Ey ttp21805 231us 12 21 2023
Ey ttp21805 231us 12 21 2023
Ey ttp21805 231us 12 21 2023
2023-15
Updated 21 December 2023
To the Point
FASB — final guidance
Overview
The Financial Accounting Standards Board (FASB or Board) amended 1 the guidance in
Accounting Standards Codification (ASC) 280, Segment Reporting, to require a public entity
to disclose significant segment expenses and other segment items on an annual and interim
basis and to provide in interim periods all disclosures about a reportable segment’s profit or loss
and assets that are currently required annually. Public entities with a single reportable segment
are required to provide the new disclosures and all the disclosures required under ASC 280.
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The FASB issued the Accounting Standards Update (ASU) in response to requests from
investors for companies to disclose more information about their financial performance at the
segment level. The ASU does not change how a public entity identifies its operating segments,
aggregates them or applies the quantitative thresholds to determine its reportable segments.
Key considerations
Significant expense principle
The guidance requires a public entity to disclose for each reportable segment, on an interim and
annual basis, the significant expense categories and amounts that are regularly provided to
the chief operating decision-maker (CODM) and included in each reported measure of a
segment’s profit or loss. 2 Additionally, it requires a public entity to disclose the title and
position of the individual or the name of the group or committee identified as the CODM.
The significant expense principle is consistent with the management approach public entities
already apply for segment reporting. That is, entities are required to disclose information
about significant segment expenses based on information that is regularly provided to the
CODM, rather than prescribed expense categories.
Regularly provided
Under the principle, an entity first identifies the expenses from the segment information regularly
provided to the CODM and included in each reported measure of a segment’s profit or loss. While
the ASU does not define “regularly provided,” ASC 280 uses the term to refer to the frequency
with which the CODM receives segment information when determining whether certain segment
items and amounts would be disclosed under existing disclosure requirements. The Board
acknowledged in the ASU’s Background Information and Basis for Conclusions that since the
term is undefined, entities will need to continue to exercise judgment when applying the term.
Easily computable
The Board decided that the significant expense principle should apply to segment expenses that
are easily computable based on information regularly provided to the CODM. Such information
may include segment expenses expressed in a form other than a caption and actual amounts
(e.g., advertising expense as a percentage of revenue) or segment expenses computed based on
other information provided to the CODM (e.g., cost of sales can be computed when segment revenue
and gross margin information are provided to the CODM), as noted in the Basis for Conclusions.
The guidance provides examples, which are not meant to be all-inclusive or limit the types of
segment expenses that may need to be disclosed. Entities need to apply judgment to determine
what is easily computed and apply those concepts consistently to identify the segment expense
categories provided to the CODM.
Significance
Once the public entity identifies segment expenses from the information regularly provided
to the CODM, it evaluates their significance to determine which to disclose by considering
quantitative and qualitative factors. The Board said in the Basis for Conclusions that a segment
expense is significant if its omission from an entity’s segment disclosures “would change a
user’s understanding about a segment to such a degree that it would change the user’s capital
allocation decisions about an entity as a whole.” This means that a segment expense could be
significant and is required to be disclosed as a significant segment expense even if another item
of a similar magnitude may not be considered significant to the consolidated financial statements.
How we see it
While the guidance leverages the existing ASC 280 management approach, judgment is
still required to apply the significant expense principle and interpret the terms “regularly
provided,” “easily computed” and “significant.”
2 | To the Point FASB requires public entities to disclose significant segment expenses and other segment items Updated 21 December 2023
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The Board acknowledged in the Basis for Conclusions that the extent of the additional
information that entities disclose will vary depending on the level of segment expense
information that is regularly provided to the CODM. As a result, an entity could disclose
different expense categories for each of its reportable segments, and those categories may
differ from what other public entities disclose.
If an entity determines that no significant expense categories are required to be disclosed for
one or more of its reportable segments, the entity is then required to disclose the nature of the
expense information the CODM uses to manage operations (e.g., whether the CODM uses
budgeted or forecasted expense information or consolidated expense information).
An entity is required to disclose for each reportable segment, on an annual and interim basis,
an amount for other segment items representing the difference between reported segment
revenues, less the disclosed significant segment expenses, and reported segment profit or
loss. Entities also have to provide a description of the composition, including the nature and
type of the other segment items. The disclosure of other segment items is required even
when the entity does not separately disclose expenses under the significant expense principle.
All public entities, including those that disclose only one measure of a segment’s profit or loss,
are required to explain in the notes to the financial statements how the CODM uses each
reported measure of a segment’s profit or loss in assessing segment performance and
determining how to allocate resources.
The Board clarified that existing segment disclosure and reconciliation requirements under
ASC 280, along with the new disclosure requirements, apply to each reported measure of a
segment’s profit or loss.
An entity that reports more than one measure of a segment’s profit or loss in the current
period is required to report the additional measure(s) for all prior periods presented if the
additional measure(s) were provided to the CODM in those periods. However, the ASU does
not preclude an entity from disclosing the additional measure(s) for the prior periods even if a
CODM was not provided with that measure in a prior comparative period.
3 | To the Point FASB requires public entities to disclose significant segment expenses and other segment items Updated 21 December 2023
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The staff also encouraged registrants that want to early adopt the guidance and provide
additional measures of segment profitability that would be considered non-GAAP financial
measures to consult with the Division of Corporation Finance’s Office of the Chief
Accountant. See our publication on the 2023 AICPA & CIMA Conference on Current SEC
and PCAOB Developments for more information.
Entities are also required to disclose significant changes from prior periods to the measurement
methods of expenses, the method of allocating expenses to a segment or changes in the
method for allocating centrally incurred expenses (e.g., changes in the method used to
allocate pension expense to reportable segments). Entities also are required to disclose the
effect, if any, of those changes on the measure of segment profit or loss.
The ASU also replaces the term “restatement” with the term “recast” throughout ASC 280.
How we see it
Under ASC 280, information is impracticable to present if the necessary information is not
available, and the cost to develop it would be excessive. Similar to how entities consider
whether information is impracticable when evaluating disclosures for a change in the
composition of reportable segments, they need to carefully consider their facts and
circumstances before concluding it is impracticable to recast their disclosures for any changes
in significant segment expenses, since impracticability is a very high standard to meet.
1
ASU 2023-07, Segment Reporting (Topic 280): Improvements to Reportable Segment Disclosures.
2
ASC 280-10-50-26A.
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4 | To the Point FASB requires public entities to disclose significant segment expenses and other segment items Updated 21 December 2023