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FASB to issue final ASU on software cost accounting

Defining Issues | May 2025

FASB completes redeliberations on software cost accounting changes and directs staff to draft final ASU.

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The Board directed staff to finalize targeted improvements to modernize the internal-use software accounting guidance in ASC 350-40. The improvements are intended to better align the guidance (1) for development of software to be sold via SaaS or license and (2) with agile software development by eliminating software project stage guidance and introducing new capitalization considerations.

Applicability

  • All entities that incur internal-use software costs, including website development costs

Relevant dates

  • issued October 29, 2024
  • Comments due January 27, 2025
  • of proposed ASU on May 7, 2025
  • FASB staff indicates final ASU may be expected late Q3 2025

At its May 7th聽meeting, the Board decided on the following effective dates:

Effective datesAll entities
Annual periods 鈥� Fiscal years beginning afterDecember 15, 2027
Interim periods 鈥� In fiscal years beginning afterDecember 15, 2027
Early adoption allowed?

Yes, in any interim or annual period for which an entity鈥檚 financial statements have not been issued (or made available for issuance) as of the beginning of the entity鈥檚 fiscal year.

Key decisions

On May 7th, the Board discussed stakeholder feedback on its proposed ASU and reached the following decisions that will be reflected in the final ASU:

Software cost capitalization

  • The internal-use software development cost capitalization threshold will change by eliminating accounting consideration of software development stages; cost capitalization will begin solely when management has committed to funding the software project and it is 鈥榩robable鈥� the project will be completed and the software used to perform its intended function (the 鈥榩robable-to-complete鈥� threshold).
  • The final ASU will explicitly link 鈥榩robable鈥� in the probable-to-complete threshold to the ASC Master Glossary definition.
  • As part of the probable-to-complete assessment, entities will assess whether software projects are subject to significant development uncertainty. If so, completion is not probable until such uncertainty is resolved.
  • Significant development uncertainty will exist when either the software or its core features/functions are novel, unique or unproven, or the significant performance requirements of the software (i.e. what the software is needed to do 鈥� e.g. its functions or features) remain unidentified or subject to substantial further revision.
  • Significant development uncertainty stemming from novel, unique or unproven features/functions must be resolved through coding and testing that establishes the software can meet its performance requirements, similar to how 鈥榟igh-risk development issues鈥� are resolved for external-use software under ASC 985-20.
  • Board members emphasized that judgment is expected in applying the updated cost capitalization guidance.

Presentation and disclosure requirements

  • Disclosures will now be required under ASC 360-10 for all software costs capitalized under ASC 350-40, regardless of how they are presented in the balance sheet (e.g. as intangible assets or PP&E).聽
  • The final ASU will not include the proposed ASU requirement to separately present cash paid for capitalized internal-use software costs.

Website development costs

ASC 350-50 on website development costs will be eliminated with relevant guidance therefrom, including that on graphics and content, and a new illustrative example codified into ASC 350-40.聽

Transition

The final ASU will be applied:

  • retrospectively;
  • prospectively only to software costs incurred on new and existing software projects after the adoption date; or
  • prospectively to software costs incurred on new and existing software projects after the adoption date with a cumulative effect adjustment for existing, in-process project capitalized costs.

Transition disclosures will be required under ASC 250 based on the transition method selected.聽

Final ASU will not change...

  • the existing accounting requirements for external-use software (i.e. software to be sold or licensed);
  • what internal-use software costs can be capitalized (e.g. data conversion/migration, training and software maintenance costs will continue to be expensed as incurred); or
  • when internal-use software cost capitalization ceases (i.e. when the software is 鈥榮ubstantially complete and ready for its intended use鈥�).

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Proposed ASU 鈥� DI

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Comment letter

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