International GAAP® 2019: Generally Accepted Accounting Practice under International Financial Reporting Standards

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  level of confidence than a Proved Mineral Reserve but is of sufficient quality to

  serve as the basis for a decision on the development of the deposit.’66

  • ‘A Proved Mineral Reserve is the economically mineable part of a Measured

  Mineral Resource. A Proved Mineral Reserve implies a high degree of confidence

  in the Modifying Factors. A Proved Mineral Reserve represents the highest

  confidence category of reserve estimate.’67

  The CRIRSCO Template contains more detailed guidance on how a competent person

  should decide on mineral resource and mineral reserve classification and contains a

  checklist and guideline for the preparation of public reports.

  2.4 Disclosure

  of

  mineral

  reserves and resources

  Mineral reserves and resources, or subcategories thereof, are a significant element in

  communications by mining companies and oil and gas companies to their stakeholders.

  IFRS requires an entity to provide ‘additional disclosures when compliance with the

  specific requirements in IFRSs is insufficient to enable users to understand the impact

  of particular transactions, other events and conditions on the entity’s financial position

  and financial performance’. [IAS 1.17(c)]. Therefore, although IFRS does not specifically

  require it, disclosures regarding mineral resources and reserves will generally be

  necessary under IFRS to provide users with the information they need to understand

  the entity’s financial position and performance.

  As noted in 2 above, entities have to use reserves data and sometimes resources data for

  a number of accounting purposes and the methodology should be consistent with the

  3210 Chapter 39

  definitions in the IFRS Conceptual Framework for asset recognition. We believe that

  users of the financial statements need to be able to identify the methodology used to

  estimate reserves and resources in order to understand an entity’s financial statements. If

  management uses proved reserves for investment appraisal and uses these same reserves

  for depreciation and impairment calculations, this should be clearly identified in the

  reserves disclosure. Conversely, if management uses different reserves and/or resources

  definitions for different purposes, that should be made clear in the financial statements.

  In the absence of guidance under IFRS, entities not subject to the requirements of a

  national regulator may wish to use the disclosure requirements of other standard-setters

  as a starting point in developing their own policies. The sections below discuss the

  disclosure requirements of several standard-setters for mineral reserve and resource

  quantities for oil and gas companies and mining companies (see 2.4.1 and 2.4.2

  respectively below) and reserve values (see 2.4.3 below).

  However, while disclosure of information about mineral reserves and resources is

  clearly very useful, users of financial statements should be aware that there are many

  variances between the requirements of different jurisdictions or even within those

  jurisdictions. Therefore, comparisons between entities may be difficult or even

  impossible. In particular, the following aspects are important:

  • Proven and probable reserves – The definition of reserves can vary greatly, e.g.

  the former OIAC SORP permitted disclosure of either ‘proven and probable’ or

  ‘proved developed and undeveloped’ reserves, whereas Accounting Standards

  Codification (ASC) Topic 932-235-50 – Extractive Activities – Oil and Gas –

  Notes to Financial Statements – Disclosure – requires disclosure of ‘proved

  reserves, proved developed reserves and proved undeveloped reserves’;68

  • Commodity price – The quantity of economically recoverable reserves may

  depend to a large extent on the price assumptions that an entity uses. Differences

  often arise because the entity:

  • uses its own long-term price assumption which, for example, was permitted

  under the former OIAC SORP;

  • is required to use 12-month average prices, which is required by the SEC

  Release No. 33-8995 in the oil and gas sector; or

  • is required to use a three year trailing average, which is required to comply

  with the SEC’s Industry Guide 7 in the mining sector;

  • Royalties – Royalties payable in-kind to the government or legal owner of the

  mineral rights may or may not be included in reserves;

  • Non-controlling interests – Generally ‘reserves’ include all reserves held by the

  parent and its consolidated subsidiaries. While in many jurisdictions mining

  companies and oil and gas companies are required to disclose the reserves

  attributable to significant non-controlling interests, this is not always required;

  • Associates, joint arrangements and other investments – An entity may have

  economic ownership of reserves through investments in associates and joint

  arrangements, equity interests (see 7 below) or royalty yielding contracts (see 5.7

  below). Such reserves are generally not included in consolidated reserves, but may

  need to be disclosed separately; and

  Extractive

  industries

  3211

  • Production sharing contracts and risk service contracts (see 5.3 and 5.5.1

  respectively below) – Frequently the mining company or oil and gas company does

  not legally own the mineral reserves and resources in the ground, i.e. the

  government retains legal ownership. A significant amount of judgement concerning

  the nature of the rights and economic interests of the entity may be required to

  determine whether the entity is the economic owner of any reserves or resources.

  Depending on the reserve reporting framework that the entity is subject to, such

  ‘economic’ reserves may or may not be included in reserves or resources.

  In addition to those matters set out above, there may be other variances in the reserves

  definition and disclosure requirements in different jurisdictions of which users of IFRS

  financial statements should be aware. Such differences may affect IFRS financial

  reporting directly.

  2.4.1

  Oil and gas sector

  Many oil and gas companies are required to disclose information about reserve

  quantities in accordance with the rules and requirements of the stock exchange on

  which they are listed. However, those oil and gas companies that are not subject to the

  specific disclosure requirements of a stock exchange or other local regulator should

  consider the need to disclose reserves and resources information to provide users with

  the information they need to understand the entity’s financial position and performance.

  Companies may continue to consider disclosing the information previously required

  under the former OIAC SORP or the US ASC 932-235-50, or could look to the example

  disclosures contained in the 2010 DP at 1.3.4 above.

  2.4.2 Mining

  sector

  Many mining companies are required to disclose information about reserve quantities

  in accordance with the rules and requirements of the stock exchange on which they are

  listed. However, those mining companies that are not subject to the specific disclosure

  requirements of a stock exchange or other local regulator may wish to consider

 
disclosing the information required under the US Securities and Exchange

  Commission’s Industry Guide 7 – Description of Property by Issuers Engaged or to Be

  Engaged in Significant Mining Operations (SEC Industry Guide 7).

  Mining companies that are subject to the SEC rules and regulations need to understand

  not only the content of Industry Guide 7, but also the current interpretation of this

  content by the SEC’s staff. While many of the definitions may seem familiar, the SEC

  staff’s interpretations may differ considerably from those of regulators in other

  countries.69 Refer to SEC Industry Guide 7 sections I-III for details.

  2.4.3

  Disclosure of the value of reserves

  As part of its work on the Extractive Activities DP (see 1.3.4 above) the IASB staff

  considered whether a disclosure-focused approach might be appropriate in an extractive

  industries financial reporting standard. It is in this context that the DP noted that, given

  the near unanimity of the feedback from users on the lack of relevance of either historical

  cost or current value accounting for reserves and resources, a disclosure-focused

  approach needed to be considered as one alternative in the discussion paper.70

  3212 Chapter 39

  One of the key issues to consider before developing a disclosure-focused approach is

  whether or not disclosure of the value of mineral reserves should be a requirement. A

  secondary issue is whether the mineral reserves should be disclosed at their fair value

  or at a standardised measure of value, similar to the requirement under ASC 932-235-50

  which is based on discounted cash net cash flows.

  This disclosure requirement is not uncontroversial, as the ‘standardized measure of oil and

  gas’ (often abbreviated to SMOG) does not represent the market value of an entity’s proved

  reserves. However, the standardised measure of the value of oil and gas reserves greatly

  reduces the impact of management’s opinion about future development on the value

  calculated, e.g. the method prescribes the discount rate and commodity price to be used.

  While this may not take into account relevant insights that management may have, the

  advantage is that comparability of the disclosures between entities is increased. As illustrated

  in Extract 39.1, some companies caution against over-reliance on these disclosures.

  Extract 39.1: BP p.l.c. (2017)

  Supplementary information on oil and natural gas (unaudited) [extract]

  Standardized measure of discounted future net cash flows and changes therein relating to proved oil and gas reserves

  [extract]

  The following tables set out the standardized measure of discounted future net cash flows, and changes therein,

  relating to crude oil and natural gas production from the group’s estimated proved reserves. This information is

  prepared in compliance with FASB Oil and Gas Disclosures requirements.

  Future net cash flows have been prepared on the basis of certain assumptions which may or may not be realized. These

  include the timing of future production, the estimation of crude oil and natural gas reserves and the application of average crude oil and natural gas prices and exchange rates from the previous 12 months. Furthermore, both proved reserves estimates and production forecasts are subject to revision as further technical information becomes available and economic conditions change. BP cautions against relying on the information presented because of the highly arbitrary nature of the assumptions on which it is based and its lack of comparability with the historical cost information presented in the financial statements.

  It is clear that reaching agreement as to what constitutes useful and relevant disclosures

  about the value of mineral reserves is not straightforward and will be controversial. Still, in

  September 2008, the Board indicated support for the Extractive Activities DP to propose

  the disclosure of ‘a current value measurement, such as a standardised measure of

  discounted cash flows, and the key assumptions necessary for a user to make use of that

  measurement’. This would not be disclosed if the minerals or oil and gas assets are measured

  on the balance sheet at fair value or some other current value measurement. In that case, an

  entity would provide disclosures similar to those required in the US (by ASC 820-10-50-1,

  2, 3 – Fair Value Measurements and Disclosures).71 Accordingly, the DP concluded that:

  • if the assets are measured at historical cost then detailed information should be

  disclosed about their current value (either fair value or standardised measure) and

  how it was determined;

  • if, instead, the assets are measured at fair value then detailed information should

  be disclosed about that fair value and how it was determined.

  2.4.3.A

  ASC 932-235-50 – disclosure of standardised measure of oil and gas

  All entities engaged in significant oil and gas producing activities that report under

  US GAAP are required by ASC 932-235-50 to disclose a standardised measure of

  Extractive

  industries

  3213

  discounted future net cash flows relating to proved oil and gas reserve quantities. There

  may also be non-US GAAP oil and gas companies who, while they are not subject to these

  specific disclosure requirements, still elect to refer to these when determining the reserves

  and resources information to provide to their users. ASC 932-235-50 is highly prescriptive

  and should be reviewed directly in full to ensure compliance with its requirements.

  3

  IFRS 6 – EXPLORATION FOR AND EVALUATION OF

  MINERAL RESOURCES

  3.1

  Objective and scope

  The IASB’s objective in developing IFRS 6, as noted at 1.2 above, was restricted to

  making limited improvements to existing accounting practices for exploration and

  evaluation (E&E) expenditures. E&E expenditures are ‘expenditures incurred by an

  entity in connection with the exploration for and evaluation of mineral resources before

  the technical feasibility and commercial viability of extracting a mineral resource are

  demonstrable’, while E&E assets are ‘exploration and evaluation expenditures

  recognised as assets in accordance with the entity’s accounting policy’. [IFRS 6 Appendix A].

  IFRS 6 is limited to specifying the financial reporting for the exploration for and evaluation

  of mineral resources, which the standard defines as ‘the search for mineral resources,

  including minerals, oil, natural gas and similar non-regenerative resources after the entity

  has obtained legal rights to explore in a specific area, as well as the determination of the

  technical feasibility and commercial viability of extracting the mineral resource’.

  [IFRS 6.1, Appendix A]. The standard also specifies when entities need to assess E&E assets for

  impairment in accordance with IAS 36 and requires certain disclosures.

  An entity may not apply IFRS 6 to expenditures incurred before the exploration for and

  evaluation of mineral resources (e.g. expenditures incurred before the entity has

  obtained the legal rights to explore a specific area such as prospecting and acquisition

  of mineral rights) or after the technical feasibility and commercial viability of extracting

  a mineral resource are demonstrable (e.g. development, construction, production and

  closure). [IFRS 6.5]. Furthermore, it deals only with E&E expenditures and does not
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  provide guidance on other sector-specific issues that may arise during the E&E phase.

  Equipment used in the E&E phase, e.g. property, plant and equipment and any other

  intangibles, such as software, are not in the scope of IFRS 6, instead, they are in the

  scope of IAS 16 or IAS 38.

  3.1.1

  Scope exclusions in other standards relating to the extractive industries

  In the Basis for Conclusions on IFRS 6 the IASB confirmed that ‘even though no IFRS

  has addressed extractive activities directly, all IFRSs (including International

  Accounting Standards and Interpretations) are applicable to entities engaged in the

  exploration for and evaluation of mineral resources that make an unreserved statement

  of compliance with IFRSs in accordance with IAS 1’. [IFRS 6.BC6]. However, certain

  aspects of activities that occur in the extractive industries that fall outside the scope of

  IFRS 6 are excluded from the scope of other standards.

  Various standards exclude ‘minerals’ from their scope, but the exact wording of the

  scope exclusions differs from standard to standard. Therefore, it would be incorrect to

  3214 Chapter 39

  conclude that the same aspects of the extractive industries’ activities are excluded from

  the scope of these standards:

  • IAS 2 – does not apply to the measurement of minerals and mineral products, ‘to

  the extent that they are measured at net realisable value in accordance with well-

  established practices in those industries’. [IAS 2.3(a), 4]. The practice of measuring

  minerals and mineral products inventories at net realisable value is, in reality,

  relatively rare in many areas of the extractive industries.

  • IAS 16 – does not apply to ‘mineral rights and mineral reserves such as oil, natural

  gas and similar non-regenerative resources’. [IAS 16.3(d)]. In addition, the standard does

  not apply to ‘the recognition and measurement of exploration and evaluation assets’.

  [IAS 16.3(c)]. Equipment used in extracting reserves is within the scope of IAS 16.

  • IAS 17 – does not apply to ‘leases to explore for or use minerals, oil, natural gas and

  similar non-regenerative resources’. [IAS 17.2(a)]. However, leases of assets used for

  exploration or evaluation activities are in the scope of IAS 17.

 

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