【正文】 who are interested in accounting practice or in the effect of de jure differences on accounting practice, I suggest that there are not two dimensions. The absence of rules on whole accounting topics is likely to be a particularly major cause of divergence in practice. By creating two dimensions, as dependent variables, Ding et al. have to double up all their generating of hypotheses. That is, for each of their ?ve independent variables (determinants), they create hypotheses for both absence and divergence. I suggest that this is arti?cial, as illustrated in below which notes that Ding et al.?s hypothesis relating to how equity weakness causes divergence is wholly expressed in terms of how equity weakness might affect absence of disclosures. . Independent variables . Accounting profession Ding et al. make ??the importance of the accounting profession” an independent variable for difference between national standards and IAS. They list it as a ??determinant”. However, in their discussion (. Section ), they more carefully say that the two are ??associated”. I suggest that the direction of in?uence is more likely to be from accounting to the profession. Nobes (1998) discusses this, and concludes that the amount and style of ?nancial reporting affects the quantity and role of auditors. For example, the presence of large numbers of listed panies in the USA and the requirements for quarterly reporting, extensive disclosure and some use of fair values led to a need for more auditors in the USA in 2021 than in countries where these things were absent (. in Germany). Later, in their , Ding et al. talk of the importance of the profession in the context of setting standards. However, in most countries, the accounting rules are largely controlled by the public sector (. in Belgium, China, France or Germany) or by independent privatesector trusts (. the UK or the US). Japan has moved from the former to the latter. So, again, the profession is not directly relevant as an independent variable. However, there is probably some ??feedback”. For example, because the accounting profession bees large, it is willing and able to take the lead in standardsetting (. in the US until 1973, in the UK until 1990, and internationally until 2021). . Equity markets When formulating an hypothesis for the variables affecting divergence from IAS (in their ), Ding et al. discuss the need for an IASlike quantity of disclosures in strong equity countries. This, they suggest, should lead to smaller divergence from IAS in such countries than in weak equity countries. However, none of the survey topics included in their measures of divergence (the ??inconsistency” categories of GAAP 2021) were related to disclosure. That is, their hypothesizing relates to the causation of a high quantity of disclosure but their dependent variable is not related to the quantity of disclosure. So, their whole subsection is of doubtful relevance. My hypothesis would be that strong equity markets need a certain style of recognition and measurement, and parability of it (broadly IAS style). Therefore, there will be a negative association between equity strength and divergence from IAS. 4. Conclusion Ding et al. (2021) provide a clear and interesting paper. Their conclusion that the absence of accounting rules on IAS topics in many countries is associated with weak equity markets and with concentrated ownership is convincing, and is indeed the main proposal in the general model of the development of accounting rules in Nobes (1998). In this paper, I provide explanations for various features of GAAP 2021 that had been mented on by Ding et al. I also ask whether those data are suitable for the purposes of academic research, including that by Ding et al. I conclude that they might be, although there are some systematic biases in the data. In particular, (i) the data leave out the aspect of ??divergence” caused by certain national rules (. US or UK) being more detailed or more restrictive than IAS in 2021, (ii) against that, one or more of these countries might have wanted to exaggerate their divergence from IAS, (iii) the equal weighting of widespread and less widespread divergences is questionable, and (iv) the ??absence” scores for developing countries are overstated because some topics are not relevant in those countries. Other potential problems might not be systematic, . the concentration on rules rather than on practices. A question concerning Ding et al.?s methodology is whether the GAAP 2021 data have meaningful additivity. While accepting that the research requires scores to be created for each country, major problems of weighting need to be considered. More fundamental to