Proposed IFRS Roadmap Published by the SEC

In August 2008, the SEC announced that it had plans to release a Roadmap with respect to transitioning from US GAAP to IFRS. The anticipation is finally over as the SEC published its proposed IFRS Roadmap on November 14, 2008. The Plan outlines milestones that would give a narrow group of companies the option to early adopt beginning with their fiscal years ending on or after December 15, 2009. The US issuers that have the option to early adopt the transition rules to IFRS would need to be among the 20 largest companies worldwide in its industry as measured by market capitalization with IFRS being the most common financial reporting basis used by those 20 companies. One item of note is that companies that elect to report using IFRS beginning with their December 31, 2009 year-end will need to provide comparable IFRS audited financial information for the 2007 and 2008 years as well. The SEC has also indicated that these early adopting companies will need to obtain a "letter of no objection" from the SEC’s Division of Corporate Finance. The "letter of no objection" will give the company the SEC’s blessing to use IFRS, but does not require it at that time.


As the IFRS train gains momentum, the SEC’s plan calls for seven milestones to achieve full adoption. These milestones are:

  • Improvements to accounting standards
  • Funding of the International Accounting Standards Committee Foundation
  • Improved ability to use interactive data for IFRS reporting
  • Improved education and training in the US
  • Limited use in a narrow group of companies (i.e. December 31, 2009)
  • SEC to determine in 2011 whether mandatory adoption of IFRS is feasible based on the progress in the first five milestones
  • Mandatory use – If decided to go full steam ahead (as discussed in milestone 6) then large accelerated, accelerated and non-accelerated filers would be required to adopt IFRS beginning with their years ending on or after December 15, 2014, 2015 and 2016, respectively.



The SEC’s Roadmap gives issuers electing to use IFRS two choices on how to present their IFRS financial information as it relates to US GAAP. The first option is a disclosure of a reconciliation from US GAAP to IFRS. The reconciliation would include a restatement and reconciliation from prior years’ financial statements and related disclosures. This would be done in accordance with IFRS 1, "First-time Adoption of International Financial Reporting Standards". The second choice would be to provide the one-time reconciliation previously discussed and then provide on an ongoing basis an unaudited reconciliation from US GAAP to IFRS. At this time, there is no prescribed format for the reconciliation, nor is it required on interim reports.


  • Certain amendments to Rule 4-01 and Article 13 of Regulation S-X would be made to incorporate the "IFRS" terminology.
  • Item 301(a) of Regulation S-K previously required five years of selected financial data in the financial filings. The amendment would allow issuers to present three years in the initial year of adoption and build to the five year requirement in subsequent year filings.

The proposed Roadmap is open for a comment period of 90 days which will begin upon its publication in the Federal Register.

EisnerAmper's International Services Group has anticipated the transition to IFRS reporting and is positioned to service clients as the transition progresses. Our experts can assist your company in understanding all of the accounting and tax implications that this transition will create.

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