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Articles

Introducing More IFRS Principles of Disclosure – Will the Poor Disclosers Improve?

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Abstract

The current paper was prepared for the International Accounting Standards Board (IASB) Research Forum 2017 and evaluates the effects of introducing more principles of disclosure as part of the IASB Disclosure Initiative. We perform a literature review of academic research on how entities have complied with disclosure requirements in the past. The review shows high levels of non-compliance and high volatility across entities, including poor disclosers being far below the average. We find no clear pattern of higher compliance for International Financial Reporting Standards (IFRS) with more reliance on disclosure principles as compared to specific requirements (i.e. IFRS 7, IFRS 8), but note the methodological problem of measuring compliance with disclosure principles. Academic research suggests that the degree of compliance depends on entities’ incentives for providing or withholding information in combination with local conditions for primary users, auditors and regulators. Based on our review, we argue that increased reliance on entities to act in ‘good faith’ when complying with disclosure requirements, in capital-market contexts where entities may be in high-incentive situations and have low costs of non-compliance, is potentially risky in terms of how well the Standards protect primary users from poor disclosers. More emphasis is needed on ensuring that the disclosure requirements are enforceable and auditable in order to secure a certain minimum level of disclosure.

1. Introduction

The International Accounting Standards Board (IASB) Disclosure Initiative was established in 2013 as ‘a broad-based initiative exploring how to make disclosures more effective in financial statements’ (IASB, Citation2017a, IN2, p. 4). The main trigger at the beginning was a perceived disclosure overload, i.e. preparers pointing at overly burdensome disclosure requirements and various stakeholders questioning whether all information in the financial statements is useful. Related to this was the problem that preparers often used boilerplate text because of ‘ … a “checklist” approach used by auditors or a need to meet the perceived “compliance” requirements of regulators’ (IASB, Citation2012).

Already in 2011, a joint working group of the Institute of Chartered Accountants in Scotland (ICAS) and the New Zealand Institute of Chartered Accountants (NZICA) published a report with the title: Losing the excess baggage – Reducing disclosures in financial statements to what’s important (ICAS/NZICA, Citation2011). The group adopted a top-down approach, aiming (a) to determine the disclosure objectives of separate International Financial Reporting Standards (IFRS) and (b) to establish what disclosure requirements that are really needed to support the existing recognition and measurement requirements in the IASB’s 2010 Conceptual Framework for Financial Reporting. Applying the objective and framework-derived minimum requirements standard by standard, the group estimated the impact to be a 30% reduction in length of financial statements (including disclosures).

However, instead of continuing on this path with standards-level reviews of disclosure requirements, the IASB decided to first seek more guidance by trying to establish general principles of disclosure. Accordingly, the actions proposed and executed so far have focused on improving the effectiveness of disclosures for the primary users of financial statements. According to the Discussion Paper (DP) on Principles of Disclosure published by the IASB, solving the disclosure problem is about enhancing the communication of relevant information and avoiding communicating irrelevant information (IASB, Citation2017a, p. 13).Footnote1 In addition to this work on principles of disclosure, the IASB has targeted disclosure overload by focusing on materiality.Footnote2 A Materiality Practice Statement (IASB, Citation2017b) has been developed and a few years earlier there was a clarification of the common formulation ‘shall be disclosed’ in IFRS Standards. Entities, auditors and regulators might previously have interpreted ‘shall be disclosed’ as a mandatory requirement to disclose the item referred to (when applicable). However, the revised version of International Accounting Standard (IAS) 1 (Presentation of Financial Statements) in 2014 clarifies that an entity does not have to disclose the ‘shall be disclosed’ information if that information would not be material (IAS 1, BC30C).

The DP states that the Board foresees that its work on disclosure principles will result in non-mandatory guidance or in a separate standard, but the IASB has also had the ambition to let takeaways from the DP guide a revision of the disclosure requirements standard by standard, i.e. the kind of work performed by ICAS/NZICA (Citation2011). The DP does not discuss how the general principles of disclosure will guide the revision of disclosure requirements in separate IFRS standards. Only in one specific instance, a reference is made as regards how a greater use of disclosure principles might affect specific IFRS Standards disclosure requirements in (IASB, Citation2017a, 4.18, p. 41): ‘If a principle is included in a general disclosure standard, it might be possible to delete the specific requirements in the Standards described … ’ However, at the meeting on 22nd March 2018, the IASB decided to perform a targeted standards-level review of disclosure requirements, which involves the development of guidance for the Board itself to use when formulating disclosure requirements, and testing this guidance on one or two identified IFRS Standards (IASB, Citation2018a).

The current paper was prepared for the IASB Research Forum in Brussels in November 2017. With regard to the DP, the scope is limited to the first two sections of the DP that pertain to the description of the disclosure problem, the objective of the project and the principles of effective communication. In addition, the paper addresses how the introduction of the general principles and reasoning referred to in the DP may affect the formulation of disclosure requirements in specific IFRS Standards (step 4 below). Accordingly, we welcome the launch of the new IASB project on a targeted standards-level review of disclosure requirements, which was ‘ … added in response to feedback on the … Discussion Paper’ (IASB, Citation2018b).

The purpose of this paper is to evaluate the effects of introducing more high-level principles of disclosure in IFRS Standards. This question is addressed in four steps: (1) A critical review of the disclosure problem as presented in the DP. Is communication of irrelevant information really a problem for the primary users? Why isn’t the problem analysed with regard to the contexts of entities, auditors, regulators and primary users? (2) A critical evaluation of the suggested solution to the disclosure problem in the DP, i.e. to rely more on principles of disclosure. What is the role of enforceability and compliance? Can we rely on entities’ ‘good faith’? (3) A literature review of prior research on disclosure compliance, primarily with IFRS. In the DP, the IASB makes several references to ‘compliance documents’ with a negative connotation. Is this because full compliance with specific disclosure requirements (‘all boxes ticked’) is presumed to prevail? What does the empirical literature show? (4) A literature review covering specific areas where the IASB has tested principles-based standard-setting for disclosures (business combinations, financial instruments, operating segments). The IASB adopts a top-down approach in the DP. It will also make sense to investigate empirically what seems to work in practice with regard to the use of high-level principles in specific IFRS Standards.

The literature review comprises a major part of the paper and it was conducted in order to find out to what extent entities comply with mandatory standards, e.g. IFRS, and the drivers of compliance. In particular, we are interested in prior research on specific IFRS Standards where the design of disclosure requirements (i.e. the use of principles versus specific requirements) differs, to learn whether any particular approach appears to be more successful.

The literature review points at significant levels of non-compliance with IFRS, both with regard to disclosures in general and in specific areas. We argue that this has important implications for the IASB, as discussed in the paper. Each standard needs to define compliant behaviour and the negative tone used in the DP towards checklists of specific disclosure requirements and the concept of compliance (‘compliance documents’) appears to be counter-productive. A good intention to rely more on principles and less on specific requirements is in fact likely to lead to even lower disclosure quality among poor disclosers. The review points at the role of entity-, auditor- and regulator-factors and contexts that tend to drive non-compliance, which may be of importance to standard setters when developing disclosure requirements in the future.

The literature review also has implications for researchers. Although the review has a specific focus on levels of compliance, it also aims to critically evaluate the reviewed studies with regard to employed research methodology and theoretical foundations. The most important implication for researchers is the need to improve the way we measure compliance with disclosure principles rather than only capturing compliance with specific requirements. This is illustrated in the paper with regard to prior research on IFRS 7 (Financial Instruments: Disclosures).

The paper is organised as follows. This introduction is followed by a section that critically evaluates the disclosure problem as formulated by the IASB in the DP. Section 3 provides a critical evaluation of the principles-based solution with reference to the DP. The results of the literature review on disclosure requirement compliance are reported in Section 4, followed by concluding remarks in Section 5. The methodology applied in the literature review is described in Section 4.2.

2. A Critical Review of the Disclosure Problem

In paragraph 1.5 of the DP, the disclosure problem is described in terms of three components: (1) information is only relevant if it is capable of making a difference in the decisions made by primary users. If financial statements do not provide enough relevant information, their users might make inappropriate investing or lending decisions; (2) too much irrelevant information is produced which is a problem for (a) users, in that relevant information might be overlooked, hard to find and difficult to understand and (b) entities, as it adds unnecessary costs to the preparation of financial statements; (3) the provided information is ineffectively communicated, which may make financial statements hard to understand and time-consuming to analyse. Additionally users may overlook relevant information or fail to identify relationships between pieces of information in different parts of the financial statements.

No doubt companies will often find the costs of preparing financial statements as being too high (2b). This has been a major argument made by entities since before the launch of the Disclosure Initiative. However, with regard to points 2a and 3, the IASB takes on the role of the primary users and suggests that they have problems in finding and understanding the information. We question whether this is a fair description. Based on the literature, it would seem that the problems for users described in parts 2 and 3 of the disclosure problem are not actual problems. Theoretically, primary users of financial statements, and their advisers, have strong incentives to study all aspects of financial statements carefully, as the entity may communicate private information or withhold information (Dye, Citation1985, Citation2017). In the empirical academic literature, the capital market tends to react positively to more disclosure (e.g. Barker et al., Citation2013). With regard to individual users, a recent example of experimental research finds that analysts are able to distinguish between complex language needed to convey information about the firm’s business transactions from complex language due to managerial obfuscation (Bushee, Gow, & Taylor, Citation2017). There is also much survey evidence and anecdotal observations suggesting that primary users do not wish to receive less financial statement information. Harris and Morsfield (Citation2012) find that investors and analysts who participate in roundtable discussions and interviews very often require data only found in financial statement footnotes. In a report by the Certified Financial Analysts (CFA) Institute in 2013 (CFA, Citation2013), 80% of the members responding did not think the amount of information in financial reports constituted a problem. For example, in the area of impairment, surveys reported by EY (Citation2010), the Financial Reporting Council (FRC) (Citation2014a) and KPMG (Citation2014) suggest that investors, analysts and lenders do use impairment information disclosed in financial statements for decision-making purposes. In addition, consider the following observation by Bischof, Daske, and Sextroh (Citation2014) who studied analyst reports in banks together with these banks’ conference calls from the first quarter 2008 until the fourth quarter 2010. They observed that analysts’ interest in the banks’ fair value accounting practices varied dramatically between the highest quarter (fourth calendar quarter 2008, i.e. following the Lehman Brothers default), when many questions were asked during the conference calls, compared to the second calendar quarter of 2010 when almost no questions were asked. The example highlights that low use of, for example, fair value disclosures by analysts during a period does not imply irrelevance – it is just a result of the way professional users of information work – they use the information when it is considered relevant in their particular decision process.

What about part (1) of the disclosure problem, i.e. the financial statements do not provide enough relevant information? When Barker et al. (Citation2013, p. 4, emphasis in the original) a few years ago commented on a similar description of the disclosure problem they stated that it does not include a ‘ …  principle setting out the purpose of disclosures, other than that they should be “relevant” … The purpose, and the consequential definition of relevance, is likely to be context dependent’.

Whether a piece of information is capable of making a difference in decisions made by primary users cannot be determined without considering the context. Paragraphs 1.6 and 1.7 of the DP describe causes of the disclosure problem, addressing, in particular, the judgement of entities and the behaviour of entities, auditors and regulators. Guided by the IFRS Standards, entities are expected to try to second-guess what information might be capable of influencing primary users’ decisions; however, entities have incentives to be more or less transparent. The description of the disclosure problem in paragraph 1.5 of the DP does not distinguish between contexts with preparer incentives supporting poor disclosers vs. contexts supporting high-quality disclosers. In turn, this may lead to too general solutions to the disclosure problem, only addressing, for example, the high-quality disclosers. Auditors and regulators will also, based on the IFRS Standards, try to second-guess what information might be capable of influencing primary users’ decisions. As acknowledged in paragraph 1.7 of the DP, they are known for using checklist approaches and materiality thresholds that may become detached from the definition of relevant information (information capable of making a difference in the decision made by the primary user). However, the enforcement context is also part of the disclosure problem rather than being just a cause of the problem.

In sum, the strong emphasis on the distinction between relevant and irrelevant information in 1.5 is not warranted given the available research evidence. Defining the disclosure problem based on this dichotomy may lead to poor disclosers classifying more information as irrelevant whereas the market would have considered it relevant. The judgement of what is relevant or irrelevant is made by the entity second-guessing what information the primary user will find relevant. The disclosed information based on this judgement does not directly reflect what a certain primary user, or the market as a whole, considers relevant or irrelevant.

3. A Suggested Solution to the Disclosure Problem

One offered solution to the disclosure problem is to adopt a principles-based approach, where principles will guide entities to disclose relevant instead of irrelevant information, and to communicate effectively. Principles of disclosure may possibly also change the behaviour of auditors and regulators so that they stop causing the disclosure problem (cf., DP para. 1.8).

As described in the Introduction, the ICAS/NZICA (Citation2011) joint working group adopted an approach where they sought to determine disclosure objectives of separate IFRS Standards and to establish minimum disclosure requirements based on what is needed to support the existing recognition and measurement requirements in the IASB’s 2010 Conceptual Framework for Financial Reporting. The report does not provide references to prior literature, but it would appear that the authors were inspired by the United States Securities and Exchange Commission (SEC) study on a principles-based accounting system (SEC, Citation2003). This report advocates a hybrid model where principles are based on the conceptual framework and each standard has a clearly stated objective, but also sufficient detail and structure to be operationalised and applied consistently with a minimum of exceptions. However, even when adopting this structured approach, it is not possible to avoid professional judgement in the application of accounting standards. Dennis (Citation2014) notes that definitions of professional judgement in the area of financial reporting comprise certain characteristics (p. 60): (i) a process that involves making choices or decisions about courses of action in a certain activity, (ii) these choices or decisions are made in the context where there are standards to be followed, (iii) such choices or decisions require certain skills, knowledge and experience to be used in making such decisions, and those making them have to exhibit certain qualities.

Disclosure requirements may be formulated as higher level principles related, ultimately, to the general purpose of providing useful information to primary users in making economic decisions about providing resources to the entity. The higher level principles cover a very wide range of circumstances that may occur, but will be difficult to operationalise and apply consistently. Still, the entity can adopt the principles and apply professional judgement to identify all circumstances for which no specific disclosure requirement applies. What about these specific requirements, do they also involve professional judgement or are they simply ‘cookbook rules’? Alternatives are always available for all aspects of financial reporting, and some professional judgement will be required also for the specified requirements (cf. IASB Conceptual Framework 2010, BC3.4), however, these judgements would primarily concern whether the entity circumstance is an exception from the specific requirement. It would seem like both principles and specific requirements have a role to play, in that the specific requirements will secure a minimum level of basic disclosures that apply to most entities subject to a Standard, while the principle will secure that circumstances that constitute exceptions from the specific requirement will also result in adequate disclosures.

A problem, however, with the above reasoning, and the discussion on professional judgement in SEC (Citation2003) and Dennis (Citation2014), is that it relies on the assumption that entities have no other incentives than to fully comply with standards; that the disclosure outcome is only a question of making the right choices based on having certain skills, knowledge and experience. If an entity has strong incentives to hide information from users, it would seem like the specific disclosure requirements would still guarantee a certain minimum level of transparency.

With regard to the applicability of a principles-based approach to disclosures, Barker et al. (Citation2013) made a comprehensive literature review, summarised below (pp. 7–8).

Empirical research shows that principles-based standards work well in certain situations, in that they permit preparers to convey private information. On the other hand, in high-incentive situations, principles-based standards tend to perform poorly, especially in the absence of strong enforcement. This is troubling, since it is in high-incentive situations that financial reporting is most important … Empirical research indicates problems with principles-based accounting standards, while analytical research supports such an approach. It is important to note, however, that this research is mostly focused on measurement issues, not on disclosure. Arguably, principles-based regulation relating to disclosures is more difficult to achieve. It is harder to know whether a principle is followed properly relating to disclosures, as it is based more on qualitative judgement. Whether a certain note contains relevant information, and whether it is understandable for users is difficult to enforce and audit. Thus, having principles-based standards for disclosures is likely to be even more difficult than suggested by existing research.

Barker et al. point at the difficulty of knowing whether a principle of disclosure is followed properly, making it difficult to enforce and audit. Why is this? It seems like one difference with disclosure principles in comparison with accounting principles regarding classification, recognition and measurement, is that there will always exist more than one way to communicate effectively (the disclosure outcome) whereas applying a principle of, for example, measurement to the specific circumstances of an entity should result in a particular measurement outcome which is compliant.Footnote3 This would imply that a principle of disclosure cannot easily be used to determine a specified minimum level of compliance. In turn, this relates to enforceability, i.e. the ability of enforcers to assess whether accounting standards have been correctly applied.Footnote4 As there will be many disclosure options, the principle may not allow for distinguishing between a correct and an incorrect disclosure outcome. Enforceability relates to the concept of verifiability in the conceptual framework, i.e. that knowledgeable and independent observers should be able to reach consensus that a particular depiction is a faithful representation of an economic phenomenon (QC26). Observing such consensus would theoretically make it possible to determine compliance with a principle of disclosure but would appear difficult to attain in practice. If specific requirements are replaced with principles, as was proposed in the ICAS/NZICA (Citation2011) report, and also possibly indicated in the DP, this implies a risk of worse disclosures than today by the poor disclosers. When entities in high-incentive situations apply principles of disclosure in the way that best corresponds with their incentives, there will be a high likelihood of poor disclosure quality. This should also be seen in combination with the recently changed guidance on materiality judgements, suggesting that entities shall test (second-guess) more carefully what is material for the decisions of its primary users, which, in turn, is expected to lead to a lower amount of disclosures as regards the specific disclosure requirements in IFRS Standards.

Compliance is the word capturing that standards are applied as intended by the standard setter, and in order to ensure compliance, standards must be written in a way that make them practically enforceable, i.e. they might need legal backing depending on the local context and there is a need for monitoring and sanctions by auditors and regulators in case of non-compliance. There is much academic research to evidence the important role of enforcement mechanisms for achieving compliance and related positive user effects of adopting IFRS and other standards (e.g. Ball, Robin, & Wu, Citation2003; Christensen, Hail, & Leuz, Citation2013; Leuz & Wysocki, Citation2016; Daske, Hail, Leuz, & Verdi, Citation2008; Holthausen, Citation2009; Hope, Citation2003). Lack of harmonised enforcement will lead to national differences in the application and enforcement of IFRS (e.g. Brown & Tarca, Citation2005).

Although compliance and enforcement issues are not part of the IASB’s responsibilities as standard setter, these issues are indirectly put forward as main issues in the DP in terms of the very high ambitions of making entities provide more relevant disclosures and more effective communication. According to paragraph 2.6 of the DP, the Board’s preliminary view is that it should develop a set of principles to help entities communicate information more effectively in the financial statements. Seven principles are suggested (p. 21): the information provided should be (1) entity-specific; (2) described as simply and directly as possible; (3) organised in a way that highlights important matters; (4) linked when relevant to other information in the financial statements; (5) not duplicated unnecessarily; (6) provided in a way that optimises comparability among entities and across reporting periods without compromising the usefulness of the information; and (7) provided in a format that is appropriate for that type of information.

If these principles are adhered to, common sense tells us that disclosures will improve; however, the preparer might acknowledge that the somewhat vague concept of ‘communicating effectively’ is explained by a number of other, mostly positively loaded, but rather vague terms that will require much judgement; for example, the trade-off between being entity-specific (1) and optimising comparability (6). This might still work if managers’ judgements are made ‘in good faith’ using a concept from Wüstemann and Wüstemann (Citation2010), but investors and lenders need to be protected from those who do not make judgements in good faith. In line with this, some Board members ‘ … observe that the principles would be difficult to enforce and audit, and therefore it would not be appropriate to include them in a Standard’ (IASB, Citation2017a, 2.13, p. 22).

There is a strong tendency in the DP to rely on entities’ ‘good faith’, i.e. a presumption that it is in everyone’s interest to improve the effectiveness of disclosures. Who can be against increased relevance? However, the ‘good faith’ assumption targets the high-quality disclosers, whereas the disclosure requirements also need to protect the primary users against too poor disclosures. Entities who are not in good faith may disclose very little when given a principle of disclosure and much flexibility to choose what to disclose (few specific requirements). It is not clear how greater reliance on principles of disclosure (and fewer specific requirements) will safeguard compliance with a minimum level of disclosure.

4. Literature Review of Prior Research on Compliance with Disclosure Requirements

4.1. Rationales for the Review

The literature review reported in this section comprises empirical studies on compliance with disclosure requirements. The first reason for making this review goes back to the reason for having mandatory disclosure requirements in accounting standards. Companies would provide disclosures even if they were not required to, and they do provide voluntary disclosures beyond regulatory requirements. However, imposing mandatory disclosure requirements is done to ensure that companies with incentives to avoid disclosure will still provide a minimum level of information, i.e. comply with the mandatory disclosure requirements. Uneven compliance will curtail the ability of international standards to reduce information costs and information risks (Ball, Citation2006).

Second, there seems to be a misunderstanding both in academic research and elsewhere that companies fully comply with regulated disclosures. Mazzi, André, Dionysiou, and Tsalavoutas (Citation2017, p. 271) argue that prior research has focused predominantly on voluntary disclosures, incorrectly assuming compliance with the mandatory requirements. The Principles of Disclosure DP (IASB, Citation2017a) speaks in a negative way about companies merely complying with the disclosure requirements, implicitly assuming that companies are today only ‘ticking the boxes’. But is this really the case – to what extent do companies applying IFRS comply with the disclosure requirements, even in terms of just ‘ticking the boxes’?

Third, it is a common starting point for the IASB to assume that a principles-based approach will always be the best. This approach involves deductive, ‘top-down’ reasoning, where specific standard-setting solutions will be derived from more general principles. In the case of disclosures, we believe there is a good reason to also consider a more inductive, ‘bottom-up’ approach, in terms of what actually works (or not) today with regard to IFRS disclosure requirements. Against this background, we will evaluate the extent to which recent IFRS Standards have resulted in compliance with both specific disclosure requirements and high-level principles of disclosure.

Although the review has a specific focus on levels of compliance, it also aims to critically evaluate these studies with regard to employed research methodology and theoretical foundations which is supposed to be helpful in making future research propositions. We also believe that a critical review of empirical evidence on disclosures, and the drivers of compliance, may inform standard setters on how to further develop disclosure requirements in accounting standards.

4.2. Methodology Used to Select Papers

The research papers for the literature review were selected in three steps. First, a search of titles, keywords and abstracts of academic articles was made for the combination of the words ‘disclosure’ and ‘compliance’ in the databases Proquest and ScienceDirect. Next, the identified papers were further checked in order to ensure that (1) they pertained to compliance with mandatory disclosure requirements within the area of accounting and standard-setting,Footnote5 (2) the papers were empirical and not too old, i.e. published 1998 or later, (3) the ranking of the journal was sufficiently high. With regard to the last point, we noted that in many cases empirical studies on compliance are likely to be viewed by editors as making a too small contribution to the literature in order to be published in the most highly ranked journals, which implies that our review cannot be restricted to these journals. At the same time, we wanted to secure a minimum level of research quality. Considering both these aspects, we chose to include papers from journals in the Academic Journal Guide 2015 at the ranking levels 2, 3 and 4.Footnote6 The above steps generated 73 papers. In the third step, we made a complementary search in the database Google Scholar for the combination of the words ‘disclosure’, ‘compliance’, ‘accounting’ and ‘standards’. The search generated approximately 222,000 hits and the top 200 were compared with the already selected papers; eight additional papers were found that fulfilled the criteria. Thus, in total, 81 papers were collected for the review following the above procedure. In addition to these papers, references are made to earlier literature reviews, and to some relevant working papers and journal articles brought to our attention after the above search was completed (April 2017).

It is important to note that the measures of disclosure compliance referred to in the reviewed studies do not fully capture materiality considerations. Companies may be compliant even though they do not disclose an item, because there may be circumstances unknown to the user that makes that disclosure immaterial. On this note, though, there are some factors to consider before concluding that a company disclosing very little is just applying the materiality principle correctly rather than being a poor discloser in relation to the standard setter’s intention. First, materiality refers to what is relevant when users, not preparers, make decisions, which means that when there is ‘ … clear evidence of activity that would be expected to generate disclosure under IFRS’ (Pope & McLeay, Citation2011, p. 249), both the user and the researcher have a good reason to believe this is non-compliance rather than lack of materiality. Researchers also put much effort into determining whether an item is applicable or not to the entity (cf. Section 4.3.1). Second, the poor disclosers do not appear randomly, but there are systematic patterns with regard to what makes companies comply more or less with the specific disclosure requirements.

The first part of the review (Section 4.3) presents the measured levels of disclosure compliance in empirical studies made around the world, including a review of the index methodology applied. Second, we review results on the determinants of disclosure compliance (Section 4.4). Finally, we examine some specific areas (business combinations, financial instruments and operating segments) where principles of disclosure interact with specific disclosure requirements (Section 4.5).

4.3. Disclosure Compliance Levels – Empirical Results and Methodology

4.3.1. Disclosure compliance levels around the world

A large body of literature has investigated the level of compliance with national accounting standards or IAS/IFRS mandatory disclosures in different countries and regions around the world. As countries have different regulatory, political or institutional settings, this dimension is potentially relevant for understanding variation in levels of disclosure compliance and drivers of compliance.

A large number of the collected studies cover developing/emerging-market countries, which, in turn, may be divided into three categories: studies of (1) the general level of disclosure compliance in a country, (2) the level of disclosure compliance in a specific area in a country and (3) studies of disclosure compliance (general or pertaining to a specific area) in a number of countries sharing some similarities (e.g. the same region, Islamic banks). The first group gathers studies dealing with the adoption of and compliance with IFRS (or national GAAP) disclosure requirements in Bahrain (Juhmani, Citation2017); Bangladesh (Akhtaruddin, Citation2005; Hasan, Karim, & Quayes, Citation2008); China (Gao & Kling, Citation2012; Peng, Tondkar, van der Laan Smith, & Harless, Citation2008; Xiao, Citation1999); Egypt (Abd-Elsalam & Weetman, Citation2003; Dahawy, Merino, & Conover, Citation2002; Hassan, Giorgioni, & Romilly, Citation2006; Hassan, Romilly, Giorgioni, & Power, Citation2009; Samaha & Abdallah, Citation2012); Ghana (Assenso-Okofo, Ali, & Ahmed, Citation2011); Jordan (Al-Akra, Eddie, & Ali, Citation2010); Kenya (Bova & Pereira, Citation2012); Malaysia (Abdullah, Evans, Fraser, & Tsalavoutas, Citation2015; Che Azmi & English, Citation2016); Saudi Arabia (Naser & Nuseibeh, Citation2003); Turkey (Çürük, Citation2009; Mısırlıoğlu, Tucker, & Yükseltürk, Citation2013) and Zimbabwe (Chamisa, Citation2000). The second category includes studies of business combinations in China (Taplin, Zhao, & Brown Citation2014); financial instrument disclosures in Malaysia (Othman & Ameer, Citation2009), Egypt (Mokhtar & Mellett, Citation2013), Jordan (Tahat, Dunne, Fifield, & Power, Citation2016) and Malawi (Tauringana & Chithambo, Citation2016); presentation of financial statements (IAS 1) in Malaysia (Rahman & Hamdan Citation2017); income taxes in Egypt (Ebrahim & Fattah, Citation2015). The third category includes general disclosure compliance studies covering Bahrain, Oman, Kuwait, Saudi Arabia and United Arab Emirates (Al-Shammari, Brown, & Tarca, Citation2008); Bangladesh, India and Pakistan (Ali, Ahmed, & Henry, Citation2004); Malaysia, Philippines and Thailand (Taplin, Tower, & Hancock, Citation2002);Footnote7 and one study of Islamic banks in Bahrain, Qatar, Jordan, Syria, Sudan, Yemen and Palestine (Sellami & Tahari, Citation2017). Summary information about all the above studies is presented in Panel A of Appendix.

illustrates reported disclosure levels in studies of compliance in developing/emerging-market countries.

Figure 1. Compliance with IAS/IFRS disclosure requirements in 17 studies of emerging and developing countries during 1996–2013. Each dot represents a country/region covered by a study in a particular year. The figure shows the average, higher bound and lower bound compliance levels in all the reviewed general and specific studies of disclosure compliance with IAS/IFRS (including national regulation with corresponding requirements) in emerging-market and developing countries, to the extent these measures are available. The average disclosure compliance level of the 17 studies is 65%, whereas the lower bound average is 46% and the higher bound average is 85%. Indicative labels of the references behind the observations are provided. Detailed information about the studies is available in Appendix. Sources: [TTH] Taplin et al. (Citation2002), [AW] Abd-Elsalam and Weetman (Citation2003), [AAH] Al-Shammari et al. (Citation2008), [A] Akhtaruddin (Citation2005), [HGR] Hassan et al. (Citation2006), [PTVH] Peng et al. (Citation2008), [ABT] Al-Shammari et al. (Citation2008), [OA] Othman and Ameer (Citation2009), [AEA] Al-Akra et al. (Citation2010), [BP] Bova and Pereira (Citation2012), [TZB] Taplin et al. (Citation2014), [AEFT] Abdullah et al. (Citation2015), [TDFP] Tahat et al. (Citation2016), [CE] Che Azmi and English (Citation2016), [C] Tauringana and Chithambo (Citation2016), [J] Juhmani (Citation2017), [ST] Sellami and Tahari (Citation2017)

Figure 1. Compliance with IAS/IFRS disclosure requirements in 17 studies of emerging and developing countries during 1996–2013. Each dot represents a country/region covered by a study in a particular year. The figure shows the average, higher bound and lower bound compliance levels in all the reviewed general and specific studies of disclosure compliance with IAS/IFRS (including national regulation with corresponding requirements) in emerging-market and developing countries, to the extent these measures are available. The average disclosure compliance level of the 17 studies is 65%, whereas the lower bound average is 46% and the higher bound average is 85%. Indicative labels of the references behind the observations are provided. Detailed information about the studies is available in Appendix. Sources: [TTH] Taplin et al. (Citation2002), [AW] Abd-Elsalam and Weetman (Citation2003), [AAH] Al-Shammari et al. (Citation2008), [A] Akhtaruddin (Citation2005), [HGR] Hassan et al. (Citation2006), [PTVH] Peng et al. (Citation2008), [ABT] Al-Shammari et al. (Citation2008), [OA] Othman and Ameer (Citation2009), [AEA] Al-Akra et al. (Citation2010), [BP] Bova and Pereira (Citation2012), [TZB] Taplin et al. (Citation2014), [AEFT] Abdullah et al. (Citation2015), [TDFP] Tahat et al. (Citation2016), [CE] Che Azmi and English (Citation2016), [C] Tauringana and Chithambo (Citation2016), [J] Juhmani (Citation2017), [ST] Sellami and Tahari (Citation2017)

In , the round dots represent the average IAS/IFRS disclosure compliance in emerging-market and developing countries or regions during 1996–2013, according to the 17 studies where such measures are available. The grey square dots represent the lower bound and the black diamond dots the higher bound. Overall, the compliance levels are low (65% is the average of all the 17 studies) and there is considerable variation in compliance over time and across countries. In the more recent studies, pertaining to applications of IFRS post-2005, average compliance levels are higher in countries such as Bahrain (81% in 2010 according to Juhmani, Citation2017) and Malaysia (88% in 2008 according to Abdullah et al., Citation2015). However, in many countries the average compliance levels are still below 70%. For specific standards, the results may be even lower, e.g. 49% and 40% compliance with IFRS 7 requirements in Jordan 2007 (Tahat et al., Citation2016) and Malawi 2009 (Tauringana & Chithambo, Citation2016), respectively. The lower bound (poorest disclosers) are in many cases 10–20 percentage points below the average compliance level (46% is the average lower bound of the studies covered).

An overall analysis of the studies referred to suggests that countries with weak legal and institutional contexts find it difficult to establish the appropriate systems needed to ensure firms’ compliance with disclosure requirements. The poor quality of corporate disclosure seems to be due to a combination of high compliance costs coupled with low non-compliance costs. The lack of qualified auditors and the insufficient number of qualified accountants make the compliance costs high. At the same time, the importance placed on social rather than economic considerations and limited development of stock markets mean that non-compliance costs are low. In a recent literature review, Samaha and Khlif (Citation2016) conclude that companies do not comply with mandatory requirements unless stringent regulation is in place, which in turn would require more efficient enforcement institutions. Bova and Pereira (Citation2012) observe that foreign ownership may play an important role for improving compliance.

The Principles of Disclosure DP (Citation2017a) does not separately address the challenges facing companies in developing/emerging-market countries. To what extent is the criticism against the use of checklists and box-ticking, referred to in the DP (1.7) targeting such entities? Although admittedly very crude as a measure, an average compliance rate of 65% and an average lower bound level of 46% suggest that there is quite a long way to go before a reasonable minimum level of compliance will be achieved. It may also be noted that the obstacles for improved compliance relate primarily to contextual factors. It may be questioned whether greater reliance on principles will lead to improved compliance, as the principles are, arguably, even more difficult to enforce and audit.

A large number of studies have also evaluated the degree of compliance with disclosure requirements mandated in developed countries. As in the preceding categorisation, the studies may be divided into three categories: studies of (1) the general level of disclosure compliance in a country, (2) the level of disclosure compliance in a specific area in a country or a region and (3) studies of general disclosure compliance in a number of countries sharing some similarities (e.g. the same industry, the same listing status). The first group comprises studies focusing on compliance with IFRS (or national GAAP) disclosure requirements in Australia (Palmer, Citation2008), Austria (Eierle, Citation2008), Germany (D’Arcy & Grabensberger, Citation2003; Glaum & Street, Citation2003), Greece (Tsalavoutas, Citation2011; Tsalavoutas & Dionysiou, Citation2014), New Zealand (Owusu-Ansah & Yeoh, Citation2005; Stent, Bradbury, & Hooks, Citation2013; Yeoh, Citation2005), UK (Mangena & Tauringana, Citation2007) and United States (Holder, Karim, Lin, & Pinsker, Citation2016; Leuz, Triantis, & Wang, Citation2008). Findings from this research line suggest that corporate compliance with regulatory disclosure requirements requires three components: high-quality financial accounting standards to be used as a benchmark together with high-quality audits and enforcement of regulation by strong regulatory bodies.

The second category, pertaining to specific areas, includes studies of business combination and goodwill impairment test disclosures in Europe (Glaum, Schmidt, Street, & Vogel, Citation2013; Mazzi et al., Citation2017), Australia (Bepari & Mollik, Citation2015; Bepari, Rahman, & Taher, Citation2014; Carlin & Finch, Citation2010, Citation2011; Guthrie & Pang, Citation2013), Singapore (Carlin, Finch, & Khairi, Citation2010), the Netherlands and Sweden (Hartwig, Citation2015); studies of financial instrument disclosures in Italy (Maffei, Aria, Fiondella, Spanò, & Zagaria, Citation2014), Portugal (Lopes & Rodrigues, Citation2007), the UK (Linsley & Shrives, Citation2006; Woods & Marginson, Citation2004), the US (Lu & Mande, Citation2014) and in European banks (Bischof, Citation2009 ); studies of segment disclosures in global IAS-adopter samples, primarily European (Prather-Kinsey & Meek, Citation2004; Street & Nichols, Citation2002),Footnote8 Germany (Franzen & Weißenberger, Citation2015), the US (Chen & Liao, Citation2015); studies of disclosure compliance in relation to financial statement presentation disclosures in the UK (Iatridis & Valahi, Citation2010); share-based payment and executive compensation disclosures in Australia (Bassett, Koh, & Tutticci, Citation2007), France (Goh, Joos, & Soonawalla, Citation2016) and the US (Robinson, Xue, & Yu, Citation2011); contingent liabilities in the US (Hennes, Citation2014) and intangible assets in Italy (Devalle, Rizzato, & Busso, Citation2016).

Finally, in the third category, there are a number of studies evaluating the extent to which disclosure requirements of IAS/IFRS or US GAAP are complied with, at a general level, from a transnational perspective (or at least, considering more one country). This category comprises studies with international samples (El-Gazzar, Finn, & Jacob, Citation1999; Street, Gray, & Bryant, Citation1999; Taylor & Jones, Citation1999; Street & Bryant, Citation2000; Street & Gray, Citation2002; Hope, Citation2003; Bradshaw & Miller, Citation2008; Hope, Kang, & Zang, Citation2007; Hodgdon, Tondkar, Harless, & Adhikari, Citation2008; Hodgdon, Tondkar, Adhikari, & Harless, Citation2009), European countries (Verriest, Gaeremynck, & Thornton, Citation2013)Footnote9 and the UK and the Netherlands (Camfferman & Cooke, Citation2002). Setting aside the large differences regarding actual levels of compliance with disclosure requirements,Footnote10 there are no unambiguous results for these studies taken together. Thus, we conclude that disclosure choices made by firms in the different countries reflect specific attributes of their environment. Consequently, there is a need to build models that include country-level factors (i.e. culture, legal, political and institutional systems) to better explain the level of compliance with mandatory disclosure requirements.

shows observed disclosure compliance levels of studies of developed countries.

Figure 2. Compliance with IAS/IFRS disclosure requirements in 19 studies of developed countries during 1997–2011. Each dot represents a country/region covered by a study in a particular year. The figure shows the average, higher bound and lower bound compliance levels in all the reviewed general and specific studies of disclosure compliance with IAS/IFRS (including national regulation with corresponding requirements) in developed countries, to the extent these measures are available. The average disclosure compliance level of the 19 studies is 70%, whereas the lower bound average is 37% and the higher bound average is 97%. Indicative labels of the references behind the observations are provided. Detailed information about the studies is available in Appendix. Sources: [SB] Street and Bryant (Citation2000), [SG] Street and Gray (Citation2002), [TTH] Taplin et al. (Citation2002), [DG] d’Arcy and Grabensberger (Citation2003), [GS] Glaum and Street (Citation2003), [LR] Lopes and Rodrigues (Citation2007), [HTHA] Hodgdon et al. (Citation2008), [HTAH] Hodgdon et al. (Citation2009), [CF10] Carlin and Finch (Citation2010), [CF11] Carlin and Finch (Citation2011), [CFK] Carlin et al. (Citation2010), [T] Tsalavoutas (Citation2011), [GSSV] Glaum et al. (Citation2013), [GP] Guthrie and Pang (Citation2013), [VGT] Verriest et al. (Citation2013), [BRT] Bepari et al. (Citation2014), [H] Hartwig (Citation2015), [GJS] Goh et al. (Citation2016), [MADT] Mazzi et al. (Citation2017)

Figure 2. Compliance with IAS/IFRS disclosure requirements in 19 studies of developed countries during 1997–2011. Each dot represents a country/region covered by a study in a particular year. The figure shows the average, higher bound and lower bound compliance levels in all the reviewed general and specific studies of disclosure compliance with IAS/IFRS (including national regulation with corresponding requirements) in developed countries, to the extent these measures are available. The average disclosure compliance level of the 19 studies is 70%, whereas the lower bound average is 37% and the higher bound average is 97%. Indicative labels of the references behind the observations are provided. Detailed information about the studies is available in Appendix. Sources: [SB] Street and Bryant (Citation2000), [SG] Street and Gray (Citation2002), [TTH] Taplin et al. (Citation2002), [DG] d’Arcy and Grabensberger (Citation2003), [GS] Glaum and Street (Citation2003), [LR] Lopes and Rodrigues (Citation2007), [HTHA] Hodgdon et al. (Citation2008), [HTAH] Hodgdon et al. (Citation2009), [CF10] Carlin and Finch (Citation2010), [CF11] Carlin and Finch (Citation2011), [CFK] Carlin et al. (Citation2010), [T] Tsalavoutas (Citation2011), [GSSV] Glaum et al. (Citation2013), [GP] Guthrie and Pang (Citation2013), [VGT] Verriest et al. (Citation2013), [BRT] Bepari et al. (Citation2014), [H] Hartwig (Citation2015), [GJS] Goh et al. (Citation2016), [MADT] Mazzi et al. (Citation2017)

In , the round dots represent the average IAS/IFRS disclosure compliance in developed countries during 1997–2011, according to the 19 studies where such measures are available. The grey square dots represent the lower bound and the black diamond dots the higher bound. Although higher than for emerging-market/developing countries, the compliance levels are relatively low (70% is the average of all the 19 studies). The variation in compliance over time and across countries is lower compared to the emerging-market/developing countries and the higher bound averages are higher. However, the lower bound (poorest disclosers) average compliance level is only 37%.

It should be noted that all the observations of compliance after 2006 refer to specific standards (e.g. IAS 36, IFRS 7), rather than IFRS compliance in general. The decrease in general studies of disclosure compliance is probably due to many journals with ABS rankings of 2 or higher not considering such studies to make significant contributions to the literature. Going forward, the IASB may want to consider ways to secure that the outcomes of the Disclosure Initiative can be measured and monitored.

Outside academic research, regulators produce reports pertaining to compliance with disclosure requirements. In their yearly reports, they often refer to the need of improved disclosures, although they do not systematically measure the degree of disclosure compliance (e.g. European Securities and Markets Authority (ESMA), Citation2014, Citation2015, Citation2016, Citation2017; FRC, Citation2013, Citation2014b, Citation2015). In these reports, it is interesting to note that although the enforcers generally commit to concerns about disclosure overload, when it comes to the detailed issues they typically ask for more information rather than less.

4.3.2. Measuring compliance: indices

Many studies use an index to measure the level of corporate disclosure and compliance. The index is typically based on a self-constructed compliance checklist, but some rely on public disclosure scores, e.g. Gao and Kling (Citation2012), Bova and Pereira (Citation2012) and Hassan et al. (Citation2006).

According to the literature, disclosure indices can be constructed on the basis of weighted or unweighted scores, where the latter approach is most commonly used (Abd-Elsalam & Weetman, Citation2003; Akhtaruddin, Citation2005; Al-Akra et al., Citation2010; Ali et al., Citation2004; Bova & Pereira, Citation2012; Bradshaw & Miller, Citation2008; Camfferman & Cooke, Citation2002; Che Azmi & English, Citation2016; Chen & Liao, Citation2015; Çürük, Citation2009; D’Arcy & Grabensberger, Citation2003; Ebrahim & Fattah, Citation2015; Eierle, Citation2008; El-Gazzar et al., Citation1999; Gao & Kling, Citation2012; Glaum & Street, Citation2003; Hasan et al., Citation2008; Hope, Citation2003; Hope et al., Citation2007; Juhmani, Citation2017; Leuz et al., Citation2008; Lu & Mande, Citation2014; Mangena & Tauringana, Citation2007; Mısırlıoğlu et al., Citation2013; Owusu-Ansah & Yeoh, Citation2005; Samaha & Abdallah, Citation2012; Sellami & Tahari, Citation2017; Stent et al., Citation2013; Street et al., Citation1999; Street & Bryant, Citation2000; Street & Gray, Citation2002; Taplin et al., Citation2002; Verriest et al., Citation2013; Williams & Tower, Citation1998). Proponents of the unweighted approach assert that each item of disclosure is equally important and focus on the overall disclosure, rather than on particular items.

The weighted approach allows for assigning varying relative importance to the information items, which reflects that users may be placing different weights on different items. There are a few studies adopting this approach: Hodgdon et al. (Citation2008); Hodgdon et al. (Citation2009); Naser and Nuseibeh (Citation2003); Tsalavoutas, Evans, and Smith (Citation2010), however, as the weighting will be subjective, all studies also provide an unweighted disclosure index and test the significance of the differences in the compliance scores identified, considering findings valid only when the results are significant under both methods.

Other authors have attempted to cover several dimensions of compliance by using more than one disclosure index. For example, Samaha and Abdallah (Citation2012) use two disclosure index measures to assess the quality of two web-based corporate disclosures dimensions: content and presentation. Verriest et al. (Citation2013) measure financial reporting quality around IFRS adoption by applying two different perspectives: transparency of IFRS restatements from local GAAP to IFRS, and compliance with specific IFRS Standards. In Mangena and Tauringana (Citation2007), three indices were calculated: overall disclosure compliance index, narrative disclosure compliance index and financial statements disclosure compliance index, whereas Taplin et al. (Citation2002) use two indices, a compliance ratio and a discernibility index, to generate insights into patterns of non-disclosure. Similarly, Street and Gray (Citation2002) determine two disclosure compliance scores with the aim of capturing both measurement and presentation issues. In their study about the convergence between Chinese national accounting standards and IFRS, Peng et al. (Citation2008) use three different indices: a compliance index, a consistency index and an index of comparability. Also, Palmer (Citation2008) uses different scores to measure the extent of disclosure (the amount of disclosure) and the quality of disclosure (the total informativeness awarded to each item disclosed).

Index-based disclosure studies provide quantified measures of compliance that can be used as a basis for evaluating the effectiveness of disclosure requirements of IFRS (e.g. and ). However, as indicated above, there are methodological limitations and problems related to the use of indices. First, compliance indices indicate the actual level of compliance, but cannot explain the causes for it to be high or low. Although the indices are used as dependent variables in many studies (see Section 4.4), there is no agreement among researchers on what variables to control for, and consequently on the possible causes of different levels of compliance. Second, for studies measuring the degree of compliance with disclosure, it is difficult to interpret the results because of the lack of benchmarks. Quite often, the assessment of whether the value of a compliance index is high or low is based on the judgement of the researcher. Similarly, it is difficult to compare across different studies, because authors use very different samples (companies, industries, countries, etc.). Thirdly, most of the studies are empirical, with no (or very limited) theoretical foundation. As these studies are not driven by a theoretical framework, it is difficult to interpret their results. This lack of theory is also a limitation for the generalisation of the findings of these studies. Fourth, the use of indices to measure compliance is subject to reliability and validity problems. With regard to reliability, as the value of compliance indices depends on the information provided by the annual report of the companies constituting the sample, non-disclosure of information in the report is a problematic issue as it is extremely difficult to establish if a disclosure item is applicable or if the company has failed to disclose a relevant item in the annual report. The validity problems pertain to the ability or inability of the indices to capture the actual extent of compliance with disclosure requirements. The use of several indices in a study can be seen as a research strategy to increase the validity.

4.4. Determinants of Compliance

There are numerous studies examining the association between the level of compliance with accounting standards and firm characteristics, country-level factors and national cultural features as hypothesised explanatory variables and/or control variables (Abdullah et al., Citation2015; Al-Akra et al., Citation2010; Al-Shammari et al., Citation2008; Ali et al., Citation2004; El-Gazzar et al., Citation1999; Gao & Kling, Citation2012; Glaum & Street, Citation2003; Hassan et al., Citation2006; Hassan et al., Citation2009; Hodgdon et al., Citation2009; Iatridis & Valahi, Citation2010; Juhmani, Citation2017;Lu & Mande, Citation2014; Mangena & Tauringana, Citation2007; Mısırlıoğlu et al., Citation2013; Samaha & Abdallah, Citation2012; Street & Bryant, Citation2000; Street & Gray, Citation2002; Tsalavoutas, Citation2011; Verriest et al., Citation2013). Appendix offers a description of the methods used in these studies. Linear and stepwise multivariate regression analyses are the most common procedures employed for determining what factors influence the extent of compliance. Some studies are based on logistic regression and others incorporate panel-data estimation techniques to account for the dynamic effects of the factors under study. There are also researchers adopting a more qualitative approach, for example, Eierle (Citation2008) and Stent et al. (Citation2013) use content analysis to investigate what discretionary narrative disclosures reveal about firms’ responses and attitudes to the adoption of IFRS disclosure requirements.

Prior research suggests that non-compliance with mandatory accounting standards does not appear randomly, but in a way consistent with the view that managers will respond to their environment and their economic incentives (De Fond & Jiambalvo, Citation1991). According to Barth and Schipper (Citation2008), there are certain features of the financial reporting system (enforcement, litigation, auditing) that will be decisive for successful implementation of mandatory standards. If the risks related to non-compliance are low (e.g. low risk of litigation), and there is absence of strong public enforcement, the mechanisms related to environment and incentives are expected to become more important.

Financial reporting aims to reduce information asymmetries between management and investors, and between different types of investors (Healy & Palepu, Citation2001) and empirical studies have shown that a higher level of disclosure is often positively associated with capital-market variables such as liquidity and the cost of capital (e.g. Leuz & Verrecchia, Citation2000 ; Mazzi et al., Citation2017). At the same time, managers may have valid reasons to withhold information that may harm their reputation or help competitors (proprietary information). Prior research has identified many possible determinants of disclosure behaviour related to firm-specific characteristics (e.g. industry, growth, country of domicile, company size, company age, multinational-company status, international diversification, membership of certain trade or economic block, company’s governmental links, market capitalisation, share turnover, profitability, liquidity, leverage, new share issuance, listing status, international cross-listing, ownership structure, audit quality and reference to IAS/IFRS in the accounting policies footnote). Relying on theoretical arguments related to agency costs, empirical support has been found for larger corporations being more likely to disclose more information to users of annual reports. Similarly, corporations that are listed on a stock exchange, domestically or internationally, are shown to have higher levels of disclosure, both with regard to mandatory and voluntary disclosures. As regards other corporate characteristics (e.g. leverage, profitability, stock ownership dispersion, industry, country of domicile and type of auditor) the results in prior research have been more mixed (Glaum et al., Citation2013, p. 169). This mixed pattern can be seen also in recently published studies (see Appendix).

Corporate governance variables can be viewed as proxies for agency-related mechanisms and have been found to explain disclosure compliance. For example, Verriest et al. (Citation2013) find that companies with stronger corporate governance tend to comply more completely with the mandatory disclosure requirements. Various corporate governance characteristics are used in empirical studies: the existence of an audit committee (AC), the independence of the AC, the AC’s financial expertise, the size of the AC, the size of the board and board’s degree of independence, CEO/chairman duality, the effectiveness of internal controls, the presence of block-holder ownership, foreign representation on the board, proportion of non-executive directors (NEDs) on the board and founding family members on the board. Empirical results are generally quite conclusive, suggesting that corporate governance mechanisms are positively associated with compliance; however, not all the studies coincide in exactly what mechanisms are more effective. Most prior studies tend to combine firm-specific characteristics with corporate governance-related mechanisms in order to investigate the disclosure and compliance choices made by firms.

Finally, besides studies considering firm-specific characteristics and corporate governance mechanisms, other research has suggested that cultural differences or other country-level-factors, as legal environment, may help explaining international differences in compliance with disclosures mandated by accounting standards. For example, cultural differences may explain why different stakeholders perceive the costs and benefits associated with financial statement disclosures differently and how this influences the amount of information actually disclosed in different countries. For instance, Williams and Tower (Citation1998) report about the significance of cultural influence on small business managers’ (Australian and Singaporean) attitudes towards accounting disclosure requirements. Likewise, in a study to assess the comprehensiveness of disclosure in the annual reports of UK and Dutch corporations, Camfferman and Cooke (Citation2002) suggest that variability in the comprehensiveness of disclosure between the countries may depend on the cultural setting. Similarly, Taplin et al. (Citation2002) analysed the levels of compliance with disclosure in four Asian countries with British colonial links and compared it with countries without such links. They conclude that British former colonies sharing the same cultural background had lower levels of non-disclosure than the rest. Eierle (Citation2008) points out that cultural values have an important influence on the cost/benefit judgments of Austrian private limited companies when it comes to compliance with mandatory disclosures under Austrian accounting standards. Dahawy et al. (Citation2002) reach similar conclusions; Egyptian companies’ decisions to implement or not to implement IASs were strongly affected by cultural factors, as the studied companies complied with the IASs when they did not conflict with local culture but deviated when conflicts existed.

Regarding other country-level factors, research has shown that the success in compliance with disclosure requirements is also dependent on the basic regulatory infrastructure of the adopting country (Ali, Citation2005; Ali et al., Citation2004; Gao & Kling, Citation2012; Taplin et al., Citation2002). Research has considered various regulatory mechanisms, such as the country’s legal system, enforcement system and the similarity between local accounting standards and IFRS. As for the legal system, countries with English common law systems tend to have better economic development, stronger capital markets and ‘better’ accounting standards than countries with code law systems. Finally, those countries with domestic accounting standards closer to IFRS also show higher disclosure levels.

4.5. Compliance with Disclosure Requirements in Specific Areas

Beyond the set of studies that focus on compliance with disclosure requirements more generally, we find in the literature also papers that focus more deeply on one or more specific areas. To approach this part of our literature review, we have divided the current section into different subsections based on the areas covered. It is interesting to note that the highest number of papers is found in the area of business combinations and goodwill impairment, followed by financial instruments and risk reporting practices, and segment reporting. For each of these areas, we have summarised some main findings. Additionally, we have reviewed papers that tackle other areas of interest but with only one or two studies found. They are discussed in the last subsection.

Given the purpose of the paper as a whole, i.e. to evaluate the effects of introducing more high-level principles of disclosure in IFRS, an important aspect concerns the extent to which principles of disclosure are used together with specific disclosure requirements in the IFRS of the specific areas dealt with. This issue will be explicitly addressed in the subsections in order to get input on the question of whether principles of disclosures seem to ‘work’ in current accounting practice.

4.5.1. Business combinations, goodwill and impairment test disclosures

Most papers that focus on business combinations, goodwill disclosures and impairment tests tend to measure the level of disclosure compliance and then try to look for determinants that may explain why companies complied or not with the requirements.

With regard to business combinations, the IFRS adopts the approach to first formulate two high-level principles (objectives) of disclosure, where the main one (IFRS 3, p. 59) requires the acquirer to disclose information that enables users of its financial statements to evaluate the nature and financial effect of a business combination during the current reporting period or soon thereafter (the other principle, p. 60, pertains to financial effects of subsequent adjustments). Second, there are 23 specific requirements listed in paragraphs B64–B67 that the acquirer shall disclose (or provide reason for non-disclosure). Third, paragraph 63 prescribes that complying with the specific requirements is not sufficient to meet the objectives, i.e. ‘ … the acquirer shall disclose whatever additional information is necessary to meet those objectives’.

Regarding business combinations, we find two quite comprehensive studies; one focusing on China (Taplin et al., Citation2014) and one on Europe (Glaum et al., Citation2013). In the first paper, the authors stress the role of auditors and observe that the level of compliance is low even in companies audited by Big-4 firms, which makes the authors question if well-resourced international auditors uphold expected standards or rather succumb to local non-compliant practices. In Glaum et al. (Citation2013), the authors analyse a large sample of European companies applying IFRS with regard to compliance with the business combinations and impairment testing standards. Their results show substantial non-compliance. At the company level, the authors identify the size of goodwill positions, prior experience with IFRS, type of auditor, the existence of ACs, the issuance of equity shares or bonds in the reporting period or in the subsequent period, ownership structure and the financial services industry, as influential factors. At the country level, the strength of the enforcement system and the size of the national stock market are associated with compliance. The country factors do not only influence compliance directly but also moderate and mediate some of the company-level factors. Finally, national culture in the form of the strength of national traditions (‘conservation’) also influences compliance in combination with company-level factors. Both studies focus on compliance with specific requirements, not the disclosure objectives of IFRS 3.

Although not covered by our search criteria, ACCA Research Report 134 by Tsalavoutas, André, and Dionysiou (Citation2014) should be mentioned. They collect data on disclosures under IAS 36, IAS 38 (Intangible Assets) and IFRS 3 for a sample of 544 non-financial companies from the EU, Australia, China, Hong Kong, New Zealand, Brazil, South Africa and Malaysia. They report a high level of disparity of information and what appears to be non-compliance with the mandatory disclosure requirements. Their results suggest that the higher the level of enforcement in a country, the higher the level of compliance. More specifically, they find that the quality of the audit environment is a key driver of this result (p. 63).

As regards disclosures related to goodwill impairment tests, the relevant standard, IAS 36, does not provide an overall disclosure principle, but lists a large number of specific requirements related to impairment (including goodwill impairment) in paragraphs 126–137, including also a reference to an illustrative example of how to present some of the required disclosures. Many studies have focused on whether companies comply with these specific requirements.

Carlin et al. (Citation2010) analyse the degree of compliance of the 168 largest goodwill-intensive Singaporean/Australian firms with requirements included in IAS 36 regarding goodwill impairment testing for a three-year period following IFRS implementation (2005–2007). The authors conclude that the level of compliance is poor across many facets of goodwill impairment testing disclosures including cash-generating unit (CGU) definition and goodwill allocation, and key input variables used in estimating CGU recoverable amounts. Their results lead them to question the quality of accounting information among goodwill-intensive firms in Singapore and the robustness of regulatory oversight institutions. Carlin and Finch (Citation2010, Citation2011) adopt similar research approaches for corresponding samples of Australian firms 2006/2007 with similar results regarding weak compliance and insufficient levels of disclosure.

In a similar fashion, Bepari et al. (Citation2014) measure the level of compliance regarding goodwill impairment testing for the period 2006–2009 for all firms included in the S&P/Australian Securities Exchange (ASX) 500 list covering 17 different industrial sectors. They conduct a determinants analysis with the purpose to explain compliance behaviour. The authors show that compliance increases over time and that audit quality, and belonging to goodwill-intensive industries, are determinants of compliance. Profitability is also positively associated with compliance, whereas firm size is not an influencing factor when industry is controlled for. However, leverage does not seem to have any influence.

Building on the results reported by Bepari et al. (Citation2014), Bepari and Mollik (Citation2015) focus on audit quality differences by separating clients of Big-4 from non-Big-4 auditors and also take into account the potential effect of AC members’ accounting and finance background. In this second study, the sample is larger and covers the period 2006–2009 and the authors conclude that there are significant differences in compliance when comparing Big-4 and Non-Big-4 clients and that the accounting and finance background of the members of the AC has a positive influence on compliance with goodwill impairment testing disclosure requirements. Based on their results, the authors claim the importance of developing institutional mechanisms such as high-quality auditing or corporate governance measures (AC members’ expertise) to promote firms’ compliance with IFRS requirements.

Other studies that review the level of compliance with goodwill reporting practices are Guthrie and Pang (Citation2013) with a sample of 287 Australian listed firms for the period 2005–2010 and Hartwig (Citation2015) with a sample of Swedish and Dutch companies listed on the Nasdaq OMX (NOMX) and the Euronext Amsterdam (EA) for the period 2005–2008. In both studies, the authors find an increase in compliance over time although not reaching full compliance. For the Australian sample, the authors show how companies tend to define a smaller, or the same, number of CGUs compared to the number of reporting segments, suggesting some CGU aggregation which would allow for influencing the incidence of goodwill impairment, and, therefore, the financial position of the firm. The authors also refer to the importance of audit attention as regards compliance with goodwill and impairment testing requirements. The results for Swedish and Dutch companies suggest that Swedish companies were more compliant than their Dutch counterparts in 2005, possibly because of a historically weak Dutch institutional oversight system. The author also looks for determinants of compliance and tests the statistical significance of company-specific variables like size, leverage, future prospects and industry and some additional enforcement variables like accounting oversight and auditing. Results show that none of these variables seem to have a determinant role in the compliance of the companies analysed.

In a literature review by Carvalho, Rodrigues, and Ferreira (Citation2016) of studies of goodwill and impairment test disclosures for the period 2002 to 2015, the authors state that there is a need for better enforcement mechanisms as a way to improve the level of compliance. They conclude that, based on their analysis of prior literature, information disclosed about goodwill is still incomplete and largely heterogeneous, indicating low levels of compliance. They also note that a significant number of company disclosures on goodwill are just reproductions of the rules prescribed with no effort to explain the entity-specific circumstances. The authors also state that, regarding the determinants, results are inconclusive as the analysis of the quality of compliance is often subjective and measures, samples and periods are often not comparable. Several conclusions can be drawn from the analysis of the literature regarding disclosure of goodwill, impairment testing and business combinations. A first one would be the low level of compliance found in the studies reported. Most studies confirm the poor levels of disclosure for the different dimensions analysed. A second one would be related to the determinants and the relevance of country-specific variables compared to company-specific ones. Adding to the conclusions of Carvalho et al. (Citation2016), our review points at enforcement characteristics, such as the strength of the enforcement process or the size of the national stock market, being positively associated with compliance together with high-quality auditing and corporate governance measures. At the company level, audit quality, goodwill positions and belonging to goodwill-intensive industries, prior experience with IFRS, the existence of ACs, the issuance of equity shares or bonds and ownership structure are found to be influential factors although the evidence found tend to be weaker than for country-level factors. None of the studies referred to above provide an answer to the question of whether the approach used in IFRS 3 (high-level principles supported by derived specific requirements) works better than the approach in IAS 36 (just a set of specific requirements). Substantial non-compliance is observed under both approaches.

4.5.2. Financial instruments and risk reporting practices

IFRS 7 is a standard of particular interest because it is a principles-based standard focusing solely on disclosures. Already in the beginning of the standard, a general disclosure principle is set out (paragraph 7):

An entity shall disclose information that enables users of its financial statements to evaluate the significance of financial instruments for its financial position and performance.

In the following paragraphs (8–30), a number of specific disclosure requirements are provided, referred to in the Basis for Conclusions which states (IFRS 7, BC 13):

In the Board’s view, entities could not satisfy the principle in paragraph 7 unless they disclose the information required by paragraphs 8–30.

Thus, the Board has derived a number of specific disclosure requirements it believes follow from applying the principle, however, this does not mean that making these specific disclosures is sufficient for compliance. In fact, throughout the BC the Board emphasises the need to comply with the principle in terms of making the appropriate links back to the financial statements, not merely providing particular items of information (e.g. BC 19, BC 24P).

A prior study by Woods and Marginson (Citation2004) may serve as a good illustration of the rationale for having a principles-based disclosure standard in the area of financial instruments. Woods and Marginson assess the usefulness of disclosures related to derivatives and other financial instruments for UK banks under UK GAAP. Their results show that disclosures are not very useful as the numerical data are generally incomplete and not always comparable and the narrative disclosures are generic in nature. This is precisely the type of problem the overall principle of IFRS 7 is targeting – the information about financial instruments in the notes should be possible to relate to the primary financial statements. Has the principles-based approach for disclosures in IFRS 7 succeeded? This should be carefully evaluated as it represents a straightforward example of adopting a high-level principle of disclosure.

In the studies found regarding financial instruments and risk disclosure, authors describe, analyse, or compare the level of compliance with the required information, and sometimes add to their analysis a search for possible determinants that may explain differences in compliance behaviour.

One example is the paper by Tahat et al. (Citation2016) that investigates financial instrument disclosures under IFRS 7 as compared to those under IAS 30/32 for a sample of Jordanian companies. Their results show an increase in compliance following adoption of IFRS 7, although still far from full compliance, and the authors point at the need for stringent enforcement measures to ensure full compliance with accounting standards. In an earlier study, Othman and Ameer (Citation2009) examine the application of IAS 32 in 2006/2007 by 429 Malaysian firms, using content analysis. They conclude that although a large number of the companies complied with the standard in terms of describing their financial risk management policy, there were systematic differences across the firms with regard to the specific disclosures in terms of level of detail (regarding both qualitative and quantitative information). The authors argue that there is a need for a more standardised risk-reporting format in order to achieve greater financial transparency for investors. In the same area, we find the paper by Lopes and Rodrigues (Citation2007) who analyse compliance with IAS 32 and IAS 39 by Portuguese firms and look for determinants. Their results suggest that the degree of disclosure is related to size, type of auditor, listing status and economic sector.

Studies dedicated to the analysis and understanding of compliance behaviour related to risk reporting are also quite often to be found in the literature. A first example of such papers is the work by Linsley and Shrives (Citation2006) where the authors explore risk disclosures for a sample of 79 UK firms using content analysis and also try to find determinants of compliant behaviour. Results show a significant positive association between the number of risk disclosures and company size and between the number of risk disclosures and environmental risk as measured by Innovest EcoValue Ratings. However, they do not find any significant association between the number of risk disclosures and company-specific risk measures like gearing ratio, book-to-market value of equity, or beta values. The paper also discusses the nature of risk disclosures made by the sample companies, specifically examining their time orientation, whether they are monetarily quantified and if good or bad risk news are disclosed. It was uncommon to find monetary assessments of risk information, but companies did exhibit a willingness to disclose forward-looking risk information. The authors’ overall conclusion is that a risk information gap exists and consequently that stakeholders are unable to adequately assess the risk profile of a company based on the risk disclosures.

With a similar aim and also using content analysis, we find the paper by Maffei et al. (Citation2014) where the authors assess the risk-related reporting practices of 66 Italian banks and examine whether bank-specific factors explain any differences observed. As stated by the authors, their purpose is to better understand how mandatory risk categories are disclosed and to provide a better understanding of the reasons why risk disclosures look less useful than they ought to be. Their results show that Italian banks comply with required risk disclosures but with high levels of discretion in terms of choosing what characteristics to disclose. Also based on disclosures in the banking industry, we find the study by Bischof (Citation2009) where the author analyses changes in disclosure levels and quality after IFRS 7 implementation in European banks. The author finds support for an increase in the level of compliance; however, he also finds differences across countries, which implies that national banking supervisors enforce and interpret IFRS 7 in different ways leading to heterogeneous disclosure practices. In a later study (Bischof, Daske, Elfers, & Hail, Citation2016), the evidence shows that the success of regulation depends on the institutional fit between the regulator and the regulated firms, and that having many regulators may lead to inconsistent implementation. The studies by Bischof (Citation2009) and Bischof et al. (Citation2016) are of particular interest as they point at the high impact of regulators’ behaviour on entities’ degree of disclosure compliance with mandatory standards. However, none of the studies refer to the principles-based nature of IFRS 7 but seem to focus exclusively on the specific requirements.

In another study on disclosures related to financial instruments, Lu and Mande (Citation2014) examine whether banks comply with the Financial Accounting Standards Board (FASB) Accounting Standards Update (ASU) 2010-06 requiring disaggregated fair value hierarchy information. Results show that 23% of banks did not comply with ASU 2010-06 and that the non-compliant banks tended to be small, lack effective internal controls and were more likely to be audited by non-specialist auditors.

With a slightly different approach, Mokhtar and Mellett (Citation2013) investigate compliance behaviour among 105 Egyptian companies. The authors provide a strong theoretical case for an expected relationship between corporate governance/enforcement variables and risk reporting. Their results show a low level of compliance with mandatory risk reporting requirements but find that competition, role duality, board size, ownership concentration and auditor type are key determinants of risk reporting practices in Egypt.

Finally, it is worth noting a more recent study by Tauringana and Chithambo (Citation2016) where the authors investigate compliance with risk disclosure requirements following IFRS 7 by Malawian Stock Exchange-listed companies over a three-year period. The authors employ a mixed-method approach (quantitative/qualitative). The quantitative approach employs the research index methodology and uses panel-data regression analysis to examine the relationship between the proportion of NEDs, size, gearing and profitability, and the extent of risk disclosure compliance. The results are triangulated by the qualitative research approach in the form of personal interviews with company managers. The results indicate that over the three years, the extent of compliance with IFRS 7 is, on average, 40% which is very low. The regression results suggest that the proportion of NEDs, size and gearing are significantly and positively associated with the extent of risk disclosure compliance under IFRS 7. The results from the qualitative part of the study are mixed, i.e. some of these results support the regression results while others are contradictory.

In sum, the literature devoted to the analysis and understanding of financial instruments and risk reporting practices shows that the level of compliance remains to be low and that corporate governance and enforcement variables seem to play a key role for increasing and maintaining higher levels of compliance. In this sense, adding to what has been already said in the previous section regarding goodwill and impairment testing, we would conclude that corporate governance and enforcement mechanisms show to be in general more important than company-specific variables for understanding why firms comply or not with disclosure requirements. In addition, it is worth noting that some authors highlight the need for a more standardised risk-reporting format together with homogeneous application and interpretation in order to achieve greater financial transparency for investors. This claim again calls for strong and consistent enforcement procedures that safeguard users’ needs of comparable information on risk.

Let us now return to what can be learned from the introduction of IFRS 7 as a principles-based standard? The answer is that, according to our review, prior research has not focused on compliance with the principle, but on compliance with the specific requirements. One reason for this may be that it is very difficult to measure principles-based compliance. However, if this is so difficult for researchers it may perhaps be so for entities, auditors and regulators as well? A few years ago, the ESMA published a report on compliance with IFRS 7 (ESMA, Citation2013) based on a study of 39 European financial institutions. The report was somewhat critical (ESMA, Citation2013, p. 4):

Overall ESMA found that disclosures specifically covered by requirements of IFRS 7 – Financial Instruments: Disclosures were generally provided and acknowledges the efforts made by financial institutions to improve the quality of their financial statements. Yet, ESMA observed a wide variability in the quality of the information provided and identified some cases where the information provided was not sufficient or not sufficiently structured to allow comparability among financial institutions. Some financial institutions provided disclosures that were not specific enough, lacked links between quantitative and narrative information, or provided disclosures that could not be reconciled to the primary financial statements. ESMA urges issuers to take a step back and consider the overall objectives of IFRS 7 against their specific circumstances when preparing disclosures.

The final points made by ESMA are important as they go beyond a piecemeal analysis of the specific disclosure requirements of IFRS 7 and target the principle. The criticism is fundamental as the main point with the principle is to make entities link information in the notes to the primary financial statements so that users can understand, for example, how the use of financial instruments contributes to how the bank earns its profits. At the same time, it is obviously difficult to quantify non-compliance with the principle.

4.5.3. Segment reporting

Another area of research is segment-reporting practices. There are some early studies in our literature review, but very few recent ones. One important reason for this is that the current IFRS Standard, IFRS 8 (Operating Segments) has effectively removed the specific disclosure requirements and therefore it is very difficult for researchers to know whether an entity complies or not with the standard. The approach used in IFRS 8 is of particular interest to the issue of how high-level principles of disclosure influence disclosure behaviour.

IFRS 8 states a high-level disclosure principle (paragraph 1):

An entity shall disclose information to enable users of its financial statements to evaluate the nature and financial effects of the business activities in which it engages and the economic environments in which it operates.

There are a number of specific requirements in terms of income statement line items, etc. to be reported and there is also implementation guidance with the suggested format of a table to be disclosed (IFRS 8, IG3). However, almost all of the specific requirements are directly dependent on whether the chief operating decision maker (CODM) regularly receives the information. This provides management with much flexibility with regard to what to disclose and this is not primarily an issue of materiality but, arguably, heavily related to management incentives. It makes sense that if the CODM does not use the information, it is not relevant for the entity to report this information, but what information the CODM actually uses is not possible to observe. As a consequence, the disclosure principle effectively removes the specific requirements and, in turn, decreases comparability across entities.

André, Filip, and Moldovan (Citation2016) study 270 multi-segment European firms who apply IFRS 8 and report non-geographical segments. They measure the quantity of segment reporting as the number of segment-level line items disclosed in the note (where only the measure of profit or loss is mandatory to disclose and the rest depends on the CODM). This lends the line-item disclosure quantity a voluntary character and gives rise to three possible groups of firms: Box-tickers; i.e. companies who disclose more or less the number of line items suggested by the standard, Under-disclosers; those that disclose fewer line items than mentioned in the standard, Over-disclosers; those that disclose more line items than suggested in the standard (p. 444). In addition to measuring disclosure quantity on the basis of the number of line items disclosed per segment, André et al. also measure disclosure quality on the basis of how diverse the segments are in terms of profitability, i.e. if the entity is willing to disclose the most and least profitable businesses this is more informative than if it aggregates businesses in order to hide low- or high-profitability businesses. André et al. find that under IFRS 8, more discretion can be exercised over the quality than the quantity of disclosures and that incentives play an important role in the sense that managers with proprietary concerns tended to solve this by (p. 443):

 … either deviating from the suggested line-item disclosure in the standard, or, if following standard guidance, by decreasing segment reporting quality.

These results suggest that when management is given much flexibility in relation to disclosure in combination with low enforceability, there will be high variation in disclosure quantity and quality in practice, to some extent related to the incentive patterns of management.

Before IFRS 8, the preceding standard (IAS 14) had specific requirements regarding what segment information to disclose. At one point, an improved version of the standard, IAS 14R, was adopted and a study by Street and Nichols (Citation2002) analysed the impact of IAS 14R on a global sample of companies trying to determine if the revised standard had resulted in a greater number of segments for some enterprises, in more meaningful and transparent geographic groupings, in companies reporting more items of information per segment or if there was an improved consistency of primary segment information with other parts of the annual report. Their results show that the revised standard resulted in a significant increase in the number of items together with an increase in consistency. On a less positive note, the authors also find that many companies continued to show vague geographic groupings and report on several companies not fully complying with all the disclosure guidelines. In a similar fashion, and also analysing the impact of IAS 14R, we find the study by Prather-Kinsey and Meek (Citation2004) where the authors also conclude that companies are responding to IAS 14R but not fully embracing it. In this case, the authors add a determinant analysis and find that companies being audited by a Big-4 firm and, to a lesser extent, companies that are larger and listed on multiple stock exchanges, are more compliant.

Another interesting example is that of Chen and Liao (Citation2015) where the authors investigate the economic consequences of SFAS No 131 (the US standard corresponding to IFRS 8) by evaluating whether improved segment-disclosure quality is associated with a reduction of cost of debt. Their results show that firms can benefit from providing high-quality segment information as the level of segment-reporting quality is significantly and negatively related to bond yield spreads, indicating that firms that provide more items of information enjoy lower cost of debt.

Finally, a more recent study by Franzen and Weißenberger (Citation2015) assesses the changes in segment-reporting practices of German listed companies after the issuance of IFRS 8. They do not find significant improvements in the companies’ behaviour before and after adoption of the new standard. In fact, they state that while the number of reportable segments slightly increased, the amount of information disclosed for each reportable segment decreased.

We can see how, for the segment-reporting analysis, research has not focused on country-level determinants but more on company-specific ones, although conclusions would not be generalisable when the number of studies found is so low. However, it is relevant to mention that variables like size, audit quality and internationalisation may influence segment disclosures and that, in line with previous areas analysed, the level of compliance is found to be low.

4.5.4. Studies regarding other areas of interest

Having covered the areas that the literature on compliance with disclosure requirements has analysed more deeply, this subsection summarises a few of the studies that analyse less frequently examined areas. We find for example studies dedicated to the analysis of compliance with disclosures regarding presentation of financial statements (Rahman & Hamdan, Citation2017), the voluntary adoption of IAS 1 (Iatridis & Valahi, Citation2010), income tax (Ebrahim & Fattah, Citation2015), contingent legal liabilities (Hennes, Citation2014), intangible assets (Devalle et al., Citation2016), stock option disclosures (Bassett et al., Citation2007; Goh et al., Citation2016), executive compensation (Robinson et al., Citation2011) and leases (Fito, Arimany, Orgaz, & Moya, Citation2015) just to name some of them.

Rahman and Hamdan (Citation2017) examined 105 Malaysian listed companies’ degree of compliance with 105 disclosure items in IAS 1 (referred to as FRS 1 in Malaysia). They found the average compliance level to be 92%. The only significant explanatory variable is firm size. The authors assign the high level of compliance with reference to IAS 1 leaving little room for companies to conceal any particular information. It may be noted that the principles-based requirements in, for example, paragraph 17 of IAS 1 were not among the 105 disclosure items evaluated.

Iatridis and Valahi (Citation2010) focus on firms’ voluntary compliance with the reporting requirements of IAS 1 before the official adoption of IASs. Their study shows that the decision-making process of firms is significantly influenced by the intention to improve key financial measures, such as leverage, profitability and growth. Consequently, firms would tend to adopt an accounting policy or regulation when they perceive that adoption would favourably impact on their reported financial situation.

Ebrahim and Fattah (Citation2015) investigate recognition and disclosure requirements for income tax accounting in Egypt. They relate the level of compliance to the regulatory environment and different socioeconomic variables including corporate governance factors. The authors design a deferred income tax disclosure index for a sample of 116 companies that have recognised deferred income taxes in the income statement during the year (2007). The average level of compliance with IAS 12, according to the index, is 83%. Their results suggest that compliance is associated with corporate governance-related factors (institutional ownership and foreign representation on the board) and having an audit firm with international affiliation (Big-4 plus Mazars and Crowe Horwath International). In addition, the results indicate that government ownership has a negative effect on the compliance level. In sum, the authors argue that their results highlight the significance of having a high level of sophistication as regards management, owners and auditor for achieving IFRS compliance in emerging economies.

The general conclusion of the papers in this residual category is that the compliance levels remain quite low, with the possible exception of IAS 1. As for the determinants analysed, they include corporate governance (board characteristics and ownership structure) variables and common company-specific variables. When we focus on company-specific variables, we observe that the generally used company-specific variables are often not significant but instead more item-specific variables may be influential as with interest expense in the case of asset-related disclosures or media coverage in the case of leases. However, these results must be considered with caution as they are based on a very small set of papers that focus, each of them, on a separate area, with also different samples, periods and regulatory contexts.

5. Concluding Remarks

The current paper investigates the possible effects of introducing more principles of disclosures as part of the IASB Disclosure Initiative. Based on our analysis, we argue that introducing more principles of disclosure must be accompanied by a clarification of the role of the specific disclosure requirements in IFRS. It is not clear to what extent the suggested increased reliance on principles of disclosures in the DP is expected to replace the need for specific disclosure requirements.

The literature review presented in Section 4 has pointed at significant levels of non-compliance both with regard to disclosures in general (Section 4.3) and specific areas (Section 4.4). In a review of IFRS-related research, Pope and McLeay (Citation2011) commented on the fact that it is hard for researchers to measure the degree of compliance as the information reflects the application of principles rather than specific rules and the user does not have sufficient information to evaluate compliance with the principle in specific circumstances. In the case of disclosures, and as seen in Section 4, academic research tends to focus on compliance with the specific disclosure requirements rather than disclosure principles in, for example, IFRS 3 or IFRS 7. The standard-setting approach for disclosures used in IFRS 3 and IFRS 7 is very appealing from a top-down perspective, i.e. the specific requirements are logically derived from the principles, so that complying with the specific requirements is a necessary but not sufficient way of satisfying the principle. However, research has not succeeded in measuring compliance with these principles, and the critical analysis of IFRS 7 compliance in the ESMA (Citation2013) report implies that entities and auditors tend to focus exclusively on the specific requirements. The question is then whether the principles of disclosure in, for example, IAS 1, IFRS 3, IFRS 7 and IFRS 8 are enforceable and possible to audit? This is important with regard to the DP (IASB, Citation2017a) as it proposes more principles-based disclosures. There is one area of disclosures, operating segments, where application of the disclosure principle has been studied by research, and where the results suggest high variation in the quantity and quality of disclosures. Entities tend to use their flexibility and the result is not only increased relevance as the information becomes very entity-specific, but also a considerable risk of abuse and deficient information for users.

All standards need to define compliant behaviour for the standard to be enforceable. Our findings from the literature review suggest that the negative tone used with regard to checklists and the concept of compliance in DP paragraph 1.7 is counter-productive. More reliance on principles and less reliance on specific requirements is not likely to solve the need for more relevant information and will most likely lead to lower disclosure quality among poor disclosers. Based on what seems to (not) work in practice, it seems like more emphasis should be put on how to make the disclosure requirements enforceable and possible to audit. The high-level principles of disclosure, as in IFRS 3 and IFRS 7, may be very useful, but in order to achieve compliance perhaps there is a way to design even more appropriate specific requirements that logically support the principles.

The Board points at the objective to develop principles of disclosure that will help entities to apply better judgement and communicating more effectively (DP, para. IN3), indicating that they are not doing this very well at the moment as stated most explicitly in paragraph 1.10 of the DP:

a set of disclosure principles could help to address the disclosure problem, however, to improve the effectiveness of disclosures in the financial statements, those principles need to be accompanied by a change in the behaviour of [entities, auditors and regulators].

The IASB’s suggested solution to the disclosure problem pertains to improving the standards per se, not the context in which these standards are applied. This is understandable given what the Board can influence, but as pointed out earlier by Barker et al. (Citation2013), the standards cannot be viewed in isolation, and what is perceived to be an improvement of a standard may not lead to the corresponding improvement in accounting practice due to various aspects of the context in which entities apply the standards.

We believe further consideration of the context is warranted also for the reason that the IASB’s actions (the principles of disclosures and the materiality guidance) so explicitly target the ‘best-in-class’ disclosers rather than setting minimum requirements that would rely less on incentive-driven judgements and the entity’s good intentions.Footnote11 Enforcers must be able to clearly distinguish between compliance and non-compliance and thus the standard setter must carefully consider this when designing the standards and formulating the requirements.

Even if disclosure requirements are only expressed in terms of high-level principles, enforcement will ultimately lead to specific interpretations in particular cases. In turn, adopting the specific interpretation will then be necessary for being compliant. From this viewpoint, specific requirements in standards can be viewed as derivations from higher principles where the standard setter foresees the needs of the user rather than leaving this for interpretation by the enforcer. In addition, as the application of a principle will ultimately result in specific disclosures, a certain level of box-ticking will always be part of compliance and should not be described as negative per se. Especially in low-enforcement environments, lack of transformation of high-level principles to specific requirements through the mechanisms of enforcement may lead to a situation where disclosures will not be of sufficient quality.

We believe the view that high-level principles of disclosure may replace specific disclosure requirements may lead to a situation where compliance requirements become vague and not possible to enforce. Our literature review of academic research on how entities have complied with disclosure requirements in the past suggests that there is high variation among entities and that poor disclosers are typically far below the average. More emphasis is needed on ensuring that the disclosure requirements are enforceable and auditable in order to secure a certain minimum level of disclosure.

Acknowledgements

The authors gratefully acknowledge the useful comments provided by Paul André, Ann Tarca, Sonja Wüstemann, one anonymous reviewer, and participants at the IASB Research Forum in Brussels, 2017, and the EUFIN Workshop in Florence, 2017.

Disclosure Statement

No potential conflict of interest was reported by the authors.

Notes

1 The Principles of Disclosure project is one of the most important projects of the Disclosure Initiative (IASB, Citation2017a, p. 16). Some projects of more limited scope have already been completed within the Disclosure Initiative (the 2014 Amendments to IAS 1 to remove barriers to the exercise of judgement, and the 2016 Amendments to IAS 7 to improve disclosures of liabilities from financing activities) and the project related to guidance on making materiality judgements was completed in September 2017 (the Materiality Practice Statement, IASB, Citation2017b).

2 According to the IASB 2010 Conceptual Framework (2.11, emphasis added), materiality is ‘ … an entity-specific aspect of relevance based on the nature or magnitude, or both, of the items to which the information relates in the context of an individual entity’s financial report.’

3 Some would argue that principles referring to recognition and measurement will also have many different outcomes, as they rely on future uncertain events (e.g., ‘value in use’ calculations). However, we would argue that measuring an asset or a liability under uncertainty in accordance with a principle will have a compliant measurement outcome, sometimes in terms of an acceptable interval reflecting the uncertainty level. This is conceptually different from applying a principle of disclosure, where infinite options appear to be available if we consider the proposed principles of effective communication.

4 We are grateful to Professor Sonja Wüstemann for providing this definition of enforceability.

5 Occasionally, the classification of requirements as ‘mandatory’ was not clear-cut and a few papers with voluntary elements were included.

6 The lowest level, level 2, is described as follows by the Chartered Association of Business Schools (Citation2015, p. 7):

Journals in this category publish original research of an acceptable standard. A well regarded journal in its field, papers are fully refereed according to accepted standards and conventions. Citation impact factors are somewhat more modest in certain cases. Many excellent practitioner-oriented articles are published in 2-rated journals.

7 The study by Taplin et al. (Citation2002) also report on disclosure compliance levels in Australia, Singapore and Hong Kong.

8 The main part of the data (72%) in Street and Nichols (Citation2002) is European, whereas 28% is from developing/emerging-market countries. Prather-Kinsey and Meek (Citation2004) is primarily based on data from IAS adopters in developed countries (about 10% of the observations are from developing/emerging-market countries).

9 There are some observations from emerging/developing countries in these studies: less than 10% in Street et al. (Citation1999), Bradshaw and Miller (Citation2008), Hodgdon et al. (Citation2008, Citation2009), and Taylor and Jones (Citation1999); less than 20% in Hope et al. (Citation2007) and Street and Bryan (Citation2000); and less than 30% in Street and Gray (Citation2002).

10 The compliance level observations of emerging/developing countries from the transnational studies were included in . The same procedure was followed with regard to developed countries in . Please note that there are observations pertaining to developing/emerging-market countries in some of the transnational studies of developed countries (see note 9).

11 A good example of targeting ‘best-in-class’ disclosers is the use of the word ‘compliance’ in quotation marks in the IASB’s press release referred to earlier (IASB, Citation2012), suggesting that there is some minimum level of superficial compliance in the minds of the regulators which is quite different from what the entities would achieve if they applied the standards as intended by the standard setter.

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Appendix.

Studies of compliance with disclosure requirements.