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Letter to IFRS Foundation on Proposed IAS 28 Amendments

April 20, 2026

April 20, 2026

IFRS Foundation
Columbus Building
7 Westferry Circus
Canary Wharf
London, E14 4HD

Sent via email to: commentletters@ifrs.org

RE: Amendments to the Fair Value Option for Investments in Associates and Joint Ventures Proposed amendments to IAS 28

To whom it may concern:

The Virginia Society of CPAs (VSCPA) Accounting & Auditing Advisory Committee has reviewed the Exposure Draft (ED) - Amendments to the Fair Value Option for Investments in Associates and Joint Ventures Proposed amendments to IAS 28, issued by the International Accounting Standards Board (IASB). The VSCPA is the leading professional association in Virginia dedicated to enhancing the success of all CPAs and their profession by communicating information and vision, promoting professionalism, and advocating members’ interests. The VSCPA membership consists of nearly 12,000 individual members who actively work in public accounting, private industry, government, and education.

Question 1 — Proposed amendments to paragraphs 18–19 of IAS 28

1)    Response: We do not support the proposal in its current form.

2)    While we appreciate the Board’s efforts to provide timely clarity for the implementation of IFRS 18, Presentation and Disclosure in Financial Statements, we have several reservations regarding the proposed "proportionate approach."

3)    Our concerns include the following:

  • Temporary Nature of the Solution: We are concerned that the current proposal may be viewed more as an interim measure than a long-term principle-based solution. Prioritizing the IFRS 18 effective date over broader conceptual deliberations risks creating a standard that lacks the permanence and rigor expected of a full IASB project.
  • Due Process Considerations: We are concerned that the IASB’s narrow-scope approach appears to prioritize expediency—particularly alignment with the IFRS 18 effective date—over a more robust and comprehensive due process. Given that the proposed amendments affect measurement and comparability, we believe a broader, principle-based evaluation with additional stakeholder outreach would have been more appropriate. As currently proposed, the amendments risk being perceived as an interim solution rather than a fully developed standard.
  • Consistency and General Acceptance: We believe that accounting standards should ideally apply to all entities equally to be truly "generally accepted." By limiting the Fair Value Option (FVO) to specific entities with a "main business activity" of investing, the proposal creates a framework that may be perceived as an industry-specific accommodation rather than a universal principle.
  • Restricted Fair Value Option and Potential Reporting Bias: We share the concerns noted in the alternative views that restricting the FVO to particular groups can introduce a degree of financial reporting bias. We believe that if fair value is considered a relevant measurement basis for a venture capital organization or an insurer, it should logically be considered relevant for any entity holding a similar investment.
  • Irrevocability and Operational Changes: Under the current proposal, the election remains irrevocable at initial recognition. We are concerned that this may preclude entities from using the equity method in the future, even if their business focus evolves and they no longer maintain investing as a "main business activity."
  • Alignment with Global Practice: We note that other major frameworks, such as U.S. GAAP, permit an unrestricted fair value option for these investments without apparent detriment to financial statement users. We believe a more inclusive approach would better serve global convergence and simplify the standard.

4)    Suggested Alternative: We recommend that the IASB consider removing the eligibility restrictions in paragraph 18 of IAS 28 to permit all entities to elect the fair value option. We believe this would replace a narrow accommodation with a robust, neutral principle that reduces complexity and provides more relevant information to a broader range of users.

Question 2 — Effective date and transition

Our disagreement is based on the foregoing comments regarding Question 1, which highlight that the current proposal functions as a narrow, industry-specific accommodation rather than a universal, principle-based solution. By prioritizing the IFRS 18 effective date over broader conceptual deliberations, the Board has missed the opportunity to create a robust, neutral principle (i.e., an unrestricted Fair Value Option) that would ensure consistency across all entities and better align with global practices like U.S. GAAP.

The VSCPA appreciates the opportunity to respond to this ED. Please direct any questions or concerns to VSCPA Vice President, Advocacy & Pipeline Emily Walker, CAE, at ewalker@vscpa.com or (804) 612- 9428.

Sincerely, 

Daniel Martin, CPA
Chair 2025-2026
VSCPA Accounting & Auditing Advisory Committee

VSCPA Accounting & Auditing Advisory Committee 2025-2026

Daniel Martin, CPA — Chair
Elisa Obillo, CPA — Vice Chair
Zach Borgerding, CPA
Scott Cohen, CPA
Jonathan Head, CPA
Joshua Keene, CPA  
Nick Kinsler, CPA 
John McIntosh, CPA
Brian Minor, CPA
Brook Peterson, CPA
Michael Phillips, CPA
Krisia Raya, CPA
Domenic Savini, CPA
Clara Tang, CPA
Charles Valadez, CPA 
Anna Wagner, CPA
Patrick Wunderlich, CPA
Natalya Yashina, CPA