EFAMA commented on IASB’s ED on IAS 12 (Pillar Two Model Rules). As the model rules drafted by the OECD establish that investment funds and investment entities should be carved out / excluded from Pillar Two, at first glance we expect them would not have a significant impact on our industry (at least on the strict product/funds side). While it is still to be confirmed what will be required from asset management firms and investors investing in funds to comply with the new rules, it is clear the analysis is highly complex.

EFAMA replied to IASB’s request for information on the Post-Implementation Review (PIR) of IFRS 9 – Classification and measurement. Our paper recaps EFAMA’s key concerns and recommendations to the IASB. The key concerns of the industry are the removal of recycling (in particular for institutional investors) and the classification of investment entities and investment funds as debt instruments.