Title: Multilevel consultation in the development of IFRS: a comparative content analysis of comment letters sent to EFRAG and the IASB

Authors: Martin Gäumann

Addresses: Chair of Accounting, Auditing and Taxation, Faculty of Business and Economics, Technische Universität Dresden, Helmholtzstr. 10, 01069 Dresden, Germany

Abstract: This paper examines characteristics of the content of comment letters (CLs) written by European constituents and sent to the European Financial Reporting Advisory Group (EFRAG) and International Accounting Standards Board (IASB) to influence the development of International Financial Reporting Standards (IFRS). Following a multi-issue, multi-period approach, the study presented here involves a manual content analysis to compare the scope (i.e., organisation-specificity), form (i.e., completeness and level of detail), and tone (i.e., level of support) of the content of 892 pairs of CLs sent to EFRAG and the IASB between 2008 and 2016. Overall, the findings illuminate the participatory practices of European constituents in a cross-organisational setting, thereby challenging the common assumption that they send almost only highly similar or identical CLs to EFRAG and the IASB, as well as elucidate EFRAG's intermediary role in setting international accounting standards.

Keywords: European Financial Reporting Advisory Group; EFRAG; International Accounting Standards Board; IASB; standard setting; International Financial Reporting Standards; IFRS; comment letters; due process.

DOI: 10.1504/IJEA.2022.130409

International Journal of Economics and Accounting, 2022 Vol.11 No.4, pp.307 - 340

Accepted: 03 Sep 2022
Published online: 19 Apr 2023 *

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