A critical analysis of the use of accounting standards’ comment letters as lobbying tools by extractive industry firms

This paper argues that comment letters in response to a recent proposed accounting standard were used by the extractive industry as lobbying tools. Specifically, a content analysis of responses received in respect of the IASC’s extractive industries issues paper reveals the greatest divergence of views on accounting treatments that have the highest potential for income management. This divergence appears to represent an attempt by lobbyists to ensure that income management strategies are not forfeited.