FORMAL VERSUS SUBSTANTIVE IFRS COMPLIANCE: A THREE-BLOCK DISCLOSURE MODEL BASED ON EVIDENCE FROM PUBLIC-INTEREST ENTITIES IN UZBEKISTAN

Uzbekistan has recently completed the institutional phase of its transition to International Financial Reporting Standards (IFRS): a regulatory framework for public-interest entities (PIEs) was introduced in 2025, the first PIE register was published in 2026, and a programme to develop 32 national financial reporting standards is currently under way. This study examines whether formal adoption has been accompanied by substantive implementation. Drawing on the full texts of IFRS financial statements published by four joint-stock companies operating in four different industries on the national corporate disclosure portal, together with a comparison of financial statements prepared under national reporting formats and IFRS by a single entity for the same reporting year, the study identifies four principal disclosure gaps. First, the bases of presentation are not consistent across entities belonging to the same regulatory category. Second, the expected credit loss allowance required under IFRS 9 is quantified in only half of the financial statements examined, with the reported amounts differing by a factor of approximately 390. Third, a modified audit opinion is associated with the absence of fundamental internal control procedures rather than with complex accounting measurement judgements. Fourth, in one case, profit or loss and total comprehensive income indicate contrasting financial outcomes without the corresponding reconciling item being prominently disclosed. The study argues that these disclosure gaps should not be attributed solely to individual preparers but can be understood as a foreseeable consequence of template-driven approaches to preparing explanatory notes. Accordingly, a three-block disclosure model is proposed, with each block designed to address a distinct information need of the primary users identified in the IFRS Conceptual Framework. The paper also outlines policy implications for the ongoing national financial reporting standards development programme.