Will technology companies that implement the new revenue standard (ASC 606) early be able to recognize more upfront revenue on sales?

Existing GAAP for software companies (SOP 97-2 or ASC 985) requires companies to defer revenue until all four criteria for revenue recognition have been met, and until fair value can be be established for any undelivered elements.  Many technology companies, particularly software providers, are subject to this guidance.

The new revenue guidance ASC 606 will do away with these stringent standards, which often caused revenue recognition to be out-of-sync with the economic reality of sales transactions.  You'll now be able to estimate aspects o revenue accounting, including fair value of promised goods and services as well as future variable consideration.

And so the question presents itself:  will companies with a better grasp of their data be able to recognize more revenue earlier through better estimates?

Let’s take a look at the concept of variable consideration, which is a key aspect of Step 3: Determine the Transaction Price under the new model.  From the opening summary of the new standard:

If the amount of consideration in a contract is variable, an entity should determine the amount to include in the transaction price by estimating either the expected value (that is, probability-weighted amount) or the most likely amount, depending on which method the entity expects to better predict the amount of consideration to which the entity will be entitled.

Companies may be able to begin recognizing revenue for promised goods or services that wouldn’t have met the delivery or the fees are fixed or determinable criteria under the existing standard.

But wait.  There's an important caveat to variable consideration, which will potentially limit companies that don’t have a firm grasp on their historical contract data: the variable constraint.

The variable constraint concept will allow companies to only recognize revenue to the extent that it is probable that a significant reversal in the amount of cumulative revenue recognized will not occur when the uncertainty associated with the variable consideration is subsequently resolved.

Companies eager to pull forward revenue that would previously have been deferred under existing GAAP will need to be weary of the variable constraint when recognizing revenue from variable consideration. 

Data will need to be aggregated and analyzed in ways that may not have been required in the past, as revenue can only be recognized to the extent you can support a significant adjustment is unlikely.

Ultimately, we believe in practice that companies will be required to estimate variable consideration, and the impact of the variable constraint will be based on external factors only.  In other words, companies will be required to have supportable estimates, as opposed to being able to take a hit on upfront revenue in exchange for being able to delay implementation.

Do you have a plan in place for assessing the data you could be collecting now to support your revenue recognition down the road?

Licensing Developments from the January 6, 2016 FASB Board Meeting

While no official decisions were made, the Board observed two major points in relation to the accounting for licenses.

Observation #1 - Under ASC 606, license renewals will not be recognized as revenue until the term of the license renewal begins.

Under current GAAP, license renewals are to be recognized once an agreement is made between the Licensor and the Customer, regardless of when the new license term actually begins.  Since no additional performance is required by the Licensor by extending the term of a license, delivery (the triggering event) has occurred.

Under the new standard, a Customer must be able to use AND benefit from a performance obligation before a Vendor can recognize revenue.  

Accordingly, a Licensor cannot recognize revenue from a term license renewal until the Customer has the right to use and benefit from the license (i.e. when the term actually begins).  

Observation #2 - The application guidance on licensing does not override the five-step revenue recognition model in Topic 606.

In other words, licensing arrangements will still be considered under the context of ASC 606.  The licensing sub-topic will work in conjunction with the new revenue standard and will not require Companies to evaluate licensing deals outside of ASC 606.

FASB to meet Wednesday, January 6. Topics include identifying performance obligations and licensing revenue. #RevRec #FASB

Wednesday at 9:15 EST the FASB will meet to discuss the following topics:

  • Revenue Recognition - Identifying performance obligations and licensing
  • Definition of a business (phase 2) - Clarifying the scope of Subtopic 610-20 and accounting for partial sales of nonfinancial assets
  • Accounting for goodwill impairment

Register here to attend the live webcast.


Five Things Tech Companies Should Know about the New Standard

This article focuses on five practical considerations as to how the new revenue standard ASC 606 will apply to technology companies, specifically those that sell software.

In future posts we'll take a deeper dive into each of these topics.

#1 - Licenses: Timing of revenue recognition depends on nature of license.

For the most part, the new standard does away with all of the industry-specific guidance that existed under the old guidance.  Still though, the technology industry receives a head nod of sorts when it comes to licenses, as ASC 606 dedicates a specific section to licenses.

Right to use vs. Right to access

Under the license guidance, the distinction between whether the customer is purchasing the right to use the license or the right to access the license is an important one, as it impacts timing of revenue recognition.

Right to use licenses will be recognized at the point-in-time in which control transfers to the customer (similar to perpetual licenses under the existing guidance). 

On the other hand, if your customer is purchasing a right to access the license, you’ll recognize revenue over the license period.

The Board is currently drafting a final ASU (Identifying Performance Obligations and Licensing) which distinguished intellectual property between functional and symbolic, and this distinction should be taken into consideration when determining the nature of the license.

Functional vs Symbolic IP

Functional IP is defined as intellectual property that has significant standalone functionality, such as the ability to process a transaction, perform a function or task, or be played or aired.  

Functional IP is indicative of a license that should be recognized at a point-in-time.

Symbolic IP is defined as intellectual property that does not have significant standalone functionality.  Substantially all of the utility of symbolic intellectual property is derived from its association with the entity’s past or ongoing activities, including its ordinary business activities.  

Symbolic IP is indicative of a license that should be recognized over time.


#2 - Specified upgrades will no longer hold up revenue recognition.

You might have just sold a software license to a customer for $1M, and you might have also promised to upgrade the customer to the newest version coming out next year for free.  Under existing GAAP, you're not going to recognize a dollar on that sale until the customer has upgraded (assuming of course that you fall in the most likely scenario of not having a history of standalone sales on the specified upgrade).

Under the new guidance, transaction price is to be allocated amongst performance obligations based on standalone selling price, which is the price a promised good or service would be sold separately to a customer.

But here's the kicker:  

If standalone selling price is not directly observable, you can estimate the standalone selling price.

Three methods are noted as being suitable for estimating standalone selling price.

  • Adjusted market assessment approach
  • Expected cost plus margin approach
  • Residual approach

The residual approach can only be used if the promised good or service is sold to different customers for a broad range of amounts, or if a price has yet to be established for the promised good or service.  The latter condition will apply to the majority of specified upgrades.


#3 - In many cases, post-contract support (PCS) will no longer be viewed as a single component.

24x7 customer support; when-and-if-available enhancements; bug fixes.  

Each of these are typical of the kinds of activities that are recognized as a single component known as post-contract support (AKA maintenance) under existing GAAP.

The concept of post-contract support will soon vanish.  ASC 606 doesn't explicitly define post-contract support as a single performance obligation, so you'll instead need to consider whether these post-contract support activities should be broken up into separate performance obligations.

So long, post-contract support.  What a long, strange trip it's been.

It gets a slightly more convoluted when you consider that each of these components may not even be performance obligations to be recognized as revenue.  A company could determine that bug fixes, for example, is merely an activity to ensure that the software complies with agreed-upon specifications, in which case it may be considered a non-revenue component of a warranty and should be accounted for under Suptopic 460-10 on Guarantees.

Bottom line:  the term post-contract support will soon fall by the wayside much like curglaff, beef-witted, and snout-fair have in centuries past.


#4 - Extended payment terms will no longer prevent revenue recognition; you'll just have to present-value it.

You ever sold software with a 6-month implementation to go-live, at which point payments will become due in equal installments over the next year and a half?

While the concept of extended payment terms wasn't stated under the general existing revenue guidance; the software-specific ASC 985-605, Software: Revenue Recognition explicitly called it out.

And under that existing guidance, you probably would've had to put your auditor in a choke hold to recognize that revenue, as the fees likely wouldn't have been considered fixed or determinable.

Good news for you (better news for your auditor), you can recognize this revenue now.  You just have to consider whether a signfiicant financing component exists to the arrangement.

In general, you should recognize an amount as revenue reflective of what your customer would've paid for in cold, hard cash.  

ASC 606 doesn't explicitly reference whether to include as consideration the brief case that may have carried the cash, so use your best judgment there.


#5 - There are two ways to account for renewal options offered at a discount.

If your company offers discounted renewal options, there's a new framework in place for allocating the transaction price to the renewal option.  If offered at a discount, these will likely be considered material rights to be identified as a separate performance obligation.

If not directly observable, you'll need to estimate what the option would be sold at on a standalone basis, which takes into account the discount the customer will receive upon renewal as well as the liklihood the customer will renew.

But under the new standard, there's another route you could take.

The practical alternative - which you can choose to elect - will allow you to gross up the revenue to be recognized over the expected renewal periods in your initial transaction price.  Essentially, you would assume the option will be exercised, and include the additional incremental goods or services in the original transaction price to be allocated over the contract period (which includes the assumed renewal periods).  Check out Illustration 6-1 on page 82 of E&Y's Revenue From Contracts With Customers for an example of how this works in practice.

The Argon Advisors Presents The Rundown: Gross vs. Net – Clarity on Services, Credit Risk, and Indicators

The IASB and FASB held joint board meetings on December 16, 2015 to discuss comments received by the public on the proposed guidance on Principal versus Agent Considerations (Reporting Revenue Gross versus Net). The Boards largely approved the proposed amendments with few changes. We have included highlights from the meetings in the second edition of the Argon Advisor's Rundown.

Click here to read the full version of the Rundown.

Sam Kerlin

Prior to joining The Argon Advisors, Sam was a partner at KPMG. Sam recently completed a rotation as an audit partner in KPMG’s Department of Professional Practice, the firm’s national technical office in New York City. Sam has served several global and public audit clients in software technology, pharmaceuticals and bio-manufacturing. Previously Sam also served as tax manager in KPMG’s Washington National Tax practice in D.C., specializing in mergers and acquisitions tax accounting. He spent several years abroad in Germany and Russia and is fluent in both languages. Sam’s rotation in KPMG’s Department of Professional Practice included serving primarily on the firm’s Revenue and Debt/Equity topic teams. Sam has also served as the lead partner on several public software and other technology companies in recent years and specializes in technology and healthcare industries. Additionally, Sam serves as a representative observer for KPMG on the AICPA’s Software Task Force. Sam helped implement the adoption of SFAS 123R, Accounting for Share-Based Payments, at several companies within the Southeast. He has served as a consultant for revenue recognition and accounting for income taxes on several advisory engagements and leads firm training in revenue recognition, income taxes, and accounting for business combinations. Sam is a frequent instructor/speaker for clients and national training events on various accounting topics, including FASB/IASB convergence, revenue recognition, and accounting for income taxes. Sam has also co-authored several articles of KPMG thought leadership and helped draft KPMG’s publication on the new revenue standard. He has also taught corporate taxation in the graduate school at Georgia State University Other Activities Member of Finance Society, Technology Association of Georgia Member of Program Committee, GaBio Sam holds a CPA license in the state of Georgia and New York. He graduated from Wake Forest University with a BA in Russian and Masters in Accountancy.

Upcoming FASB Meeting 12/16: Principle versus Agent Considerations (Gross vs Net Recognition) #RevRec

Refer to the FASB upcoming meetings page to register for the video conference. The meeting will be held Wednesday 12/16 at 8:00 AM EST.

The FASB will redeliberate changes proposed in its August 2015 Proposed Accounting Standards Update, Revenue from Contracts with Customers (Topic 606): Principal versus Agent Considerations (Reporting Revenue Gross versus Net), in light of stakeholder feedback received. 

These redeliberations will be conducted jointly with the IASB as it redeliberates the proposed amendments to principal versus agent considerations in its Exposure Draft, Clarifications to IFRS 15.

Free Webinar - Wednesday 12/16, 1-3 PM Eastern: New ASUs and Transition Resource Group Meetings

On Wednesday, December 16 from 1-3 PM Eastern, EITF member Tony Sondhi will present a TRG update. The webinar is eligible for 2 free CPEs.

From his website:

"Please join us on Wednesday, December 16, 2015 from 1:00 to 3:00 PM (EST), when EITF Member Tony Sondhi, (author, instructor and one of the preeminent experts in the fields of revenue recognition and financial reporting risks), presents the tenth in a series of webcasts on the deliberations of the TRG on the significant challenges preparers and users face as they evaluate ASU 2014-09 and the related proposed amendments (ASUs) for their impact on financial reporting requirements and prepare to implement the new requirements. The second half of this webcast will address some of the other significant changes in reporting pronounced by standard setters. You will learn about the following critical issues (among others) in this webcast:

Major changes to reporting revenue and other topics,
Implementation and interpretation issues discussed by the TRG, and
Changes proposed and other standards by the Boards."

Free webinar this Thursday, 12 PM Eastern: Revenue Recognition Update for the Technology Industry #RevRec

Mayer Hoffman McCann PC will offer a free webinar this Thursday, December 10, at 12 PM Eastern (eligible for 1 CPE credit).

According to their website, the webinar will:

  • Provide an overview of the new standards and how they will affect the technology industry
  • Provide an update on the most recent changes and implementation considerations for the new standards for revenue recognition
  • Identify areas of the standard that will present new challenges to the auditor
  • Present guidance for best practices entities can consider in preparing for transition
  • Discuss how changes will affect key performance measures going forward

GAAP Dynamics: STEP 3: DIFFERENCES IN ASC 605 / SAB 104 AND ASC 606 #RevRec

GAAP Dynamics posted part 3 in their Step-by-Step series.  The post illustrates the 3rd step, Determine the Transaction Price, of the 5 Step model prescribed by the new revenue guidance (ASC 606).  The post focuses on a hypothetical example in which a performance bonus is included in a contract, highlighting how revenue previously deferred under the existing guidance can be pulled forward under the new standard.

Reminder: Part II of EY's 3-Part Revenue Recognition Live Webcast Airs 12.2.15 #RevRec

Click here to register for Session 2 of EY's three-part webcast series*, The new revenue recognition standard: a closer look, airing 2:00 PM EST on 12/2/15This webcast series includes a detailed discussion and a variety of examples for each step of the new revenue recognition model.  You will receive 1.5 hours of CPE for attending.

The following requirements of the new revenue recognition model will be discussed:

  • Determining the Transaction Price (Step 3)
  • Allocating the Transaction Price to the Performance Obligations in the Contract (Step 4)

Reminder: PwC webcast on implementation for Entertainment & Media industry TOMORROW at 12 PM Eastern #RevRec

PwC will be hosting a 1 hour webcast on implementation of the new revenue standard for the Entertainment & Media industry.  The webcast will air at 12 PM Eastern and will be hosted by Stefanie Kane, Assurance Leader of Entertainment, Media, and Communications group.

Register for the free webcast here.