Summary of Submissions
[ Last Updated 21 November 2005 ]
Submissions received on Review of the Financial Reporting Act 1993 Part I: The Financial Reporting Structure: Discussion Document
14 July 2004
Approximately 90 submissions were received from a range of entities, including public and private companies, government agencies, legal and accountancy firms, representative bodies, academics, private individuals, and the not-for-profit sector.
Feedback from the discussion document on the financial reporting structure indicated a number of broad trends:
- There was general agreement that some form of differential reporting requirements were appropriate;
- The majority of submitters were in favour of (at least) three tiers of reporting entities, although there was some support for an Australian two-tier approach;
- Some submitters suggested alterations to the numerical thresholds proposed, with 50 employees (instead of 20) the most common revision suggested;
- Most submitters agreed with removing requirements for tier 3 entities, Many also favoured the prospect of a "best-practice" guide for these companies;
- Some companies queried why a business that is closely-held, operated by its owners, and with potentially very few (or no) external stakeholders should be required to report publicly;
- Most not-for-profit entities were concerned at the potential cost implications of producing complex financial reports;
- There was some concern at lack of detail (at this stage) as to the substantive reporting requirements of tier 2 entities;
- Fewer trends were apparent in relation to audit and filing; and
- Some submitters also expressed views in relation to the consolidation of accounts and the reporting requirements on overseas companies. Both these issues will be included in Part II of the Review.
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