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Conversion to Ind-AS

Key questions that boards and audit


committees should ask
Content
Background .................................................................................................................................................................................................... 1
Role of the board/audit committee ................................................................................................................................................................. 3
Initial considerations ....................................................................................................................................................................................... 4
1. How can our organization capitalize on the opportunities presented by the conversion to Ind-AS? ............................................................... 4
2. What are the most significant risks associated with converting to Ind-AS? .................................................................................................. 5
3. How will converting to Ind-AS affect our stakeholders and what should be done to manage the expectations of capital markets? ..................6
Financial reporting considerations................................................................................................................................................................... 7
4. What are the high-level differences in accounting and disclosures between previous GAAP and Ind-AS, and what
are the estimated effects on the income statement and the balance sheet?.................................................................................................... 7
5. How is the adoption of Ind-AS expected to impact management reporting? ................................................................................................ 9
6.How will Ind-AS affect the accounting for income taxes and tax filings? .....................................................................................................10
Conversion project considerations.................................................................................................................................................................11
7. How do we plan to approach the conversion to Ind-AS and how ready are we to do this? ...........................................................................11
8. What are the key areas that need to be addressed during the conversion?................................................................................................12
9. What is the timeline for our Ind-AS conversion project; what are the resources that will be required and how much will it cost? ...................13
10. What can we learn from the conversion experiences of others, including Europe and Australia? ..............................................................14
Non-financial reporting considerations ..........................................................................................................................................................15
11. Other than financial reporting, which other business areas are likely to be impacted by the conversion? ..................................................15
12. Can our current IT systems handle the business’ revised data collection requirements under Ind-AS? ......................................................16
List of abbreviations ....................................................................................................................................................................................17
Background
The issuance of IFRS roadmaps applicable to the non-financial In accordance with the clarification, the ICAI has already issued
services sector and the financial services sector by the Ministry exposure drafts (ED) of all IFRS-converged standards that will
of Corporate Affairs (MCA) have crystallized the date of IFRS apply to Indian companies. These standards are likely to be
conversion for Indian companies. In addition, the MCA has known an “Indian Accounting Standards” (Ind-AS).
clarified that companies covered by the IFRS conversion
We welcome the initiatives that are being taken by various
roadmaps will not have an option to use “full IFRS.” Rather, they
regulatory bodies to achieve conversion. We believe that the
will need to comply with IFRS-converged standards that are
conversion to IFRS is a historic step, which will elevate Indian
being issued by the Institute of Chartered Accountants of India
companies and their finance and accounting professionals to
(ICAI) and will be notified under the Companies Act, 1956, as a
greater heights.
separate set of standards. This will effectively create a separate
body of accounting standards, which may not necessarily be
the same as IFRS issued by the International Accounting
Standards Board (IASB).

IFRS conversion roadmap: non-financial services sector


Ind-AS will apply in three phases as below:

Phase Date Coverage


Phase I Opening balance sheet as at i. Companies that are a part of the NSE Index — Nifty 50
1 April 2011*
ii. Companies that are a part of the BSE Sensex — BSE 30

iii. Companies whose shares or other securities are listed on a stock exchange outside India

iv. Companies, whether listed or not, with net worth exceeding `1,000 crores
Phase II Opening balance sheet as at Companies, not covered in phase I, and with net worth exceeding `500 crores
1 April 2013*
Phase III Opening balance sheet as at Listed companies not covered in the earlier phases
1 April 2014*

* If the financial year of a company commences at a date other than 1 April, then it will prepare its opening balance sheet at the commencement of the immediate
following financial year.

1 Conversion to Ind-AS
IFRS conversion roadmap: financial services sector
Like the non-financial sector, the roadmap requires Ind-AS to be applied to companies in the financial services sector in a phased
manner. Given below is the applicability date:

Applicability date Insurance companies Banking companies Non-banking finance companies (NBFCs)*
Opening balance sheet as at 1 All insurance companies — —
April 2012
Opening balance sheet as at 1 — i. All scheduled commercial i. NBFCs that are a part of the NSE Index —
April 2013 banks Nifty 50
ii. Urban co-operative banks ii. NBFCs that are a part of the BSE Sensex —
(UCBs) with the net worth BSE 30
exceeding `300 crores
iii. NBFCs, whether listed or not, with the net
worth exceeding `1,000 crores
Opening balance sheet as at — UCBs with the net worth All listed NBFCs and NBFCs with the net worth
01 April 2014 exceeding `200 crores, but not exceeding `500 crores, but not covered in the
exceeding `300 crores previous phase

* If the financial year of an NBFC commences at a date other than 01 April, then it will prepare its opening balance sheet at the commencement of the immediate following
financial year.

Companies not covered in the above conversion roadmaps have been given an option to continue to either follow Indian GAAP or
adopt Ind-AS.

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Role of the board/audit committee
Converting to Ind-AS will be one of the most fundamental account, and the statement of cash flows. A person is considered
changes that Indian companies will have to deal with over the to have accounting or related financial management expertise if
coming years. Such a momentous change will bring with it both he or she has experience in finance or accounting, or requisite
significant opportunities and associated risks. The management professional certification in accounting, or any other comparable
in every company will be responsible for the operational planning experience or background, which results in the individual’s
and implementation of the Ind-AS transition, but the ultimate financial sophistication, including being or having been a chief
onus lies with those charged with governance. A company’s executive officer, chief financial officer or any other senior officer
board of directors, particularly its audit committee, will play a with financial oversight responsibilities.
key oversight role. It is crucial for directors to have a general
To help directors and audit committee members perform this role
understanding of what the transition to Ind-AS means for their
in a more efficient manner, this publication sets out questions
organization. The members of the audit committee should have a
that will assist them in understanding the potential scope of the
greater insight about the implications of Ind-AS so that they are
change management exercise that conversion may pose for
well equipped to manage the upcoming conversions.
their business. In addition, the publication provides guidance
Audit committees need to be sufficiently educated and to directors and audit committee members on key questions
knowledgeable about Ind-AS to enable them to fulfil their duties that they should ask the management as they prepare for the
and discharge their responsibilities. This includes the ability to conversion.
use their discretion to arrive at well substantiated perspectives
The questions are organized into four main groups:
and give relevant judgment on the management’s analysis of
accounting alternatives and the selection of accounting policies. A. Initial considerations
In case of listed companies, clause 49 of the listing agreement
B. Financial reporting considerations
requires that all members of the audit committee should be
financially literate and that at least one member should have C. Conversion project considerations
accounting or related financial management expertise.
D. Non-financial reporting considerations
“Financially literate” means the ability to read and understand
basic financial statements, i.e., balance sheet, profit and loss

3 Conversion to Ind-AS
1. How can our organization capitalize on the opportunities presented by the
conversion to Ind-AS?

The conversion to Ind-AS may present potential opportunities financial reports to investors and other interested parties based
that companies would want to further examine and explore. on the same accounting standards used by those peers may
In the absence of any specific guidance under the current Indian increase the company’s comparability with its peers.
GAAP, companies may currently find themselves accounting Once the conversion commences, companies will want to
for transactions in a manner that does not best reflect the understand the financial reporting decisions being made by their
substance of the transaction. For example, under the current peers and other companies around exemptions/relaxations given
A. Initial Indian GAAP, there is no guidance on the identification of leases on first-time adoption. This will require converting companies to
contained in sales/purchase or service contracts. Keeping this share their thoughts and perspectives on potential policies with
considerations in view, companies typically do not identify leases contained each other. Notably, companies that have already adopted IFRS
in such arrangements. The application of Ind-AS will require in Europe, Australia or elsewhere can provide useful information.
the management to thoroughly analyze the substance of a Further, investors and market analysts will also want to be aware
transaction for applying Ind-AS principles. This creates an of the choices that the company is making and how these choices
opportunity for companies to identify and select accounting that compare against the ones made by the company’s peers.
they believe will result in the most appropriate representation
of their financial results and position. Further, the exposure Some companies will realize that there is a significant underlying
draft (ED) of Ind-AS 41 First-time Adoption of Indian Accounting opportunity in using the conversion project as a means to drive
Standards provides many voluntary exemptions from full other areas of change. For example, companies may consider the
transition. The selection of appropriate exemptions/relaxations conversion to Ind-AS as an opportunity to streamline accounting
will need careful consideration in any Ind-AS conversion. and reporting processes or to accelerate the financial statement
close process.
A large number of companies operate on a global scale and have
competitors that are not based in India. Being able to provide

4 Conversion to Ind-AS
A. Initial considerations (Cont’d.)

2. What are the most significant risks associated with converting to Ind-AS?

The conversion to Ind-AS would be one of the most fundamental consequences in the design and/or effectiveness of existing including the potential to have to rethink accounting policy
changes in financial reporting in the Indian history. The internal controls; hence increasing the risk component. As a decisions made by subsidiaries who have already adopted
potentially pervasive nature of the changes at the accounting, result, risk management functions will need to be engaged in the IFRS or their equivalents
functional, transactional and internal control levels increases conversion process to mitigate the risks involved.
• Retention of key employees
the risk of misstatement. Further, the current financial reporting
There are various risks associated with the conversion to Ind-AS
environment has little tolerance for mistakes, and it will be • Excessive costs brought on by ineffective planning, project
that will have to be addressed by the management. The examples
important for all companies to get the conversion right in the management and/or rework
of potentially significant risk areas include:
first time. Misstatements, as well as missed reporting deadlines,
• Unreasonable or excessive work levels, brought on by
present a significant risk to companies that are converting. • Failure to communicate the effects and results to
inappropriate planning or unreasonable expectations
stakeholders, including boards, audit committees, investors
A robust system of internal controls is a company’s best
and analysts • Missed deadlines in the conversion timetable
method of ensuring reporting integrity and minimizing the risk
of misstatements. To maintain effective internal controls on • Accounting and reporting under multiple accounting • Inability of the CEO/CFO to conclude and certify on the
financial reporting, management will need to consider the impact frameworks during the transition period effectiveness of the company’s internal controls over
that changes to financial accounting and reporting may have on financial reporting as required under clause 49 of the
• Maintaining consistency in the manner in which the various
internal controls. A period of change, such as one encountered Listing Agreement
Ind-AS principles are applied throughout the organization,
during an accounting conversion, could lead to unintended

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A. Initial considerations (Cont’d.)

3. How will converting to Ind-AS affect our stakeholders and what should be done to manage the expectations of the
capital markets?

The European and Australian experience in adopting IFRS differences between their current accounting policies and • 2005 annual financial statements: For most listed entities
was that the conversion from the various local accounting the ones they know with sufficient certainty they will have to in Europe, these will be the first complete set of financial
frameworks to IFRS did not, in and of itself, affect market ratings. apply under IFRS. statements presented under IFRS.
Many attributed this fact to the effective communication with
investors, analysts and regulators about the possible effects • Publication of the 2004 annual report (including the 2004 Unlike Europe, the regulators in India, viz., ICAI or MCA, have not
of IFRS on their financial reporting. These communications financial statements): As soon as an entity can quantify prescribed any specific disclosures that should be made during
were made periodically throughout the conversion process. In the impact of the change to IFRS on its 2004 financial the transition period. Nonetheless, frequent communication with
the context of the European Union (EU) transition to IFRS in statements in a sufficiently reliable manner, it should investors and analysts is equally important for Indian companies.
2005, the Committee of European Securities Regulators (CESR) disclose the relevant quantified information. Managing investors’ and other stakeholders’ expectations with
published detailed recommendations on how listed EU entities respect to the effects of Ind-AS and the company’s progress
• 2005 interim financial reports (half-yearly and quarterly
can effectively communicate to investors the potential impact of toward conversion will be an important area for the boards to
financial reports): In the interim financial reports for 2005,
transitioning to IFRS in 2005. The recommendations identified monitor. Further, clear, continuous and consistent communication
listed entities should start applying as of 1 January 2005,
the following four key milestones in the transition process: with stakeholders will reduce the risk of misunderstandings and
either IAS 34 Interim Financial Reporting, or, if this is not
aid a smooth transition. Indian companies will need to sound
• Publication of the 2003 annual report (including the possible, at least the IFRS recognition and measurement
investors/ analysts about the expected changes in advance.
2003 financial statements): Entities should explain (a) how principles that will be applicable at the year end.
They will also need to provide assistance to investors/analysts
they intend to carry out the transition to IFRS (plans and
to understand financial reporting under Ind-AS to avoid the
degree of achievement for the transition), and (b) the key
potential risk of misinterpretation.

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4. What are the high-level differences in accounting and disclosures between
previous GAAP and Ind-AS, and what are the estimated effects on the income
statement and balance sheet?

The first step in an effort involving the conversion to Ind-AS • Change in revenue numbers: Under the Indian GAAP,
is to identify, at a high level, the differences between the new real estate companies recognize revenue based on
set of standards and the previous GAAP that will affect the the “percentage of completion method.” The ED-Ind-
company’s financial reporting. For Indian companies, this should AS 9 Revenue will in most cases allow revenue to
be a relatively straightforward exercise, as the most significant be recognized only on the delivery of the unit to the
B. Financial differences between IFRS and Indian GAAP are well understood. purchaser. Apart from the impact on revenue numbers,
this may also significantly affect performance indicators
Since the ICAI has not made any major differences while issuing
reporting EDs of Ind-AS, the same differences are likely to prevail in the such as operating profit, EBITDA and EPS.
transition to Ind-AS. But, the “devil will often be in the detail.”
cosiderations This analysis will provide the foundation for further analysis,
• Mismatch of profits and cash flow: The application of
service concession contract accounting prescribed in
including systems as well as any other impact. ED-Ind-AS 7 Construction Contracts by infrastructure
Converting to Ind-AS likely will have far-reaching effects on companies will require them to recognize revenue
the way financial reporting is conducted. Some of the key when the construction of infrastructure asset is in
effects include: progress. Actual cash flow will take place only in future
periods when the infrastructure asset is completed
1. Transitional effect on the bottom line: There are several and operation commences. This is likely to result in
significant differences, as well as numerous minor a sizeable gap between revenue numbers and actual
differences between the Indian GAAP and Ind-AS, which cash flows. In the initial years, the company will have
have the potential to materially affect previously reported significant revenue and profits, but it may not have any
financial results. For example, a real estate and infrastructure cash to pay dividends.
company may have the following peculiar impact on the
adoption of Ind-AS (if the EDs in their current form The application of Ind-AS will affect many other areas
are finalized): of financial reporting, such as component accounting,

7 Conversion to Ind-AS
B. Financial reporting cosiderations (Cont’d.)

embedded leases, business combination and financial income statement or equity. Ind-AS also allows the use of iii) Company’s objectives, policies and processes for
instruments. Considering these changes, companies can fair value measurement for certain non-financial assets/ managing capital
expect a significant change in their pattern of earnings and liabilities. For instance, ED-Ind-AS 37 Investment Property
iv) Fair value of financial instruments (including those
financial position, and should be comfortable in explaining allows the use of the fair value model for investment
measured at the amortized cost)
those changes to their stakeholders. property. The increased use of fair value in Ind-AS regime
may result in more volatility in the reported earnings and v) Information that enables users of financial statements
2. Change in the basis of accounting: Converting to a new
equity. Further, to comply with the fair value requirements to evaluate the nature and extent of risks arising from
accounting basis will necessitate changes in numerous
of Ind-AS, the company will need to either develop in-house financial instruments, including the company’s objectives,
accounting policies. The application of new accounting
expertise or engage outside valuation experts. policies and processes for managing those risks
policies will require companies to closely monitor their
arrangements to identify potential issues such as embedded 4. Increased financial disclosures: The reviews of the 2005 To ensure compliance with these disclosures, companies
derivatives, embedded leases and compliance with debt financial statements of European companies suggested that will need to give both qualitative as well as quantitative
covenants. To ensure that the company is applying the Ind- financial disclosures under IFRS increased by more than 30%, information. This may require changes/updates in the
AS principles consistently across the organization, it may as compared with their previous disclosures. We believe that existing systems/processes.
have to expand its corporate-level finance function. The the application of Ind-AS will require Indian companies to
5. Changing data needs: The presentation of Ind-AS financial
management will also need to determine that the selected make significant additional disclosures. For example:
information may require the use of data that is not
policies and their applications are sufficiently described in
i) Significant judgments made by the management in already captured or warehoused. For example, certain
the financial statements.
applying accounting policies Ind-AS disclosures about the risks of financial instruments
3. Increased volatility of financial results: The Indian GAAP require information that is likely not currently captured.
ii) Assumptions made about the future and other major
recognizes fair value measurement at certain places; Management will need to identify their data “gaps” early on
sources of estimation uncertainty that involve a
however, its use is very limited. As compared to this, Ind-AS so that any information that needs to be captured will be
significant risk of resulting in a material adjustment to the
lays down a greater emphasis on the fair value measurement captured and recorded for all periods required to
carrying amounts of assets and liabilities within the next
of assets and liabilities, particularly, financial assets and be converted.
financial year
liabilities, and recognizing the resulting gains/losses in the

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B. Financial reporting cosiderations (Cont’d.)

5. How is adoption of Ind-AS expected to impact management reporting?

The changes to accounting policies expected from applying One of the significant trends reported in Europe was the
Ind-AS and the need to record and classify information in specific increased use of “non-IFRS” measures1 (i.e., performance
ways to comply with the new standards may affect the financial indicators not defined under IFRS) by the management while
information generated by the business. Management reporting communicating business performance to the market. Certain
formats and processes will need to be reviewed and updated Indian companies are already using non-GAAP measures for
accordingly. In addition, management will need to consider the the purpose of communicating their results to the markets.
effects on the key performance indicators used for measuring It is expected that in the initial years of Ind-AS application,
success and reviewing trends. There may also be effects on the an increased number of companies may resort to non-GAAP
way budgeting and planning functions operate. measures till the time they gain confidence that the
numbers generated by the new standards are well understood
by stakeholders.

1
Observations on the Implementation of IFRS, published by Ernst & Young LLP, 2006.

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B. Financial reporting cosiderations (Cont’d.)

6. How will Ind-AS affect accounting for income taxes and tax filings?

While the specific differences between the Indian GAAP and Ind- to be made for items such as unrealized gains/losses, while issues is expected only once the study group completes its work,
AS in accounting for income taxes frequently receive attention in computing taxable income. which may take some more time. If the contentious issues are
conversations around a potential conversion to Ind-AS, there are not resolved in time, it is possible that the tax base will continue
ii) In countries such as France and Germany, tax computation is
many other equally important tax-related issues of conversion to be determined in accordance with the Indian GAAP. In the
still based on local GAAP.
that boards and management need to discuss on priority. meantime, these issues may continue to result in significant
iii) In very few cases, for e.g., Australia, tax laws entail debate among companies and tax authorities.
Currently, profit before tax (PBT) in accordance with the Indian
detailed rules for the computation of tax liabilities, i.e., tax
GAAP is used to calculate taxable income and tax expense Ind-AS conversion may also afford an opportunity to re-examine
computation is based on neither local GAAP nor IFRS.
thereon. Upon the application of Ind-AS, the first question that is and improve the operational efficiency and effectiveness of the
most likely to arise is whether the tax authorities will accept new We believe that the last two approaches will require companies to tax function by addressing its legacy data processes, controls and
standards as a base to determine taxable income, albeit after maintain two separate sets of books: one for financial reporting other organizational issues. A company-wide conversion project
appropriate adjustments? Countries that have already adopted purposes and the other for tax computation, and thereby, may be viewed as an opportunity to undertake a review of the tax
IFRS are following varying practices. For example: significantly raise the cost of implementation. provision process, with the goal of strengthening or remediating
existing tax controls.
i) There are countries such as the UK, Singapore, New Zealand The Central Board of Direct Taxes (CBDT) and the ICAI have
and Hong Kong, which are using IFRS as a starting point for constituted a joint study group to identify direct tax issues
tax computation. Nonetheless, certain adjustments need arising from the convergence. Additional clarity on tax-related

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7. How do we plan to approach the conversion to Ind-AS and how ready are we to
do this?

Converting to Ind-AS will entail a business wide change management • The determination, at a high level, of the accounting policy
exercise and should be approached using a structured methodology and financial reporting differences between Ind-AS and the
encompassing the best practices of project management. As with company’s current accounting policies, including any industry-
any major finance transformation project, the full support of the specific issues
board and senior management will be critical to the success of the • The identification of the main business effects expected from
conversion effort. the adoption of Ind-AS
C. Conversion Boards should pay close attention to the details of the management’s
proposed approach to the Ind-AS conversion and satisfy themselves
• An assessment, at a high level, of the likely impact on IT
systems and identification of the modifications necessary to
project that it covers all appropriate areas, and is based on sound project facilitate the collection of the information required to satisfy all
management principles. While the management will be responsible Ind-AS disclosure requirements
considerations for the conversion execution, boards need to be confident in the • The identification of the nature of potential tax-related effects
management’s plan, thoroughness and diligence. Management should of conversion
inform the board and the audit committee on a regular basis as to its
• The identification of any hurdles to conversion presented by the
plan and progress. As such, audit committees should typically include
existing finance organizational structure
a standing Ind-AS agenda update item at their periodic meetings.
• A high-level road map for future phases of the conversion
Any Ind-AS conversion project should commence with some form
• The identification of the potential interdependence between
of impact assessment, diagnostic activity or scoping exercise. This
the Ind-AS conversion project and the current or planned
will allow the management and the board of directors to visualize
organization-wide initiatives (for e.g., new accounting system
the extent and complexity of the conversion and allow them to make
implementations such as ERP and finance transformation)
better decisions about how to plan, structure and resource the
project and determine the next steps. Typically, the CFO would be the • An assessment of whether the company has adequate
sponsor. resources to complete a conversion
The diagnostic phase should then be followed by solution
The major outcomes that management should expect from this
development and the implementation phase. As IFRS are dynamic
phase include:
standards and are constantly changing and evolving, the process of
change is unlikely to cease.
11 Conversion to Ind-AS
C. Conversion project considerations (Cont’d.)

8. What are the key areas that need to be addressed during the conversion?

No two Ind-AS conversion projects will ever be the same. Audit committees and boards will need to review and be the approach adopted by the management to compile
However, while the specific issues that the companies will comfortable with the policies selected by management. this information.
face during their conversion will vary widely because of all the
3. Application of Ind-AS 41: Another key area that the 6. Transition approach: While some companies outside the
variables at play, the key areas that the management and
management will need to address with respect to accounting India converted “top-side” only at a consolidated level, this
boards will need to address during the conversion should be
policies is how it will apply Ind-AS 41. The ED-Ind-AS 41 spreadsheet approach is not ideal. Accounting treatments
broadly similar.
provides guidance for businesses on how to adopt Ind-AS and controls should be pushed down to the subsidiary
1. Project launch and planning activities: The initial decisions for the first time and provides companies with a number of and transaction level. This will be very useful in compiling
made during the project set-up phase tend to be crucial for voluntary exemptions and mandatory exceptions from the relatively more accurate data and maintaining effective
eventual project success. These include: requirements of other standards. The decisions made in control. Further, the spreadsheet approach may not work
applying Ind-AS 41 will often have a significant effect on the in long term. The audit committee will need to carefully
a. Creating a project management function to coordinate
financial statements for many years to come. consider and opt for the transition approach that is more
project activity and monitor/report progress
appropriate and better suited to its business.
4. Development of skeleton financial statements compliant
b. Structuring the project team based on the results of the
with Ind-AS: Companies will have to redraft the sections 7. Identifying and resolving data capture issues: The increased
impact assessment phase
of their financial statements to meet Ind-AS disclosure level and complexity of certain financial disclosures expected
c. Assigning sufficient resources to the project and requirements. There are multiple benefits in preparing a under Ind-AS may require significant project resources to
determining that the team comprises individuals with skeleton set of financial statements during the preliminary identify and set up processes to collate this data. Some of the
appropriate skills to fulfil their responsibilities phases of the project as it focuses attention on the actual data underlying the new disclosures may be time consuming
disclosure requirements of the business, and therefore, is to extract or may need significant analysis before it is ready
2. Revision of accounting policies: Reassessing accounting
crucial in the process of identifying “data gaps” that need for disclosure purposes. Boards need to be satisfied that
policies under Ind-AS will be one of the most important
to be plugged. It is also useful to put the overall change the management’s plans include adequate mechanisms to
elements of the project because the decisions made in this
management challenge in perspective and give project identify and resolve data gaps.
area will drive many of the changes required throughout
teams a concrete goal.
the business and will have direct implications for the future 8. Retraining of personnel: Boards need to be satisfied in terms
business results. For instance, accounting policy decisions 5. Preparation/restatement of financial information from of adequate investment being made in retraining employees
will affect data collection requirements, which, in turn, will Indian GAAP to Ind-AS for comparative accounting periods: throughout the organization in order to meet their changed
affect IT system requirements, business processes to collect The compilation of comparative financial information for technical knowledge needs, as well as be equipped to
and record the data, internal control systems covering inclusion in the first set of Ind-AS financial statements may facilitate the roll out of accounting policy changes and the
data validity and functional resourcing requirements. prove to be one of the most challenging areas of the project. associated revised business processes and procedures.
The tax-related effects of revisions of accounting policies The board, through its audit committee, needs to be satisfied
will also need to be addressed in the conversion process. as to whether careful consideration has been given to

12 Conversion to Ind-AS
C. Conversion project considerations (Cont’d.)

9. What is the timeline for our Ind-AS conversion project, what resources will be required and how much will it cost?

The main consideration regarding the timeline will be: “Will the There are few meaningful benchmarks that exist regarding effort
organization be ready on time?” and cost, as the impact of changes in accounting principles on
functional areas and related processes varies significantly among
By performing an impact assessment or diagnostic exercise and
companies and within industries, depending on pre-existing
conducting careful planning at the beginning of the project, it
business or accounting processes. The size and complexity of
should be possible to determine the major areas relevant to the
accounting conversion projects means that there are so many
business and, from there, construct reasonable estimates of the
variables affecting the timeline and cost considerations that
resources required, the time to complete the project and the
concrete assessments are not possible without an appropriate
related costs that will be incurred.
diagnostic and project plan.

13 Conversion to Ind-AS
C. Conversion project considerations (Cont’d.)

10. What can we learn from the conversion experiences of others, including Europe and Australia?

Indian business has the benefit of the experience of countries that have already converted to IFRS. We have detailed some of the issues encountered and the key lessons one can learn from their
experiences in the following table:

Issues identified Key lessons learnt


The scale and complexity of the project and the time frame needed were underestimated. Conducting a thorough impact assessment, followed by a detailed planning exercise up front, is crucial for a
successful transition. Conversions could entail functional changes as well as technical accounting changes.
The project lacked adequate buy-in from the company’s senior management early on in the project. The “tone from the top” is an important driver of change. The board sponsorship of the project is crucial.
The projects suffered from poor project management. The importance of having a proper project management office function capable of coordinating project activities
and a well- structured conversion methodology cannot be overemphasized.
Slight accounting differences can have a significant effect on financial results. A methodical approach to review accounting differences is essential to assess the overall financial impact.
Unfamiliarity of “numbers” and principles arising from changes Technical training will be a critical component of the conversion, especially for business unit heads, who may not
be familiar with the implications of the changes that new standards will bring. Investor relations will also need a
strong educational grounding to communicate the impact to investors.
Poor communication existed between project team and business units regarding effects of changes. Invest the time necessary to roll out business process changes such as accounting practices, updated control
mechanisms and changes in reporting requirements to the wider organization.
Changes were often not fully embedded in back offices and general ledger systems. As a result, EU companies that used manual workarounds to meet short deadlines are now redesigning processes and
“stand-alone manual workarounds” were created, including “spreadsheet accounting.” augmenting their systems to eliminate the inefficiencies these workarounds created. Indian companies should
use the time available to proactively address these changes.
The top-side solutions did not work. The top-side solutions do not cause the organization to adjust, and the finance group feels “all the pain.” It is
important to “push down” the conversion to the transaction level throughout the organization as early
as possible.
Tax personnel were frequently underrepresented in the conversion process. The tax implications of the conversion process may extend beyond accounting effects. The early involvement
of tax personnel in the process may mitigate the potential for unexpected results. Companies will benefit
from sufficient resources and adequate lead time to address tax issues and to make necessary changes to tax
processes and technology.

14 Conversion to Ind-AS
11. Other than financial reporting, which other business areas are likely to be
affected by the conversion?

Ind-AS is expected to impact a wide range of business functions tied to the company’s performance targets. Companies should
beyond financial reporting. These may include changes to the expect earnings, earnings per share and the financial position
management’s internal reporting, data gathering and IT systems, to change. In so far as these changes also affect the metrics
the use of key performance indicators, the content of employee used to evaluate or compensate executives, evaluation and
and executive compensation plans, the activities of investor compensation guidelines may also need to change.
relations, changes to policies and procedures and the 4. Investor relations: During the transition, it will be important
D. Non-financial resultant impact on internal control documentation and
certification requirements.
to manage investor expectations and respond quickly to issues
to avoid misunderstandings. Going forward, companies will
reporting The following parameters outline some of the potential effects: need to be aware that analysts will have access to comparable
1. Performance reporting: The accounting recognition and global data on their industry sectors against which they
considerations measurement changes brought about by Ind-AS will affect can benchmark their results, and be prepared to respond
the measures used by companies and investors to assess accordingly. Further, an effective communication strategy
performance and may result in the realignment of the to address investor queries and concerns arising during and
management’s performance targets, financial covenants immediately after the transition will be vital.
and performance-related remuneration. 5. Dividend distribution policies: Boards may need to review,
2. Financial covenants: The key performance indicators and and if necessary, amend dividend distribution policies in
ratios used by businesses to measure performance are also light of the company’s changed financial situation that could
closely linked with the financial covenants that a company emerge from applying Ind-AS.
may have in its contracts. A complete review of and the 6. Regulatory capital: For companies operating in a regulated
modification to contracts containing financial covenants environment (for e.g., insurance companies, banks, etc.) and
may also be required. where the Ind-AS financial statements will be the basis for
3. Executive compensation: Compensation committees should regulatory reporting, the conversion to Ind-AS is likely to have
be able to articulate their process for establishing the an impact on regulatory capital. This may require additional
compensation for executives based on the objective criteria capital, and where regulated subsidiaries are involved, the
amount of distributions may be restricted to the parent.

15 Conversion to Ind-AS
D. Non-financial reporting considerations (Cont’d.)

12. Can our current IT systems handle the business’ revised data collection requirements under Ind-AS?

Since Ind-AS is likely to change certain data collection efforts late in the project, resulting in manual workarounds and heavy
as a result of the changes in accounting policies and financial reliance on spreadsheets. One would also expect that the need
statement disclosure requirements, IT systems used to collect for IT system changes will be greater for companies operating in
and report financial data may need to be modified in order industries in which the differences between Indian GAAP and Ind-
to meet the new requirements. It will be important to identify AS are more significant (for example, financial services, utilities,
as early as possible the specific impact on IT systems and mining, oil and gas).
understand how easily changes can be made to a company’s
When the volume of IT system changes required in order to be
existing systems. The age, flexibility and upgrade path of the
Ind-AS ready is significant, management should consider the IT
current IT systems will be instrumental in determining whether
resource requirements as well as whether the Ind-AS project plan
the existing systems can be enhanced or must be replaced.
reflects the IT upgrade timelines. In addition, many companies
While the effect of the Ind-AS conversion on each company’s may already be planning to replace or upgrade their existing
IT systems will be different, the experience in Europe and financial systems. As such, the new Ind-AS requirements should
Australia was that the systems most likely to be affected were the be included in the system selection process and constitute a part
financial, treasury and human resources systems. The impact on of the design phase.
IT systems and business processes often was not considered until

16 Conversion to Ind-AS
Abbreviations
AS Non-converged accounting standards currently applicable in India (non- Indian GAAP GAAP applicable in India in the pre-Ind-AS scenario, i.e., pre-conversion GAAP
converged standards) applicable in India
ASB Accounting Standards Board of ICAI IRDA Insurance Regulatory and Development Authority
BSE Bombay Stock Exchange MCA Ministry of Corporate Affairs
CESR Committee of European Securities Regulators NACAS National Advisory Committee on Accounting Standards
CFO Chief Finance Officer NBFC Non-Banking Finance Company
CFS Consolidated financial statements NSE National Stock Exchange of India
EAC Expert Advisory Committee of ICAI OCI Other comprehensive income
ED Exposure draft RBI Reserve Bank of India
ED-Ind-AS Exposure draft of Ind-AS ROI Return on investments
EPS Earnings per share RRB Regional Rural Bank
ESOP Employee stock option plan SCB Scheduled Commercial Bank
FVPL Fair value through profit or loss SCI Statement of comprehensive income
GAAP Generally Accepted Accounting Principles SCODA SEBI Committee on Disclosures and Accounting Standards
IAS International Accounting Standards SEBI Securities and Exchange Board of India
IASB International Accounting Standards Board SEC US Securities and Exchange Commission
ICAI The Institute of Chartered Accountants of India SFS Standalone financial statements
IFRIC International Financial Reporting Interpretations Committee SIC Standing Interpretations Committee
IFRS International Financial Reporting Standards SOCIE Statement of changes in equity
Ind-AS Indian Accounting Standards (IFRS-converged standards) being issued by ICAI SORIE Statement of recognized income and expenses
that will apply to Indian companies covered by IFRS conversion roadmaps
UCB Urban Co-operative Bank

17 Conversion to Ind-AS
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EYIN1009-096 Conversion to Ind-AS

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