time adopter must still make the principal disclosures relating to the nature and
extent of share-based payments required by paragraphs 44 and 45 of IFRS 2;
[IFRS 1.D2]
(c) if a first-time adopter modifies the terms or conditions of a grant of equity
instruments to which IFRS 2 has not been applied, the entity is not required to
apply the requirements of IFRS 2 (in paragraphs 26-29) if the modification
occurred before the date of transition to IFRSs; [IFRS 1.D2] and
(d) a first-time adopter is ‘encouraged, but not required, to apply IFRS 2 to liabilities
arising from share-based payment transactions that were settled before the date of
transition to IFRSs’. [IFRS 1.D3].
There are a number of interpretation issues concerning these exemptions and
requirements:
• Meaning of ‘disclosed publicly’ under (a) above
IFRS 1 only permits retrospective application of IFRS 2 if the entity has
‘disclosed publicly’ the fair value of the equity instruments concerned, but IFRSs
do not define what is meant by ‘disclosed publicly’. While IFRS 1 does not
specifically require public disclosure of the fair value of an entity’s share-based
payment transactions in its previous financial statements, it is clear that IFRS 1
requires fair value to have been published contemporaneously. In addition, the
requirements in IFRS 1 to disclose publicly the fair value of share-based payment
transactions can be met even if the fair value is only disclosed in aggregate rather
than for individual awards.
• First-time adopters encouraged to apply IFRS 2 under (a)(ii) and (d) above
The ‘date of transition to IFRSs’ to which those exemptions refer is the first day of
the earliest comparative period presented in a first-time adopter’s first IFRS
financial statements. This effectively means that an entity could accelerate the
vesting of an award that was otherwise due to vest after the date of transition to
IFRSs, in order to avoid applying IFRS 2 to that award.
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• Consistent selection of the exemptions under (a) and (d) above
A first-time adopter can choose which of the exemptions under (a) and (d) it wants
to apply, i.e. there is no specific requirement to select the exemptions in a
consistent manner.
• Meaning of ‘encouraged’ under (a) and (d) above
Under IFRS 1, a first-time adopter is ‘encouraged’, but not required, to apply IFRS 2
to certain categories of share-based payment transactions (see (a) and (d) above).
IFRS 1 does not specifically prohibit a literal reading of ‘encouraged’, which could,
for example, allow a first-time adopter to decide to apply IFRS 2 only to some
share-based payment transactions granted before 7 November 2002. We believe
that it would generally be acceptable for a first-time adopter to apply IFRS 2 only
to share-based payment transactions:
(1) after an earlier date chosen by the entity (e.g. 1 January 2001), while not
applying it to earlier transactions;
(2) for which fair values were disclosed publicly.
• Treatment of modifications, cancellations and settlements under (c) above
There is a slight ambiguity concerning the interpretation of the exemption under (c)
above, because paragraph D2 of IFRS 1 refers only to the modification of awards. This
could allow a literal argument that IFRS 2 and IFRS 1 do not prescribe any specific
treatment when an entity cancels or settles, as opposed to modifying, an award falling
within (a) above. However, paragraph D2 also requires an entity to apply
paragraphs 26-29 of IFRS 2 to ‘modified’ awards. These paragraphs deal not only with
modification but also with cancellation and settlement; indeed paragraphs 28 and 29
are not relevant to modifications at all. This makes it clear that the IASB intended
IFRS 2 to be applied not only to modifications, but also to any cancellation or
settlement of an award falling within (a) above, unless the modification, cancellation
or settlement occurs before the date of transition to IFRSs. [IFRS 1.D2, IFRS 2.26-29].
• Transactions where the counterparty has a choice of settlement method
These are not specifically addressed in the first-time adoption rules. It therefore
appears that, where such transactions give rise to recognition of both an equity
component and a liability component, the equity component is subject to the
transitional rules for equity-settled transactions and the liability component to
those for cash-settled transactions. This could well mean that the liability
component of such a transaction is recognised in the financial statements, whilst
the equity component is not.
• Application of IFRS 2 to cash-settled transactions settled before the date of
transition to IFRSs under (d) above
It is not entirely clear what lies behind the exemption under (d) above, since a first-
time adopter would never be required to report a share-based payment transaction
(or indeed any transaction) settled before the date of transition.
Extract 5.5 from Manulife Financial Corporation (Manulife) provides an illustration of
typical disclosures made by entities that applied the share-based payments exemption.
In the extract below, Manulife applied the exemption not to apply IFRS 2 to share-
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based transactions that were fully vested at the transition date. The extract also
illustrates the implicit limitation of the share-based payment exemption for awards that
were granted after 7 November 2002 and that were still vesting at the date of transition
to IFRS.
Extract 5.5: Manulife Financial Corporation (2011)
Notes to Consolidated Financial Statements [extract]
Note 25 First-time Adoption of IFRS [extract]
As outlined in note 1, the Company has adopted IFRS as a replacement of previous Canadian GAAP effective
January 1, 2011. References to Canadian GAAP throughout this note relate to Canadian GAAP prior to the adoption
of IFRS. The Company’s opening Consolidated Statement of Financial Position was prepared at January 1, 2010,
the Company’s date of transition to IFRS (the “Transition Date”) in accordance with the requirements of IFRS 1
“First-Time Adoption of International Financial Reporting Standards”. This note explains the principal adjustments
made by the Company in preparing the opening IFRS Consolidated Statement of Financial Position as at January 1,
2010 compared to the Consolidated Balance Sheet as at December 31, 2009 under Canadian GAAP and the required
adjustments between IFRS and previous Canadian GAAP to total equity and total comprehensive income for the
2010 comparative year.
IFRS has been applied retrospectively, except for certain optional and mandatory exemptions from full retrospective
application provided for under IFRS 1, as detailed below.
(a) First-time adoption elections [extract]
Optional exemptions [extract]
Share-based payment transactions – The Company elected to apply IFRS 2 “Share-based Payments” to all equity
instruments granted after November 7, 2002 that had not vested by the Transition Date. The Company applied
IFRS 2 for all liabilities arising from share-based payment transactions that exist
ed at the Transition Date.
5.3.1
Use of previously published fair values
There is no explicit requirement in IFRS 1 or IFRS 2 that any voluntary retrospective
application of IFRS 2 must be based on the fair value previously published. This might
appear to allow a first-time adopter the flexibility of using a different valuation for
IFRS 2 purposes than that previously used for disclosure purposes. However, the
requirements of IFRS 1 in relation to estimates under previous GAAP (see 4.2 above)
mean that the assumptions used in IFRS must be consistent with those used in the
originally disclosed valuation. The entity will also need to consider the implications of
the assertion, in effect, that there is more than one fair value for the same transaction.
5.3.2
Restatement of costs recognised under previous GAAP
A first-time adopter may elect to take advantage of the transitional provisions in IFRS 1
which allow it not to apply IFRS 2 to equity-settled share-based payment transactions
that were vested before the date of transition to IFRS, despite having recognised a cost
for those transactions in accordance with its previous GAAP. Neither IFRS 1 nor IFRS 2
clearly indicates the appropriate treatment of the costs of share-based payment
transactions that were recognised under the previous GAAP. There are mixed views on
this issue in different jurisdictions, some of which are being driven by local regulatory
expectations. In practice, either of the following approaches is considered acceptable,
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provided that the treatment chosen is disclosed in the financial statements if the
previously recognised costs are material:
• does not change expense previously recognised under previous GAAP for equity
instruments subject to transitional relief under IFRS 1. This approach is consistent
with the approach for cash-settled share-based payment transactions that are
settled prior to the date of transition to IFRS, since the entity must reflect the
reduction in cash that was actually paid (and therefore the reduction in retained
earnings) in the first IFRS financial statements; or
• derecognise share-based payment expense under previous GAAP for equity
instruments subject to transitional relief under IFRS 1. In other words, reverse
cumulative amounts recognised in the retained earnings and equity accounts of the
opening IFRS statement of financial position.
5.4 Insurance
contracts
A first-time adopter may apply the transitional provisions in IFRS 4 – Insurance
Contracts. [IFRS 1.D4].
The claims development information (see Chapter 51) need not be disclosed for claims
development that occurred more than five years before the end of the first IFRS reporting
period. For entities taking advantage of this relief, the claims development information
will be built up from five to ten years in the five years following adoption of IFRSs.
Additionally, if it is ‘impracticable’ for a first-time adopter to prepare information about
claims development that occurred before the beginning of the earliest period for which
full comparative information is presented, this fact should be disclosed. [IFRS 4.44].
Furthermore, the IASB issued the amendments to IFRS 4 – Applying IFRS 9 – Financial
Instruments – with IFRS 4 Insurance Contracts – in September 2016. The amendments
permit insurers to either defer the application of IFRS 9 or use an ‘overlay approach’. See
10 of Chapter 51 for more details of these approaches and treatments for first-time adopters.
IFRS 17 – Insurance Contracts – was issued in May 2017 and will be effective for annual
reporting periods beginning on or after 1 January 2021. Early application is permitted for
entities that apply IFRS 9 and IFRS 15 – Revenue from Contracts with Customers – on
or before the date of initial application of IFRS 17. An entity must apply the transition
provisions in paragraphs C1 to C24 and C28 in Appendix C of IFRS 17 to contracts
within the scope of IFRS 17 (see Chapter 52 – Insurance Contracts – at 17). The
references in those paragraphs in IFRS 17 to the transition date must be read as the date
of transition to IFRS. [IFRS 1.B13].
5.5 Deemed
cost
IFRS 1 requires full retrospective application of standards effective at the end of a first-
time adopter’s first IFRS reporting period. [IFRS 1.7]. Therefore, in the absence of the
deemed cost exemption, the requirements of, for example, IAS 16, IAS 38, IAS 40 –
Investment Property – and IFRS 6 – Exploration for and Evaluation of Mineral
Resources – would have to be applied as if the first-time adopter had always applied
these standards. This could be quite onerous because:
First-time
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• these items are long-lived which means that accounting records from the time of
acquisition may not be available anymore. In the case of formerly state-owned
businesses, the required accounting records possibly never even existed;
• the entity may have revalued the items in the past as a matter of accounting policy
or because this was required under national law; or
• even if the items were carried at depreciated cost, the accounting policy for
recognition and depreciation may not have been IFRS compliant.
Given the significance of items like property, plant and equipment in the statement of
financial position of most first-time adopters and the sheer number of transactions
affecting property, plant and equipment, restatement is not only difficult but would often
also involve huge cost and effort. Nevertheless, a first-time adopter needs a cost basis for
those assets in its opening IFRS statement of financial position. Therefore, the IASB
decided to introduce the notion of a ‘deemed cost’ that is not the ‘true’ IFRS compliant
cost basis of an asset, but a surrogate that is deemed to be a suitable starting point.
There are five separate deemed cost exemptions in IFRS 1:
• fair value or revaluation as deemed cost (see 5.5.1 below);
• event-driven fair value measurement as deemed cost (see 5.5.2 below);
• deemed cost for oil and gas assets (see 5.5.3 below);
• deemed cost for assets used in operations subject to rate regulation (see 5.5.4
below); and
• deemed cost in determining the cost of an investment in a subsidiary, joint venture
or associate (see 5.8.2 below).
5.5.1
Fair value or revaluation as deemed cost
To deal with the problem of restatement of long-lived assets upon first-time adoption
of IFRSs, the standard permits a first-time adopter – for the categories of assets listed
below – to measure an item in its opening IFRS statement of financial position using an
amount that is based on its deemed cost: [IFRS 1.D5, D6]
• property, plant and equipment including bearer plants (see 7.4 below); [IFRS 1.D5]
• investment property, if an entity elects to use the cost model in IAS 40. [IFRS 1.D7].
The fact that the exemption can only be applied to investment property accounted
for under the cost model will not pose any problems in practice as the fair value
model under IAS 40 requires an entity to measure its inv
estment property at fair
value at its date of transition to IFRSs;
• right-of-use assets under IFRS 16 – Leases; [IFRS 1.D7] and
• intangible assets (see 7.14 below) that meet:
• the recognition criteria in IAS 38 (including reliable measurement of original
cost); and
• the criteria in IAS 38 for revaluation (including the existence of an active
market). [IFRS 1.D7].
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A first-time adopter cannot use this deemed cost approach by analogy for any other
assets or for liabilities. [IFRS 1.D7].
The use of fair value or revaluation as deemed cost for intangible assets will be very
limited in practice because of the definition of an active market in IFRS 13. An active
market is defined as one in which transactions for the item take place with sufficient
frequency and volume to provide pricing information on an ongoing basis.
[IFRS 13 Appendix A]. It is therefore unlikely that a first-time adopter will be able to apply this
exemption to any intangible assets (see Chapter 17).
It is important to note that this exemption does not take classes or categories of
assets as its unit of measure, but refers to ‘an item of property, plant and equipment,’
and similarly for investment property, right-of-use assets under IFRS 16 and
intangible assets. [IFRS 1.D5]. IAS 16 does not ‘prescribe the unit of measure for
recognition, i.e. what constitutes an item of property, plant and equipment. Thus,
judgement is required in applying the recognition criteria to an entity’s specific
circumstances’ (see Chapter 18). [IAS 16.9]. A first-time adopter may therefore apply
the deemed cost exemption to only some of its assets. For example, it could apply
the exemption only to:
• a selection of properties;
• part of a factory; or
• some of the right-of-use asset leased under a single lease agreement.
The IASB argued that it is not necessary to restrict application of the exemption to
classes of assets to prevent arbitrarily selective revaluations, because IAS 36 ‘requires
an impairment test if there is any indication that an asset is impaired. Thus, if an entity
uses fair value as deemed cost for assets whose fair value is above cost, it cannot
ignore indications that the recoverable amount of other assets may have fallen below
International GAAP® 2019: Generally Accepted Accounting Practice under International Financial Reporting Standards Page 55
