Changes to UK GAAP – Revenue recognition

The changes to UK GAAP arising from the periodic review introduce a new single comprehensive model for all types of revenue. We explain the impact on businesses and how to best prepare.
The UK GAAP changes focus on the transfer of control, rather than solely on the transfer of risks and rewards. The new model is a more detailed and prescriptive approach to accounting for revenue and may impact the timing and amount of revenue recognised by entities.
The amendments are applicable for all FRS 102 reporters, including those reporting under FRS 102 Section 1A Small entities. The amendments to revenue accounting are also applicable for all FRS 105 reporters.
Entities may apply the amendments using a fully retrospective approach (i.e. restating comparatives) or using a modified retrospective approach (i.e. using a cumulative ‘catch-up’ adjustment in retained earnings).
The five step approach
For periods beginning on or after 1 January 2026, revenue is required to be recognised using a five-step approach, similar to that used in IFRS 15 Revenue from Contracts with customers.
The five steps are:
- Identify the contract(s) with a customer
- Identify the performance obligation(s) in the contract
- Determine the transaction price
- Allocate the transaction price to the performance obligations in the contract
- Recognise revenue when (or as) the entity satisfies a performance obligation
All entities subject to the Periodic Review will need to undertake an assessment to understand the impact of the changes. Where entities are subject to audit, they will be required to evidence how they have complied with the new model for audit purposes.
How will I be impacted by the changes to accounting for revenue?
The impact of the changes will vary depending upon the nature and terms of your customer contracts. For example, the amount of revenue recognised might change where entities regularly sell bundles of goods and services or where there are discounts, incentives or customer options.
The changes may also impact the timing of revenue recognition. This is likely to have practical implications, such as impacting key performance metrics, taxation, loan covenants and any performance-linked remuneration. The greatest impact is expected to be seen for those entities with customer contracts that are complex, longer term in nature and span the reporting period end.
Industries that are expected to see significant change are:
- Real estate and construction
- Manufacturing and engineering
- Software
- Telecoms
- Technology and media
- Professional services
How can I prepare for the changes?
Practical considerations to start thinking about include:
- Do customer contracts require revision? The wording of contracts can have significant implications on revenue recognition. There is still time to change your commercial terms, for example where the changes result in deferral of revenue.
- Are changes needed to IT systems and data collection in order to track revenue and to satisfy new disclosure requirements?
- Where the amount and timing of revenue is impacted, how do performance KPIs change?
- Is there a change to profit or EBITDA, profit shares, bonus arrangements or any earn-out arrangements?
- Do other agreements, such as loan agreements with covenants linked to profit measures require renegotiation?
- Is there a significant impact on distributable reserves, affecting a company’s ability to pay out dividends?
- How will you manage investor expectations?
What should I do next?
For more complex customer contracts, the adoption of the amendments may require months of preparation. An early start will minimise disruption and ensure compliance. Entities should:
- Upskill finance and commercial teams to understand the impact on the business
- Engage early and communicate with stakeholders
- Decide on the transition approach that will be adopted
- Undertake an impact assessment on revenue accounting
- Gather revenue contracts and group them into different categories (e.g. standard contracts, bespoke contracts, modified contracts etc.)
- Where commercial terms require amendments, obtain these before the initial application date
- Appoint a project sponsor and develop an implementation plan
- Consider changes to data and IT system requirements to track revenue and to satisfy new disclosure requirements