The Analyst's Path

Accounting standard setters

Accounting standard setters are the bodies that write accounting standards, and they are separate from the regulators that make companies follow them. In the US the Financial Accounting Standards Board (FASB) writes US GAAP and the SEC enforces it, including by requiring restatements. In India the Institute of Chartered Accountants of India drafts, and a standard becomes law only when the Ministry of Corporate Affairs notifies it. Analysts need the split to know who wrote a rule and who can force a company to follow it.

4 min readPart of The Reporting Framework, Lessors, Revaluation and the Phase 1 CompletionsOpen in course mode

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Standard setting and enforcement are separate functions performed by separate bodies, and confusing them is why people say "the SEC requires" when they mean "the FASB requires".

Who writes and enforces the rules in the US and abroad?

In the United States, the Financial Accounting Standards Board writes US GAAP, which since 2009 has lived in a single Accounting Standards Codification. The FASB is a private body overseen by the Financial Accounting Foundation. It has no legal authority of its own. What gives its output force is that the Securities and Exchange Commission, which does have statutory authority under the securities laws, has designated the FASB as the recognised standard setter for public company filings. The SEC enforces, comments on filings, and can and does require restatements. Audit quality for public company audits is inspected by the Public Company Accounting Oversight Board.

Internationally the International Accounting Standards Board writes IFRS Accounting Standards under the oversight of the IFRS Foundation. It also has no legal authority. A standard binds a company only when the company's own jurisdiction adopts it, which most of the world outside the United States now does in some form (check the current jurisdiction count against the IFRS Foundation's own profiles). The European Union, for instance, endorses each standard separately, which has produced at least one long-running carve-out.

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Who sets the rules in India, and what is IOSCO?

India's architecture has more moving parts than either. The Institute of Chartered Accountants of India drafts, the National Financial Reporting Authority recommends and monitors, and the Ministry of Corporate Affairs notifies a standard into law under the Companies Act, 2013. Until the MCA notifies it, an Ind AS does not exist as a legal requirement however finished the drafting. Ind AS is converged with IFRS but not identical to it, each standard carrying the number of its IFRS twin, with a set of deliberate carve-outs where India chose differently. You have already met one, the treatment of a bargain purchase gain on the purchase price allocation page. The investment property page contains another, and it is the more consequential of the two for anyone comparing an Indian filer with a European one. Listed entities also answer to SEBI, whose listing regulations set the reporting calendar and much of the disclosure content, and whose enforcement is separate from the accounting standards themselves.

IOSCO stands above all of this without writing standards. It is the association of the world's securities regulators, and its 2000 recommendation that members permit the international standards for cross-border offerings turned them from an interesting project into the default outside the United States.

How are standards made, and did convergence work?

Due process is worth one paragraph because it tells you where to look when a standard is coming. Both boards work through an agenda consultation, a discussion paper, an exposure draft with a public comment period, redeliberation, and a final standard with a stated effective date and transition provisions. Comment letters are public. If you want to know what the largest filers in an industry think a proposed rule will do to their numbers, their own comment letters say so, at length, before the rule exists.

Convergence deserves a plain epitaph, and it isn't a hopeful one. The two boards worked jointly from 2002, and the projects that finished are the ones you now use daily: revenue recognition, which produced substantially identical standards, and leases, which produced two standards that agree on the balance sheet and disagree on the income statement. The financial instruments and insurance projects did not converge. The formal joint programme wound down in the mid-2010s. The practical position for an analyst is that revenue and lease liabilities are now broadly comparable across the border, and impairment, revaluation, investment property, development costs, inventory costing and the presentation of the income statement are not.

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Part of the course

This page is part of The Reporting Framework, Lessors, Revaluation and the Phase 1 Completions (M1.11), in Phase 1: Accounting: the language of business. The module's flashcards and its quiz are in the app.