The FRC’s report on offsetting reflects the Corporate Reporting Review (CRR) team’s experience in relation to offsetting in annual reports and accounts over recent years and focuses on the requirements for offsetting in areas where the CRR found more frequent application issues.
The FRC notes that although the requirements for offsetting are reasonably well established, it regularly identifies material errors in this area, even in fairly straightforward scenarios.
In the thematic, the FRC reminds companies that:
- Cash flows should be presented gross, unless otherwise required or permitted. The FRC also clarifies that the accounting requirements for including overdrafts within cash and cash equivalents in the cash flow statement differ significantly from those relating to the offset of overdrafts and cash and cash equivalents in the statement of financial position.
- Bank overdrafts and positive bank balances that form part of a cash pooling arrangement are offset in the statement of financial position only when there is an intention to exercise a legally enforceable right to set off period-end bank balances. The FRC emphasises that the existence of this right, in itself, is insufficient for offsetting conditions in IAS 32 Financial Instruments: Presentation to be met and that the second part of the offset criteria relates to an intention to exercise this right.
- High quality disclosures are important where financial instruments have been offset or are subject to a master netting arrangement or similar agreement. Companies should disclose material accounting policy information relating to offsetting as well as any significant judgements made by management in applying these policies.
- A reimbursement asset is required to be separately presented from the associated provision. Further, any reimbursement rights that satisfy the contingent asset requirements of IAS 37 Provisions, Contingent Liabilities and Contingent Assets should be appropriately disclosed.
The thematic review also provides observations related to offsetting in other areas including, but not limited to, deferred taxes, revenue from contracts with customers, refund liabilities and right of return assets, employee benefits and non-current assets held for sale and discontinued operations.
The report also clarifies that while IAS 34 Interim Financial Reporting does not contain explicit requirements for disclosures on offsetting, it does require an entity to include in its interim report an explanation of events and transactions that are significant to an understanding of the changes in financial position and performance since the end of the last annual reporting period which may include disclosures on offsetting when it was not applied previously.
The press release and the full publication are available on the FRC website.