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There is great ambiguity on the true representation of the ‘’adoption’’ of International Financial Reporting Standards (IFRS). What constitutes the ‘’adoption’’ of IFRS? At what point can a country, company or entity claim to have adopted IFRS? What is the best measure for IFRS adoption?

International diffusion literature and transnational governance literature provides insights as to the point of departure of how global norms are translated into local laws. It suggests that laws, norms, ideas or global regulations when diffusing turn to be reshaped and edited as they are transformed into local practices. To be exact, actors translate ideas, recombine new, externally given elements and old locally given ones to form local laws. Scholars in this arena argue that, in this context, never can we suggest that passive adoption of global standards has taken place. Yet, in many other contexts, actors at both the local level and the transnational level have tended to refer to such process as ‘adoption’ as opposed to a reflection of the variant of the law, idea or norm so implemented. In many cases, only portions of the diffused law or standards are implemented. Nevertheless, actors often refer to such as adoption as opposed to a modification of the diffused law. At other times, different actors refer to the modification of the diffused law as the adaptation of the law. This ambiguity so created has led to mixed results when looking into the idea of International Financial Reporting Standards.

In the global accountancy arena there have been several calls for the world to embrace the idea of a single global high quality accounting standard- thus IFRS. These calls have been stronger following the recent financial crisis as the world continues to pursue globalization strategies and capital flows across borders became even more pronounced. In this direction, accounting standard setters have been working to design high quality accounting standards that is applicable by nearly every country irrespective of the unique economic and cultural conditions that confront these entirely diverse countries and continents. These standards promulgated by the International Accounting Standards Board (IASB) has however, been applied in different ways than that put forth by the global accounting standard setter (IASB). In this blog entry, it is my aim to try to provide some lines of reasoning on the true meaning of IFRS adoption. I do not claim that this is the first of such arguments. However, it is my claim that global standard setters, local actors responsible for the implementation of IFRSs have often referred to entirely different versions of IFRSs when referring to IFRS adoption. If indeed IFRSs were adopted, we should expect a single version of the standard in all the jurisdictions that claim to have adopted the standards.

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More than three years after I posted ‘Fair value accounting in retreat?’ on this blog, it seems appropriate to take stock of the results of reform initiatives undertaken after the financial crisis. Just as a brief reminder: In the course of the financial crisis, International Financial Reporting Standards were suspected to have exacerbated the collapse of financial markets. Particularly the use of “fair value accounting” for banks’ financial assets was scrutinized for its contribution to downwards spirals between devaluated market assets and banks’ rising capital requirements. Previously considered as a purely technical matter, accounting principles suddenly became a matter of international politics. The G20, the Financial Stability Board, IOSCO and the two leading standard setters, IASB and the US-American FASB, all got involved in what appeared a busy beehive of reform debates. Three-and-a-half years later, with the financial crisis followed and superseded by the European sovereign debt crisis, accounting principles seem to have returned to their status of “sleeping beauty”. Yet, this impression is misleading. Accounting principles continue to be a crucial link between the reporting of financial institutions and financial market regulation. All the more a reason for reviewing two recent publications which analyse international accounting standards reform and harmonisation.

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Why should Africa adopt IFRSs? Adoption is less of the story.. not practicing what you preach is the bigger evil.

In the past decade the rise in the use of the International Financial Reporting Standards (IFRS) in many countries around the world has moved the wave towards developing countries considering adopting these standards. Factually, about 120 countries presently use IFRS across the globe. Out of this number about 13 countries in Africa have already adopted (i.e as issued by the IASB without any modification) or adapted (.i.e with modification to meet local socio-economic needs of a particular accounting jurisdiction) to IFRS.

A diverse Continent a uniform accounting standard? Primarily, former Anglo-Saxon colonies have adopted IFRSs.

(Source: Data from PwC IFRS map, Own drawings)

However, it is quite surprising that Africa as whole is considering adopting IFRS given the chaotic nature of these standards on the international front and the often unseen justification given for the adoption of IFRS particularly in Africa. Many international organizations like the World Bank , the World Trade Organization , USAID and UNCTAD  have all been arguing for the adoption of IFRS in less developed countries . There are many reasons why Africa should not adopt IFRS. I will try to explain and to some extent justify this line of reasoning.

Politics over Economics

First, the merits of IFRS often mentioned include, improved comparability and uniformity of financial statements among companies and countries, resulting in a decrease in the equity cost of capital, improved transparency, a decline in information processing cost and a reduction in risk of international investment decisions amongst others. Whilst these benefits look very desirable, it is also the case that these benefits cannot be reached in every economy.

To be clear, IFRSs were designed for developed and matured capital markets. At least the economics speaks for itself. It is an undeniable fact that financial statements assist investors in making critical investment decisions. As pointed out in the general purpose of financial statements in the conceptual framework of the IASB, financial statements should aid users in valuing securities, be it when buying or when selling.

The argument for the use of IFRSs in developed countries in plausible. However, what I find puzzling is the push for IFRS adoption even in countries that have no stock markets or stock market listed companies. I do not deny that quality financial reporting should be present in economies where there are no capital markets. But I also admit that such countries have totally different financial reporting needs than industrialized countries. Accounting systems of a country are traditionally shaped by its socio- economic, cultural and political environment. Some economies are totally different from others and therefore we must recognize that these differences in accounting needs shape financial reporting.

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This post is provided by our first “guest blogger” Sebastian Botzem. He is research fellow at the department „Internationalization and Organization” at the Social Science Research Center (WZB) in Berlin.

Fair value accounting has been identified as one of the causes of the current global financial crisis (see, for example, on this blog “Fair Value Accounting in Retreat?“). While it would be unfair to bookkeepers, accountants, auditors and academics to make them solely responsible for the loss of wealth and jobs, the present twists and quirks with regard to accounting policy are remarkable and merit closer attention.

A good example to show that the logic of accounting is questioned is Germany’s “bad bank”  solution: In principle there seems to be agreement to clear balance sheets from heavily impaired assets in order to free up capital and cut the risk of further writedowns. How that should be done, however, remains a big question. One of the great unknowns is of course how to determine the price for the assets to be transferred. Also, it needs to be determined how and to which degree the German taxpayers are eventually being burdened with liabilities not just for years, but for decades. The legal construction is also interesting: Germany’s “bad banks” are supposed to be set up as Special Purpose Entities (SPE). Günther Merl, former speaker of Germany’s public banking rescue fund Soffin (Sonderfonds Finanzmarktstabilisierung, in English: Financial Market Stabilization Fund), has just argued in the German quality daily Süddeutsche Zeitung that the government should exempt the proposed “bad banks” from the usual regulation that applies to financial institutions. The intention of such a move is to allow for accounting provisions that treat “bad banks” not as banks. The creation of Special Purpose Entities – one cause of much of the turmoil at financial markets – to rescue financial institutions indicates the dire straits market advocates are in. Read the rest of this entry »

It doesn’t happen very often that technical matters like accounting standards make it into the final declaration of a G20 summit, agreed by the heads of government of the world’s leading nations. Nevertheless, yesterday it happened (PDF). After deliberating for two days in the City of London about the appropriate means to cure the most severe worldwide financial crisis since 1929, the leaders of the G20 stated in their declaration on strengthening the financial system

We have agreed that the accounting standard setters should improve standards for the valuation of financial instruments based on their liquidity and investors’ holding horizons…. We also welcome the FSF recommendation on procyclicality that address accounting issues. We have agreed that accounting standard setters should take action by the end of 2009 to … (for more see PDF)

Why did something so mundane make it to the agenda of world politics? While it is certainly the merit of Nicolas Sarkozy’s populist threat to walk demonstratively out of the summit that made bloggers and newspaper writers wonder whether accounting standards could save the G20, the reasons for the G20 leaders dealing with “fair value” and “dynamic provision” are certainly more complex. Some, like David Zaring, also wonder whether the G20 summit produced more than just rhetoric. Read the rest of this entry »

The financial crisis is turning many things upside down. Nevertheless, it is amazing to see how the positions of key market actors on financial reporting standards have changed since the crisis started. While investment banks, accounting firms, regulators and governments in the heyday of financial market capitalism stood firmly together in unanimous and unfettered support of fair value accounting, this front has been collapsing.

In April 2008, Neue Züricher Zeitung reported Claude Bébéar, president of the French Insurance Group Axa, as saying that mark-to-market rules which require firms to value assets according to (hypothetical) market prices had contributed to the financial crisis. Henri de Castries, CEO of the same group, was quoted as referring to a “conceptual mistake” which had forced companies and banks to write down billions of assets. In September 2008, Newt Gingrich commented on “Suspend Mark-to-Market Now!”, quoting Brian S. Webury, chief economist at First Trust Portfolios of Chicago:

“It is true that the root of this crisis is bad mortgage loan, but probably 70% of the real crisis that we face today is caused by mark-to-market accounting in an illiquid market.”

With the financial crisis lingering on and politicians, regulators and banks still searching for solutions, debates on the pros and cons of mark-to-market accounting have perked up again during the last weeks.

On March 11, 2009, investor Warren Buffet admitted in an CBNC interview that mark-to-market had been “gasoline on the fire” while remarkably equivocally maintaining that Read the rest of this entry »

The Book

Governance across borders: transnational fields and transversal themes. Leonhard Dobusch, Philip Mader and Sigrid Quack (eds.), 2013, epubli publishers.
February 2017
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