Reporting and assurance of service performance information - Consultation Paper Feedback Form

Section 1 Summary – Purpose and Scope of Consultation

The XRB seeks feedback from not-for-profit entities, assurance practitioners, and users on challenges and possible improvements in service performance reporting and assurance.
Input is requested on reporting experiences, proposed amendments, and guidance materials.
Feedback can be provided via sessions or written submissions by 29 August 2025.

Section 2 Summary – Background to Service Performance Reporting

PBE FRS 48 sets out requirements for service performance reporting by Tier 1 and 2 public benefit entities.
The standard uses a principles-based approach, requiring relevant performance measures and related disclosures for accountability and decision-making.
Not-for-profits have only recently started following these requirements and assurance standards.

Respondent details

Name

Organisation

Contact email

Section 3 Summary – Key Challenges and XRB’s Proposed Actions

Workshops identified strong support for high-quality reporting, but several challenges:
- Lack of clarity due to flexible, principles-based requirements.
- Different needs and capacities between public sector and not-for-profits.
- Immature systems and processes in not-for-profits.
- Verification difficulties due to incomplete evidence, especially for qualitative information and uncertainty about the level of evidence required for assurance.
The XRB proposes targeted amendments and additional guidance to address these issues.

Question 1 (for reporting entities and assurance practitioners)

Do you agree that the root causes described above are contributing to the key challenges in preparing and assuring service performance information?

Do you have any other feedback on the challenges?

Section 4 Summary – Potential Amendments to PBE FRS 48

Feedback highlighted practical challenges:
- Ambiguity about what to report, especially around long-term impacts.
- Uncertainty about identifying users and selecting performance measures.
- Sector differences affecting how not-for-profits report.

Proposed amendments include:
- Clarifying the purpose, scope, and user focus.
- Aligning terminology with the PBE Conceptual Framework.
- Adding disclosure requirements on preparation and judgements.
- An appendix with not-for-profit-specific guidance (e.g., framework steps, reporting within annual periods).

Question 2 (for reporting entities and assurance practitioners)

Do you agree that amending the requirements of PBE FRS 48 at this time would help to address current challenges?

Do you anticipate additional costs will be incurred if the requirements are amended?

Question 3 (for reporting entities and assurance practitioners)

Do you agree with all the proposed targeted amendments in (a) – (d)?

Are there any other areas that may need clarifying and why?

Question 4 (for reporting entities and assurance practitioners)

Do you consider that adding an appendix to PBE FRS 48 for the not-for-profit sector in (e) would be beneficial to address some challenges experienced by not-for-profit entities?

Question 5 (for reporting entities and assurance practitioners)

Do you agree with the topics for the proposed not-for-profit appendix in (e)? If not, please explain the areas that could be clarified.

Section 5 Summary – Proposed Reporting Guidance

Preparers face challenges with:
- Developing performance frameworks and measures.
- Collecting and documenting supporting evidence.
- Using qualitative as well as quantitative measures.
The XRB proposes workshops and supplementary material, especially for key sub-sectors, to address these challenges.

Question 6 (for reporting entities)

Do you agree that the XRB hosting workshops for significant sub-sectors preparers to develop further supplementary material for service performance reporting would be beneficial?

What other material or approaches to guidance would be beneficial?

Section 6 Summary – Assurance Guidance

Assurance challenges include:
- Verifying reported information without sufficient evidence, particularly for qualitative data.
- Applying assurance standards, such as sampling and materiality.
- Limited internal controls over service performance information.
The XRB aims to provide guidance on evidence, internal controls, materiality, and sampling.

Question 7 (for assurance practitioners)

Do you agree that guidance to address the identified challenges will be useful to assurance practitioners?

What areas, other than sufficient appropriate evidence, would be beneficial?

Question 8 (for assurance practitioners)

Do you agree that the targeted amendments to PBE FRS 48 and further service performance reporting guidance material as proposed in previous sections could also help address some of the assurance challenges?

Section 7 Summary – User Perspectives

Users (funders, donors, service recipients) sometimes find current reports insufficient for their accountability and decision-making needs.
The XRB is considering clearer disclosures and basis of preparation to improve usefulness.
Feedback is invited on user challenges and further improvements needed.

Question 9 (for users)

How do you use service performance information to make decisions?

Do you face any challenges in understanding service performance information and what may be the cause of these challenges?

Question 10 (for users)

Do you consider the proposals around the inclusion of a basis of preparation and further disclosures (as noted in Part 4) would enhance your understanding and use of service performance information? If not, what other actions should the XRB consider furth

Question 11 (for all respondents)

Do you have any other comments on the reporting and assurance of service performance information?