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How to account for leases under IFRS and US GAAP: Recognition, measurement, and disclosure

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Leasing is a core financing strategy for many organizations, enabling access to assets without immediate ownership. The accounting for leases significantly influences balance sheets, income statements, and key financial ratios. Both IFRS (IFRS 16) and US GAAP (ASC 842) require lessees to recognize most leases on the balance sheet, but they differ in classification, expense recognition, and disclosure requirements. Understanding these differences is essential for accurate financial reporting and for comparing results across jurisdictions.



Most leases are recognized on the balance sheet under both IFRS and US GAAP.

IFRS 16 requires lessees to recognize a right-of-use (ROU) asset and a corresponding lease liability for nearly all leases with a term longer than 12 months, unless the underlying asset is of low value. At commencement, the ROU asset is measured at cost (including initial direct costs, prepaid lease payments, and estimated restoration obligations), and the liability equals the present value of lease payments not yet paid.


US GAAP (ASC 842) similarly requires lessees to recognize an ROU asset and a lease liability for most leases, but distinguishes between finance leases (similar to capital leases under the previous ASC 840) and operating leases. Both types are on the balance sheet, but expense recognition differs.

Aspect

IFRS 16

US GAAP (ASC 842)

Scope

All leases (few exceptions)

All leases (few exceptions)

ROU asset and liability

Recognized for all, unless exempt

Recognized for finance/operating

Short-term/low value

Exempt, can elect not to recognize

Exempt (short-term only, <12 months)


Initial and subsequent measurement of lease assets and liabilities.

Initial measurement for both frameworks is similar:

  • Lease liability: Present value of future lease payments, discounted at the rate implicit in the lease or lessee’s incremental borrowing rate.

  • ROU asset: Includes lease liability, initial direct costs, prepayments, less lease incentives received.


Subsequent measurement diverges:

  • IFRS 16: ROU asset is depreciated, and lease liability is unwound using the effective interest method. All leases result in a front-loaded expense pattern on the income statement.

  • US GAAP (ASC 842): Finance leases follow the same expense recognition as IFRS 16, with interest and amortization presented separately. Operating leases, however, present a single lease expense on a straight-line basis, combining interest and amortization for income statement purposes.

Expense pattern

IFRS 16

US GAAP (ASC 842)

Finance/capital lease

Depreciation + interest

Amortization + interest

Operating lease

Same as finance lease

Single lease expense, straight-line


Lease classification and exemptions.

IFRS 16 eliminates lease classification for lessees—all leases are treated similarly, with exemptions for short-term leases (≤12 months) and low-value assets (e.g., laptops, phones).

US GAAP (ASC 842) retains a dual classification:

  • Finance leases: Substantially all risks and rewards of ownership transfer to the lessee.

  • Operating leases: Do not meet finance lease criteria, but are still on the balance sheet. Expense is presented as a single operating expense.

Lessors continue to classify leases as operating or sales-type/direct financing under both frameworks, with more technical distinctions in US GAAP.


Measurement of variable payments, options, and reassessments.

  • Variable lease payments based on usage or sales are generally not included in the initial measurement of lease liability (unless they depend on an index or rate).

  • Options to extend or terminate: Included in lease term if reasonably certain to be exercised.

  • Reassessment: Both standards require lease liability and ROU asset to be remeasured if key lease terms change, such as modifications, exercise of options, or changes in payment indices.


Disclosure requirements and presentation.

IFRS 16 and US GAAP (ASC 842) both require extensive disclosures to enhance transparency:

Disclosure area

IFRS 16

US GAAP (ASC 842)

ROU asset and lease liability

Separate presentation or in notes

Separate or included in PPE/other liabilities

Maturity analysis of lease liabilities

Required

Required

Expense breakdown (interest, amortization, short-term, low value, variable)

Required

Required

Qualitative disclosures (leases not yet commenced, extension options, restrictions)

Required

Required

Cash flow information

Separate cash flow presentation

Separate (operating/financing)


Key differences and practical impacts for lessees.

Feature

IFRS 16

US GAAP (ASC 842)

Lessee lease classification

None (all on balance sheet, same treatment)

Finance/operating distinction, both on balance sheet

Income statement impact

All leases have front-loaded expense

Finance: front-loaded, Operating: straight-line

Low-value asset exemption

Permitted

Not permitted

Reassessment requirements

Broader, more frequent

More restrictive

Lessor accounting

Similar to previous IAS 17

Similar to previous ASC 840


Careful contract analysis, accurate discount rate selection, and robust tracking of lease modifications are essential for compliance under both IFRS and US GAAP. The new rules have increased transparency but require greater judgment and disclosure than previous standards. ____________

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