Exploration For and Evaluation of Mineral Resources: International Financial Reporting Standard 6
Exploration For and Evaluation of Mineral Resources: International Financial Reporting Standard 6
Exploration For and Evaluation of Mineral Resources: International Financial Reporting Standard 6
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CONTENTS
paragraphs
INTRODUCTION IN1–IN5
INTERNATIONAL FINANCIAL REPORTING STANDARD 6
EXPLORATION FOR AND EVALUATION OF MINERAL RESOURCES
OBJECTIVE 1–2
SCOPE 3–5
RECOGNITION OF EXPLORATION AND EVALUATION ASSETS 6–7
Temporary exemption from IAS 8 paragraphs 11 and 12 6–7
MEASUREMENT OF EXPLORATION AND EVALUATION ASSETS 8–14
Measurement at recognition 8
Elements of cost of exploration and evaluation assets 9–11
Measurement after recognition 12
Changes in accounting policies 13–14
PRESENTATION 15–17
Classification of exploration and evaluation assets 15–16
Reclassification of exploration and evaluation assets 17
IMPAIRMENT 18–22
Recognition and measurement 18–20
Specifying the level at which exploration and evaluation assets are assessed for
impairment 21–22
DISCLOSURE 23–25
EFFECTIVE DATE 26
TRANSITIONAL PROVISIONS 27
APPENDICES
A Defined terms
B Amendments to other IFRSs
APPROVAL OF IFRS 6 BY THE BOARD
APPROVAL OF AMENDMENTS TO IFRS 1 AND IFRS 6 BY THE BOARD
BASIS FOR CONCLUSIONS
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International Financial Reporting Standard 6 Exploration for and Evaluation of Mineral Resources (IFRS 6) is set out in
paragraphs 1–27 and Appendices A and B. All the paragraphs have equal authority. Paragraphs in bold type state the main
principles. Terms defined in Appendix A are in italics the first time they appear in the Standard. Definitions of other terms
are given in the Glossary for International Financial Reporting Standards. IFRS 6 should be read in the context of its
objective and the Basis for Conclusions, the Preface to International Financial Reporting Standards and the Framework
for the Preparation and Presentation of Financial Statements. IAS 8 Accounting Policies, Changes in Accounting
Estimates and Errors provides a basis for selecting and applying accounting policies in the absence of explicit guidance.
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Introduction
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(c) varies the recognition of impairment from that in IAS 36 but measures the impairment in accordance
with that Standard once the impairment is identified.
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Objective
1 The objective of this IFRS is to specify the financial reporting for the exploration for and evaluation of mineral
resources.
2 In particular, the IFRS requires:
(a) limited improvements to existing accounting practices for exploration and evaluation expenditures.
(b) entities that recognise exploration and evaluation assets to assess such assets for impairment in
accordance with this IFRS and measure any impairment in accordance with IAS 36 Impairment of
Assets.
(c) disclosures that identify and explain the amounts in the entity’s financial statements arising from the
exploration for and evaluation of mineral resources and help users of those financial statements
understand the amount, timing and certainty of future cash flows from any exploration and evaluation
assets recognised.
Scope
3 An entity shall apply the IFRS to exploration and evaluation expenditures that it incurs.
4 The IFRS does not address other aspects of accounting by entities engaged in the exploration for and evaluation
of mineral resources.
5 An entity shall not apply the IFRS to expenditures incurred:
(a) before the exploration for and evaluation of mineral resources, such as expenditures incurred before the
entity has obtained the legal rights to explore a specific area.
(b) after the technical feasibility and commercial viability of extracting a mineral resource are
demonstrable.
Measurement at recognition
8 Exploration and evaluation assets shall be measured at cost.
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to which the expenditure can be associated with finding specific mineral resources. The following are examples
of expenditures that might be included in the initial measurement of exploration and evaluation assets (the list is
not exhaustive):
(a) acquisition of rights to explore;
(b) topographical, geological, geochemical and geophysical studies;
(c) exploratory drilling;
(d) trenching;
(e) sampling; and
(f) activities in relation to evaluating the technical feasibility and commercial viability of extracting a
mineral resource.
10 Expenditures related to the development of mineral resources shall not be recognised as exploration and
evaluation assets. The Framework and IAS 38 Intangible Assets provide guidance on the recognition of assets
arising from development.
11 In accordance with IAS 37 Provisions, Contingent Liabilities and Contingent Assets an entity recognises any
obligations for removal and restoration that are incurred during a particular period as a consequence of having
undertaken the exploration for and evaluation of mineral resources.
Presentation
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Impairment
Disclosure
23 An entity shall disclose information that identifies and explains the amounts recognised in its financial
statements arising from the exploration for and evaluation of mineral resources.
24 To comply with paragraph 23, an entity shall disclose:
(a) its accounting policies for exploration and evaluation expenditures including the recognition of
exploration and evaluation assets.
(b) the amounts of assets, liabilities, income and expense and operating and investing cash flows arising
from the exploration for and evaluation of mineral resources.
25 An entity shall treat exploration and evaluation assets as a separate class of assets and make the disclosures
required by either IAS 16 or IAS 38 consistent with how the assets are classified.
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Effective date
26 An entity shall apply this IFRS for annual periods beginning on or after 1 January 2006. Earlier
application is encouraged. If an entity applies the IFRS for a period beginning before 1 January 2006, it
shall disclose that fact.
Transitional provisions
27 If it is impracticable to apply a particular requirement of paragraph 18 to comparative information that relates to
annual periods beginning before 1 January 2006, an entity shall disclose that fact. IAS 8 explains the term
‘impracticable’.
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Appendix A
Defined terms
This appendix is an integral part of the IFRS.
exploration and Exploration and evaluation expenditures recognised as assets in accordance with the entity’s
evaluation assets accounting policy.
exploration and Expenditures incurred by an entity in connection with the exploration for and evaluation of
evaluation expenditures mineral resources before the technical feasibility and commercial viability of extracting a
mineral resource are demonstrable.
exploration for and The search for mineral resources, including minerals, oil, natural gas and similar non-
evaluation of mineral regenerative resources after the entity has obtained legal rights to explore in a specific area, as
resources well as the determination of the technical feasibility and commercial viability of extracting the
mineral resource.
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Appendix B
Amendments to other IFRSs
The amendments in this appendix shall be applied for annual periods beginning on or after 1 January 2006. If an entity
applies this IFRS for an earlier period, these amendments shall be applied for that earlier period.
*****
The amendments contained in this appendix when this IFRS was issued in 2004 have been incorporated into the relevant
pronouncements published in this volume.
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Mary E Barth
Hans-Georg Bruns
Anthony T Cope
Jan Engström
Robert P Garnett
Gilbert Gélard
James J Leisenring
Warren J McGregor
Patricia L O’Malley
John T Smith
Geoffrey Whittington
Tatsumi Yamada
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Mary E Barth
Hans-Georg Bruns
Anthony T Cope
Jan Engström
Robert P Garnett
Gilbert Gélard
James J Leisenring
Warren J McGregor
Patricia L O’Malley
John T Smith
Geoffrey Whittington
Tatsumi Yamada
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CONTENTS
paragraphs
BASIS FOR CONCLUSIONS ON
IFRS 6 EXPLORATION FOR AND EVALUATION OF MINERAL RESOURCES
INTRODUCTION BC1
REASONS FOR ISSUING THE IFRS BC2–BC5
SCOPE BC6–BC8
DEFINITION OF EXPLORATION AND EVALUATION ASSETS BC9–BC16
Expenditures incurred before the exploration for and evaluation of mineral resources BC10–BC13
Separate definitions of ‘exploration’ and ‘evaluation’ BC14–BC15
Mineral resources BC16
RECOGNITION OF EXPLORATION AND EVALUATION ASSETS BC17–BC31
Temporary exemption from IAS 8 paragraphs 11 and 12 BC17–BC23
Elements of cost of exploration and evaluation assets BC24–BC28
Measurement after recognition BC29–BC31
PRESENTATION OF EXPLORATION AND EVALUATION ASSETS BC32–BC34
IMPAIRMENT OF EXPLORATION AND EVALUATION ASSETS BC35–BC48
Assessment of impairment BC36–BC39
The level at which impairment is assessed BC40–BC47
Reversal of impairment losses BC48
CHANGES IN ACCOUNTING POLICIES BC49
DISCLOSURES BC50–BC57
Commercial reserves BC55
Stages after exploration and evaluation BC56
Project timing BC57
EFFECTIVE DATE BC58
TRANSITION BC59–BC65A
SUMMARY OF CHANGES FROM ED 6 BC66
DISSENTING OPINIONS ON IFRS 6
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Introduction
BC1 This Basis for Conclusions summarises the International Accounting Standards Board’s considerations in
reaching the conclusions in IFRS 6 Exploration for and Evaluation of Mineral Resources. Individual Board
members gave greater weight to some factors than to others.
Scope
BC6 In the Board’s view, even though no IFRS has addressed extractive activities directly, all IFRSs (including
International Accounting Standards and Interpretations) are applicable to entities engaged in the exploration for
and evaluation of mineral resources that make an unreserved statement of compliance with IFRSs in accordance
with IAS 1 Presentation of Financial Statements. Consequently, each IFRS must be applied by all such entities.
BC7 Some respondents to ED 6 encouraged the Board to develop standards for other stages in the process of
exploring for and evaluating mineral resources, including pre-exploration activities (ie activities preceding the
exploration for and evaluation of mineral resources) and development activities (ie activities after the technical
feasibility and commercial viability of extracting a mineral resource are demonstrable). The Board decided not to
do this for two reasons. First, it did not want to prejudge the comprehensive review of the accounting for such
activities. Second, the Board concluded that an appropriate accounting policy for pre-exploration activities could
be developed from an application of existing IFRSs, from the Framework’s definitions of assets and expenses,
and by applying the general principles of asset recognition in IAS 16 Property, Plant and Equipment and IAS 38
Intangible Assets.
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BC8 The Board also decided not to expand the scope of IFRS 6 beyond that proposed in ED 6 because to do so would
require additional due process, possibly including another exposure draft. In view of the many entities engaged in
extractive activities that would be required to apply IFRSs from 1 January 2005, the Board decided that it should
not delay issuing guidance by expanding the scope of the IFRS beyond the exploration for and evaluation of
mineral resources.
Mineral resources
BC16 Some respondents asked the Board to define mineral resources more precisely. The Board concluded that, for the
purposes of the IFRS, elaboration was unnecessary. The items listed in the definition of exploration for and
evaluation of mineral resources were sufficient to convey the Board’s intentions.
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for greater clarity with respect to these paragraphs and more examples of types of expenditures that would be
included or excluded.
BC25 In the light of the responses, the Board decided to redraft the guidance to state that the list is not exhaustive and
that the items noted are examples of expenditures that might, but need not always, satisfy the definition of
exploration and evaluation expenditure. In addition, the Board noted that IFRSs require that expenditures should
be treated consistently for comparable activities and between reporting periods. Any change in what is deemed to
be an expenditure qualifying for recognition as an exploration and evaluation asset should be treated as a change
in an accounting policy accounted for in accordance with IAS 8. Pending the comprehensive review of
accounting for extractive activities, the Board does not think that it is feasible to define what expenditures should
be included or excluded.
BC26 ED 6 paragraph 8 proposed to prohibit expenditure related to the development of a mineral resource from being
recognised as an exploration and evaluation asset. Respondents expressed difficulty identifying expenditures on
‘development’. The Board did not define ‘development of a mineral resource’ because this is beyond the scope of
the IFRS.
BC27 However, the Board noted that development of a mineral resource once the technical feasibility and commercial
viability of extracting the mineral resource had been determined was an example of the development phase of an
internal project. Paragraph 57 of IAS 38 provides guidance that should be followed in developing an accounting
policy for this activity.
BC28 ED 6 proposed that administration and other general overhead costs should be excluded from the initial
measurement of exploration and evaluation assets. Several respondents suggested that general and administrative
and overhead costs directly attributable to the exploration and evaluation activities should qualify for inclusion
in the carrying amount of the asset. These respondents saw this treatment as consistent with the treatment of such
costs with respect to inventory (paragraph 11 of IAS 2 Inventories) and intangible assets (paragraph 67(a) of
IAS 38). However, the Board noted that such a treatment would seem to be inconsistent with paragraph 19(d) of
IAS 16. The IFRS was not regarded as the appropriate Standard in which to resolve this inconsistency, and the
Board decided to delete the reference in the IFRS to administrative and other general overheads. The treatment of
such expenditures would be an accounting policy choice; the chosen policy should be consistent with one of the
treatments available under IFRSs.
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amount reflecting that consumption is part of the cost of the intangible asset. However, using the drilling rig to
develop an intangible asset does not change a tangible asset into an intangible asset.
BC34 Pending completion of the comprehensive review of accounting practices for extractive activities, the Board did
not wish to decide whether and which exploration and evaluation assets should be classified as tangible or
intangible. However, the Board concluded that an entity should classify the elements of exploration and
evaluation assets as tangible or intangible according to their nature and apply this classification consistently. This
classification is the foundation for other accounting policy choices as described in paragraphs BC29–BC31 and
for the disclosures required by the IFRS.
Assessment of impairment
BC36 In some cases, and particularly in exploration-only entities, exploration and evaluation assets do not generate
cash flows and there is insufficient information about the mineral resources in a specific area for an entity to
make reasonable estimates of exploration and evaluation assets’ recoverable amount. This is because the
exploration for and evaluation of the mineral resources has not reached a stage at which information sufficient to
estimate future cash flows is available to the entity. Without such information, it is not possible to estimate either
fair value less costs to sell or value in use, the two measures of recoverable amount in IAS 36. Respondents
noted that this would lead to an immediate write-off of exploration assets in many cases.
BC37 The Board was persuaded by respondents’ arguments that recognising impairment losses on this basis was
potentially inconsistent with permitting existing methods of accounting for exploration and evaluation assets to
continue. Therefore, pending completion of the comprehensive review of accounting for extractive activities, the
Board decided to change the approach to recognition of impairment; the assessment of impairment should be
triggered by changes in facts and circumstances. However, it also confirmed that, once an entity had determined
that an exploration and evaluation asset was impaired, IAS 36 should be used to measure, present and disclose
that impairment in the financial statements, subject to special requirements with respect to the level at which
impairment is assessed.
BC38 Paragraph 12 of ED 6 proposed that an entity that had recognised exploration and evaluation assets should assess
those assets for impairment annually and recognise any resulting impairment loss in accordance with IAS 36.
Paragraph 13 proposed a set of indicators of impairment that an entity would consider in addition to those in
IAS 36. Respondents stated that these indicators would not achieve the Board’s intended result, especially in
circumstances in which the information necessary for an assessment of mineral reserves was not available.
BC39 The Board replaced the proposals in paragraphs 12 and 13 of ED 6 with an exception to the recognition
requirements in IAS 36. The Board decided that, until the entity had sufficient data to determine technical
feasibility and commercial viability, exploration and evaluation assets need not be assessed for impairment.
However, when such information becomes available, or other facts and circumstances suggest that the asset
might be impaired, the exploration and evaluation assets must be assessed for impairment. The IFRS suggests
possible indicators of impairment.
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BC41 Respondents disagreed with the Board’s proposal. In particular, and for various reasons, they did not accept that
the special CGU would provide the relief it was intended to provide, because:
(a) small, start-up or exploration-only entities might not have adequate cash flows to support exploration
and evaluation assets that were not cash-generating.
(b) entities applying the successful efforts method of accounting typically conduct impairment tests
property by property. However, because of the way in which the special CGU was defined in ED 6 such
entities would be forced to carry out impairment tests at the CGU level.
(c) the special CGU permitted management extensive discretion.
In addition, there was concern that, because the exploration and evaluation assets could be aggregated with other
assets in the special CGU, there would be confusion about the appropriate measurement model to apply (fair
value less costs to sell or value in use). As a result, many respondents to ED 6 did not think that the Board had
achieved its intention in this respect, and said that they preferred to apply IAS 36 without the special CGU.
BC42 Although the Board disagreed with some of the arguments put forward by respondents, it acknowledged that the
special CGU seemed to be more confusing than helpful. This suggested that it was not needed. Paragraph BC20
of the Basis for Conclusions on ED 6 noted the Board’s reluctance to introduce a special CGU. Removing the
special CGU would eliminate much of the complexity in the proposed IFRS and the confusion among
constituents. It would also mean that entities with extractive activities would assess their assets for impairment at
the same level as other entities—providing a higher level of comparability than might otherwise be the case.
BC43 Board members noted that paragraph 22 of IAS 36 requires impairment to be assessed at the individual asset
level ‘unless the asset does not generate cash inflows that are largely independent of those from other assets or
groups of assets’. In addition, paragraph 70 of IAS 36 requires that ‘if an active market exists for the output
produced by an asset or group of assets, that asset or group of assets shall be identified as a cash-generating unit’.
In some cases in which exploration and evaluation assets are recognised, eg in the petroleum sector, each well is
potentially capable of producing cash inflows that are observable and capable of reliable measurement because
there is an active market for crude oil. The Board was concerned that removing the special CGU would cause
entities recognising exploration and evaluation assets to test for impairment at a very low level.
BC44 The issue was highlighted in the July 2004 issue of IASB Update, in the project summary and in the Effect of
Redeliberations documents available on the IASB’s Website. These documents were also sent to the Board’s
research project team and others with a request to encourage their constituents to respond to the issues raised.
The Board received 16 comment letters.
BC45 The majority of respondents continued to support the elimination of the special CGU. They also supported the
notion that entities should test impairment at the level of the cost centre and suggested that the Board should
consider defining an ‘asset’ as it applied to exploration and evaluation assets. The respondents argued that such
an approach would reflect more accurately the way in which the industry manages its operations. The Board was
persuaded by these arguments and decided that it should permit entities some flexibility in allocating exploration
and evaluation assets to cash-generating units or groups of units, subject to an upper limit on the size of the units
or groups of units.
BC46 The Board decided that its approach to the impairment of goodwill in the 2004 revisions to IAS 36 paragraphs
80–82 offered the best model available within IFRSs to accomplish its objective. It noted that entities might be
able to monitor exploration and evaluation assets for internal management purposes at the level of an oilfield or a
contiguous ore body. The Board did not intend to require impairment to be assessed at such a low level.
Consequently, the IFRS permits CGUs to be aggregated. However, the Board decided to require the level at
which impairment was assessed to be no larger than a segment, based on either the entity’s primary or the entity’s
secondary segment reporting format in accordance with IAS 14 Segment Reporting. The Board concluded,
consistently with the approach to goodwill in IAS 36, that this approach was necessary to ensure that entities
managed on a matrix basis could test exploration and evaluation assets for impairment at the level of reporting
that reflects the way they manage their operations. This requirement is no less rigorous than ED 6’s requirement
that the special CGU should ‘be no larger than a segment’. 1
BC47 Consequently, the Board decided to remove the proposed special CGU. In doing so, it noted that eliminating this
requirement would have the following benefits:
(a) once an impairment was identified, the measurement, presentation and disclosure of impairment would
be more consistent across entities recognising exploration and evaluation assets.
(b) it would remove the confusion about what practices entities recognising exploration and evaluation
assets for the first time should follow.
1
In 2006 IAS 14 was replaced by IFRS 8 Operating Segments, which does not require the identification of primary and secondary segments. See
paragraph BC150A of the Basis for Conclusions on IAS 36 Impairment of Assets.
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(c) it would remove the risk noted in some comment letters that the special CGU could become the
‘industry norm’, limiting the Board’s options when the comprehensive review of accounting for
extractive activities is completed.
Disclosures
BC50 The disclosure requirements in the IFRS are based on a principle that an entity should disclose information that
identifies and explains the amounts recognised in its financial statements that arise from the exploration for and
evaluation of mineral resources, supplemented by specified disclosures to meet that objective.
BC51 Although respondents agreed that entities should be allowed flexibility in determining the levels of aggregation
and amount of disclosure, they suggested that the Board should introduce more specific and standardised
disclosure requirements. Some respondents were concerned that the variety of accounting for the exploration for
and evaluation of mineral resources could reduce comparability.
BC52 The Board concluded that the ED 6 approach was superior to requiring a long list of detailed and prescriptive
disclosures because concentrating on the underlying principle:
(a) makes it easier for entities to understand the rationale for the requirements, which promotes
compliance.
(b) avoids requiring specific disclosures that may not be needed to meet the underlying objectives in the
circumstances of every entity and could lead to information overload that obscures important
information in a mass of detail.
(c) gives entities flexibility to decide on an appropriate level of aggregation that enables users to see the
overall picture, but without combining information that has different characteristics.
(d) permits reporting exploration and evaluation expenditure by segment on either an annual basis or an
accumulated basis.
BC53 Some respondents suggested that the Board should require disclosures similar to those in paragraphs 73 and 74
of IAS 16 or in paragraphs 118–125 of IAS 38. Both IAS 16 and IAS 38 contain scope exclusions for exploration
and evaluation assets. Therefore, entities recognising these assets could claim that the requirements were not
applicable. The Board decided that, although the scope of those standards excludes exploration and evaluation
assets, their required disclosures would provide information relevant to an understanding of the financial
statements and useful to users. Consequently, the Board concluded that the IFRS should confirm that the
disclosures of IASs 16 and 38 are required consistently with how the entity classifies its exploration and
evaluation assets (ie tangible (IAS 16) or intangible (IAS 38)).
BC54 In addition, some respondents suggested that the Board should require disclosure of non-financial information,
including:
(a) commercial reserve quantities;
(b) rights to explore for, develop and produce wasting resources;
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Commercial reserves
BC55 The Board acknowledged that information about commercial reserve quantities is, perhaps, the most important
disclosure for an entity with extractive activities. However, it noted that commercial reserves are usually
determined after the exploration and evaluation stage has ended and it concluded that such disclosure was
beyond the stated scope of the IFRS.
Project timing
BC57 The Board also concluded that disclosure of the number of years since exploration started and the estimated time
remaining until a decision could be made about development would apply only to large scale exploration
activities. It noted that if the project is significant, paragraph 103(c) of IAS 1 already requires its disclosure, ie as
additional information that is necessary for an understanding of the financial statements.
Effective date
BC58 ED 6 proposed that the IFRS should be effective for annual periods beginning on or after 1 January 2005. The
Board decided to change the effective date to 1 January 2006 to allow entities more time to make the transition to
the IFRS. It also decided to permit an entity that wishes or is required to adopt IFRSs before 1 January 2006 to
adopt IFRS 6 early.
Transition
BC59 The Board did not propose any special transition in ED 6. Consequently, paragraphs 14–27 of IAS 8 would apply
to any changes in accounting that are necessary as a result of the IFRS.
BC60 Some respondents expressed concern about the application of the proposals to prior periods—especially those
related to impairment and the inclusion or exclusion of some expenditures from exploration and evaluation
assets. In particular, respondents requested that if the Board were to require restatement, it should give
transitional guidance on how to identify elements previously recognised as exploration and evaluation assets now
outside the definition.
BC61 IAS 8 would require entities recognising exploration and evaluation assets to determine whether there were any
facts and circumstances indicating impairment in prior periods. The Board concluded that retrospective
application was not likely to involve the use of hindsight because the facts and circumstances identified in the
IFRS are generally objective indicators and whether they existed at a particular date should be a question of fact.
However, the Board noted that it provided transitional relief in IFRS 4 for applying the liability adequacy test to
comparative periods on the basis of impracticability, principally because the liability adequacy test involves the
use of current estimates of future cash flows from an entity’s insurance contracts. The Board does not expect that
IFRS 6’s approach to impairment will involve current estimates of future cash flows and other variables to the
same extent. However, it is aware that the variety of approaches to assessing recoverability means that current
estimates of future cash flows and other variables are likely to be in use by some entities.
BC62 Therefore, consistently with IFRS 4, the Board concluded that if it is impracticable to apply the impairment test
to comparative information that relates to annual periods beginning before 1 January 2006, an entity should
disclose that fact.
BC63 Some respondents were concerned that entities would have difficulty in compiling the information necessary for
2004 comparative figures, and suggested that entities should be exempted from restating comparatives on
transition, given that the IFRS would be introduced close to 1 January 2005, and could result in substantial
changes.
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BC64 The Board considered a similar issue when it developed ED 7 Financial Instruments: Disclosures, in which it
concluded that entities that apply the requirements proposed in ED 7 only when they become mandatory should
be required to provide comparative disclosures because such entities will have enough time to prepare the
information.
BC65 In ED 7, the Board decided to propose that an entity that both (a) adopts IFRSs for the first time before 1 January
2006 and (b) applies the IFRS before that date should be exempt from the requirement to produce comparative
information in the first year of application. The Board compared the concerns raised by constituents in response
to ED 6 and the issues it considered in developing ED 7 and decided that its conclusions in ED 7 were also
appropriate for the IFRS.
BC65A In June 2005, the Board made a minor amendment to IFRS 1 paragraph 36B to clarify its intention that the
exemption provided in this paragraph applies to the recognition and measurement requirements of IFRS 6, as
well as the disclosure requirements.
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