Exposure Draft of Reporting Standard 1: The Operating and Financial Review - ACT Response

The ACT welcomes the new approach to the OFR of which this Reporting Standard will be a key part.

Summary of principal comments

It is important that the Reporting Standard emphasise that the OFR goes beyond both the financial and the historical reporting elsewhere in annual reports.

The Reporting Standard should use terminology consistent with the governing Companies Acts and Regulation.

Emphasis should be on director’s judgement on what is to be included and in setting out their views of future trends and developments. A very high level of unreasonableness of such judgments, without application of perfect hindsight after the event, should be required before directors risk incurring any penalty for those judgements.

In the discussion of risks and uncertainties it is not possible to understand the implication of individual risks alone, but rather as part of an overall portfolio. Therefore the Standard should require directors to discuss their overall understanding and general approach to integrated risk management.

There are a number of paragraphs of the Standard which we believe go too far or not far enough in requirements for disclosures.