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Subsidiaries of companies using IFRS® Accounting Standards can substantially reduce their disclosures and focus more on users’ needs following the release of IFRS 19 Subsidiaries without Public Accountability: Disclosures, from the International Accounting Standards Board. 

A subsidiary that does not have public accountability, and has a parent that produces consolidated accounts1 under IFRS Accounting Standards, is permitted to apply IFRS 19. 

Subsidiaries that currently apply the IFRS for SMEs® Accounting Standard or local GAAP in their statutory financial statements will no longer need to prepare two sets of accounts for group reporting purposes if IFRS 19 is applied.

IFRS 19 offers eligible subsidiaries a practical way of addressing the problems of over-disclosure while reducing their reporting costs – removing the need to either provide disclosures beyond users’ needs or to maintain two separate sets of accounting records.

Brian O’Donovan,
Global IFRS Leader,
KPMG International Standards Group

The requirements in brief

IFRS 19 allows eligible subsidiaries to apply IFRS Accounting Standards with the reduced disclosure requirements of IFRS 19. 

A subsidiary may choose to apply the new standard in its consolidated, separate or individual financial statements provided that, at the reporting date: 

  • it does not have public accountability2
  • its parent produces consolidated financial statements3 under IFRS Accounting Standards. 

A subsidiary applying IFRS 19 is required to clearly state in its explicit and unreserved statement of compliance with IFRS Accounting Standards that IFRS 19 has been adopted (see FAQs below).

Frequently asked questions (FAQs)


All subsidiaries meeting the above eligibility requirements – for example those in sectors such as technology, energy, consumer staples, real estate, industrials, telecommunications, basic materials, healthcare and utilities, along with certain financial services companies.

No. A subsidiary is required to state that it has applied IFRS 19 in its statement of compliance, but the standard does not provide an example disclosure. The following wording may be appropriate:

These [consolidated/separate/individual] financial statements have been prepared in accordance with IFRS Accounting Standards and the reduced disclosure requirements of IFRS 19 Subsidiaries without Public Accountability: Disclosures.

Yes. In fact, additional disclosures are required where they are necessary for users to understand the effect of transactions, and other events and conditions, on the subsidiary’s financial position, financial performance and cash flows.

Conversely, a subsidiary need not provide a specific disclosure included in IFRS 19 if the information resulting from it is not material.

No. A subsidiary can choose to revoke its application of IFRS 19 for future periods. It may also choose to apply the standard again in subsequent periods.

It depends. The reporting framework that the subsidiary used in its immediately preceding period will affect whether the subsidiary is a first-time adopter of IFRS Accounting Standards, as illustrated in the table:

Subsidiary’s financial statements for the immediately preceding period prepared under: Would IFRS 14 apply?
IFRS for SMEs Accounting Standard Yes*
Local GAAP Yes*
IFRS Accounting Standards No


*IFRS 19’s disclosure requirements relating to IFRS 1 First-time Adoption of International Financial Reporting Standards would apply; not those in IFRS 1 itself.

Yes. IFRS 18 Presentation and Disclosure in Financial Statements replaces IAS 1 Presentation of Financial Statements for annual reporting periods beginning on or after 1 January 2027. A subsidiary applying IFRS 19 before IFRS 18 will apply disclosure requirements set out in an appendix to IFRS 19, which are based on IAS 1 rather than IFRS 18.

Effective date and transition

Eligible subsidiaries can choose to apply the standard for reporting periods beginning on or after 1 January 2027. Earlier application is permitted.

Consider whether your subsidiaries are eligible to apply this new IFRS Accounting Standard. Speak to your local KPMG contact for further guidance.

1 That are available for public use.

2 A subsidiary generally has public accountability if it is listed on a public market or holds assets in a fiduciary capacity as one of its primary businesses (e.g. banks, mutual funds etc.). Refer to the standard for the full definition.

3 That are available for public use.

4 IFRS 1 First-time Adoption of International Financial Reporting Standards

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