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Navigating the Upcoming FRS 102 Revenue Recognition Changes

In our previous article, What You Need to Know About the Major FRS 102 Changes, we introduced the upcoming amendments to FRS 102, which take effect from 1 January 2026, bringing significant changes across multiple areas of financial reporting.
Lease 102
15 July 2025

 

Our previous articles in the series, What You Need to Know About the Major FRS 102 Changes and Is Your Business Ready for the New FRS 102 Lease Accounting Changes? introduced the upcoming amendments to FRS 102, which take effect from 1 January 2026 and elaborated further on the impact these amendments will have on lease accounting. 

Another area to be significantly impacted by the upcoming changes is revenue recognition and how to account for contracts held with your customers.

These changes represent one of the most significant updates to FRS 102 in recent years and Hall Morrice is ready to support businesses through every step of the transition. Whether you are a growing SME or a larger organisation, our experienced team can guide you through impact assessments, system changes and strategic planning. These changes matter to finance teams, business owners, lenders and investors, with potential effects on borrowing, financial reporting and tax. Early preparation with expert advice can help you avoid misstatements and stay ahead of compliance risks.

What’s Changing with Revenue Recognition under FRS 102?

As part of the latest amendments to FRS 102, a new revenue recognition model is being introduced that aligns more closely with IFRS 15. The revised model brings greater consistency and comparability in financial reporting by applying a principles-based approach to all contracts with customers, regardless of the nature of the goods or services involved.
In simple terms, this means your business will need to match revenue with performance – recognising it only when specific obligations to the customer are fulfilled.

At the core of the revised standard is a five-step model for recognising revenue:

  1. Identify the contract(s) with a customer.
  2. Identify the performance obligations in the contract.
  3. Determine the transaction price.
  4. Allocate the transaction price to the performance obligations.
  5. Recognise revenue when (or as) the entity satisfies a performance obligation.

While conceptually straightforward, the practical implementation of this model presents a number of challenges for entities, particularly those with complex or bundled offerings, or contracts that include variable pricing.
Hall Morrice can help you assess how each of these steps applies to your contracts and reporting processes, helping you minimise disruption and reporting risk.

Key Practical Impacts of the Five-Step Model

1. Identifying Performance Obligations: More Judgement Required

One of the more significant changes is the requirement to break down a contract into distinct performance obligations. These are components that the customer can benefit from either on their own or together with other readily available resources.

Under the previous version of FRS 102, these elements were often accounted for as a single deliverable. The new model requires entities to identify and assess the separability of individual goods or services, which may not have been separately accounted for in the past.

In practice, this can be difficult, especially where goods or services are bundled into a single offering (e.g. software with installation, ongoing support, or warranties). Businesses will need to assess:

  • Whether each element is distinct or part of a combined performance.
  • If there are implicit promises, such as ongoing customer support, that need to be accounted for separately.
  • How to treat modifications to existing contracts, which may give rise to new performance obligations or alter the pattern of revenue recognition.

Our team supports clients by reviewing sample contracts and helping to identify and document performance obligations.  

2. Allocating the Transaction Price: Complexity with Bundled Sales

Under the new model, the total transaction price must be allocated to each identified performance obligation based on their relative standalone selling prices. This can be particularly challenging when:

  • There is no directly observable selling price for one or more components.
  • Discounts or incentives are applied across a bundle.
  • The selling price of one item is highly variable or uncertain.

This may require the use of estimation techniques, such as the adjusted market assessment or expected cost-plus margin approach, and a greater degree of professional judgement and documentation.

3. Recognising Revenue Over Time: Assessing Control and Progress

Entities must determine whether revenue should be recognised at a point in time or over time. For many service-based businesses or long-term contracts, such as construction or maintenance, this assessment will be critical.

Revenue can be recognised over time if:

  • The customer simultaneously receives and consumes the benefits as the entity performs.
  • The entity’s performance creates or enhances an asset that the customer controls.
  • The asset created has no alternative use to the entity and the entity has an enforceable right to payment.

If one of these conditions is met, the entity must choose a method of measuring progress, either output-based (such as milestones) or input-based (such as costs incurred). Each approach has strengths and limitations, and care must be taken to ensure it reflects the substance of the arrangement.
This will be a significant change for many businesses, and selecting the right measurement approach will be crucial. Our team can help you evaluate your current practices and align them with the new standard, so you're ready well before the deadline.

4. Variable Pricing: Estimation and Constraint

Contracts that include variable consideration, such as volume discounts, performance bonuses, or penalties require further consideration. Entities must estimate the amount of variable consideration to include in the transaction price, but only to the extent that it is highly probable that the entity will be entitled to this consideration. 

This introduces subjectivity and the need for careful estimation and ongoing reassessment as circumstances change. It also affects the timing of revenue recognition and may lead to the recognition of contract assets or liabilities that were not previously captured under the old FRS 102 rules.

Balance Sheet and Disclosure Implications

The revised model may impact the timing of revenue recognition, which in turn affects key balance sheet figures such as:

  • Contract assets recognised when revenue is earned but not yet invoiced.
  • Contract liabilities recognised when payment is received before performance is complete.

Additionally, the new disclosure requirements under FRS 102 place a greater emphasis on transparency. Entities are required to explain:

  • The methods used to recognise revenue.
  • Significant judgements made in applying the five-step model.
  • Year-end balances relating to customer contracts.
  • Information about unsatisfied or partially satisfied performance obligations.

What Should Businesses Be Doing Now?

The changes to FRS 102 will require many businesses to re-evaluate their existing contracts, pricing models, and revenue recognition policies. Key steps include:

  • Reviewing and documenting performance obligations within standard and bespoke contracts
  • Establishing or refining methodologies for estimating standalone selling prices and variable consideration
  • Ensuring systems are in place to track progress on long-term contracts
  • Training staff on the new recognition and disclosure requirements

These steps can take time to implement, so it's important to start early, especially if your business deals with complex, multi-element contracts.

How Can Hall Morrice Assist You?

The upcoming changes to FRS 102 will have a significant impact on lease accounting and revenue recognition. While businesses have until 1 January 2026 to prepare before the changes, it’s essential to start planning now to understand the effects on financial statements, KPIs, and disclosures.

Hall Morrice has been closely monitoring developments in this area and is available to assist with your transition process. We’ll work alongside your team to make the changes manageable, reduce disruption, and help you maintain confidence in your reporting.

Whether you need guidance on how to approach the transition independently or are looking for comprehensive support throughout the process, please reach out to Paul Archibald (p.archibald@hall-morrice.co.uk) for expert advice and tailored assistance.

 

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