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Navigating the future of financial reporting

FRS 102 amendments – guidance on first time adoption

Is your business truly ready for the most significant changes to FRS 102 in a decade?

Effective for periods commencing on or after 1 January 2026, the amendments to FRS 102 will fundamentally reshape how many businesses report revenue and leases. These aren't just accounting adjustments, they carry far-reaching implications for your financial statements, KPIs, systems, and even tax positions for years to come.

Our polls from last year's FRS 102 webinar, attended by over 400 external participants, revealed that 69% of CFOs, senior finance, and tax leaders expect their businesses to be significantly impacted by these amendments. Yet only 6% of CFOs have a strong understanding of the amendments and key disclosure requirements.

Understanding the FRS 102 amendments: why they matter to your business

On 27 March 2024, the FRC issued amendments to FRS 102 The Financial Reporting Standard applicable in the UK and Republic of Ireland and other FRSs – Periodic Review 2024. The effective date for most amendments is periods beginning on or after 1 January 2026*, with early adoption permitted. These amendments seek to provide greater consistency and alignment to international accounting standards. Whilst incorporating appropriate simplifications.

The amendments are pervasive, affecting most sections of FRS 102. Of particular note are the changes in respect of revenues and leases which could significantly impact your financial results.

Register below to access our on-demand webinar, offering an overview of common pitfalls and valuable lessons learned.

This webinar is your essential guide to understanding the FRS 102 amendments and ensuring you are aware of key considerations and complexities for a smooth transition.

Key changes introduced by the amendments:

The amendments introduce a new 5-step model for revenue recognition (based on that of IFRS 15), requiring a more detailed analysis of contracts with customers. This will impact how and when revenue is recognised, potentially altering the timing and amount of reported income.

While not exhaustive, the list below outlines some of the key accounting and wider requirements, including potential challenges as a result of the amendments.

Accounting Requirements and Challenges:

  • Identifying performance obligation (“PO”): Businesses will need to carefully assess what is being promised to the customer. This assessment is broader than just determining whether multiple goods or services within a single contract should be accounted for separately as distinct POs. It also requires a clear understanding of what constitutes a PO.
  • Allocation of the transaction price: Where a contract contains more than one performance obligation, the total transaction price must be allocated between those performance obligations. The starting point for this allocation will be the stand-alone selling prices of the performance obligations, which may differ from the amounts specified in the contract.
  • Variable Consideration: Variable consideration (e.g., bonuses, penalties) is included in the transaction price, only to the extent that it is highly probable that an entity will be entitled to the revenue recognised when the uncertainty is resolved. The estimation of variable consideration can require judgment.
  • Agent vs. Principal: More prescriptive requirements on determining whether an entity is acting as a principal (recognising gross revenue) or an agent (recognising net revenue/commission). In practice, under the new requirements having primary responsibility would be expected to make an entity a principal. Experience from transition to IFRS 15 suggests that many entities will need to reconsider their principal vs agent assessments on transition to the new requirements. 

Other Impacts & Challenges:

System, data and process challenges

  • The need to obtain and analyse historic contracts for retrospective application of requirements, coupled with the demand for granular contract data, often necessitates upgrades to ERP and revenue management systems.

A single-lease model for lessees is introduced, meaning most leases will now result in the recognition of a 'right-of-use' asset and a corresponding lease liability on the balance sheet.

While not exhaustive, the list below outlines some of the key accounting and wider requirements, including potential challenges as a result of the amendments.

Accounting Requirements and Challenges:

  • Most operating leases will move onto the balance sheet, significantly increasing reported assets and liabilities. As a result, certain key ratios such as debt/equity leverage and interest coverage are expected to be impacted, potentially affecting loan covenants and credit ratings. However, EBITDA measures might be expected to improve.
  • Entities will need to determine appropriate discount rates for lease liabilities, often requiring expert judgment or external support.
  • Clearer definitions and considerations for determining the lease term, including options to extend or terminate which can require judgment.
  • Optional recognition exemptions exist for short-term leases (12 months or less) and leases of low-value assets, which entities will need to consider and which would impact the lease accounting for these assets on a go-forward basis.
  • Identifying all leases (including embedded leases in service contracts) can be complex and labour-intensive.
  • Accounting for transactions that would historically have been regarded as a sale-leaseback will now be inherently more complex with the need to assess whether control passed on the sale, and potentially changes to the way in which any gains (or losses) are recognised. 

Impacts & Challenges:

System, data and process challenges

  • Organisations often lack a centralised lease database, or legacy systems may be inadequate for tracking lease balances, payments, depreciation and interest. 

Critical Timeline:

  • Mandatory Effective Date: Accounting periods commencing on or after 1 January 2026.
  • Early Adoption: Early adoption is permitted if ALL amendments are adopted simultaneously. 


* The amendments for supplier finance arrangements are effective from 1 January 2025.

The far-reaching impact on your business

These changes extend beyond the finance department, affecting various aspects of your organisation:

  • Financial Statements: Expect significant alterations to your balance sheet, income statement, cash flow statement and disclosures.
  • Key Performance Indicators (KPIs): Crucial metrics such as revenue, EBITDA, net profit, net debt, and net assets could be impacted, potentially affecting investor perceptions, loan covenants, and even bonus and remuneration plans.
  • Systems & Processes: Updates to accounting software, data collection methods, and internal controls are essential to capture the necessary information for compliance and reporting purposes. This is particularly critical for lease management, where robust systems are needed to track and account for the right-of-use assets and lease liabilities.
  • Tax Implications: Potential tax impact, including the treatment of the transitional adjustments for tax purposes and implications for deferred tax in various situations.

Key considerations for finance teams:

  • What is the potential impact on KPIs?
  • Are amendments to existing customer contracts required?
  • Is the data required to quantify the adjustments readily available?
  • Are your systems and processes capable of capturing all required information and monitoring leases effectively?
  • Does your current finance team have the bandwidth to quantify and implement these complex amendments?
  • How will the impact on financial results and disclosures be communicated to affected stakeholders?
  • What are the specific tax implications for your business?

 

What you should be doing now: proactive preparation is key

Assess and review the impact:

Understand the specific impact of the new standards on your financial position and performance metrics, and conduct a thorough review of your current revenue and lease agreements to identify necessary adjustments.

Educate your teams:

Inform finance, sales, and other relevant internal stakeholders about the upcoming changes and their responsibilities. For example: Do sales teams need to understand how contract terms can impact revenue recognition, and do procurement teams need to be aware of the implications of lease agreements?

Evaluate systems:

Assess whether your current accounting systems can handle the new data requirements and reporting complexities.

Plan your transition:

Develop a clear implementation plan, including timelines, resource allocation, and communication strategies.

Seek expert advice:

Engage with financial reporting specialists to navigate the complexities and ensure compliance, particularly around the determination of appropriate discount rates.

How Deloitte supports businesses through FRS 102 amendment adoption

Whether you need immediate, tailored advice, or are planning your transition, our team is here to help. For further assistance or to discuss your specific situation and how these amendments will impact your business, please contact us. We are here to help you address the complex challenges you may face.

Deloitte offers a bespoke solution focussed on areas where we can provide you maximum value in your plan to enhance compliance and deliver high-quality financial information. Our multi-disciplinary team provides tailored support, covering accounting, discount rate analysis, system solutions, and tax support for a seamless transition.

We simplify the journey by offering bespoke solutions that ensure a smooth transition and enhance your organisation's readiness. Our offerings are designed to address the key considerations and actions outlined above, providing clear support to you as you address your challenges.

Our key offerings:

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