Recent IFRS Disclosure Guidance From the Ontario Securities Commission

The Ontario Securities Commission (OSC) recently released the results of its preliminary review of Ontario reporting issuers’ first International Financial Reporting Standards (IFRS) interim financial reports for the quarter ended March 31, 2011. As well, in IFRS Release No. 2 – A Reminder Before You File Your First IFRS Interim Financial Report, the OSC released a tip sheet to assist issuers in ensuring that they include certain elements in their first IFRS interim financial reports (the Tip Sheet). Both documents are available at this website, recently established by the OSC to provide, in one place, information and guidance to assist issuers with the transition to IFRS.

In its IFRS Release No.1 – Filing Deficiencies in Issuers’ First IFRS Interim Financial Reports (the Release), OSC Corporate Finance has identified three recurring deficiencies made in IFRS filings to date:

  • missing IFRS 1 reconciliation disclosures as required by paragraph 32 of IFRS 1 First Time Adoption of International Financial Reporting Standards;
  • missing opening IFRS statement of financial position on the face of the financial statements, as required by subsection 4.3(2)(e) of National Instrument 51-102 Continuous Disclosure Obligations (NI 51-102); and
  • missing statement of changes in equity as required by subsection 4.3(2)(b) of NI 51-102 and paragraph 20(c) of IAS 34 Interim Financial Reporting.

The OSC noted that the majority of these deficient filings appear to have been reviewed by the issuer’s auditor, since the filings did not include the accompanying notice required by subsection 4.3(3) of NI 51-102 when an interim review has not been performed. If the filings are not reviewed by the auditor, issuers should ensure that they include this required notice.

The Release reminded issuers to ensure that their internal control over financial reporting (ICFR) and disclosure controls and procedures (DC&P) are robust enough to address changes resulting from IFRS transition. The OSC recommended that where necessary, issuers should establish or modify specific ICFR and DC&P in order to prepare its financial statements in accordance with IFRS and securities legislation.

Additional suggestions and reminders are noted in the Tip Sheet, including, with respect to IFRS 1, reconciliations, notes to the interim financial report, unreserved statements of compliance with IAS 34 Interim Financial Reporting, and disclosure regarding accounting policies.

Issuers that have yet to report their interim IFRS financial reports should carefully review the guidance and suggestions offered in the Release and the Tip Sheet. Further guidance on IFRS reports and disclosure is available by clicking here.