Industry views

Telecommunications Industry Accounting Group

Making sense of a complex world*

IFRIC 13 – Customer loyalty programmes

*connectedthinking pwc
Introduction

The issuance by the International Financial

Reporting Interpretations Committee (IFRIC)
of IFRIC 13, Customer Loyalty Programmes,
has implications for telecom operators. This
publication considers the accounting and
the practical implications that arise from the
guidance in IFRIC 13.
Telecom companies operate in a highly competitive
environment. For many operators, the focus has
moved from acquiring new customers to maintaining
market share and encouraging the customer base to
increase usage. One manifestation of this change in emphasis is the proliferation
of customer incentive and customer loyalty programmes.
The accounting practice for customer loyalty arrangements in the telecoms sector
has been varied. IFRIC 13 was issued to bring consistency and comparability to
accounting for loyalty programmes across industry sectors. While understanding
the technical provisions of the interpretation is important, it is only half the battle.
As operators prepare to apply IFRIC 13 in upcoming interim and annual financial
statements, the practical implications in terms of data gathering and changes to
systems and processes are becoming apparent.
We trust that you will find this publication useful as you look to apply IFRIC 13 for
the first time.

Paul Barkus
Chairman
PwC Telecom Industry Accounting Group

Making Sense of a Complex World 1

Why was IFRIC 13 issued?
Customer loyalty programmes are widespread. Telecom operators, retailers,
airlines, hotels and similar businesses offer many incentives to their customers.
The incentives offered through loyalty programmes often take the form of a
“points” scheme, in which customers earn points for purchasing goods or
services. The customers can redeem the points for free or discounted goods
and services.
This publication explores the accounting for award credits, or points, under
IFRIC 13 Customer Loyalty Programmes (IFRIC 13).

How will IFRIC 13 affect telecom operators?

Most telcos operate in a highly competitive environment and invest significantly
in acquiring and retaining customers. Their incentive arrangements typically
include:
• Free gifts (such as MP3 players or digital cameras) on signing or renewing a
contract for service.

• Arrangements in which customers can earn the right to a discount on

equipment (handsets, modems and other devices) or service on the
condition that they renew their service contract.

• Awards that entitle customers to discounted goods and services from their
telecom service provider.

• More complex arrangements that include points that entitle the holder to
discounted goods or services provided by another company (for example,
the ability to earn air miles).
In our view, there are two key areas of consideration for telecom operators:
1. Which customer incentive arrangements are within the scope of IFRIC 13?

2. If the arrangement is within the scope, how can the fair value of the
incentive be determined?
Before examining these two specific areas, we have summarised, below, the
principal requirements of IFRIC 13.

2 Making Sense of a Complex World

Background
Historically, the accounting for loyalty programmes has been varied, and many
companies have treated the cost of redeeming award credits or points as a
marketing expense.

So, what exactly is a loyalty programme?

According to IFRIC 13, a customer loyalty programme has the following
characteristics:
• Entities use loyalty programmes to incentivise customers to buy additional
goods or services.

• Entities grant credits (in the form of points) to customers with each purchase
of goods or services.

• Customers may redeem the points to receive free or discounted goods or

services in the future.

• The programmes can operate in a variety of ways:

-- Customers must collect a minimum number or value of points before

redeeming them.

-- Customers may earn points on a single purchase or on contract renewal

over a specified period.

-- Either the entity or a third party may run the programme.

As noted above, historically the accounting for loyalty points has been varied.
But IFRIC 13 treats points as something sold in their own right as part of a
multiple element arrangement. Although not part of the interpretation itself, the
IFRIC also clarified that points are distinct from marketing expenses because
they are granted to a customer as part of a sales transaction. Marketing
expenses, in contrast, are incurred independently of the sales transactions they
are designed to secure.
The following table summarises the expected impact of IFRIC 13 on common
current practice.

Current practice IFRIC 13

Income statement Allocation of revenue to Allocation of revenue to

classification separable elements or charge separable elements
to marketing expense

Balance sheet classification Accrual/provision Deferred revenue for amounts

allocated to points

Measurement Various, but generally at Fair value to the customer

related cost to fulfil the
obligation for the company

Point of recognition of Various: at grant or at At redemption

the awards in the income redemption
statement

Making Sense of a Complex World 3

Background (continued)
IFRIC 13 clarifies that loyalty programmes are multiple element arrangements,
in which the consideration received for the sale of goods or services (from
which points are earned) is allocated between:
1. The goods or services delivered; and

2. The points that will be redeemed in the future.

The consideration should be allocated to the goods or services initially
provided and to the points, based on their fair value. Fair value is defined
as the amount that the points could be sold for on a stand-alone basis. The
consideration allocated to the points should be presented as deferred revenue
on the balance sheet and should be released to the income statement when
the points are redeemed or expire.
The following simple example illustrates the basic principles of IFRIC 13.

Example 1
An operator launches a loyalty programme under which it grants points to
customers in exchange for purchasing airtime. The points may be redeemed for
a discount on the price of a handset upon renewing a contract. Customers who
earn 100 points will be entitled to a discount of €50 off the handset.
A customer uses services throughout the initial 12-month contract term, paying
€20 per month for airtime (a total of €240 over the contract term) and earning
100 points. The operator has assessed that the customer will redeem the
points.
Throughout the year, the operator should record a total of €50 as deferred
revenue, thus recognising €190 (€240 - €50) as airtime revenue. The €50 of
deferred revenue represents the fair value of the points to the customer.
When the customer redeems the points, the €50 of deferred revenue will be
released and recognised as revenue. Hence, overall the total revenue always
will be €240 (€190 + €50). However, because the customer has been granted
points that s/he is expected to redeem, some of the total revenue (€50) is
allocated to the points (based on fair value) and is deferred until the points are
redeemed or expire.
Note: The basis of determining fair value has not been considered in this
example (see example 2 for further discussion).

4 Making Sense of a Complex World

Understanding the scope of IFRIC 13
A customer incentive arrangement is included within the scope of IFRIC 13 if
both of the following conditions are met:
• The entity grants points to its customers as part of a sales transaction -
that is a sale of goods or a rendering of services; and

• Subject to meeting any further qualifying conditions, the customers can

redeem the points in the future for free or discounted goods or services.
It follows that IFRIC 13 does not apply where there is no link to a sales
transaction. An example is a voucher for a price reduction on a handset
included in a newspaper promotion.
Many markets are characterised by operators giving incentives and discounts
at the outset of a relationship with a customer. Examples include free gifts,
for example DVD or MP3 players and, in some markets, domestic appliances.
We do not believe that these types of arrangements fall within the scope of
IFRIC 13. The customer is given the gift at the outset, and there are no further
qualifying conditions or points granted that the customer could redeem in the
future. We have considered the accounting for free gifts and handsets in our
publication Accounting for handsets and subscriber acquisition costs1.
In more mature markets, it is increasingly popular for operators to give
customers the right to a free or discounted handset on the renewal of their
service contract. These rights are granted to customers when they sign their
first service contract.
Earlier we considered the example of customers earning points that they could
redeem against a handset on renewal of their contract. It is common that, by
the time customers are ready to renew their contract, the options available
to new customers are at least as advantageous, if not better, and existing
customers will be able to participate in the new customer schemes. While
these arrangements are within the scope of IFRIC 13, careful consideration
needs to be given to questions of the value of the discount or the incentive to
customers as well as the likelihood that customers will redeem the points.

1 Making Sense of a Complex World: Accounting for Handsets and Subscriber Acquisition Costs. Pricewater-
houseCoopers, August 2008

Making Sense of a Complex World 5

What is fair value?
Consideration received or receivable from customers is allocated to the various
elements of the arrangement using fair values. This might be estimated using
just the fair value of the points or the relative fair values of the points and the
goods or services sold. IFRIC 13 allows management’s judgement and does
not mandate a specific approach for estimating a point’s fair value.
The guidance also recognises that there may not be an observable market for
the incentive and hence an estimate will be required. The fair value of a point is
expected to be based on:
• The discount that the customer will receive, that is,
“the amount the customer will save”; and
• The expected redemption rate of the points.
The application of the guidance is considered in the example below.

Example 2
Year 1
• An operator launches a loyalty programme in which points are granted for
using services or buying equipment.
• The points entitle the holder to a discount on the retail price of a handset or
an airtime credit. For example, a customer who has accumulated 100 points
may purchase for the reduced price of €50 a mobile phone that retails for
€150 (that is, one point has a face value of €1).
• The operator expects half of the points granted to be redeemed (that is, a
redemption rate of 50%).
• At the end of the first period after launching the programme:
-- Customers have accumulated a total of 200,000 points.
-- The total consideration from customers amounts to €1,000,000.
Initial allocation of revenue
• The total consideration should be allocated to both elements of the
arrangement, that is, the initial sales transaction and the points earned by
the customers. The allocation should be based on fair value.
Accounting at end of initial period
• As noted above, the face value of each point is €1. That is the amount a
customer will save through redeeming each point. Dr € Cr €

• The fair value of the points is calculated as follows: Cash 1,000,000 Service 900.000
200,000 points x €1 (face value) x 50% (redemption rate) = €100,000. revenue
Therefore, the fair value of the points accumulated by customers in year 1 is
€100,000. That amount should be recorded as deferred revenue. Deferred 100,000
revenue
• The remaining consideration of €900,000 (€1,000,000 - €100,000) should
be recorded as service revenue in accordance with the operator’s normal Total 1,000,000 1,000,000
accounting policies.

6 Making Sense of a Complex World

What is fair value? (continued)

Year 2
• The operator continues the scheme in year two. A further 160,000 points
are granted.

• Consideration received from customers amounts to €800,000.

• The scheme remains the same, that is, the face value of a point is still €1. Accounting for new points at the
end of year 2
• Of the points granted in year 1, 120,000 are redeemed during the year,
and the operator changed its views about redemption rates, assuming that Dr € Cr €

75% of the points will be redeemed.

Year 2 points

Subsequent accounting (year 2)

Cash 800,000 Service 680.000
Accounting for the new points issued in year 2 revenue

• The face value of the points continues to be €1. Deferred 120,000

revenue
• The fair value of the points awarded in year 2 is €120,000 calculated as
follows: 160,000 points x €1 (face value) x 75% (redemption rate). Total 800,000 800,000

• Hence, revenue of €120,000 should be deferred at the end of year 2 in

respect of the new points granted, and service revenue of €680,000 should
be recorded in the year (€800,000 - €120,000).
Accounting for year 1 points
Accounting for year 1 points still outstanding outstanding at the end of year 2

• The operator has reassessed the redemption rate from 50% to 75%. This Dr € Cr €
means that the operator expects 150,000 of the points issued in year 1 to
be redeemed (200,000 points issued in year 1 x 75%). Year 1 points

• By the end of year 2, 120,000 of the points have been redeemed. Revenue Balance 100,000
should be recognised in respect of the year 1 points redeemed in b/fwd
proportion to the expected levels of redemption, as shown below:
Deferred 80,000 Service 80.000
-- Proportion of points redeemed: 120,000/150,000 = 80% revenue revenue

-- Revenue deferred in year 1: €100,000 Balance 20,000

c/fwd
-- Revenue to be recognised in year 2: €80,000 (€100,000 x 80%)

Making Sense of a Complex World 7

What is fair value? (continued)
Fair value is the amount the customer will save by redeeming the points. The face
value of a point is not necessarily its fair value. It is also necessary to take into
account the redemption rate assumed in respect of the points.
While the redemption rate should be revisited each balance sheet date, as
illustrated in Example 2, the amount of revenue deferred in respect of the points
is not remeasured. The rate of recognition of the deferred revenue is adjusted for
any changes in redemption rates.

Principal or agent?
IFRIC 13 requires an entity issuing points to determine whether it is collecting
revenue on its own account (as principal in the transaction) or on behalf of a third
party (as an agent). When the entity is collecting revenue on behalf of a third party,
it earns commission income:
• Commission income is the net amount - the difference between the
consideration allocated to the points and the amount payable to the third party
supplying the points.
• Commission income should be deferred until the third party is obliged to
supply the awards and is entitled to receive consideration for doing so.
When the issuing entity is acting as principal and is collecting consideration on
its own behalf, then revenue should be measured as the gross consideration. An
element of the revenue, however, clearly will need to be deferred until the points
are redeemed or expire.

Example 3
An operator has a loyalty programme arrangement with an airline company called
Miles & More. For every €1 that is billed to a customer for mobile services, the
customer is awarded one mile.
The awarded miles can be redeemed for air tickets under the airline’s scheme.
The benefits to the operator are that:
• There is no need to administer the scheme.
• The operator does not have an obligation in respect of outstanding points.
The face value of each point is €0.10, and for each point issued, the operator will
pay €0.09 to the airline. In doing so, the operator will earn €0.01 of commission
income. Once the operator has made payment to the airline, it has no further
obligation to the customer.
The accounting for this arrangement would be as follows:
When the operator makes a sale of €10, it issues points with the face value of €1:
Dr Cash €10.00
Cr Revenue €9.00
Cr Commission income €0.10
Cr Liability to airline €0.90
The operator will need to consider whether the commission income should be
recorded as revenue or as other operating income.

8 Making Sense of a Complex World

Revenue or other income?
The points might be redeemed against goods or services not supplied in the
normal course of business. There are two aspects to consider:
1. Typically a company would not buy or trade goods that are not used in its
ordinary course of business, so a third party is likely to be involved. Hence,
it will be necessary to determine whether the operator is acting as agent or
as principal.

2. When no third party is involved, the guidance in IAS 18 should be applied

to determine whether the income statement credit is to revenue or to
other income. The standard defines revenue in the context of “the ordinary
activities of the entity”. Determining the ordinary activities, and therefore
distinguishing revenue from other income, is not always clear. Indeed, an
item could be revenue for one operator but other income for another in
the same market. The facts and circumstances of the business and the
transaction should be considered on a case-by-case basis.

What data does the company need to collect?

Operators that issue points will need to collect sufficient information to enable
them to estimate the individual fair value of the points, expected level of
redemptions, actual redemptions and cancellations/lapses.
The following list illustrates how individual fair value should be determined.

Type of incentive Indicative individual fair values

Money-off coupon or voucher attached to a Cash value of coupon or voucher

product

Points earned as goods or services are Based on the value of the goods or services
purchased the points can buy or on the price at which
they can be sold

Points earned from the operator that can be Based on the value of the goods or services
used in other stores the points can buy

Historical information often will provide the best evidence to support an

estimate of the redemption rate. However, the assumptions used in highly
complex arrangements may need to be discussed with a valuation specialist.

Making Sense of a Complex World 9

What happens when an incentive could result in a loss on
future sales?
As noted previously, free gifts are not within the scope of IFRIC 13. However, the
unlikely situation could occur that a point (within the scope of IFRIC 13) is issued that
results in a loss on the sale of the later item. The point arrangement then would be
accounted for as an onerous contract, and provision would be made in accordance
with IAS 37 Provisions, Contingent Assets and Contingent Liabilities.
Discount vouchers issued separately from a sales transaction (and therefore outside
IFRIC 13’s scope) are deducted from revenue when a sale is made and the discount
voucher is redeemed. There are no accounting entries in advance of the sales
transaction, unless redemption of the vouchers will result in products (or services)
being sold at a loss. In these circumstances, the seller has created an onerous
contract, and provision should be made in accordance with IAS 37.

The date for applying IFRIC 13

The interpretation is to be applied to financial periods beginning on or after
1 July 2008. Consequently, calendar year reporters will be required to adopt the
interpretation in financial statements for the year ending 31 December 2009.
Operators should remember that interim financial statements and the comparatives
should reflect IFRIC 13. There are no special transitional provisions, so any change
in accounting policy should be accounted for in accordance with IAS 8 Accounting
Policies, Changes in Accounting Estimates and Errors. Hence, operators will need to
consider the position at both the beginning and the end of the comparative period.

Brief comparison to US GAAP

The US Financial Accounting Standards Board’s Emerging Issues Task Force (EITF)
was unsuccessful in developing a model to account for these point and loyalty
programmes in its deliberations of EITF 00-22 Accounting for “Points” and Certain
Other Time-Based or Volume-Based Sales Incentive Offers, and Offers for Free
Products or Services to Be Delivered in the Future.
Of the five issues discussed by the task force, Issue 3 (how a vendor should account
for an offer to a customer to rebate or refund a specified amount of cash that is
redeemable only if the customer completes a specified cumulative level of revenue
transactions or remains a customer for a specified period of time) was the only issue
on which a consensus was reached. It was later codified in EITF 01-9 Accounting for
Consideration Given by a Vendor to a Customer (Including a Reseller of the Vendor’s
Products).
Due to the lack of consensus in EITF 00-22, there remains a divergence in practice
in the US for the accounting for loyalty programmes. It is acceptable for operators to
account for loyalty programmes as multiple element arrangements using an analogy
to EITF 00-21 Revenue Arrangements with Multiple Deliverables, or to IFRIC 13. In
certain circumstances, when the costs of fulfilling the points are inconsequential or
perfunctory, the incremental cost model may be appropriate under US GAAP. But
using this approach will not be acceptable under IFRS once IFRIC 13 is adopted.
Operators should use the appropriate US GAAP literature (for example, EITF 01-9)
for other types of incentive programmes.

10 Making Sense of a Complex World

Telecommunications Industry Accounting
Group (TIAG)

PricewaterhouseCoopers’ Telecommunications Industry Accounting Group (TIAG)

brings together PwC telecom specialist knowledge worldwide to help our clients.
Our role is to help operators interpret and implement new and complex standards
that have a particular impact on our industry.
Our TIAG Portal provides FREE online access to a wealth of industry-
specific guidance and best practices on the application of GAAP within the
Communications sector.
Updated regularly by PwC’s telecoms experts, the site provides:
• Industry-specific accounting solutions.

• Hot topics from our telecom technical specialists.

• Relevant technical publications.

• Industry thought leadership.

• Industry news.

• Links to relevant PwC sites.

• Opportunities to consult the experts through our discussion forum.

To find out more, please contact Nirmal Shah at nirmal.k.shah@uk.pwc.com or
+44 (0) 20 7213 1436.

11
Related PwC publications

IFRS 8 Operating segments Accounting for Handsets and Revenue Recognition in

Subscriber Acquisition Costs Contracts with Customers

Industry views
Telecommunications Industry Accounting Group

Making sense of a complex world*

IFRS 8 Operating Segments

*connectedthinking  

Communications Review: Communications Review: Communications Direct

Weathering the Storm Cultivating Growth www.communicationsdirectnews.com

12 Making Sense of a Complex World

Contacts

PricewaterhouseCoopers has dedicated IFRS specialism in most territories. Should you wish to talk
to a specialist in your country, please contact a member of the team who will be able to put you in
touch with the most relevant person.

Americas EMEA Asia Pacific

John Horan Paul Barkus Laura Butler
San Jose London Beijing
john.horan@us.pwc.com paul.barkus@uk.pwc.com laura.butler@cn.pwc.com
+1 408 817 3809 +44 20 7213 5514 +86 10 6533 2363

Pierre-Alain Sur Fiona Dolan Matthieu Moussy

Little Rock London Tokyo
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+1 501 907 8085 +44 20 7213 4885 +81 80 3520 5216

Richard Veysey Katharine Finn Sean Tuckfield

New York London Hong Kong
richard.veysey@us.pwc.com katharine.finn@uk.pwc.com sean.tuckfield@hk.pwc.com
+1 646 471 7973 +44 20 7213 4105 +852 2289 2368

Peter Hogarth
London
peter.hogarth@uk.pwc.com
+44 20 7213 1654

Fernand Izeboud
Amsterdam
fernand.izeboud@nl.pwc.com
+31 20 568 4226

Rich Sharko
Moscow
rich.sharko@ru.pwc.com
+7 495 9676054

Thomas Tandetzki
Düsseldorf
thomas.tandetzki@de.pwc.com
+49 211 981 1105
www.pwc.com
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