In the year 2005, European Union made it mandatory for all the companies which were listed have to comply with International Financial Reporting Standards (IFRS) requirements when presenting their financial statements. This marked the beginning when International Accounting standard Board (ISAB) was professed as “legitimate’’. Ever since then IFRS has spread swiftly across the world. Initially there were few hindrances like by the end of year 2004 “full text of endorsed IFRS was not even available in several EU languages’’. This research examines the evolution and obstacles to convergence of Indian Accounting Standards to IFRS starting 1st April 2011 when all the listed companies in India, will be required to present their financial statements in accordance with IFRS regulations. This research also highlights the need for the country like India, to converge their Local GAAP to IFRS.
American Writer Mark Twain once commented on India and said “the cradle of the human race ,the birthplace of human speech ,the mother of history ,the grandmother of legend, and the great grandmother of human speech of the tradition.’’ India is now seen as one of the fastest growing economies in the world. The increase of number of Indian companies being listed at various stock exchanges may it be NASDAQ, NYSE or LSE, the takeovers of companies like Corus by TATA or the exponential increment of Foreign Direct Investment in the country does indicate that India is now the destination where everyone wants to be a part of it. The strong economic growth, technological advancements, inflows of foreign exchange and the ever-increasing interest of almost every nation to be a part of this growth embraces the requirement of a common language in financial statements. (Purvis, gernon, and Diamond ).
Various studies done by researchers have concluded that “principle based standards are better enforced than rule based” and this becomes one of the reasons why harmonisation is becoming more and more essential. As far as advantages and disadvantages in adhering a common accounting rule there are still concerns within a country leave apart the issue of international convergence (Ray Ball, 2006). Only time will tell whether this convergence really serve the purpose or it was just a decision made in haste to be a part of so called IFRS “brand names’’ countries.
IFAC Compliance Programme
IFAC was founded in 1977 with New York as its Headquarters. Its initial purpose was “the development and enhancement of a coordinated worldwide accounting profession with harmonised standards”(brennan,1979). Presently it is “a global organisation for the accountancy profession” and as at 10th August 2009 IFAC has 158 members from 122 countries representing 2.5 million accountants. “Its formal mission is stated as being
“To serve the public interest,IFAC will continue to strengthen the worldwide accountancy profession and contribute to the development of strong international economies by establishing and promoting adherence to high quality professional standards ,furthering the international convergence of such standards and speaking out on public interest issues where the profession’s expertise is most relevant.
To carry out this mission ,we work closely with our member bodies and regional accountancy organisations and obtain the input of regulators, standard-setters, governments and others who share our commitment to creating a sound global financial architecture”(IFAC,2006).
IFAC does not set International Financial Reporting Standards (IFRSs) are not set by IFAC rather these are set by International Accounting Standards Board (IASB) . The IFAC Board formed “the Member Body Compliance Program” to ensure that all the members adhere to the standards set by IFAC for its membership. The primary objective of which was to encourage members and strive for improvement in this area of compliance.
The IFAC Compliance program is overseen by the Compliance Advisory Panel. The primary objective of Compliance Advisory panel is to make sure that the IFAC compliance program is properly implemented as well as properly operated by the staff members of IFAC.
Statements of Membership Obligations
The IFAC Board through its Statement of Membership Obligations (SMOs) issue guidelines for the members to assist in implementation of “International standards” which are issued by IFAC and International Accounting Standard Board (IASB). The motto of SMOs is to provide pre-requisites for “quality assurance” and to investigate any disciplinary actions against any members.
All the IFAC members also have to participate in a program which is in three parts. The main purpose of this programme is that it “seeks to understand whether and how the SMO requirements are being fulfilled”. The information from this program helps the compliance committee to evaluate whether the members have prudently adhered to all the SMO requirements. These responses by the Members are taken on a periodical basis. Any changes in “legal and regulatory environment” or any other development made by any member is to be informed to this committee. This information is also updated in a questionnaire which is available online, by all the members and if there are any changes than the members are supposed to inform the compliance committee which publishes these updated responses on IFAC website.
Part 1 of this questionnaire is “Assessment of the Regulatory and Standard-Setting Framework”. This Questionnaire provides information from its members about their “regulatory and standard-setting framework in their jurisdiction”.
Part 2 is “SMO Self Assessment” which requires members to fill up a “self assessment questionnaire” which indicates how the members have incorporated or implemented international standards which are issued by IFAC and the IASB. This questionnaire also helps the committee to know whether all the members have adhered to professional standards set by the governing bodies.
Part 3, of the questionnaire is about “Action Plans”. This questionnaire requires that members to “to develop action plans, including identifying tools, resources, and regulatory changes to address areas identified through the Part 2 self-assessment”. Part 1, Part 2 and Part 3 questionnaires are accessible to public at large.
“Harmonization, standardization, and uniformity are all terms used in the literature and in previous research” (Iordanis N.Floropulos, 2006). According to Van der Tas (1988): “Materially measurable harmonization is an increase in the degree of comparability and means that more companies in the same circumstances are applying the same accounting method to an event or giving additional information in such a way that the financial reports of more companies can be made comparable.’’ Harmonisation can be understood as a procedure by which the gap between different accounting practices are reduced (Doupnik,1987).
Sir David Tweedie, Chairman of International Accounting Standards Board said “ If they all use the same methods and the accounting for one transaction is the same in Sydney, as in Seattle, as in Strasburg, and in Sheffield , then they will know where they are, and there is a demand for that type of certainty.”(FEI 2001).
Mark T.Bradshaw and Gregory S.Miller(2007) also reiterated the same and argued that the evidences are in favour of a single set of Accounting Standards which will “increase the comparability of accounting information across the countries that differ economically, politically ,and culturally”.
Emphasising the need for a “common set of accounting standards” IASB, laid three broad objectives:
a) Improvement : Improvement in existing standards,
b) Convergence : Reducing the gap between different accounting standards followed in different geographical regions,
c) Leadership : Addressing issues not resolved and developing new standards( Geoffrey Whittington,2005)
“The principles behind the adoption of International Accounting Standards by different countries have always been the subject of controversy in accounting literature” (D.Zeghal, K.Mhedhbi, 2006).India’s decision to converge to IFRS is perceived by many researchers as premature decision. Although harmonisation of accounting standards not only enhances the quality of financial reporting, increases the comparability of financial statements but without considering of “country specific environment factors” the logic/reasons for such convergence will be forfeited. Talaga and Ndubizu (1986) insisted “that a country’s accounting principles must be adapted to its local environmental conditions”. In fact, Perera(1989a) went much ahead and stated that “the accounting information produced according to developed countries is not relevant to the decision models of less developed countries”.
Case studies by different researchers with respect to developing countries have not reached any consensus whether the convergence or so called “follow the Bandwagon approach” for IFRS’s will have or is having any positive effect on economic growth. It is yet to be seen that whether India will adopt IFRS or will converge its accounting standards to IFRS. Larson (1993) studied the economic growth effect of African countries with and without these standards. His results show a positive correlation in economic growth rate with adoption of IFRS’s when adapted with “country’s local condition”.
But Woolley (1998) researched the effect of such convergence or adoption of IFRS’s in Asian countries and he concluded that there are “no significant differences in the economic growth rates”. This again emphasises the fact that researchers have distinct opinion on whether IFRS adoption results in better economic growth or does not have any significant role. Researchers like Wolk, Francis ,and Tearney (1989) argued that ,harmonisation of accounting standards is “beneficial for developing countries because it provides them with better-prepared standards as well the best quality accounting framework and principles”. Chamisa (2000) studied the “usefulness of IAS’’ for developing countries. In his case study of Zimbabwe, he argued that these standards do have a positive impact on the emerging financial markets in the developing countries.
“Economic conditions are a major determinant in the development of a country’s accounting system” D Zeghal, K Mhedhbi (2006). No doubt with the present economic growth in India which is presuming better than in any other developing nation, IFRS will definitely boost this growth. India, by adopting IFRS gives a platform for itself where the financials can be compared easily with the peers across the globe. According to Alhashim and Arpan (1992), who argued that “environmental forces influencing accounting are economic forces, social forces, the legal system, culture, and the political system”.
Though the legal structure or political system or culture might have an impact of financial reporting but there are other factors which have greater impact than these. One of these can be the education standards of the professionals in a country. As IFRS are more principle based so lots of prudence will be required from the professionals . Cooke and Wallace (1990) added to these and argued that factors such as Size of business, education level, history of country, level of wealth, their development of financial markets may have influence on accounting standards. Accounting standards are governed by economics and politics( Watts,1977 ; Watts and Zimmerman,1986) so convergence has more or less enhanced integration of markets and politics across the borders (Ball,1995).
D Zeghal, K Mhedhbi (2006) gave five hypotheses on the basis of these environmental forces. In his first Hypothesis he argues that if the country economic growth increases then the chances of adoption of the International Accounting Standards increases. This hypothesis correlates with the present status of a country like India which is exponentially growing. To maintain this growth rate it needs to be in line with global standards which will increase it “legitimacy”. As a result of which the foreign investments will increase.
In the second hypothesis he argues that the probability of adoption of IFRS increases with the increase in education level. This simply means that there is a positive relationship between educational level and the competence of the professional accountants. This hypothesis indicates that “in countries where the educational level is low and expertise is weak, there is a real barrier to the adoption of IAS”. This infers that if a country wants to adopt IFRS then it needs to strengthen its educational level. This raises few concerns if test this hypothesis with the current situation in India where there is scarcity of experts who have good knowledge of IFRS.
In his third Hypothesis which states that if a developing country has “high degree of external economic openness it will be more inclined to adopt IAS”. India being one of the fastest growing nations with increasing foreign investments is an ideal case for adoption of IFRS’s as per this hypothesis. Sir David Tweedier, IASB Chairman restating uniformity of accounting standards argued “As the world’s capital markets integrate, the logic of a single set of accounting standard is evident. A single set of international standards will enhance comparability of financial information and should make the allocation of capital across the borders more efficient. The development and acceptance of international standards should also reduce compliance costs for corporations and improve consistency in audit quality.”
Abdelsalam and Weetman (2003) argued that a factor like “familiarity and language” seems to favour countries which are Anglo-American because of obvious reasons. One being Anglo-American predominantly had a greater influence in the formulation and development of IASB and the other being, English being language of communication. Chamisa (2000) found that he anticipates that the developing countries which have “Anglo-American culture” will find it easier to adopt IFRS. This becomes the Fourth Hypothesis.
In his Fifth and final hypothesis D Zeghal and and K Mhedbi states that developing countries which have capital markets are most likely to adopt/converge to IFRS. This hypothesis emphasises the need and why India as a country should adopt IFRS. With the present scenario where all capital markets are hitting new lows, Indian markets are performing far better than any other markets across the globe. But one should always In a recent report by world bank, it has been reported that Asian countries are recovering from the present financial crises. Research done by Adhikari and Tondkar (1992) showed the similar results, that adoption of a “particular accounting system” is effected by the existence of capital market. Adhikari & Tondkar (1992) specifically argued that “country’s level of economic growth has a positive effect on the development of accounting system and practices”.
L.L.Rodrigues, R.Craig(2007) in their research by using “Hegelian dialectic concept of thesis, antithesis and synthesis” gave innovative approaches for convergence of local accounting standards with IFRS’s. They went on to and argued that “in modern society, the global harmonization of accounting standards might be regarded as uncontroversial, unremarkable, and inevitable”. Hegel in his “theory of dialectic” laid a concept which states that “contradiction is regarded as the root of all change” (hegal, 1969). He argued that change is inevitable and brings in a new structure or a concept( a thesis) which always have contradictions, which is always opposite to what stated (antithesis) but which brings in something new which is in-between both the concepts(synthesis).
Referring to this concept L.L.Rodrigues, R.Craig argued that A thesis to be a “support for globalization of accounting” and Antithesis can be said to be “conflict area” that means opposing globalization of accounting. As a consequence of thesis and antithesis another view is generated this is referred as synthesis. They outlined few proposals which arose due to thesis and antithesis. In one of the proposals they argued that all the companies should follow their national accounting standards and prepare their financial statements accordingly. At the same time these companies should also enclose few annexure in the form of reconciliation with the International accounting standards (hoarau, 1995). In their second proposal they argued that countries should “seek regional harmonization of accounting standards” (European Union or ASEAN countries).
Analysing the “regional paradigm” of harmonisation of accounting standards, Saudagaran and Diga (1997, p.2,16-7) claims that in 1997 European Union supported the idea of regional harmonisation and also in the year 1992-1993 AFA “pursued regional harmonization as a policy objective”. Referring to The Accounting and Auditing Organization for Islamic Financial Institutions (AAOIFI) which is an “an Islamic international autonomous non-for-profit corporate body that prepares accounting, auditing, governance, ethics and shari’a standards for Islamic financial institutions and the industry”. These standards “are either mandatory or used as guidelines by the regulators in….the kingdom of Bahrain, Dubai International financial centre ,Jordan, Lebanon, Qatar, Sudan and Syria (http://www.aaoifi.com/overview.html). These arguments are in favour of “dual standards”.
Also many countries have adopted IFRS but not for all companies rather they have two tier system. One for big corporate houses and the other for small and medium-sized entities (SMEs). Because it is the cost factor which is bothering these smaller entities. But this view is not supported by the big international accounting firms, who caution that “a two standard system, where some companies continue to use national GAAP ,may be difficult to maintain in the long run….[and] …governments and national setters [should] develop formal convergence plans to eliminate these dual standards”(Larson and Street ,2004,p.113). L.L. Rodrigues and R.Craig also argued that companies might think full adoption of IFRS but practically it will more like to have “ostensible compliance” that is “in the form of window dressing to appease capital markets or other users of financial information”.
Chand (2005) throws a caution on Developing countries who are tempted to be a part of so called IFRS compliance members without evaluation the “cost and benefit involved in implementing IFRS”. He also emphasises the need to “improve the level of professional expertise in IFRS” before adoption or convergence to IFRS. Similar caution was advised by Shyam Sunder (2009) in his commentary “IFRS and the Accounting Consensus” stating “Get aboard if you do not wish to be left behind on the platform” cannot be a reason to converge or adopt IFRS. He argues that the standards should be developed not just as rules but rather it should be restricted to principles. Secondly a single set of accounting standards should be applied to companies especially those which are traded as it helps investors/stakeholders to compare them with their peers across the globe.
Further he argues that there should be a body which must be consisting of professionals and experts which can act as a regulatory just as Securities Exchange Commission (SEC) does in United States. He emphasis the need of educating professional to a level that they can interpret IFRS’s in a prudent manner. Financial Accounting Standard No. 157 (FASB 2006) which states that the companies can value their assets in any one of the three methods given in this standard. These methods are mark-to-market or mark-to-model or mark-to-judgement. The last method gives liberty to companies to value “as they deem fit”. Warren Buffet called this as “mark-to-myth”. Clarifications on such concept of “fair” valuation are needed as it gives an opportunity for accountants to mislead the users of the financial statements. He argues that the standard setters should minimize this “need for judgement” by properly responding to the queries/objections/suggestions raised by the professionals on these standards.
Shyam Sunder (2009) also stated a practical reason as far implementation of IFRS’s goes. He states any professional anywhere across the globe “who has been drilled to memorize the specifies” of their own national accounting standards will find it quite difficult to now thoroughly understand and cope up with the clauses of IFRS’s. Also there is only one language in these internationally acceptable accounting languages and that is English only. So those nations like China, Japan or say Italian or German would not find exact version of these standards. And we are talking about a common language of Financial Reporting.
One of the past presidents of The Institute of Chartered Accountants (ICAI) states “people who invest overseas naturally want to be able to keep track of the financial health of the securities issuers. Convergence of accounting standards is the only means to achieve this. Only talking the same language one can understand each other across borders”. N.C.Shil (2009) argues that though harmonisation will give an effect in the form of “global community as a single entity”. But there are major concerns when it comes to adoption of IFRS’s in United States where US GAAP is still functional. And it is yet to be seen as how far they will converge or they will just adopt.
Secondly, different countries have “different legal, economic, social and cultural environments” and it is very essential to analyse these differences as they just cannot be written off just to make sure that we are in line with internationally acceptable reporting standards. Thirdly, they emphasised the need of implementation not just adoption. It is quite a tedious task to implement without adequate regulatory authority. IFRS’s are principle based standards so again load of prudence will be required by the professionals who were implementing rules based accounting standards till date.
Another issue which is inevitable is the scarcity of skilled manpower in developing countries. China has reported a “shortfall of 300,000 qualified accountants and is likely to require a further three million” in times to come (N.C.Shil, 2009). More or less the same is the condition if we talk about India. At present with the current state of affairs “The ROC Mumbai has over 150,000 registered companies out of which approximately 50 percent file their documents. Over 5,000 new companies are registered every year.ROC Mumbai has 4 staff who are employed to scrutinize these fillings, none of them of whom are Chartered Accountant or Company Secretaries’’. Analyse the situation of now if India without a proper infrastructure (skilled manpower) adopt or converge to IFRS.
The concern at this hour is whether the adoption is “merely as a label” or there is a serious commitment to it. If the IFRS’s are adopted with such an intension then this will lead to increase in transparency , substantially decrease “information asymmetry, uncertainty and estimation risk”, and as a will result in “lower cost of capital and higher market liquidity”(Leuz and Verrecchia, 2000; Lambert et al., 2007a). This hypothesis was analysed by H.Daske,L.Hail,C.Leuz and R.Verdi (2007) who examined IFRS adoption by 24 countries between 1988 to 2004 and concluded that these the firms show a substantial decrease in cost of capital and exhibit “higher market liquidity” after converting themselves from their Local GAAP to IFRS. The problem faced even by European countries was the lack of clarity at the time of first-time adoption of IFRS. This issue still persists and there are still no clarifications on “transactions of specific nature such as pension and other post-retirement benefits” (R.K.Larson, D.L.Street 2004).
“The focus tends to be on what the rules say, not on how they are implemented in practice’’ (Ray Ball, 2006). In practice this has been a major concern even in Europe where implementation is still a major concern. Developing countries like India need to understand that mere restructuring or reorganisation of the standard setting body would not resolve this crisis. But including Government agencies on their board will overcome this tedious task of implementation (Peter Carlson,1997).
“The harmonisation of such standards is regarded to be neither practical nor truly valuable” (Goeltz, 1991, p.85) possibly because “investors may have developed adequate coping mechanism so that their financial decisions are not impeded”(Choi and Levich,1991,p.2)
Because different users require different information it is difficult to satisfy their financial reporting needs with the constraints of a set of inter national accounting standards.
A survey of 112 companies in India ,by Ernst & Yong showed 67% of them welcomed the decision of convergence to IFRS. But majority of them were susceptible with the deadline set by the Institute of Chartered Accountants of India and the reasons stated were quite obvious. One being the cost, whether it up gradation of IT software or cost of skilled manpower. The other reason was the jugglery in the statutory laws. The Tax laws, Companies Act 1956 and all other statutory laws are yet to be modified and in a manner that they are in line with the IFRS regulations. Taking a clue from the nations who have already transited to IFRS India as a country needs to analyse the cost benefit ratio before implementing these IFRS regulations.
“UK companies recorded an average of £ 625,000 for IFRS conversion training in 2005”.
Also Securities Exchange commission has reported that “average US corporation will spend nearly $ 32 million in IFRS adoption cost”.
Also there is a mixed feeling of whether India will follow full IFRS regulations or will opt for “modified country specific version” like in European Union ,Singapore, Japan or Australia.
Ray Ball(2006) on “International Financial reporting Standards: Pros and Cons” argued that without any doubts the “high quality” standards have now been adopted by more than 100 countries is in itself commendable. On the other side he predicts the problems with the “fascination” of IASB and FASB with “fair value accounting”. When market prices are available, for any assets, then the opportunity of manipulation by managers decreases. However there is a flaw that the managers can still manipulate by using “mark-to-model” accounting. This particular clause in IFRS increases gives an opening to managers to fabricate the valuations as per their discretion. However , IASB and FASB are determined to go move ahead with “fair value accounting” and FASB member L.Todd Johnson commented
“The Board has required greater use of fair value measurements in financial statements because it perceives that information as more relevant to investors and creditors than historical cost information. Such a measures better facilitate assessing their past performance and future prospects. In that regard, the Board does not accept the view that reliability should outweigh relevance for financial statement measures”
Ball, Robin and Wu(2003) investigated “the relationship between accounting standards and the structure of other institutions on the attributes of financial reporting system”. The study was based on four Asian countries namely Hong Kong, Singapore, Malaysia and Thailand.
They argued that these countries have a greater influence towards International Accounting Standards which as a result should produce high quality financial reporting. But the “institutional structures that provide incentives to issue low quality reports” (Robert W. Holthausen, 2003). Hence Ball, Robin and Wu predicted that outcome of such structure will have a negative impact of financial reporting.
Researchers are also of the view that the manner in which the European Union is formed, in the same manner Asian Countries can come together and come to a common consensus which allows “free mobility of capital, Labour and enterprises across the national borders of its member countries”.( Peter Carlson, 1997).
History and Overview
India is a Sovereign, Secular, Democratic Republic country. It has a Government or rather “Parliamentary system of Government”. The President is the constitutional head .In the states it is the Governor who acts as a representative of the president. There are 28 states and 7 Union territories. Each and every part of the country has a different and unique “demography, history and culture, dress, festivals, languages etc”. India is “seventh-largest country by its geographical area, second most populous country and the most populous democracy in the world”.
In India, responsibility of maintaining high standards in accounting, auditing and ethical standards are bestowed on the Institute of Chartered Accountants of India (ICAI). The Institute was established in 1949 under an act of Parliament. The headquarters of this accounting body is in New Delhi. The Institute also has five regional offices situated in Mumbai, Chennai, Kanpur, Kolkata, and New Delhi, along with these regional offices the Institute has 117 branches across the country. The Institute has also 19 chapters outside India and an office in Dubai. Presently the Institute has enrolled 350,000 students and 140,000 members. The Institute of Chartered Accountants of India is presently the Second largest accounting Body in the world.
The Institute has maintained high standards of applicability of Accounting and Ethical standards in India. Except the recent saga of Satyam Computers no major incidence of this stature had ever been reported from India.
Applicability of IFRS in India
Under the new system the following companies or entities will have to comply with the IFRS requirements:
a) Companies which are listed in any of the recognised stock exchanges.
b) Banks, Insurance companies and Financial Institutions
c) Companies which in the preceding year had a turnover or more than Rs 1 billion.
d) Companies which in the preceding year had borrowings in excess of Rs 250 million.
e) Holding or subsidiary of any of the above companies
At present IFRS is not applicable to SME’s.
Differences between the prsent regime under local GAAP and IFRS
There are issues which really putting doubts in the mind of professionals or the users of financial statement which needs immediate attention. Following are few of them:
1) As per the companies act 1956, there are specified rates for depreciation to be charged to assets by every company. The clause states that every company must charge a minimum rate of depreciation to each and every asset held. IFRS does not recognise this concept of “minimum depreciation”.
2) In India, every amalgamation must be approved by the High Court. There is no such obligation in IFRS regulation.
3) Clause 41 of the listing agreement clearly states that there should be a separate presentation of extraordinary items in the financial reporting of the listed companies whereas IFRS prohibits such presentation of extra-ordinary items.
4) IFRS conversion will have a direct impact on the reporting of Indian Banks. The transition to IFRS will affect reported net-worth, capital adequacy and available capital for all Indian Banks. Report on “IFRS convergence: Challenges and Implementation Approaches for Banks in India” argues that there will be a “significant impact” on the Banking industry in India particularly in the reporting of Financial Instruments, Derivatives and provisions to be made in case of loss on loans and advances. The” Financial parameters” such as Capital Adequacy Ratio (CAR) and “valuation metrics” on the basis of which the analysis is done, predictions on future aspects of the company are made will change drastically once IFRS is implemented.
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