Submissions

Making submissions on a range of issues affecting the reporting ecosystem is a critical part of the XRB's work. The majority of our submissions are focused on international developments, and despite New Zealand being a small country, the XRB has developed a strong standing and voice internationally. 

Feature Image

This page lists submissions from the XRB, NZASB, NZAuASB and SRB since 2017

Accounting submissions

Title Date submitted

RFI 2025/1 Request for Information - Post-Implementation Review IFRS 16 Leases

Oct 2025

ED 2024/8 Provisions - Targeted Improvements

Mar 2025

ED 2024/7 Equity Method of Accounting 

Dec 2024

ED 2024/6 Climate-related and Other Uncertainties in Financial Statements

Nov 2024

ED 2024/3 Contracts for Renewable Electricity

Aug 2024

ED/2024/1 Business Combinations—Disclosures, Goodwill and Impairment 

Jul 2024

ED/2023/5 Financial Instruments with Characteristics of Equity

Mar 2024

IFRS Interpretations Committee tentative agenda decision Climate-related Commitments

Feb 2024

Request for Information: Post-Implementation Review of IFRS 15 Revenue from Contracts with Customers

 Oct 2023

Request for Information: Post-Implementation Review of IFRS 9 - Impairment

Sep 2023

ED/2023/2 Amendments to the Classification and Measurement of Financial Instruments 

Jul 2023

ED/2022/1 Third edition of the IFRS for SMEs Accounting Standard

Feb 2023

IFRS Interpretations Committee tentative agenda decision Negative Low Emission Vehicle Credits

Apr 2022

ED/2021/9 Non-current Liabilities with Covenants

Mar 2022

ED/2021/7 Subsidiaries without Public Accountability: Disclosures

Jan 2022
ED/2021/3 Disclosure Requirements in IFRS Standards — A Pilot Approach Nov 2021
Request for Information: Third Agenda Consultation Sep 2021
DP 2020/2 Business Combinations under Common Control Aug 2021

ED 2021/2 Covid-19-Related Rent Concessions beyond 30 June 2021

Feb 2021

DP/2020/1 Business Combinations – Disclosures, Goodwill and Impairment

Dec 2020

ED/2019/7 General Presentation and Disclosure

Sep 2020

ED/2019/6 Disclosure of Accounting Policies (Proposed amendments to IAS 1 and IFRS Practice Statement 2)

Nov 2019
DP/2018/1 Financial Instruments with Characteristics of Equity Dec 2018
ED/2018/1 Accounting Policy Changes (Proposed amendments to IAS 8) May 2018
DP 2017/1 Disclosure Initiative—Principles of Disclosure Oct 2017
Other body Title Date submitted
Finance and Expenditure Committee Inquiry into performance reporting and public accountability November 2025
IVSC Standards Review Board IVSC Standards Review Board IVS Agenda Consultation  August 2017

Auditing and assurance submissions

Title Date Submitted

Use of external experts narrow scope amendments

July 2025

Auditor responsibilities relating to fraud in a financial statement audit

Jun 2024

Proposed narrow scope amendments as a result of revisions to the definitions of listed entity and public interest entity in the IESBA Code

Apr 2024

Sustainability Assurance

Nov 2023

Going Concern

Aug 2023

Proposed IAASB Strategy and Work Plan 2024-2027

Apr 2023

ISA 500 (Revised) Audit Evidence

Apr 2023

Proposed narrow scope amendments to operationalise the IESBA transparency requirement in the Code

Oct 2022

Proposed International Standard on Auditing for Audits of Financial Statements of Less Complex Entities

Jan 2022
Work Plan Survey 2022-2023 Aug 2021
Conforming Amendments to Other Assurance Engagement Standards and Review Engagements May 2021 
Auditor Reporting Prescribed Investor Rate Survey (National Standard Setters) Nov 2020
ISA 600 (Revised), Special Considerations-Audits of Group Financial Statements (Including the Work of Component Auditors) Oct 2020
Proposed Non-Authoritative Guidance Extended External Reporting Assurance Jul 2020
Discussion Paper: Going Concern and Fraud Feb 2020 
Conforming Amendments to the IAASB International Standards as a Result of the Revised IESBA Code Jan 2020
Audits of Less Complex Entities Oct 2019
Quality Management Overview  Jul 2019
International Standard on Quality Management 1  Jul 2019
International Standard on Quality Management 2  Jul 2019
ISA 220 (Revised), Quality Management for an Audit of Financial Statements Jul 2019
Proposed Strategy for 2020-2023 and Work Plan for 2020-2021  Jun 2019
Extended External Reporting Assurance Jun 2019
ISA 315, Identifying and Assessing the Risks of Material Misstatement Oct 2018
ISA 540 (Revised), Auditing Accounting Estimates and Related Disclosures Aug 2017
Discussion Paper: Agreed-upon Procedures Engagements Mar 2017
Exploring the Growing use of Technology in the Audit, with a Focus on Data Analytics Feb 2017
Discussion Paper: Supporting Credibility and Trust in Emerging Forms of External Reporting: Ten Key Challenges for Assurance Engagements Feb 2017
Title Date Submitted
IESBA Collective Investment Vehicles and Pension Funds - Auditor Independence June 2025
IESBA Independence and Ethics for Sustainability Assurance Practitioners May 2024
Using the Work of an External Expert April 2024
Proposed IESBA Strategy and Work Plan 2024-2027 June 2023
IESBA Strategy Survey 2022 Jul 2022
Proposed Technology-related Revisions to the Code Jun 2022
Definition of Engagement team and Group Audits Jun 2022
Conforming Amendments to the Code following revisions to the Quality Management Standard Sep 2021
Long Association Post-implementation Review May 2021
Public Interest Entity Definition Apr 2021

Fee-related Provisions of the Code

Jun 2020

Non-Assurance Services

Jun 2020

Proposed Revision to the International Code Addressing the Objectivity of Engagement Quality Reviewers

Mar 2020

Proposed Revisions to Part 4B of the Code of Ethics

Jul 2019

Professional Scepticism and Meeting Public Expectations

Aug 2018
Proposed Strategic Work Plan 2019-2023 Jul 2018
Fees Questionnaire 2017 Jan 2018
Proposed Revisions to the Code Pertaining to the Offering and Accepting of Inducements Dec 2017
Strategy Survey Questionnaire Aug 2017
Proposed Application Material Relating to Professional Scepticism and Professional Judgment Jul 2017
Improving the Structure of the Code of Ethics for Professional Accountants – Phase 2 May 2017 
Proposed Revisions Pertaining to Safeguards in the Code—Phase 2 and Related Conforming Amendments  Apr 2017 
Proposed Revisions to Clarify the Applicability of Provisions in Part C of the Extant Code to Professional Accountants in Public Practice  Apr 2017

 

Climate submissions

XRB Board submissions

From time-to-time the XRB Board makes submissions to domestic and international bodies. 

These normally relate to the XRB Board’s financial reporting strategy function.

Please note that submissions on particular accounting, assurance, or climate standards issues are usually made instead by the NZASB, NZAuASB and SRB respectively.

Submission title Date
Submission on Charities Amendment Bill Dec 2022
Submission to ISSB on draft IFRS S1 and draft IFRS S2 Jul 2022
Submission on Incorporated Societies Bill May 2021
IFRS Foundation Consultation Paper on Sustainability Reporting  Dec 2020
Final Survey Response Framework Revision – XRB staff views  Sep 2020
Submission to the International Integrated Reporting Council on the Framework Revision-Focused Engagement  Mar 2020 
Survey of IPSASB Oversight Arrangements Feb 2020

Submission on Climate-related Financial Disclosures to MBIE-MfE Discussion Document

Dec 2019 
Submission to the Governance and Administration Select Committee on the Auckland Regional Amenities Funding Amendment Bill Nov 2019
Submission to the Productivity Commission on Local Government Funding and Financing – Draft Report Aug 2019
Submission to the Department of Internal Affairs on Modernising the Charities Act 2005 May 2019
Submission to the Productivity Commission on Climate Change Draft Recommendations Apr 2018
Submission to Monitoring Group on Global Audit Standard-setting Governance Feb 2018
Submission to NZX on Listing Rules Nov 2017
Submission to FMA on Disclosing non-GAAP financial information Apr 2017
Submission to MoJ on ED AML/CFT Amendment Bill Jan 2017

Periodically, the XRB Board calls for submissions on particular matters.  

Consultation title Date
Targeted Review of the NZ Accounting Standards Framework 15 Nov 2019