It’s not just U.S. regulators are who are fretting over the enormity of accounting change on the horizon and calling on companies to give their investors some advance warning. International regulators are starting to freak out a little as well.
The International Organization of Securities Commissions, an association of regulators that includes the U.S. Securities and Exchange Commission, issued a six-page statement on the implementation of new accounting standards globally that provides some implementation and transition marching orders for companies everywhere. The message is similar to those that have been channeled by staff members at the SEC throughout 2016, especially at a recent year-end accounting conference, where the call for disclosure around revenue recognition was hard to miss.
IOSCO’s statement focused on the accounting changes occurring for companies following International Financial Reporting Standards, namely big changes in revenue recognition, leases and financial statements. But the changes are in many ways the same as those facing companies following U.S. Generally Accepted Accounting Principles.
The International Accounting Standards Board worked in tandem with the Financial Accounting Standards Board for many years to develop similar standards for revenue recognition, leases, and financial instruments. The boards agreed on most key aspects of the standards, although there will be some differences in how companies reflect leases and credit losses as a result of the final requirements adopted by the two boards for their respective rulebooks.
IOSCO’s statement explains the big differences that are ahead in those key accounting areas, and it offers some transition and implementation directives to companies that are following international rules. The key message is to provide investors with plenty of disclosure in the periods leading up to transition so they won’t be caught off guard by the changes.
With respect to implementation, for example, IOSCO tells companies to identify necessary changes to systems, process and controls to comply with the new rules, and determine the effect on financial conditions such as loan covenants, any applicable regulatory capital requirements, future tax liabilities, employment compensation packages, and the ability to pay dividends.
Companies must provide disclosure before the effective dates of new standards regarding “known or reasonably estimable information” that would be relevant to understanding the impact of adoption, IOSCO says. That might include disclosure in footnotes, management discussion and analysis, and other public filings to assure investors and analysts understand the expected impact of new standards.
IOSCO also tasks auditors with considering their responsibilities in terms of understanding an entity’s transition process, internal controls, disclosure requirements, and accounting policies.
In the United States, the SEC has made numerous calls on companies throughout 2016 to provide investors with both quantitative and qualitative disclosures about their plans to transition to new accounting standards, especially revenue recognition. Staff members have said companies need to be moving beyond boilerplate “we’re still assessing” disclosures by the end of 2016, or need to explain why they can’t say more if that’s still the case.