Survey for users of financial statements on the IASB’s Exposure Draft Risk Mitigation Accounting

Background of the IASB’s Risk Mitigation Accounting project


1. The IASB has a project on Risk Mitigation Accounting (RMA), (previously Dynamic Risk Management (DRM)), to enable investors to understand the effect of a company’s dynamic approach to risk management of repricing risk due to changes in interest rate and to evaluate the effectiveness of interest rate risk management.

2. Currently, when applying the hedge accounting requirements in IFRS 9 Financial Instruments and/or IAS 39 Financial Instruments: Recognition and Measurement, it is difficult to account for dynamic risk management. There are practical challenges in aligning the accounting requirements with the way companies manage repricing risk[1].

3. These challenges make it difficult to faithfully portray the economic effects of such dynamic and complex risk management activities in their financial statements in a way that delivers decision‑useful information to users.

4. The IASB published an Exposure Draft Risk Mitigation Accounting - Proposed amendments to IFRS 9 and IFRS 7 (ED), as well as the related Basis for Conclusions and Illustrative Examples and Implementation Guidance, on 3 December 2025. The IASB’s consultation is open for comment until 30 November 2026.

[1] For the purposes of the ED, repricing risk is a type of interest rate risk that exposes a company to variability in the cash flows from, and fair value of, financial instruments, arising from differences in:
• the timing of when financial instruments reprice to benchmark interest rates; and
• the amount of financial instruments that reprice in a particular period.

Introduction and Objective

5. The objective of the users’ survey is to collect input on whether the IASB’s proposals on the ED provide useful, relevant and understandable information for users of financial statements. The survey aims to assess whether the proposed disclosures meet users’ needs, whether they enhance transparency on interest rate risk management, whether additional information would be necessary. The survey also looks at cost-benefit considerations. The results will support EFRAG in evaluating the usefulness of the proposed disclosures when preparing its final comment letter on the IASB’s ED on RMA.

6. This survey covers the following topics based on the IASB’s ED:
(a) Section 2: General questions on the RMA model;
(b) Section 3: The objective and scope of risk mitigation accounting;
(c) Section 4: Underlying portfolios;
(d) Section 5: Presentation and disclosure requirements;
(e) Section 6: Effective date and withdrawal of IAS 39;
(f) Section 7: Risk mitigation strategy for insurers;
(g) Section 8: Costs versus benefits of implementing the ED proposals; and
(h) Section 9: Other technical areas.

7. This survey is directed at users. There will be a separate survey directed at IFRS preparers.

8. The survey is expected to take approximately one hour to complete.
 

Timeline and relevant information

9. The deadline to fill out the survey is 15 September 2026. Please submit your answers by clicking on the ‘Submit’ button at the end of the survey.

10. Results from this survey will be used as input for EFRAG’s comment letter, and a summary report of the survey will be published on EFRAG’s website. The collected information will remain confidential and, when used in documents, will be presented in such a way that no individual company or person can be identified.

11. EFRAG published its draft comment letter on 10 February 2026, with a comment period deadline of 09 October 2026.
 

What are users expected to do?

12. User participants are not required to respond to all questions of the survey. Whilst EFRAG would welcome feedback on as many elements as possible, participants are invited to focus on the issues they find the most relevant.

13. Please note that you can save the draft questionnaire and return to it at a later time by clicking on the button ‘Save and continue later’ in the top right corner of the page (please check the spam folder of your mailbox, if needed). EFRAG will only consider submitted surveys.
 

EFRAG Secretariat availability

14. For any technical questions or to receive more information, please contact Sapna Heeralall (sapna.heeralall@efrag.org) or Serge Vinogradov (serge.vinogradov@efrag.org).