1 March 2023 Dr. Keith Kendall Chair Australian Accounting Standards Board Level 14, 530 Collins Street Melbourne VIC 3000 Via email: standard@aasb.gov.au
Dear Dr. Kendall SUBMISSION – POST-IMPLEMENTATION REVIEW – INCOME OF NOT-FOR-PROFIT ENTITIES We appreciate the opportunity to provide comment to the Australian Accounting Standards Board (the AASB) on the AASB’s Post-implementation Review – Income of Not-for-Profit Entities (the Review). Pitcher Partners is an association of independent firms operating from all major cities in Australia. Firms in the Pitcher Partners network are full service firms and we are committed to high ethical standards across all areas of our practice. Our clients come from a wide range of industries and include listed and non-listed disclosing entities, large private businesses, family groups, government entities, not-for-profit entities and small to medium sized enterprises. We consider that the standards AASB 15 and AASB 1058 as applicable to not-for-profit entities (NFPs) is confusing for NFP preparers and practitioners, it is open to significant judgement and as a result comparability is lacking between NFP entities. Further, the specific NFP requirements seems to be over and above that required for for-profit entities. Whilst the FAQ document developed by AASB staff was a good attempt to assist and educate the sector, we do not consider in the long-term separate FAQ documents to be helpful, as they are difficult to locate. We consider that examples should be part of the guidance within the relevant standard. However, it is also important to consider that NFPs have interpreted the requirements to the best of their ability (albeit with inconsistent outcomes) and would not want to see substantial changes made to the standards that would make it even more difficult to apply the standards and require more guidance and more examples.