Financial Reporting Update

May 2022: Illustrative disclosure checklists, IFRS and more

20 May 2022

16 min read

Uncertain times

Your company, your employees and your customers are likely to be facing challenges in these uncertain times. COVID-19, natural disasters, geopolitical events such as the Ukraine-Russia conflict and inflation are just some of the major issues driving global economic uncertainty today. This evolving uncertainty creates a variety of issues and risks, including changes in consumer demand, disrupted supply chains, staff shortages, increased market volatility and changes to the way we work.
The KPMG resource centre identifies and discusses some of the risks – and opportunities – that are facing governments and organisations in selected economies, which may help you to better understand what the short-term future may hold, and to consider the potential financial reporting implications

Climate change

All companies are facing climate-related risks and opportunities and are making strategic decisions in response – including around their transition to a low-carbon economy. These climate-related risks and strategic decisions could impact their financial statements – and KPIs.
Our climate change resource centre provides FAQs to help you identify the potential financial statement impacts for your business and continues to be updated as significant accounting and reporting issues arise:

Sustainability reporting

Demand for more relevant information continues to grow as businesses are increasingly exposed to climate and other sustainability-related issues.
The new International Sustainability Standards Board (ISSB) will aim to develop sustainability disclosure standards that are focused on enterprise value. This will be a key step towards a global baseline of such standards for organisations around the world.
https://home.kpmg/xx/en/home/insights/2021/12/issb-sustainability-disclosures-talkbook.html

IFRS 17 and IFRS 9 expected impact disclosures for insurers & IFRS 17 for non-insurers

From 2023, the new insurance standard, IFRS 17 Insurance Contracts, will apply for all companies. This is because it applies to contracts, regardless of the issuer, and therefore all companies could be affected, not just insurers.
As we get closer to the date of the initial application, there will be an increasing focus from regulators and investors on understanding the financial impacts. Entities need to determine what disclosures to include in any financial statements issued prior to 2023 to meet the requirements set by IAS 8 to provide useful information to users.
Our IFRS 17 for non-insurers guide (PDF 360 KB) will help you navigate the complexities. It includes a framework for identifying insurance contracts and illustrative examples.

The KPMG 2022 condensed interim illustrative disclosures publication and interim disclosure checklist are available at the link below: https://home.kpmg/xx/en/home/services/audit/international-financial-reporting-standards/ifrs-illustrative-financial-statements.html
The illustrative disclosures guide includes climate change impact related to emission schemes.

Financial Reporting Council (FRC) Publications

FRC 2022 editions of UK and Ireland accounting standards (as well as the foreword to accounting standards and overview of the financial reporting framework).
FRC - XBRL tagging guide – FRC taxonomies. (PDF, 2.3MB) The publication provides guidance on the use of the UKSEF 2021 and UKSEF 2022 taxonomies.
The Wates Corporate Governance Principles for Large Private Companies (PDF, 2.9MB) - The Extent, Coverage and Quality of Corporate Governance Reporting.
Modern slavery reporting practices in the UK (PDF, 4.1MB) – evidence from modern slavery statements and annual reports.
Thematic Review: Discount rates

Ongoing FRC projects

The FRC has two ongoing projects in respect of local GAAP relating to the Periodic Review of FRS 102 and a review of implementation issues.
Further detail on the above ongoing projects being undertaken by the FRC

KPMG Tool for generating newly effective and upcoming IFRS

For further information on new and upcoming IFRS and amendments to IFRS, please refer to the KPMG web tool which allows you to generate a customised list of newly effective and forthcoming IFRS standards for both IASB IFRS and EU IFRS depending on the accounting period of your entity and which contains links to further guidance on each standard or amendment.

EU Taxonomy – FAQs

On 20 December 2021, the European Commission published 22 FAQs (PDF, 825KB) on how financial and non-financial undertakings should report taxonomy-eligible economic activities and assets in accordance with the Taxonomy Regulation Article 8 Disclosures Delegated Act.
On 2 February 2022, the European Commission published a 2nd set of FAQs complimenting the original FAQs issued in December 2021. Both sets of FAQs are intended to assist financial and non-financial undertakings in the implementation of the relevant legal provisions of the EU Taxonomy.

EU Taxonomy - Forthcoming disclosures

Complimentary Climate Change Delegated Act issued on 2 February 2022 – incorporates certain nuclear and gas energy activities into the list of economic activities which will need to be considered for Taxonomy eligibility and alignment reporting going forward. Expected to come into effect from 1 January 2023.
Future Environmental Delegated Act setting out the technical screening criteria for the 4 remaining environmental objectives is expected to be published during 2022.
Further more extensive disclosure requirements for financial undertakings & non-financial undertakings from 1 January 2023, 2024 & 2026 (as applicable) in respect of the Non-Financial Statement under the “Article 8” Delegated Act.
Future Corporate Sustainability Reporting Directive – originally envisaged FY 2023 for large companies listed on EU regulated markets but more likely FY 2024, FY 2026 for small and medium-sized companies listed on EU regulated markets (excluding listed micro entities).

SFDR – Deferral of application date of RTS

The Regulatory Technical Standard (RTS) on SFDR detailing the required Level 2 disclosures was originally deferred from 1 January 2022 to 1 July 2022. On 6 April 2022, the EU Commission published its revised RTS on SFDR (replacing the February 2021 and October 2021 draft reports) which will now be subject to scrutiny by the European Parliament and the Council. It is expected to come into force on 1 January 2023.
In view of the further deferral, the Commission envisages that financial market participants that publish a statement on their due diligence policies on principal adverse impacts of investment decisions on sustainability factors (Article 4(1)(a), 4(3) & (4) of SFDR) will have to comply with the related disclosure requirements on principal adverse impacts laid down in the RTS for the first time by 30 June 2023, with a first reference period of 1 Jan 2022 to 31 Dec 2022.

Extension of TCFD reporting to UK standard listed companies and certain other firms

Climate-related disclosures aligned to the Task Force on Climate-related Financial Disclosures (‘TCFD’) recommendations were originally introduced into the FCA listing rules for ‘premium’ listed UK & overseas commercial companies effective for financial years commencing on or after 1 January 2021. TCFD requirements have now been extended to the following: Issuers of standard listed shares and Global Depositary Receipts, Asset managers, Life insurers and FCA-regulated pension providers.
See links to the FCA publications for information on same and the relevant effective dates: Standard listed companies

Recent UK legislation on climate-related disclosures

The UK Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022 and the UK Limited Liability Partnerships (Climate-related Financial Disclosure) Regulations 2022 were published on 17 January 2022 and apply in respect of any financial year of an in-scope UK company or UK LLP which commences on or after 6 April 2022.
See link to Guidance/FAQs issued by the Department of Business, Energy & Industrial Strategy (PDF, 289KB)

Further extension to Companies (Miscellaneous Provisions) (Covid-19) Act 2020

The interim period of the Companies (Miscellaneous Provisions) (Covid-19) Act 2020 has been further extended to 31 December 2022 by the Companies Act 2014 (Section 12A(1)) (Covid-19) Order 2022 (S.I. 220/2022) and the Industrial and Provident Societies Act 1893 (Section 14A(1)) (Covid-19) Order 2022 (S.I. 219/2022).
See link to the Department of Enterprise, Trade and Employment

Irish Corporate Governance (Gender Balance) Bill 2021

The Bill is currently at the second stage of debate at Dáil Éireann (as at May 2022). The Bill provides for the regulation of gender balance on the boards and governing councils of corporate bodies and for gender quotas to be introduced at boardroom level. It will require all ‘corporate bodies’ (as defined in the legislation) to have 33% of each gender on their boards within a year of commencement of the legislation and 40% within three years.
See link to the Bill at: Irish Corporate Governance (Gender Balance) Bill 2021 – No. 124 of 2021 – Houses of the Oireachtas

New UK listing rules on Diversity and Inclusion

In April 2022, the FCA published its final policy statement on Diversity and inclusion on company boards and executive management (PS22/3). The policy statement introduces new Listing Rules to require certain issuers (as set out in the policy statement) to include a statement in their annual report setting out whether they have met specific board diversity targets. It also expands the reporting requirements to cover the diversity policies of key board committees and to indicate that reporting on board and board committee diversity policies could consider wider diversity characteristics. The requirements are effective for financial years commencing on or after 1 April 2022.
See link to the FCA policy document (PDF, 645KB)