Language Barriers to commenting on IASB proposals

A recent paper looked at whether language barriers deter people from responding to IASB exposure drafts. It also discussed whether the IASB pays too little attention to comment letters from countries where the main language is very different from English. The paper “No Comment”: Language Barriers and the IASB’s Comment Letter Process, by Eduardo Flores, Brian R. Monsen, Emily Shafron and Christopher G. Yust looked at responses to 88 exposure drafts the IASB issued between 2007 and 2020.

In this post, I look at the 2 main topics the authors discussed. Those topics relate to comment letters from countries where the main language is linguistically distant from English:

  • were stakeholders in those countries less likely to submit a comment letter than stakeholders in other countries?
  • was the comment letter summary (prepared by the IASB staff) less likely to quote directly from comment letters submitted by stakeholders in those countries?

I then look at how the authors measured the linguistic distance between English and other languages.

    Does linguistic distance inhibit comments?

    Flores and his co-authors found that the stakeholders were less likely to send the IASB comment letters if the stakeholders are in countries with a main language linguistically distant from English. The authors make the plausible suggestion that this difference arises (at least partly) from language barriers. The barriers exist because the IASB issues exposure drafts in English and it also only accepts comment letters in that language.

    Flores and his co-authors note that the IASB does some things that reduce language barriers, at least to some extent:

    • it has issued translations of some exposure drafts into French (since 2007), Japanese (since 2009) and Spanish (since 2013).
    • it has an international mix of Board members and staff.

    To that list, I would add the fact that the IASB now carries out a deep and broad programme of outreach during comment periods.

    Other findings on the 1st question

    Flores and his co-authors found that stakeholders from a particular country were more likely to comment:

    • if exposure drafts are translated into the main language of that country.
    • if Google Translate has become available between that language and English. The authors suggest that availability of Google Translate for a language is a sign that several tools have become available to people using that language. Those tools may reduce language frictions, making it easier for those people to read the exposure draft and to write a comment letter (not necessarily using Google Translate).
    • if either a Board member or the project manager was from that country.

    Summary on 1st question

    Flores and his co-authors uncovered some useful evidence that people are less likely to submit comment letters to the IASB if they are from a country where the main language is distant from English. But that evidence probably doesn’t surprise anyone.

    Perhaps more interestingly, they also found that people are more likely to submit a comment letter if the IASB translates exposure drafts into a local language, or if linguistic tools (such as Google Translate) have become more widely available.  

    Does linguistic distance make comments less visible?

    The 2nd main question examined by Flores and his co-authors was about comment letter summaries prepared by the IASB staff for the IASB. They found some evidence that those comment letter summaries were less likely to quote comment letters from more linguistically distant stakeholders.

    In further analysis, the authors concluded that:

    • comment letters by respondents from more distant languages were written less well.  Flores and his co-authors measured this using Grammarly, an Artificial Intelligence tool that ‘assesses writing characteristics such as grammar, spelling, clear and concise sentences, and wording choices that sound natural to a fluent speaker, as well as readability’.
    • comment letters from those languages were less ‘unique’. They measured this by ‘calculating median pairwise cosine similarity between a comment letter and all other comment letters submitted in response to a given exposure draft’.
    • the comment letter summary was less likely to include direct quotations from comment letters that were written less well, or that were less ‘unique’.

    In their view, this suggests that language barriers make it less likely:

    • that non-English-speaking stakeholders provide feedback in ways;
    • that the IASB considers helpful; and
    • that IASB members consider that feedback seriously and that feedback from those stakeholders can affect the IASB’s redeliberations.

    The assumptions made by Flores and co-authors

    The suggestion by Flores and his co-authors seems to be based on the following assumptions, explicit or implicit:

    • that IASB members give more attention to those comment letters quoted verbatim in the comment letter summary.
    • if the comment letter summary does not quote a comment letter directly, IASB members pay little or no attention to that letter.
    • the comment letter summary is the only channel for points made in comment letters to reach IASB members.

    None of those assumptions is justified, as I discuss below under the following sub-headings:

    • role of direct verbatim quotation
    • how information in comment letters reaches IASB members
    • the summary isn’t the last channel

    Role of direct verbatim quotation

    Direct verbatim quotation from comment letters plays little to no role in the IASB’s process. Indeed, there is no need for the comment letter summary to include any verbatim quotations at all:

    • Some project managers very rarely (if ever) include direct verbatim quotations. In my 26 years on the staff of the IASB and its predecessor (IASC), I was in that group. I rarely (if ever) thought direct quotation would add anything useful to a good summary.
    • Some other project managers include a few direct quotations if they find a quotation expressing clearly and concisely a point made by many or several respondents.
      From memory, I would say this happened more often on projects conducted jointly with the US standard setter, the Financial Accounting Standards Board. Perhaps the FASB prefers this style of presentation.
    • Even when a comment letter summary does contain verbatim quotations, there are only a handful of those quotations. For a large project, the summary covers dozens or even hundreds of points made by respondents. The summary captures almost all of those points by précis, not by quotation.

    How information in comment letters reaches IASB members

    It is a mistake to think that information in a comment letter reaches the Board only if the comment letter summary uses the respondent’s exact words and names the respondent.

    IASB staff papers provide information by summarising and aggregating points from several comment letters. They do not list out the same point several times using slightly different words each time. This is the case in both the initial comment letter summary and the more detailed later papers on individual topics

    It is also usually unnecessary to list each respondent on each side of each debate—though it is often helpful to provide a summary of their characteristics, for example by geography or by type of respondent (such as preparer, user, auditor, regulator).  

    The summary isn’t the last channel

    The comment letter summary is not the last (or only) channel for information in comment letters to reach IASB members. The comment letter summary is only an initial high-level overview of the comments. At later meetings, the Board discusses individual topics.

    The papers for those later discussions contain much more detailed analysis of what the comment letters said. Even in those papers, though, the information from comment letters is captured by concise précis, not by verbatim quotation.

    Could Flores and co-authors have looked at something more useful?

    If there were evidence that IASB pays less attention to comments made by people whose first language is not English, it would be important to know that fact.  In my view, Flores and his co-author’s work on their 2nd question provides no useful evidence on that point. Their underlying assumption is that the (occasional) selection of direct quotations for the initial comment letter summary affects how the IASB’s subsequent discussion plays out. As I said above, that assumption is not valid.

    In my view, there is a more useful question to ask, though finding the evidence to answer that question would probably consume much more time. The IASB staff play a key role in capturing, aggregating and summarising the points made in comment letters and conveying it in Board papers. They do this both in the initial comment letter summary and, maybe more importantly, in papers for the later discussions. Is there any evidence that linguistic distance leads to a staff paper omitting or distorting a significant argument?

    Measuring linguistic difference

    To measure linguistic difference from English, Flores and his co-authors used a ‘Language Friction Index’ (LFI) index, described in Joshi and Lahiri (2015). I discussed Joshi and Lahiri’s LFI in a post on my blog Language Miscellany at  

    The Joshi and Lahiri paper distinguishes what they call ‘language frictions’ from what they call ‘language barriers’:

    • language barriers are an obstacle to the accurate and complete flow of knowledge between two parties who cannot use a shared language.
    • language frictions are a form of cultural friction arising from structural differences in the respective languages used by potential partners to reason and solve problems together. For example, a native speaker of a Mandarin and a native speaker of German may both be proficient in English as a second language and may deal with each other in English. Using that shared language may not change how each party thinks about the possible transaction in that own party’s structurally different native language.

    Joshi and Lahiri’s paper focusses on language frictions between English and other languages, not on language barriers arising from people with only limited knowledge of English. Perhaps this explains partly why they picked the name Language Friction Index.

    The 1st question Flores and his co-authors look at is perhaps more about language barriers than about language frictions. Their 2nd question is perhaps more about language frictions. Nevertheless, as far as I can tell, the Language Friction Index is equally useful for both the questions they consider.


    Flores and his co-authors have found some evidence that people whose first language is not English are less likely to respond to IASB exposure drafts. That evidence is not surprising.

    More interestingly, the authors do find further evidence that:

    • translating exposure drafts into a local language can increase response rates; and
    • wider availability of translation services and tools can also increase response rates.

    The authors also find evidence that the IASB staff’s initial summary of comment letters is less likely to include direct verbatim extracts of comment letters from speakers of languages distant from English. However, in my view, that finding has no implications because direct quotation of that kind plays no role in the IASB’s discussion.

    I suggest above one possible avenue for further research: looking at how the IASB staff summarise comment letters.


    “No Comment”: Language Barriers and the IASB’s Comment Letter Process, Eduardo Flores, Brian R. Monsen, Emily Shafron, Christopher G. Yust (2023)

    There is a summary of that paper at No Comment: Language Barriers and the IASB’s Comment Letter Process | CLS Blue Sky Blog (

    Language friction and partner selection in cross-border R&D alliance formation, Amol M Joshi and Nandini Lahiri, Journal of International Business Studies, Vol 46, No 2 (2015)

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