ASIC expectation gap on new revenue requirements in AASB 15

The Australian Securities and Investments Commission (ASIC) has outlined its focus areas for 30 June 2018 financial reports. Although preparers have had extended time to implement the new requirements, many will not be able to adequately communicate the extent of the impact of the new revenue standard in their financial statements.

By Nikole Gyles, Michael Davern and Brad Potter

The new revenue requirements in AASB 15 Revenue from Contracts with Customers will potentially significantly impact the amount, timing and disclosure of revenue, as well as firm-wide processes, data, debt agreements, managerial compensation and bonus calculations.

In its release of its Areas of Focus for year-end reporting, ASIC has, once again, highlighted an expectation that the extent of the impact of the new revenue requirements be disclosed in the financial statements –  with quantification of the impact expected.

The reality of whether companies are able to make disclosure of the extent of the impact of the new revenue requirements is another matter.

Recent research undertaken by the University of Melbourne (Professor Michael Davern, Nikole Gyles, Associate Professor Brad Potter and Victor Chang) examined the implementation of AASB 15. The results indicate that ASIC’s expectations are unlikely to be met by most companies.

The survey of 143 preparers conducted in late 2017 found that many entities had not started the implementation process for the new revenue requirements, with over 40 per cent of entities still only in the early stages of developing a high-level impact assessment, or not having started at all.

Only 11 per cent had completed a high-level impact assessment, and only six per cent had completed a detailed impact assessment.

Related article: Time ticks down for NFPs as new accounting standards come into effect

Further, more than half of entities were still in the early stages of considering reporting and disclosure, or had not yet started at all. This indicates that, unless there have been significant recent developments, many entities will not be able to provide the disclosure expected by ASIC at year-end – and certainly will not be able to quantify the impact.

This lack of implementation progress is not due to a lack of understanding by preparers of the potential impact of the new requirements. In fact, 63 per cent indicated that the effects on the whole organisation were at least somewhat concerning, and these effects potentially impact multiple areas beyond the accounting function.

So why have companies been so slow to start the implementation process?

First, it seems that many companies are at a loss to know how to execute an efficient and effective implementation. Over 35 per cent of survey respondents were uncertain how to translate AASB 15 into practice. More than half of the respondents were uncertain as to how much data they would need to compile and integrate as part of complying with AASB 15.

It is unsurprising, therefore, that over two-thirds of respondents expected to have at least moderate reliance on external accounting advisory services in their implementation efforts, with nearly 10 per cent indicating they would have complete reliance on external consultants to implement the new requirements.

Further, uncertainty about data requirements, which contributes to the reliance on external advisory sources, is also problematic. Together with the impending time pressure of the effective date, the existence of uncertainty will allow professional services firms to extract a premium in pricing their advice.

Second, compliance is not viewed as an absolute concept. Rather, entities viewed compliance as relative - with more than half of respondents agreeing that compliance was something assessed by benchmarking to competitors - what matters is not absolute compliance, provided they had complied as least as well as the other players in the industry in which they operate.

Although preparers have had an extended timeframe to implement the new requirements, it seems that in delaying the implementation efforts, many companies will not be able to adequately communicate the extent of the impact of the new revenue standard in their financial statements.

ASIC is likely to be disappointed, and perhaps more importantly, many companies will have missed an opportunity for potential business improvement.

Nikole Gyles Enterprise Fellow, University of Melbourne; Michael Davern, Professor, University of Melbourne; Brad Potter, Associate Professor, University of Melbourne.

Read next: Everything you need to prepare for IFRS 15


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