The Ministry of Finance is publicly soliciting comments on the Request for Information on the Post-implementation Review of the financial instruments standard issued by the International Accounting Standards Board.

On October 12, the Ministry of Finance issued the "Letter on Publicly Soliciting Comments on the Request for Information on the Post-implementation Review of the Financial Instruments Standard Issued by the International Accounting Standards Board." On September 28, 2026, the International Accounting Standards Board issued the "Post-implementation Review of IFRS 9 Financial Instruments and IFRS 7 Financial Instruments: Disclosures in Relation to Hedge Accounting (Request for Information)" (hereinafter referred to as the Request for Information), soliciting comments from stakeholders worldwide. In order to deeply participate in the development of International Financial Reporting Standards and to ensure that the revision and improvement of International Financial Reporting Standards better meet the needs of China's stakeholders, the Ministry of Finance requests relevant entities to organize and submit comments on the Request for Information, and to provide written comments to the Ministry of Finance by November 15, 2026. The Request for Information includes specific content in three areas: an overall assessment of the hedge accounting requirements in IFRS 9, an overall assessment of the hedge accounting-related disclosure requirements in IFRS 7, and other matters related to the post-implementation review. The Board wishes to understand stakeholders' experiences in applying the hedge accounting requirements of IFRS 9 and the hedge accounting-related disclosure requirements of IFRS 7, in order to assess overall whether these requirements are functioning as intended, whether implementation costs have not significantly exceeded expectations, and whether they provide decision-useful information. The original text is as follows: Letter on Publicly Soliciting Comments on the Request for Information on the Post-implementation Review of the Financial Instruments Standard Issued by the International Accounting Standards Board Cai Kuai Bian Han [2026] No. 52 To relevant entities: On September 28, 2026, the International Accounting Standards Board issued the "Post-implementation Review of IFRS 9 Financial Instruments and IFRS 7 Financial Instruments: Disclosures in Relation to Hedge Accounting (Request for Information)" (hereinafter referred to as the Request for Information), soliciting comments from stakeholders worldwide. In order to deeply participate in the development of International Financial Reporting Standards and to ensure that the revision and improvement of International Financial Reporting Standards better meet the needs of China's stakeholders, please organize and submit comments on the Request for Information, and provide written comments to us by November 15, 2026. When providing comments, please address the questions listed in the Request for Information and put forward opinions and suggestions in light of China's actual circumstances. We will provide feedback to the International Accounting Standards Board based on the compilation, summary, and analysis of comments from all parties. The Chinese introduction and English original text of the Request for Information can be downloaded from the "Work Notices" section of the Accounting Department sub-channel of the Ministry of Finance website (kjs.mof.gov.cn) and the "Work Notices" section of the China Accounting Standards Committee website (www.casc.org.cn). The Chinese introduction is for reference only; in case of any inconsistency with the English original text, the English original text shall prevail. Contact person: Guo Yingxiao, Research Division, China Accounting Standards Committee Telephone: 010-68518577 Address: 2nd Floor, Yuexin Building, No. 14 Yuetan South Street, Xicheng District, Beijing (Postal Code: 100045) Email: comments@casc.org.cn Attachments: 1. Chinese Introduction to the "Post-implementation Review of IFRS 9 Financial Instruments and IFRS 7 Financial Instruments: Disclosures in Relation to Hedge Accounting (Request for Information)" 2. English Original Text of the "Post-implementation Review of IFRS 9 Financial Instruments and IFRS 7 Financial Instruments: Disclosures in Relation to Hedge Accounting (Request for Information)" Accounting Department, Ministry of Finance October 10, 2026 "Post-implementation Review of IFRS 9 Financial Instruments and IFRS 7 Financial Instruments: Disclosures in Relation to Hedge Accounting (Request for Information)" Chinese Introduction On September 28, 2026, the International Accounting Standards Board (hereinafter referred to as the Board) issued the "Post-implementation Review of IFRS 9 Financial Instruments and IFRS 7 Financial Instruments: Disclosures in Relation to Hedge Accounting (Request for Information)" (hereinafter referred to as the Request for Information), aimed at assessing the impact of the hedge accounting requirements in IFRS 9 Financial Instruments (hereinafter referred to as IFRS 9) on preparers and users of financial statements, auditors, and regulators, whether these requirements are consistent with the Board's original intentions when developing the standard in 2014, and whether the hedge accounting-related disclosure requirements in IFRS 7 Financial Instruments: Disclosures (hereinafter referred to as IFRS 7) can provide decision-useful information to users of financial statements. The comment period for the Request for Information will close on January 26, 2027. I. Background The Board issued IFRS 9 in July 2014 to replace IAS 39 Financial Instruments: Recognition and Measurement (hereinafter referred to as IAS 39). The newly developed IFRS 9 became effective on January 1, 2018. Compared with IAS 39, IFRS 9: first, improved the approach to classification and measurement of financial instruments, requiring entities to classify financial instruments based on their business model and contractual cash flow characteristics; second, changed the approach to recognizing impairment provisions for financial instruments, requiring entities to recognize impairment losses on financial instruments in a timely and adequate manner based on the expected credit loss model; third, established a hedge accounting model that effectively integrates risk management and accounting treatment. Regarding the new hedge accounting model, the Board provided entities with an accounting policy choice, allowing all their hedging activities to consistently apply either IAS 39 or IFRS 9. However, entities applying IFRS 9 may still apply the relevant provisions of IAS 39 for fair value hedges of interest rate risk exposure of a portfolio of financial assets or financial liabilities. The post-implementation review is intended to assess the impact of applying the new standard on preparers and users of financial statements, auditors, and regulators, and whether this is consistent with the Board's original intentions when developing the new standard. When conducting a post-implementation review, the Board will assess whether the new standard is functioning overall as intended, whether there are fundamental issues with the clarity and applicability of its core objectives or principles, and will seek stakeholder feedback on issues related to the application of the new standard. In October 2020, the Board decided to undertake the post-implementation review of IFRS 9, which was divided into three phases to be conducted sequentially: classification and measurement of financial instruments, impairment of financial instruments, and hedge accounting. The Board completed the post-implementation reviews of the first two phasesclassification and measurement of financial instruments (including the related disclosure requirements in IFRS 7) and impairment of financial instruments (including the related disclosure requirements in IFRS 7)in 2022 and 2024 respectively, concluding that the relevant requirements are functioning as intended and provide decision-useful information to users of financial statements. In December 2025, the Board decided to commence the post-implementation review of the hedge accounting requirements (including the related disclosure requirements in IFRS 7) in the first quarter of 2026. In September 2026, the Board issued the Request for Information for the third phase of IFRS 9 in accordance with its work plan, focusing on issues encountered in the implementation of hedge accounting-related requirements. II. Main Content of the Request for Information The Request for Information includes specific content in three areas: an overall assessment of the hedge accounting requirements in IFRS 9, an overall assessment of the hedge accounting-related disclosure requirements in IFRS 7, and other matters related to the post-implementation review. The Board wishes to understand stakeholders' experiences in applying the hedge accounting requirements of IFRS 9 and the hedge accounting-related disclosure requirements of IFRS 7, in order to assess overall whether these requirements are functioning as intended, whether implementation costs have not significantly exceeded expectations, and whether they provide decision-useful information. (I) Overall assessment of the hedge accounting requirements in IFRS 9. Compared with IAS 39, the hedge accounting requirements in IFRS 9 retain the three types of hedging relationshipsfair value hedges, cash flow hedges, and hedges of a net investment in a foreign operationas well as the related hedge accounting mechanics, but expand the scope of eligible hedged items and hedging instruments, introduce the hedge cost approach to address profit or loss volatility of the non-risk-hedged portion of hedging instruments, remove the retrospective effectiveness test and the rules-based 80%125% hedge effectiveness test requirement and replace them with a principles-based hedge effectiveness assessment requirement, require basis adjustments for non-financial items, and remove the option to discontinue a designated hedging relationship and introduce a hedging relationship rebalancing mechanism. Recently, based on preliminary feedback the Board has received from preparers of financial statements, auditors, standard-setting bodies, and securities regulators, the hedge accounting requirements in IFRS 9 are generally functioning as intended. Some feedback suggests that certain requirements of the hedge accounting provisions (for example, the "highly probable" criterion, the hedge cost approach, the hedging relationship rebalancing mechanism, and the specific application of basis adjustments for non-financial items) involve significant judgment or have high implementation costs, and suggests that the Board provide more application guidance or supporting materials. Through the Request for Information, the Board wishes to understand whether the hedge accounting requirements are functioning as intended, whether implementation costs have not significantly exceeded expectations, and whether they provide decision-useful information. In addition, the Board also wishes to understand stakeholders' views on repealing IAS 39. (II) Overall assessment of the hedge accounting-related disclosure requirements in IFRS 7. When the Board revised IFRS 9, it also made corresponding revisions to the hedge accounting-related disclosure requirements in IFRS 7, requiring entities to disclose separately in the notes to the financial statements, for different categories of risk, their risk management strategies, the potential effects of hedging activities on the amount, timing, and uncertainty of future cash flows, and the effects of hedge accounting on their financial statements. Recently, based on preliminary feedback the Board has received, a small number of users of financial statements believe that the above disclosure requirements can provide more decision-useful information; some users of financial statements, auditors, standard-setting bodies, and regulators believe that the level of detail of information disclosed by entities varies, and that the disclosed information is often lengthy with little substantive content, lacks business context, and is inconsistent in disclosure basis across entities; some users of financial statements and auditors also suggest that entities disclose the reasons for rebalancing decisions and discontinuing hedging relationships, entities' economic hedging and structural hedging activities, entities' expectations regarding hedge duration and hedge rollover strategies; many preparers of financial statements believe that the above disclosure requirements have excessively high implementation costs and are burdensome, increasing labor costs and audit fees. Through the Request for Information, the Board wishes to understand whether the hedge accounting-related disclosure requirements in IFRS 7 are functioning as intended, whether implementation costs have not significantly exceeded expectations, and whether they provide decision-useful information. (III) Other matters related to the post-implementation review. Through the Request for Information, the Board wishes to understand whether there are any other issues related to the IFRS 9 hedge accounting post-implementation review project that need further discussion. III. Main Questions in the Request for Information (I) Question 1: Overall assessment of the hedge accounting requirements in IFRS 9. The Board wishes to understand, in your view: 1. Do the hedge accounting requirements in IFRS 9 achieve the Board's intended objectives? If not, please explain the specific reasons. 2. Are the overall initial application costs, ongoing application costs, and related audit and regulatory implementation costs of applying the hedge accounting requirements in IFRS 9 broadly in line with the Board's expectations? If the overall costs are significantly higher than expected, please explain the specific reasons, provide suggestions on how to reduce these costs, and explain the impact of your suggestions on the benefits of the relevant requirements. 3. Is the usefulness of the information provided to users of financial statements by applying the hedge accounting requirements in IFRS 9 broadly as the Board expected? If the overall benefits of information usefulness are significantly lower than expected, please explain the specific reasons and provide suggestions on how to improve the usefulness of this information. For the costs and benefits of the hedge accounting requirements in IFRS 9, please refer to paragraphs BCE.174 to BCE.238 of the Basis for Conclusions on IFRS 9. You may also provide opinions and suggestions on the timing and manner in which the Board plans to repeal IAS 39. Please pay particular attention to the transition provisions of the hedge accounting requirements in IFRS 9 and whether additional requirements are needed when repealing IAS 39. (II) Question 2: Overall assessment of the hedge accounting-related disclosure requirements in IFRS 7. The Board wishes to understand, in your view: 1. Do the hedge accounting-related disclosure requirements in IFRS 7 achieve the Board's intended objectives? If not, please explain the specific reasons. 2. Are the overall initial application costs, ongoing application costs, and related audit and regulatory implementation costs of applying the hedge accounting-related disclosure requirements in IFRS 7 broadly in line with the Board's expectations? If the overall costs are significantly higher than expected, or if disclosing the relevant information requires entities to incur excessive costs or efforts, please explain the following: first, the specific reasons (identifying the specific requirements and cost drivers); second, how you suggest the Board reduce costs; third, the impact of your suggestions on the benefits of the disclosure requirements. 3. Is the usefulness of the information provided to users of financial statements by applying the hedge accounting-related disclosure requirements in IFRS 7 broadly as the Board expected? Please explain the following: first, which disclosures provided are most useful and why; second, in your view, whether the information provided is sufficient to help users of financial statements understand an entity's hedging activities; third, if the overall benefits of information usefulness are significantly lower than expected, please explain the specific reasons and provide suggestions on how to improve the usefulness of this information. For the costs and benefits of the hedge accounting-related disclosure requirements in IFRS 7, please refer to paragraphs BCE.174 to BCE.238 of the Basis for Conclusions on IFRS 9. (III) Question 3: Other matters related to the post-implementation review. Are there any other matters that the Board should discuss as part of this post-implementation review? If so, please explain the specific reasons in light of the objectives of the post-implementation review. This article is excerpted from the official website of the "Ministry of Finance." Edited by GMTEight: Feng Qiuyi.