Significant amendments to FRS 102 from the 2024 Periodic Review take effect for accounting periods beginning on or after 1 January 2026. One of the most notable updates is the shift to an IFRS‑aligned framework for revenue recognition – a change that will reshape how many organisations measure and report income.
While early adoption is permitted, the scale of the changes means businesses should start preparing now to ensure systems, processes and disclosures are ready.
A new model for recognising revenue
Section 23 has been substantively revised, replacing the long‑used “risks and rewards” approach with a five‑step model aligned to IFRS 15. The emphasis moves to recognising revenue as control transfers to the customer.
The five steps are:
- Identify the contract with the customer
- Identify the performance obligations within that contract
- Determine the transaction price, including variable elements such as rebates or discounts
- Allocate the transaction price to each performance obligation
- Recognise revenue when (or as) each obligation is satisfied, based on the transfer of control
For many entities, this may mean a material shift in revenue timing. Income that was previously recognised at a point in time may now need to be recognised over a contract period, while others may see the opposite effect.
These changes apply to all entities using FRS 102, including small entities under Section 1A and micro‑entities applying FRS 105. Organisations can adopt either full retrospective application or a modified retrospective application approach with an adjustment to opening reserves.
Who will be most affected?
Sectors involving long‑term contracts or multi‑element service arrangements are expected to see the most significant impact, including:
- Media and creative services
That said, no entity is untouched. Even straightforward revenue streams will require a review of contract terms, system capabilities and accounting policies.
To illustrate how the revised model may play out in practice, here are examples of how the changes could affect different industries:
What this means for construction businesses
How will project costs be handled differently?
- Current FRS 102: Revenue and costs are commonly recognised by reference to stage of completion, which tends to produce a smooth and consistent margin across the life of a contract.
- Revised FRS 102: Revenue continues to follow progress, but costs are recognised when they are actually incurred, rather than being spread in line with project progress.
What this means in practice:
margins may appear more uneven or “bumpy” from period to period – even where the anticipated overall profit for the contract is unchanged. This has implications for WIP reporting, project dashboards, covenant headroom, and bonus schemes. Construction finance teams should prioritise contract reviews, cost‑capture processes and project reporting in their transition plans.
What this means for software and technology businesses
Software and technology businesses often use subscription models or sell bundled offerings, meaning the revised model could significantly affect how revenue is split and when it is recognised.
Key considerations include:
- Breaking down bundled arrangements such as licences, implementation services and support into separate performance obligations where required.
- Determining whether each element is recognised at a point in time (such as certain licences) or over time (such as Software as a Service ‘SaaS’ or ongoing support).
- Estimating variable elements such as usage‑based fees, rebates or tiered pricing.
What this means in practice:
revenue patterns may shift, particularly where hybrid or multi‑element contracts are involved. This may affect internal KPIs, sales incentives, ARR reporting and investor communications.
What this means for media and professional services businesses
Media, creative and professional services businesses typically deliver project‑based or retainer‑based services, which are directly impacted by the five‑step model.
Key considerations include:
- Assessing when control transfers, as some services are delivered over time while others transfer at a specific point (for example, delivery of a final asset or report).
- Identifying whether strategy, creative work, production, analytics or reporting constitute distinct performance obligations.
- Incorporating variable consideration such as performance fees, rebates or volume discounts.
What this means in practice:
revenue may become less linear across a project, affecting forecasting, resource planning and management reporting.
Practical steps to take now
To prepare for the transition, organisations should begin by:
1) Reviewing customer contracts
Identify distinct performance obligations and whether each should be recognised over time or at a point in time.
2) Assessing system readiness
Ensure accounting software and processes can track performance obligations, contract assets and contract liabilities, including allocations across multi‑element contracts.
3) Evaluating financial impact
Model how changes in revenue timing could influence EBITDA, profit‑related pay, bank covenants, credit ratings and the timing of tax liabilities – and consider the communications needed for boards, lenders and investors.
Implications for auditors
Revenue recognition is already one of the highest‑risk areas in audit, and the revised requirements heighten this risk. Auditors will need to:
- Perform enhanced risk assessments
- Undertake deeper contract evaluations – particularly for long‑term or complex arrangements
- Challenge management on estimates and judgements (e.g., variable consideration, identifying performance obligations)
- Evidence professional scepticism with stronger documentation and clearer rationale
Expect closer scrutiny and more robust audit files, especially where income streams are complex.
A period of adjustment – and opportunity
The transition to the revised FRS 102 framework is a significant change for all stakeholders. Starting early – by evaluating contracts, updating systems and modelling financial effects – will help organisations minimise disruption and approach the change with confidence.
If you would like tailored support in assessing how these changes may affect your organisation, our teams would be happy to help.