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The FRC has issued substantial amendments to FRS 102, that aim to ‘enhance the quality of UK financial reporting’ by aligning UK GAAP with IFRS in key areas, including new revenue recognition and lease accounting models. Charites report under the Charities SORP which uses FRS 102 as its base, here we look at the impact on those organisations.

Charities SORP

As the process for updating FRS 102 has been ongoing, work has also been underway to revise the Charities Statement of Recommended Practice (SORP) (FRS 102). The Charities SORP development process was established to address recommendations made in a , which concluded in 2019. As a result of this review an expert committee was assembled – The Committee -  with 14 Committee members drawn from the 4 charity law jurisdictions covered by UK-Irish GAAP. In its latest statement, issued on the SORP website, the Committee have said:

“The drafting of the new SORP is well under way, and this can now be progressed based on the final FRS102 amendments. The new SORP will be subject to a 3-month consultation period which is anticipated to go live early in 2025. It is likely that the new SORP will be published no later than Autumn 2025 for an effective date of 1 January 2026.”

Changes for all

The two headline changes to FRS 102 are:

• revenue recognition – there is a new model based on IFRS 15’s five-step model, with appropriate simplifications. How entities will be impacted will depend on the form of their contracts with customers; and
• lease accounting requirements – there is a new model for lease accounting, based on IFRS 16’s on-balance sheet model, with some simplifications. Many businesses that use operating leases will be impacted.

Key considerations for the charity sector

Whilst the changes noted above will impact all sectors that report under UK GAAP some areas of the updated standard are likely to have a greater impact on the not-for-profit sector when compared to other sectors. We will explore those below.

1. Lease containing a non-exchange transaction

Section 20 of FRS 102 includes guidance on the treatment of leases where the lease payments are significantly below market rent – something regularly seen in the charity sector. In cases such as this, the lessor is effectively providing the lessee with incoming resources from a ‘non-exchange’ transaction for the difference between the amounts paid and the expected market rent. Under the new standard the incoming resources from such a transaction would be recognised as part of the cost of the right-of-use asset.

The addition of these right-of-use assets will consequently increase the total assets of a charity, a few charities not currently required to have a statutory audit may now need one despite having relatively low levels of income and employees.

Section 20 does note that in some cases the contractual payments in such arrangements may be so low that the arrangement may not meet the definition of a lease. We will await the publication of the new SORP to see if further guidance will be provided for the sector.

The recognition of the addition to the right-of-use asset is fairly straight forward once measured, . However, it is not clear whether the receipt should be recognised as deferred income at the commencement of the lease and released to income over the life of the right-of-use asset (as expected) or recognised in full at the commencement of the lease. We will check the new SORP for additional clarification on this point.

2. Incoming resources from non-exchange transactions

Section 34 includes a number of areas that specifically relate to public benefit entities. One such area includes incoming resources from non-exchange transactions. In the main, this section has been expanded to include some helpful narrative:

• Examples of resources that should be capable of reliable measurement and conversely those that may not be.
• Examples of resources that may be impracticable to measure such as low-value goods that have been donated for resale – allowing for these to be recognised when sold or distributed. Or volunteer time that not expected to be recognised at all as reliable measurement is so difficult.
• Further detail on how these types of incoming resources should be recognised and measured – both ‘value to the entity’ in the case of donated services and facilities and ‘fair value’ for all other incoming resources.

However, the updated standard does not provide guidance or examples on what should be classed as a donated service or facility and, therefore, what falls into the ‘other’ category. The response of the joint SORP making body to FRED 82 noted that the lack of clarity, particularly in the case of leases, may cause the sector to treat similar non-exchange transactions differently. Hopefully the updated SORP will make this clearer.

3. Legacy income

Accounting for income from legacies is often a complex area  faced by charities. Previously legacy income was dealt with in Appendix B to Section 34 – this entire Appendix has been removed in the updated standard. Legacy income is now included within the body of Section 34 but the clarification wording on when a legacy receipt is probable has been removed. The removal of these explanation paragraphs from the new FRS102 indicates that the Charities SORP will be the guide used to interpret and provide further guidance on legacy income recognition.

4. Heritage Assets

The updated standard also provides clearer wording on what constitutes a heritage asset and should,  be accounted for in line with Section 34 and those assets that have the characteristics of a heritage asset but should be accounted for in line with another applicable section within the standard. For example, historic buildings used for teaching by education establishments should be accounted for in line with Section 17 rather than Section 34.

The updated standard also makes it clear that heritage assets that have been acquired in a non-exchange transaction should be recognised at their fair value. The wording of Section 34 has also been updated to state that it will only be in exceptional cases that the fair value of the heritage asset will not be capable of being measured reliably at a cost which is commensurate with the benefits to users of the financial statements.

Nick Sladden (Head of Charities at RSM) says, ‘The charity sector is eagerly awaiting the update to the Charities SORP.  The SORP making body, in their response to FRED 82, noted that the charity sector in the UK and Ireland is dominated by smaller organisations and, as such, a particular focus of their work is to understand how smaller charities can be provided with an accounting framework that is proportionate, appropriate and practical. The changes to FRS 102, especially in relation to leases, are likely to be onerous for smaller charities so it will be interesting to see what other areas of simplification may be made available in the upcoming revision to the SORP.’

The effective date for most of the amendments to FRS 102 is for the periods commencing on or after 1 January 2026. Please remember the following text:

"We have not yet received the first draft of the updated SORP or an estimated date for when the new SORP will be finalised. However, charities can still make significant preparations in the meantime based on the changes to FRS 102."