Adoption Model: SEC IFRS Roadmap Series
After having gotten satisfied that broad international consensus on application & interpretation of IFRS had been reached and the IASC was securely funded, the SEC would decide whether to proceed with adoption of IFRS. It’s roadmap foresees that decision being made in 2011.
After reviewing the status of the milestones and the study discussed below (CIFiR), the Commission would determine, in 2011, whether to proceed with rules requiring U.S. public companies to file financial statements prepared in accordance with IFRS by 2014 if it is in the public interest and promotes investor protection for us to do so.
We are proposing this Roadmap towards the mandatory, rather than elective, use of IFRS for U.S issuers in order to promote fully a single set of high-quality globally accepted accounting standards to improve the comparability of financial information prepared by U.S. public companies and foreign companies. (p. 33)
The agency outlines a staggered adoption format that schedules the largest capitalization companies to adopt first (in 2014), followed by small and mid-cap filers in the following year and smaller reporting companies (market caps under $75m) for the year ended 12/31/2016. Companies would file the full three years of Reg. S-X audited financials under IFRS in their year of adoption (two years for smaller reporting companies).
One means of implementing IFRS reporting by U.S. issuers that we are considering is a staged transition, as opposed to all U.S. issuers transitioning at once. Provisionally, under the transition, IFRS filings would begin for large accelerated filers for fiscal years ending on or after December 15, 2014. Accelerated filers would begin IFRS filings for years ending on or after December 15, 2015. Non-accelerated filers, including smaller reporting companies, would begin IFRS filings for years ending on or after December 15, 2016.
In each instance, this would allow the filer to begin its books and records and internal accounting controls with respect to IFRS reporting for all three years of audited financial statements that would be required in its first year of IFRS reporting (e.g., 2012 to 2014 for large accelerated filers, 2013 to 2015 for accelerated filers, and 2014 to 2016 for non-accelerated filers). (p .35)