach ow uld ecx lude n� ancial assets that are clearly held in respect o f activities other than issuing contracts in the scope o f IFR S .4 Optional or What did the staff recommend? mandatory Reassessing the business model of r managing n� ancial assets on reassessment transition to the of rthcoming insurance contracts standard ow uld be of the business permitted rather than reuq ired. model What else did the staff consider? hT e sta f f noted that the obej ctive o f providing relie f of r the reassessment o f the business model is to address the af ct that, of r some entities, the assessment o f the business model based on af cts and circumstances that eix st hw en the of rthcoming insurance contracts standard is initially applied could be dief f rent rf om the assessment based on af cts and circumstances that eix sted hw en IFR S 9 aw s initially applied. oH ew ver, that ow uld not be the case of r all entities that issue insurance contracts. hT e sta f f thereof re thought that entities that do not af ce such an issue should not be of rced to reassess the business model. Application of What did the staff recommend? the reliefs for nO transition to the of rthcoming insurance contracts standard, the classifcation reassessment o f the business model of r managing n� ancial assets and and designation and ded- esignation o f n� ancial assets under the F O V and the measurement other comprehensive income ICO( ) presentation election of r investments in euq ity instruments should be based on the af cts and circumstances that eix st on initial application o f that standard – i.e. the beginning o f the latest period presented. hT e resulting classic� ations ow uld be applied retrospectively – i.e. as i f the n� ancial assets had alaw ys been so classie� d – and the cumulative eef f ct o f any changes in classic� ation and measurement o f n� ancial assets as a result o f applying those transition reliesf ow uld be recognised in the opening balance o f retained earnings or accumulated ICO . 6 © 2015 KPMG IFRG Limited, a UK company, limited by guarantee. All rights reserved. Topic Staff recommendations and considerations Application of What else did the staff consider? the reliefs for hT e sta f f noted that this treatment ow uld be consistent iw th the transition classifcation reuq irements in IFR S 9 and that it ow uld be dic� f ult of r an entity to and assess the business model of r managing n� ancial assets based on measurement af cts and circumstances that eix sted in the past, particularly iw thout (continued) the use o f hindsight. hT e sta f f also believed that it ow uld be more appropriate to reassess the business model on the basis o f the current af cts and circumstances so that an entity can more accurately ree� ct its business model of r managing n� ancial assets hw en it initially applies the of rthcoming insurance contracts standard. Disclosure What did the staff recommend? requirements hT e entity should disclose its policy of r designating n� ancial assets to hw ich the transition relie f is applied. For any changes in classic� ation and measurement o f n� ancial assets as a result o f applying the transition provisions in the of rthcoming insurance contracts standard, an entity ow uld be reuq ired to disclose, by class o f n� ancial assets : • the measurement category and carrying amount immediately beof re initial application ; • the ne w measurement category and carrying amount determined as a result o f applying the transition provisions ; • the amount o f any n� ancial assets in the statement o f n� ancial position that ew re previously designated under the F O V but are no longer so designated, distinguishing betew en those that the entity aw s reuq ired to ded- esignate and those that it elected to ded- esignate ; and • uq alitative inof rmation that ow uld enable users o f the n� ancial statements to understand ho w the entity has applied the transition provisions to those n� ancial assets hw ose classic� ation has changed as a result o f initial application, including : – the reasons of r any designation or ded- esignation o f n� ancial assets under the F ;O V and – an epx lanation o f hw y the entity came to a dief f rent conclusion in reassessing its business model. What else did the staff consider? hT e sta f f noted that the IA BS has already developed and issued disclosure reuq irements of r changes in the classic� ation and measurement o f n� ancial assets as a result o f applying dief f rent versions o f IFR S 9 – e.g. i f an entity initially applies IFR S 9 2( 00 )9 and subseuq ently applies IFR 9 �S 2( 01.)4 hT e sta f f thought that these disclosure reuq irements ow uld provide useuf l inof rmation of r changes in the classic� ation and measurement o f n� ancial assets on transition to the of rthcoming insurance contracts standard. © 2015 KPMG IFRG Limited, a UK company, limited by guarantee. All rights reserved. 7 What did the IASB discuss? Topic What did the IASB discuss? Optional or hT e oB ard discussed the obej ctive o f reassessing the business model on mandatory initial application o f the of rthcoming insurance contracts standard, and reassessment noted that: of the business • the obej ctive is dief f rent rf om the obej ctive o f reclassic� ation under model IFR S ;9 • the reassessment is based on the af cts and circumstances that eix st at the date o f the initial application o f the of rthcoming insurance contractss� tandard; • the reassessment is similar to initially applying IFR S 9 again ; and • the intention is to provide a onet- ime transition relie.f Disclosure nO e oB ard member believed that uq alitative inof rmation ow uld not be requirements useuf l because it ow uld reef r simply to reclassiyf ing because the ne w standard alloew d it. oH ew ver, other members agreed iw th the sta f f that the uq alitative disclosures ow uld be relevant, because they ow uld disclose the changes in af cts and circumstances that led to changes in the business model assessment. hT ese disclosures ow uld help to provide assurance that the transition relie f aw s used only hw en appropriate. What did the IASB decide? hT e IA BS agreed iw th the sta f f recommendation. The Board Restatement of comparative information on initial application confrmed the What’s the issue? restatement of At present, entities that issue insurance contracts in the scope o f IFR S 4 account of r n� ancial comparative assets under IA S .93 In the uf ture, these entities iw ll have to account of r: information • n� ancial assets under IFR S ;9 and for insurance contracts and • insurance contracts under the of rthcoming insurance contracts standard. that it would not hT e oB ard has reached dief f rent conclusions on the restatement o f priorp- eriod comparative be mandatory for inof rmation under IFR S 9 and in its redeliberations on the of rthcoming insurance contracts standard. transition reliefs for fnancial hT e dief f rent transition approaches are as of llosw : assets. • IFR S 9 contains certain eex mptions rf om uf ll retrospective application of r the classic� ation and measurement reuq irements, including impairment. I f an entity does not restate prior periods, then it ow uld recognise any dief f rence betew en the previous carrying amount and the carrying amount at the beginning o f the annual reporting period that includes the date o f initial application in the opening balance o f euq ity. nE tities ow uld be alloew d to restate comparatives i f this is possible iw thout the use o f hindsight ; and • the DE ow uld reuq ire an entity to apply the of rthcoming insurance contracts standard retrospectively to measure eix sting insurance contracts at the beginning o f the earliest period presented using the of lloiw ng approaches: 8 © 2015 KPMG IFRG Limited, a UK company, limited by guarantee. All rights reserved. – retrospective application, unless this is impracticable as den� ed in IA S 8 Accounting Policies, Changes in Accounting Estimates and Errors; – a simplie� d approach, i f uf ll retrospective application is impracticable ; or – a af ir value approach to retrospective application, in cases hw ere both uf ll retrospective application and the simplie� d approach are impracticable. hT e IA BS considered tow situations based on the dief f ring transition approaches: • an entity initially applies IFR S 9 at the same time as it initially applies the of rthcoming insurance contracts standard ; and • an entity applies IFR S 9 beof re it initially applies the of rthcoming insurance contracts standard. hT e sta f f considered that: • any recommended approaches should be consistent iw th the transition principles o f IFR S 9 and the of rthcoming insurance contracts standard ; and • the presentation o f comparable inof rmation about insurance contracts on the af ce o f the n� ancial statements is important of r assessing the results o f the ne w model, even i f the euq ivalent inof rmation of r n� ancial assets is not reuq ired due to IFR S 9 transition reliesf . For entities that apply IFR S 9 beof re the of rthcoming insurance contracts standard, the sta f f thought that, hw en setting the provisions of r restatements o f comparative inof rmation about n� ancial assets, any decision should aim to arrive at transition reuq irements that are consistent iw th a( nd do not create a disadvantage compared iw th:) • those provided in IFR S 9 of r the initial application o f that standard ; and • those that ow uld apply to entities that apply IFR S 9 and the of rthcoming insurance contracts standard at the same time. What did the staff recommend? hT e sta f f recommended that on initial application o f the of rthcoming insurance contracts standard: • an entity be reuq ired to restate comparative inof rmation about insurance contracts r( egardless o f hw en it initially applies IFR S ;)9 and • i f an entity has applied IFR S 9 beof re the of rthcoming insurance contracts standard, it be permitted to restate comparative inof rmation about n� ancial assets on adoption o f the latter only i f this is possible iw thout hindsight and i f the entity chooses to apply the of lloiw ng transition reliesf in the of rthcoming insurance contracts standard: – to designate or ded- esignate n� ancial assets under the F O V or ICO presentation election of r investments in euq ity instruments ; and – to reassess the business model of r managing n� ancial assets. What did the IASB discuss? hT e oB ard noted that it ow uld be possible of r an entity to restate its n� ancial assets on initial application o f the of rthcoming insurance contracts standard iw thout the use o f hindsight, i f it plans accordingly and begins to trac k the appropriate data hw en it applies IFR S .9 nO e oB ard member believed that the use o f hindsight could be less o f a barrier in practice, given that entities are aaw re o f the ne w standards on the horioz n and ow uld be able to plan accordingly. What did the IASB decide? hT e oB ard agreed iw th the sta f f recommendations. © 2015 KPMG IFRG Limited, a UK company, limited by guarantee. All rights reserved. 9 KPMG insight Insurers iw ll af ce a maoj r challenge in implementing IFR S 9 alongside the of rthcoming insurance contracts standard.o T support them during this transition, the IA BS has developed specic� transition reliesf of r insurance activities. hT is months’ decision to speciyf the same scope of r reassessing the business model of r managing n� ancial assets on adoption o f the of rthcoming insurance contracts standard as of r applying the overlay approach should reduce operational costs and compleix ties of r an entity that chooses to apply IFR S 9 iw th the overlay approach beof re it initially applies the of rthcoming insurance contracts� tandard. hT e oB ard seems to be of cused on maintaining the obej ctive o f retrospective application o f the of rthcoming insurance contracts standard. Modiyf ing this obej ctive might cause insurers more compleix ty hw ile maik ng the transition and ow uld create uf rther comparability issues. It is unclear hw ether entities that apply the overlay approach ow uld be reuq ired to restate comparative inof rmation to reverse out overlay aduj stments on initial application o f the of rthcoming insurance contracts standard b( ecause the overlay approach ow uld o� w rf om amendments to IFR S )4 or hw ether this ow uld be permitted b( ecause the overlay approach relates to accounting of r n� ancial assets ) or prohibited b( ecause this aw s not mentioned as an option in eS ptembers’ discussion.) 10 © 2015 KPMG IFRG Limited, a UK company, limited by guarantee. All rights reserved.