Comment letter ICA IFRS for SMEs

INTERNATIONAL Route des Morillons 15 Tel: (41 22) 929 88 88 CO-OPERATIVE 1218 Grand-Saconnex Fax: (41 22) 798 41 22 ALLIANCE Geneva E-mail: ica@ica.coop Switzerland Website: www.ica.coop SME Comment Letters International Accounting Standards Board 30 Cannon Street London EC4M 6XH UNITED KINGDOM Comment Letter on the Exposure Draft of a Proposed IFRS for SMEs Dear Members of the IASB, On behalf of the international co-operative community of 800 million members, I am writing to you to comment on the Exposure Draft of a Proposed IFRS for SMEs. The International Co-operative Alliance (ICA), established in 1895, is an association of 230 national co-operatives in 92 countries. A majority of co-operatives being SMEs, we are highly concerned by the IASB proposed IFRS for SMEs and wish to be fully associated and consulted on this project and invited to the round-table discussions. Changes in accounting standards over the past few years have created big challenges for cooperatives. Even though we understand the advantages of creating a unique set of international financial reporting standards for SMEs, it appears to us that some of these standards are not relevant or useful for SMEs and particularly for cooperatives. Indeed, IFRS for SMEs are based on full IFRS: the implementation and use of IFRS for SMEs would require a knowledge and understanding of the full IFRS, which would be difficult for small and medium-size ...