Accounting Standards Board of Japan
Financial Accounting Standards Foundation
Sustainability Standards Board of Japan

Comment Letters

Comments to the IASB

 2025/3/31 Comments on the Exposure Draft Provisions – Targeted Improvements (Proposed amendments to IAS 37)
 2025/1/17 Comments on the Exposure Draft Equity Method of Accounting IAS 28 Investments in Associates and Joint Ventures (revised 202x)
 2024/11/21 Comments on the Exposure Draft Climate-related and Other Uncertainties in the Financial Statements
 2024/8/2 Comments on the Exposure Draft Contracts for Renewable Electricity (Proposed amendments to IFRS 9 and IFRS 7)
 2024/7/12 Comments on the Exposure Draft Business Combinations-Disclosures, Goodwill and Impairment (Proposed amendments to IFRS 3 and IAS 36)

Comments to the IFRS Foundation

2025/3/28 Joint Response on the Exposure Draft Proposed Amendments to the IFRS Foundation Due Process Handbook
2019/7/29 Comments on Exposure Draft IFRS Foundation Due Process Handbook
2016/9/15 Comment on Exposure Draft – Trustees’ Review of Structure and Effectiveness: Proposed Amendments to the IFRS Foundation Constitution
2015/11/30 Comment on IFRS Foundation Request for Views “Trustees’ Review of Structure and Effectiveness: Issues for the Review”
2012/12/17 Comments on the Invitation to Comment “Proposal to Establish an Accounting Standards Advisory Forum”

Comments to the FASB

2019/10/11 Comments on the FASB’s Invitation to Comment “Identifiable Intangible Assets and Subsequent Accounting for Goodwill”
2015/10/23 Comments on FASB’s Proposed Accounting Standards Update ” Principal versus Agent Considerations (Reporting Revenue Gross versus Net) – Revenue from Contracts with Customers (Topic 606)”
2015/7/3 Comment on FASB’s Proposed Accounting Standards Update “Identifying Performance Obligations and Licensing – Revenue from Contracts with Customers (Topic 606)”
2015/5/29 Comment on FASB’s Proposed Accounting Standards Update “Deferral of the Effective Date – Revenue from Contracts with Customers (Topic 606)”
2014/8/29 Comment on FASB’s ED, Conceptual Framework for Financial Reporting (Chapter 8: Notes to Financial Statements)

Comments to the EFRAG

2021/7/30 Comments on the EFRAG’s Discussion Paper “Accounting for Crypto-assets (Liabilities)”
2018/5/23 Comments on EFRAG’s Discussion Paper “Equity Instruments-Impairment and Recycling”
2014/6/17 Comment on EFRAG Short Discussion Series The equity method: a measurement basis or one-line consolidation?
2014/6/17 Comment on EFRAG Research Paper The role of the business model in financial statements
2013/1/18 Comment on Discussion Paper Towards a Disclosure Framework for the Notes

Others

2023/9/15 Comments on the IOSCO’s Consultation Paper “Consultation on Goodwill”
2006/5/19 Comments on the Discussion Paper “Measurement Bases for Financial Accounting-Measurement on Initial Recognition”