PwC comment letter on the IIRC consultation draft of the international integrated reporting framework

Comment letter Jul 15, 2013

The PwC network of member firms submitted a comment letter supporting the IIRC’s consultation draft of the international integrated reporting framework.

Overview

The PwC network of member firms submitted a comment letter supporting the IIRC’s consultation draft of the international integrated reporting framework.

We believe integrated reporting has the potential to enhance the depth, breadth and quality of corporate reporting and a principles based framework is a major step in its development. However, integrated reporting is in the development stage and the expansion of reporting to cover environmental, social, governance and other nonfinancial matters will be an evolutionary process that will be guided by stakeholders. As such, PwC network of member firms believes, among other things, that:

  • Emphasis should currently be on how companies can best apply the principles in the framework across all of its applicable reporting, rather than on the preparation of a single integrated report
  • As companies begin the integrated reporting journey, to the extent they report such information, they should report under the framework using the capitals
  • The IIRC, as owner of the framework, should develop application guidance to support the framework
  • The IIRC should clarify the extent to which it will provide practical direct support to companies implementing the framework

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David Schmid
IFRS & US Standard Setting Leader, National Professional Services Group
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