As with any major corporate initiative,planning ahead is critically important.Sizing the task at hand allows for prudent assignment of resources within the company and engaging external assistance.Recognition and indeed sponsorship by top management will help to ensure the success of an IFRS implementation.
Project cost considerations
The cost of an IFRS implementation will be determined largely by the size and nature of the respective company.The SEC predicted that the largest U.S.registrants that adopt IFRS early would incur about $32 million per company in additional costs for their first IFRS-prepared annual reports.This includes both internal and external costs.
Since the costs to convert can be substantial,the upfront planning and project sizing are very important.The estimates by the SEC are clearly averages and may not correlate closely with individual company experiences.
It is evident that the time leading up to the conversion will absorb the vast majority of budgeted dollars.If managed strategically,the implementation could be leveraged to accomplish other needed reporting enhancements previously delayed.When viewed over a longer horizon,an IFRS project could also accelerate system improvements that were only onwish listsfor possible future consideration.
The extent of IFRS conversion
In evaluating and planning for an IFRS conversion,it is not always clear at the outset where thatconversionwill take place.The following summarizes some options plus implications for IT.
a.Consolidated financial statements
In some companies,top-level-only adjustments may be required to convert to IFRS.This may be accomplished in existing consolidation tools and/or may require supporting calculations for the adjustments.While this may suggest that the impact on IT would be minimal,it could nevertheless be necessary for underlying systems to generate the data/information to make the toplevel adjustments.Tools such as Convergence Assistant (discussed later)may be of help here as companies make adjustments to convert to IFRS.
b.Separate financial statements(e.g.subsidiary level)
In an international company operating under various jurisdictional requirements,it may be appropriate for changes connected with IFRS to be made at a subsidiary level.This means,of course,that the underlying transactional detail must be compiled at the subsidiary level.The subsidiary systems may or may not be able to capture such detailed information,which means that system enhancements must be made at that level.
c.In parallel within the ERP system
Some ERP systems have the capability for running parallelsets of accountsfor example,under U.S.GAAP and IFRS.This may assist companies having such systems to plan for and successfully convert to IFRS.IT challenges can still remain under such systems.
Decisions must be made as to the appropriate treatment of transactions so that information feeding into the parallel accounts is appropriate.Further,depending on the accounting issue,information may need to be generated/ understood at a deeper level such as in the payable or receivable systems.In other words,the underlying systems of record may need to be altered to accommodate anew way of looking at things(IFRS).
d.Allow for the possibility of variousversionsof IFRS
Although great efforts are being made to arrive at a singular IFRS that cuts across all global jurisdictions,there is the distinct possibility that companies may face different versions of IFRS.For example,there could be IFRS issued by the IASB,adjustments under European Union regulations,localized versions of IFRS,and so on.IT systems can play an important role in facilitating reporting under such varied scenarios if the systems can render data and information at a granular enough level to be rolled up in different ways.Unless a company's IT systems allow for such fluidity,workarounds may need to be developed.
One possible solution to handling reporting expectations could be the use of XBRL as further discussed below in the Case Study Example:IFRS Transition in Canada.A key feature of the XBRL Global Ledger(GL)Framework and tools such as Convergence Assistant is that they can facilitate reporting under different standards such as U.S.GAAP and IFRS in parallel.XBRL GL can also represent granular business information in parallel such as maturity information,depreciation and many more items.
As companies begin to plan for the conversion project,the project team should be aware that the conversion project will involve multiple years of planning,design and implementation.This is assuming that two years of dual reporting will be mandated or required before the set adoption date.A sample project line summary is presented below.
Internal Control considerations
Compliance with Sarbanes-Oxley requirements and meeting external auditor expectations requires a company to have a documented process of how financial reports are completed.Depending on the extent to which processes will change,be created,or run in parallel in an IFRS implementation,internal controls will need to keep pace.Consequently,internal audit departments must be involved from the beginning of an IFRS implementation and risks and controls identified with any process changes.
The process of creating financial reports under IFRS not only includes different ways of compiling data but also involves judgments as to what that data means.In other words,internal control systems/documentation may need to be expanded to reflect the increased use of judgments and textual descriptions associated with IFRS.
AICPA's Suggested Timeline Chart
As an example,IFRS requires certain assets and depreciation be recorded at component levels and consequently,processes will need to be upgraded to capture this more granular data,and judgments must be documented related to identifying components and determining depreciation lives.
As suggested by the first arrow in the above timeline in Exhibit 4,Awareness and Knowledgemust be gained early in the process.Such training can be obtained either outside the company or through courses available on the internal learning management system.Significant to note is that the need for training extends beyond the accounting department.Anyone that is moderately involved in the IFRS conversion should have some basic understanding of what is driving the need and system upgrades.
Following the initial burst of training,companies will need to develop an ongoing program that keeps staff current on IFRS developments and fast-tracks new hires into this new knowledge arena.Most accountants in the U.S.will have had little or no previous educational background with IFRS.Organizations such as the AICPA have committed to being an excellent resource to the entire financial community on IFRS subjects.