ASC 606 (revenue recognition) transition: The role of internal control over financial reporting (ICFR) and auditor expectations
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FASB delays revenue recognition and lease standard effective dates for certain entities

On June 3, 2020, the Financial Accounting Standards Board (FASB) issued Accounting Standards Update (ASU) No. 2020-05, Revenue from Contracts with Customers (Topic 606) and Leases (Topic 842), Effective Dates for Certain Entities which delays the effective dates of ASU No. 2014-09, Revenue from Contracts with Customers (Topic 606) and ASU No. 2016-02, Leases (Topic 842) for certain entities. The ASU changes the effective dates of Topics 606 and 842 as follows:

Revenue from Contracts with Customers (Topic 606)

For all entities that have not yet adopted Topic 606 (i.e., were not already required to adopt Topic 606 and have not yet issued, or made available for issuance, financial statements reflecting the adoption of Topic 606), the amended effective date is for annual reporting periods beginning after Dec. 15, 2019 (i.e., Jan. 1, 2020, for calendar year-ends). Early adoption will continue to be permitted.

Leases (Topic 842)

For private companies and private not-for-profit entities, the amended effective date is for fiscal years beginning after Dec. 15, 2021 (i.e., Jan. 1, 2022, for calendar year-ends). For not-for-profit entities that have issued or are conduit bond obligors for securities that are traded, listed or quoted on an exchange or an over-the-counter market, and which have not yet issued or made available for issuance financial statements reflecting the adoption of Topic 842, the amended effective date is for fiscal years beginning after Dec. 15, 2019 (i.e., Jan. 1, 2020, for calendar year-ends). Early adoption will continue to be permitted.

David A. Johnson
Partner, CPA
tax reform resource center
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