The Intangibles Disclosure Industry Working Group is conducting a public consultation on the proposed Intangibles Disclosure Framework. The public consultation period is from 14 December 2022 to 28 February 2023.
The Singapore Intellectual Property Strategy 2030 (SIPS 2030) is a 10-year roadmap to strengthen Singapore’s position as a global hub for Intangible Assets (IA), including Intellectual Property (IP), where innovative enterprises can bring their ideas and intangible assets to the market effectively. A key focus is to build a conducive ecosystem for intangible asset commercialisation, transactions, and financing.
Increasing transparency and disclosure around enterprise intangible assets, including their technologies, brands and data, is critical. To this end, an industry working group has worked closely with an inter-agency committee over the last 12 months to co-develop the proposed Intangibles Disclosure Framework. The intention is to provide a standardised and consistent basis for enterprises to disclose and communicate the details of their intangibles, thereby providing stakeholders with comparable information about an enterprise’s intangibles, so that more informed assessments of the business and financial prospects can be made. This will facilitate intangible asset commercialisation, transactions, and financing. The proposed Intangibles Disclosure Framework can also serve as a precursor or base for subsequent development of valuation guidelines for intangibles.
The objective of this consultation is to ensure the proposed Intangibles Disclosure Framework helps enterprises in identifying and communicating their intangibles to support business activities, in particular intangible asset commercialisation, transactions, and financing.
The proposed Intangibles Disclosure Framework is set out in this consultation paper.
We invite interested persons to comment on the questions in the next section. Comments are most helpful if they contain a clear rationale and, where applicable, suggestions for an alternative approach. All comments received will be considered. However, we seek the public’s understanding that we might not be able to individually acknowledge or address every comment. To maintain confidentiality of feedback contributors, we will anonymise and aggregate the results of this public engagement. Please submit your comments via this FormSG link (Link disabled as consultation has closed).
Request for Comments
Part 1 – The Four Thematic Pillars
The proposed Intangibles Disclosure Framework seeks to provide stakeholders with standardised information about an enterprise’s intangibles, so that they can make more informed assessments of its business and financial prospects. Accordingly, the proposed framework outlines the key principles that an enterprise should follow when disclosing its intangibles in a report. The principles are anchored on four pillars: Strategy, Identification, Measurement, and Management.
Q1. Do the proposed thematic pillars (SIMM) provide a suitable and sufficient basis for enterprises to provide standardised information on intangibles for stakeholders to make more informed assessment of enterprises’ business and prospects?
a. [Strategy pillar] Is the proposed outline suitable and sufficient to explain how intangibles are used by an enterprise to generate long term returns?
b. [Identification pillar] From an enterprise, investor and/or lender perspective, are the six categories of intangibles appropriate and applicable to your business?
c. [Measurement pillar] Do you agree with the proposed value-related (metrics) information to be disclosed for each category of intangibles?
d. [Management pillar] Do you agree that the proposed disclosures adequately communicate information about businesses’ risk management approach to intangibles?
Q2. Are there additional topics within the four thematic pillars you would propose to add? E.g., other disclosures that would be helpful to show how intangibles drive business value and growth?
Q3. Please indicate the ease of understanding the SIMM pillars from your perspective (from 1 being complex to 5 being easy to understand). Please provide explanations on your response.
Part 2 – Adoption / Use
The proposed Intangibles Disclosure Framework should be practical in that it helps enterprises in identifying and communicating their intangibles to support business functions and growth. Examples where the proposed Intangibles Disclosure Framework could be applied and/or used include (but are not limited to): (i) annual corporate reporting, (ii) supplements to financial and/or strategic update to Board of Directors, and (iii) prospectus used for capital raising.
Q4. Do you agree that the Intangibles Disclosure Framework can help to close the information gap on intangibles? Why?
Q5. Do you agree that enterprises could rely on their intangibles to raise capital, or grow their market values? If yes, how could the Intangibles Disclosure Framework help enterprises reap such opportunities?
Q6. In your perspective, what are the key benefits of adopting the Intangibles Disclosure Framework?a. Enhanced market transparency around intangibles
b. Better management of intangibles
c. Greater access to intangibles-based financing or capital raising
d. Others (please specify)
Q7. If you are adopting the Intangibles Disclosure Framework, are you likely to prepare the disclosures in-house or through a consultant? Why?
Q8. In your view, what may be practical steps or support that could incentivise businesses to adopt the framework?
Annex A - Intangibles Disclosure Framework Public Consultation