Indian Accounting Standard (IND AS) 19

Transcription

1 Indian Accounting Standard (IND AS) 19 Implications for companies in India Indian Accounting Standard (IND AS) 19 is replacing AS 15 (revised, 2005) with regulatory guidelines making it mandatory for companies with a net worth exceeding INR 500 crores to make this transition effective 1 April Sooner or later all companies, will have to transition to IND AS 19 and hence understanding the changes will be critical to stay prepared, ensure accurate forecasting and identifying key drivers impacting the value of employee benefit liabilities on the financial statements.

2 Introduction The Ministry of Corporate Affairs (MCA) has issued a notification on 16 February 2015 announcing a roadmap for the implementation of IND AS. The roadmap provides a phase-wise approach, primarily based on a company s net worth. Effective 1 April 2016, adoption of IND AS will be mandatory for companies with net worth exceeding INR 500 crores. The roadmap also allows voluntary adoption of IND AS prior to 1 April Key Changes Introduced By IND AS 19 IND AS 19 introduces a number of changes which will impact the financial reporting of postemployment and other long term employee benefit schemes for companies in India. We highlight key changes (as compared to the current version of AS 15 (revised, 2005) and also how this will impact companies for both Indian plans and plans for overseas subsidiaries (which are reported locally in India). 1. Recognition of actuarial gains and losses Change: For post-employment benefits, actuarial gains and losses arising from experience differing from what was assumed, changes in assumptions and investment gains and losses on plan assets are to be recognised immediately through the Other Comprehensive Income (OCI) statement. Currently under AS 15, actuarial gains and losses are recognised immediately in Profit and Loss ( P&L ). Impact: Recognising actuarial gains and losses through the OCI is probably the most significant change in the new Standard. One of the biggest perceived challenges with AS15 is the volatility on the P/L due to changes in discount rates that is market linked. During the financial year , discount rates had increased from 8% at the beginning of the year to 9.25% towards the end, while the reverse happened in In FY13-14, most companies recognised material gain through the P/L due to the assumption gain on discount rate increase while in FY14-15, approximately 10-20% of the overall liabilities have been recognised as additional losses through the P/L due to the reduction in the discount rate basis. Once the new Standard becomes effective, such fluctuations (and also those that arise due to

3 actual experience being different from the assumptions) will not go through P/L but will be recognised immediately through Other Comprehensive Income (OCI), for postemployment benefits. This is expected to provide some level of stability to the P/L. Actuarial assumptions play a pivotal role in actuarial valuations. Under AS15 (revised), the impact of any experience gains/losses flowed through P&L. However, under IND AS19, the assumptions used for valuation would eventually result in gains/losses flowing through the OCI due to experience gains/losses. Hence we would expect a greater and critical scrutiny of the basis being used for valuation by actuaries and auditors. Note: Actuarial gains and losses on Other Long- Term Employee Benefit plans continue to be required to be recognised through P&L. 2. Financing Cost Change: Interest cost and expected return on plan assets are replaced with net interest income/cost on the net asset or liability recognised on the balance sheet. This net interest income or cost is measured based on the plan's discount rate. Under AS 15 (revised, 2005), the P&L cost includes interest cost (on the plan liabilities) offset by the expected return on plan assets. Separate assumptions are used for the discount rate (used in calculating interest cost) and the expected return on plan assets. Now, under IND AS 19, the expected return on plan assets assumption is replaced with the discount rate, so that effectively interest accrues on the difference between the plan liabilities and plan assets. Impact: This approach will remove judgment in selecting assumption on expected return on assets. For funded plans, the P&L impact depends on whether the discount rate is higher or lower than the expected return on plan assets. All other things being equal, a lower discount rate would lead to an increase in the P&L cost and vice versa. In terms of emerging plan experience, asset returns greater than or less than the discount rate are to be recognised as an actuarial gain or loss in OCI. 3. Disclosure Requirements Change: There is greater focus on disclosures, which have been expanded to include more insight about the risks to the company associated with the post-employment and other long-term benefits. These risks include the timing, amount and uncertainty of future cash flows, and the implications of the regulatory environment in which plans operate. Impact: The disclosures will provide more insight about the company s risks associated with the retirement plans so that investors can better assess the company s current operating performance. However, considerable amount of time and effort will be required to prepare the onerous disclosures. We also understand that the additional disclosure requirements may lead to more questions from stakeholders, e.g. auditors. In India we anticipate that the following additional information will need to be disclosed (over and above that previously required under the AS 15 (revised, 2005): Sensitivity to key assumptions DBO considering +/- 1% on discount rate DBO considering +/- 1% on salary increase rate For certain plans, sensitivity information on attrition rate assumption, medical cost and post retirement mortality assumptions may also be required. Future cash flows Expected benefit payments for each of the next 10 years (years 1-5 individually and years 6-10 combined) Longevity/term of future benefit payments

4 Information about the maturity profile of the defined benefit obligation. This will include the weighted average duration of the defined benefit obligation and split of actuarial gains and losses due to assumption changes in the following manner, Actuarial gain/loss due to change in demographic assumptions Actuarial gain/loss due to change in financial assumptions Detailed disclosures relating to the fair value of assets in order to focus more on risk exposure, that include: Disaggregation of fair value of plan assets into asset classes based on nature and risks Further subdivided by quoted market price versus no quoted price Further segregated by type of issuer and credit quality. Finally, additional requirement under IND AS 19 have been expanded to include information on the regulatory framework within which schemes operate and the governance of schemes (e.g. information on responsibilities of the trustees of funded schemes). 4. Other changes For plan changes, the non-vested portion of the related past service cost /credit can currently be spread across the future time period over which benefits are vested. Going forward under IND AS 19, all past service costs / credits must be fully recognised immediately in P&L. The revised standard also provides additional guidance on the recognition of plan expenses and the treatment of special events. For settlements and curtailments, e.g. when a plan is terminated, or there is a significant reduction in headcount, the revised standard requires the cost to be recognised immediately in the P&L under service cost. Transition and Next Steps IND AS 19 requires a comparative year to be disclosed upon adoption. If a company adopts IND AS 19 effective 1 April 2016, it must also show the comparative position for the financial year as if reported under the revised standard. It is our understanding however that the additional disclosure information may not be required for this comparative year. Companies who previously had unrecognised past service costs/ credit should also discuss transition requirements with their Actuary and Auditors. In summary, a number of changes have been introduced under the new standard. Understanding the changes will be critical for companies to stay prepared, to ensure accurate forecasting and to identify the key drivers impacting the value of employee benefit liabilities on the financial statements. In view of this, we recommend that companies start preparing for the transition well in advance so that they are fully aware of the changes and implications to the financial statements.

5 FAQs Q1 What is the difference between IAS 19 and IND AS 19? IND AS 19 is very similar to IAS 19 (Revised 2011). The primary difference is in the way discount rate should be set for valuations. As per IAS 19 the discount rate should be based on high quality corporate bonds if there is a deep market in such bonds. IND AS 19 has not given that option at all and the discount rate should be based on government bond yields as on the date of valuation. However, for Indian MNCs with subsidiaries in other countries IND AS 19 does given an option to use yields on corporate bonds if the local market has a deep market in corporate bonds. Q4 Q5 Can the gains and losses in the other comprehensive income account (OCI) can be amortised over the future working lifetime of the company? Gains and losses will be recognised immediately through the OCI and cannot be amortised over the future working lifetime of the plan. Should leave schemes be treated as other long term benefits (and hence gains and losses continue to be recognised in P/L) or as other postemployment benefits in which case gains and losses will flow through OCI? Q2 Q3 How will the balance sheet position get impacted at the time of adoption of IND AS 19? The principle of calculation of net liabilities (liability minus the asset) remains the same. You might have an option of reinstating the liabilities for the foreign subsidiaries where they have a market in deep corporate bonds and the discount rate could be changed accordingly. Moreover, for those schemes where there are unrecognised past service costs/credits, the balance sheet position may change. Will the assumption setting principles change? The principles will not change (except the discount rate for foreign subsidiaries of Indian MNCs as mentioned above and expected return on assets will be equal to the discount rate). Scrutiny on the assumptions might increase given that gains and losses are going to a separate account outside the P/L and may gain more visibility from stakeholders. Q6 Q7 It will depend on the leave benefit policy. If leaves can only be encashed at the time of exit then it may be classified as postemployment benefits plan. If encashment is allowed while in service, it is likely to be classified as other long term benefits. We recommend that you discuss the features of the leave plan with your auditors as well to determine whether it should treated as a long term benefit or as a post-employment benefit. Is there any obligation to fund plan assets mandatorily or is it left to companies to fund? IND AS 19 relates to the accounting of employee benefits for the company s financial statements. It does not set out any minimum funding requirement for benefit plans. In India, currently, there is no legal requirement to fund employee benefit plans like Gratuity and Leave. If a company is required to adopt IND AS from 1 April 2016, how does this change affect the company for the current financial year, i.e ?

6 Companies adopting IND AS from financial year need to provide comparative figures for the previous financial year. So, effectively, the financial statements for the current year need to be produced on the basis of the current AS 15 as well as the new IND AS standards. We would urge companies to start preparing for the transition well in advance so that they are fully aware of the changes and implications to the financial statements. Q8 Will the P/L reduce under IND AS 19 compared to AS 15? Not necessarily. If actuarial losses arise during the year (which currently go through P/L), then under this scenario the P/L will reduce under IND AS 19 since these losses now flow through OCI. However, the reverse will happen and the P/L will increase when actuarial gains arise during the year. For more information, please contact: Ritobrata Sarkar, FIAI Consulting Leader Benefits, India (North and East) 2nd Floor, Tower B, Unitech Business Park, South City-1, Gurgaon , Haryana, India T E: ritobrata.sarkar@ Monika Bhargava Consulting Leader Benefits, India (West) 511/512, Solitaire Corporate Park Andheri-Kurla Road, Andheri East Mumbai , Maharashtra, India Tel: 91 (22) E: monika.bhargava@ This technical update is provided for general information only and should not be relied upon as advice on your specific circumstances. About Towers Watson Towers Watson is a leading global professional services company that helps organisations improve performance through effective people, risk and financial management. With 15,000 associates round the world, we offer consulting, technology and solutions in the areas of benefits, talent management, rewards, and risk and capital management., we offer solutions in the areas of employee benefits, talent management,