Chapter 34
FRS 104 – Interim financial reporting

List of examples

Chapter 34
FRS 104 – Interim financial reporting

1 INTRODUCTION

FRS 104 – Interim Financial Reporting – was issued originally in March 2015. A revised version was issued in March 2018, to update the edition issued in March 2015 for the following:

  • Amendments to FRS 102 Triennial review 2017 – Incremental improvements and clarifications (Triennial review 2017) issued in December 2017;
  • The replacement of Appendix III: Significant differences between FRS 104 and IAS 34 with a Basis for Conclusions; and
  • Some minor typographical and presentational corrections.

This chapter reflects the March 2018 version of FRS 104.

FRS 104 does not require any entity to prepare an interim report, nor does it change the extent to which laws or regulations may require the preparation of such a report. FRS 104 is intended for use in the preparation of interim reports by entities that prepare financial statements in accordance with UK GAAP. In particular, it is intended for use by entities which apply FRS 102 – The Financial Reporting Standard applicable in the UK and Republic of Ireland. Most of this chapter therefore deals with the use of FRS 104 by FRS 102 preparers. However, entities which apply FRS 101 – Reduced Disclosure Framework – when preparing their annual financial statements may also use FRS 104 when preparing their interim financial reports.

FRS 104 is based on the equivalent international standard IAS 34 – Interim Financial Reporting, but with some minor adjustments and the omission of certain paragraphs which deal with presentational aspects of IAS 34 or paragraphs of IAS 34 which include disclosures not required in the annual financial statements of entities reporting under FRS 102. These amendments are summarised in the Basis for Conclusions. [FRS 104.BC10].

1.1 Definitions

The standard defines an interim period as ‘a financial reporting period shorter than a full financial year’. [FRS 104 Appendix I].

The term ‘interim financial report’ means a financial report for an interim period that contains either a complete set of financial statements (as described in Section 3 – Financial Statement Presentation – of FRS 102) or a set of condensed financial statements (see 3.2 below). [FRS 104 Appendix I].

2 OBJECTIVE AND SCOPE OF FRS 104

2.1 Objective

FRS 104 sets out content, recognition and measurement principles for interim financial reports. [FRS 104.1A]. It notes that ‘timely and reliable interim financial reporting can improve the ability of investors, creditors, and others to understand an entity's capacity to generate earnings and cash flows and its financial condition and liquidity’. [FRS 104.1].

2.2 Scope

FRS 104 is intended for use by entities that prepare annual financial statements in accordance with FRS 102. If an entity prepares its annual financial statements under FRS 101 and applies FRS 104, it should replace references to FRS 102 in FRS 104 with the equivalent requirements in EU-adopted IFRS, as amended by paragraph AG 1 of FRS 101. [FRS 104.2A].

This chapter is written primarily for entities that prepare their annual financial statements in accordance with FRS 102. However, a discussion on the application of FRS 104 to FRS 101 reporters is included at 5 below.

FRS 104, in itself, does not require an entity to prepare interim financial reports and does not mandate, how often, or how soon after the end of an interim period an interim financial report should be issued. Where an entity is required by laws or regulations or voluntarily chooses to prepare interim financial reports it may voluntarily choose to apply FRS 104. [FRS 104.2]. Therefore, entities need to consider if there are any applicable laws and regulations which require them to prepare interim financial statements. For example, UK issuers not using EU-adopted IFRS that publish half-yearly reports which include a statement that a condensed set of financial statements has been prepared in accordance with FRS 104, must apply the standard. [FRS 104.3A]. See 2.2.1 below.

In practice, we expect a limited number of entities (primarily investment trusts and venture capital trusts) will be required to apply FRS 104. However, for entities which prepare annual financial statements under FRS 101 or FRS 102, FRS 104 may be applied voluntarily for interim reporting purposes.

2.2.1 Issuers required to comply with the Disclosure Guidance and Transparency Rules (DTR)

Issuers of securities that are required to publish half-yearly financial reports in accordance with the Disclosure Guidance and Transparency Rules (DTR) must include a responsibility statement in the report. In accordance with paragraph 4.2.10.R of the DTR, a person making the responsibility statement will satisfy the requirement to confirm that the condensed set of financial statements gives a true and fair view of the assets, liabilities, financial position and profit or loss of the issuer (or the undertakings included in the consolidation as a whole) by including a statement that the condensed set of financial statements has been prepared in accordance with either:

  • IAS 34; or
  • for UK issuers not using EU-adopted IFRS, FRS 104 issued by the FRC. [FRS 104 Appendix IV.3].

The application of FRS 104 is conditional upon the person making the responsibility statement having reasonable grounds to be satisfied that the condensed set of financial statements prepared under FRS 104 is not misleading. [FRS 104 Appendix IV.4].

In accordance with the DTR, an issuer that is required to prepare consolidated accounts must prepare the condensed set of financial statements in accordance with IAS 34 and the requirements set out in FRS 104 do not apply to these issuers. [FRS 104 Appendix IV.5]. An issuer that is not required to prepare consolidated accounts must, as a minimum, apply the content and preparation requirements set out in paragraph 4.2.5.R of the DTR. The content and preparation requirements of FRS 104 are consistent with those set out in the DTR, although they are more prescriptive and detailed. [FRS 104 Appendix IV.6].

2.2.2 Unlisted entities and entities not subject to the DTR

While not in the scope of the DTR, unlisted entities or entities with securities admitted to trading on an exchange not subject to the DTR may prepare and present interim financial statements. In those circumstances, there may be no requirement to follow a particular standard on interim financial reporting. However, we would expect that where annual financial statements are prepared under either FRS 101 or FRS 102 that the interim financial statements would be prepared under FRS 104.

3 FORM AND CONTENT OF AN INTERIM FINANCIAL REPORT UNDER FRS 104

FRS 104 does not prohibit or discourage an entity from:

  • publishing a complete set of financial statements (as described in Section 3 of FRS 102) in its interim financial report, rather than condensed financial statements and selected explanatory notes; or
  • including in condensed interim financial statements more than the components and selected explanatory notes as set out in paragraph 8 of FRS 104.

The recognition and measurement guidance in the standard, together with the note disclosures required by the standard, apply to both complete and condensed financial statements presented for an interim period. [FRS 104.7].

3.1 Complete set of interim financial statements

If an entity publishes a complete set of financial statements in its interim financial report, the form and content of those statements should conform to the requirements of Section 3 of FRS 102. [FRS 104.9]. A complete set of financial statements should include the following components: [FRS 102.3.17]

  • a statement of financial position as at the reporting date;
  • a statement of comprehensive income for the reporting period to be presented either as:
    • a single statement of comprehensive income for the reporting period, displaying all items of income and expense recognised during the period including those items recognised in determining profit or loss (which is a subtotal in the statement of comprehensive income) and items of other comprehensive income; or
    • a separate income statement and a separate statement of comprehensive income. In this case, the statement of comprehensive income begins with profit or loss and then displays the items of other comprehensive income;
  • a statement of changes in equity for the reporting period;
  • a statement of cash flows for the reporting period; and
  • notes comprising significant accounting policies and other explanatory information.

The presentational requirements of Section 3 of FRS 102 are discussed in Chapter 6. In addition, the entity should make the disclosures specifically required by FRS 104 for interim financial reports (see 4 below) as well as those required by FRS 102. [FRS 104.7].

An entity that will not present a statement of cash flows in its next annual financial statements is not required to include that statement in its interim financial report. [FRS 104.9].

3.2 Condensed interim financial statements

In the interest of timeliness, cost, and avoiding repetition of previously reported information, an entity might be required or elect to give less information at interim dates as compared with its annual financial statements. [FRS 104.6]. FRS 104 defines the minimum components of an interim report, as including condensed financial statements and selected explanatory notes, as follows: [FRS 104.6, 8]

  1. a condensed statement of financial position;
  2. a single condensed statement of comprehensive income or a separate condensed income statement and a separate condensed statement of comprehensive income;
  3. a condensed statement of changes in equity;
  4. a condensed statement of cash flows; and
  5. selected explanatory notes.

Other titles for the statements can be used, as long as they are not misleading. [FRS 104.8E].

An entity that will not present a statement of cash flows in its next annual financial statements is not required to include that statement in its interim financial report. [FRS 104.8F].

FRS 104 requires entities to confirm that the same accounting policies and methods of computation are followed in the interim financial statements as compared to their most recent annual financial statements or, if those policies or methods have changed, to describe the nature and effect of the change (see 8.1.2 below). Accordingly, an entity would only depart from the presentation applied in its most recent annual financial statements if it has determined that the format will change in its next annual financial statements. [FRS 104.8D].

The condensed income statement and condensed statement of comprehensive income referred to at (b) above should be presented using the same basis as the entity's most recent annual financial statements. Accordingly, if an entity presents a separate income statement in its annual financial statements, then it should also present a separate income statement in the interim financial report. Similarly, if a single statement of comprehensive income is presented in the annual financial statements, the same format is adopted in the interim financial report. [FRS 104.8A].

Where the only changes to equity arise from profit or loss, payment of dividends, corrections of prior period errors or changes in accounting policies, an entity may have presented a single statement of income and retained earnings in place of the statement of comprehensive income and statement of changes in equity in its most recent annual financial statements under FRS 102. If that continues to be the case during any of the periods for which the interim financial statements are required to be presented, the entity may continue to present a single condensed statement of income and retained earnings. [FRS 104.8B].

Similarly, where an entity in its most recent annual financial statements has presented only an income statement or a statement of comprehensive income in which the bottom line is labelled profit or loss (by virtue of there being no items of other comprehensive income), that entity is permitted to use the same basis of presentation in its interim financial statements if there are no items of other comprehensive income in any of the periods for which the interim financial statements are being presented. [FRS 104.8C].

As a minimum, the condensed financial statements should include each of the headings and subtotals that were included in the entity's last annual financial statements. [FRS 104.10].

A strict interpretation of this minimum requirement could mean that, for example, an entity is only required to present non-current assets, current assets, etc., in an interim statement of financial position. However, one of the purposes of an interim report is to help the users of the financial statements to understand the changes in financial position and performance of the entity since the end of the last annual reporting period. [FRS 104.15]. To that end, FRS 104 also requires additional line items or notes to be included if their omission makes the condensed interim financial statements misleading. [FRS 104.10]. In addition, the overriding goal of FRS 104 is to ensure that the interim report includes all information relevant to understanding the entity's financial position and the performance during the interim period. [FRS 104.25]. Therefore, judgement is required to determine which line items provide useful information for decision-makers, and are presented accordingly.

Inclusion of all of the line items from the annual financial statements will often be most appropriate to help users of the interim financial statements understand the changes since the previous year-end. Nonetheless, entities may aggregate line items used in the annual financial statements, if doing so does not render the information misleading or prevent users of the interim financial statements from performing meaningful trend analysis.

The following example illustrates one possible way in which an entity might choose to combine line items presented separately in the annual financial statements when preparing a condensed set of interim financial statements for an individual set of accounts prepared under Format 1 of Schedule 1 to the Regulations. However, such presentation is at the discretion of management, based on facts and circumstances, including materiality (as discussed at 7 below), regulatory environment, and the overarching goal of FRS 104 to provide relevant information. [FRS 104.25]. Accordingly, other presentations may be appropriate.

A statement of changes in equity and statement of cash flows are not presented in this example.

3.3 Requirements for complete and condensed interim financial information

The general principles for preparing annual financial statements are equally applicable to interim financial statements. These principles include fair presentation, going concern, materiality and aggregation. See Chapter 6 at 9.

Furthermore, irrespective of whether an entity provides complete or condensed financial statements for an interim period, basic and diluted earnings per share should be presented for an interim period when earnings per share (EPS) information has been presented in the entity's most recent annual financial statements. [FRS 104.11]. Such information should be given on the face of the statement that presents components of profit or loss for an interim period. [FRS 104.11A].

3.4 Management commentary

A management commentary is not explicitly required by FRS 104, but we would expect one to be included by entities in their interim financial reports along with the interim financial statements.

FRS 104 allows information required under the standard to be presented outside the interim financial statements, i.e. in other parts of interim financial report. [FRS 104.15B, 16A]. Thus, some of the required disclosures may be included in a management commentary (see 4.2.1 below). The standard itself does not establish specific requirements for the content of a management commentary beyond what should be contained in (or cross-referred from) the interim financial statements.

4 DISCLOSURES IN CONDENSED FINANCIAL STATEMENTS

FRS 104 contains a number of disclosure principles:

  • Entities should provide information about events and transactions in the interim period that are significant to an understanding of the changes in financial position and performance since the end of the last annual reporting period. In this context it is not necessary to provide relatively insignificant updates to information reported in the last annual financial statements (see 4.1 below). [FRS 104.15, 15A].
  • In addition to information to explain significant changes since the last annual reporting period, certain ‘minimum’ disclosures are required to be given, if not disclosed elsewhere in the interim financial report (see 4.2 below). [FRS 104.16A].
  • The materiality assessment for disclosure is based on the interim period by itself to ensure all information is provided that is relevant to understanding of the entity's financial position and its performance during the interim period (further discussed at 7 below). [FRS 104.25].

Overall, applying those disclosure principles requires the exercise of judgement by the entity regarding what information is significant or relevant. The practice of interim reporting confirms that entities take advantage of that room for judgement, both for disclosures provided in the notes to the interim financial statements and outside.

4.1 Significant events and transactions

FRS 104 presumes that users of an entity's interim financial report also have access to its most recent annual financial report. [FRS 104.15A]. On that basis, an interim financial report should explain events and transactions that are significant to an understanding of the changes in financial position and performance of the entity since the previous annual reporting period and provide an update to the relevant information included in the financial statements of the previous year. [FRS 104.15, 15C]. The inclusion of only selected explanatory notes is consistent with the purpose of an interim financial report, to update the latest complete set of annual financial statements. Accordingly, condensed financial statements avoid repeating previously reported information and focus on new activities, events, and circumstances. [FRS 104.6].

Disclosure of the following events and transactions in interim financial reports, if they are significant, is required: [FRS 104.15B]

  1. write-down of inventories to net realisable value and the reversal of such a write-down;
  2. recognition of a loss from the impairment of financial assets, property, plant, and equipment, intangible assets, or other assets, and the reversal of such an impairment loss;
  3. reversal of any provisions for the costs of restructuring;
  4. acquisitions and disposals of items of property, plant and equipment;
  5. commitments for the purchase of property, plant and equipment;
  6. litigation settlements;
  7. corrections of prior period errors;
  8. changes in the business or economic circumstances that affect the fair value of the entity's financial assets and financial liabilities, where those assets or liabilities are measured at fair value;
  9. any loan default or breach of a loan agreement that is not remedied on or before the end of the reporting period;
  10. related party transactions, unless the transaction was entered into between two or more members of a group, provided that any subsidiary which is a party to the transaction is wholly owned by such a member; and
  11. changes in contingent liabilities or contingent assets.

FRS 104 states that the above list of events and transactions is not exhaustive and the interim financial report should explain any additional events and transactions that are significant to an understanding of changes in the entity's financial position and performance. [FRS 104.15, 15B]. Therefore, when information changes significantly (for example, the values of non-financial assets and liabilities that are measured at fair value), an entity should provide disclosure regarding such change, in addition to the requirements listed above; the disclosure should be sufficiently detailed to explain the nature of the change and any changes in estimates.

The disclosures in the above list can be given either in the notes to the interim financial statements or, if disclosed elsewhere in the interim financial report, cross-referred to the disclosure in the notes to the interim financial statements. [FRS 104.15B].

4.1.1 Relevance of other standards in condensed financial statements

Whilst FRS 102 specifies disclosures required in a complete set of financial statements, if an entity's interim financial report includes only condensed financial statements as described in FRS 104, then the disclosures required by those other standards are not mandatory. However, if disclosure is considered to be necessary in the context of an interim report, FRS 102 provides guidance on the appropriate disclosures for many of these items. [FRS 104.15C]. For example, in meeting the requirements of (g) at 4.1 above to disclose the impact of corrections of prior period errors, the requirements of Section 10 would be relevant (see Chapter 9 at 3.7.3).

4.2 Other disclosures required by FRS 104

In addition to disclosing significant events and transactions as discussed at 4.1 above, FRS 104 requires an entity to include the following information either in the notes to its interim financial statements or, if disclosed elsewhere in the interim financial report, cross-referred from the notes: [FRS 104.16A]

  1. a statement that the same accounting policies and methods of computation are followed in the interim financial statements as in the most recent annual financial statements or, if those policies or methods have been changed, a description of the nature and effect of the change;
  2. explanatory comments about the seasonality or cyclicality of interim operations;
  3. the nature and amount of items affecting assets, liabilities, equity, profit or loss, or cash flows that are unusual because of their nature, size, or incidence;
  4. the nature and amount of changes in estimates of amounts reported in prior interim periods of the current financial year or changes in estimates of amounts reported in prior financial years;
  5. issues, repurchases, and repayments of debt and equity securities;
  6. dividends paid (aggregate or per share) separately for ordinary shares and other shares;
  7. certain segment disclosures as discussed at 4.3 below; but only if the entity has presented segment information in accordance with IFRS 8 – Operating Segments – in its most recent annual financial statements;
  8. events after the interim period that are not reflected in the financial statements for the interim period;
  9. the effect of changes in the composition of the entity during the interim period, including business combinations, obtaining or losing control of subsidiaries and long-term investments, restructurings, and discontinued operations. For business combinations, the entity shall disclose the information required by paragraphs 19.25 and 19.25A of FRS 102 (see Chapter 17 at 4.1); and
  10. for financial instruments, certain disclosures in respect of financial instruments measured at fair value and as required by paragraphs 11.43, 11.48A(e) and 34.22 of FRS 102; but only if the entity would be required to make the disclosure in the annual financial statements, as discussed at 4.4 below.

This information is normally reported on a financial year-to-date basis (see 8 below). [FRS 104.16A].

For business combinations that occurred during the reporting period which, individually, are not material, FRS 102 allows the disclosure of revenue and profit or loss to date to be given in aggregate. [FRS 102.19.25A]. However, materiality is assessed for the interim period, which implies that FRS 104 may require more detailed disclosures on business combinations that are material to an interim period even if they could be aggregated for disclosure purposes in the annual financial statements prepared under FRS 102.

If an entity has operations that are discontinued or disposed of during an interim period, these operations should be presented separately in the condensed interim statement of comprehensive income following the principles set out in Section 5 – Statement of Comprehensive Income and Income Statement.

An entity contemplating a significant restructuring that will have an impact on its composition should follow the guidance in Section 21 – Provisions and Contingencies – for the recognition of any restructuring cost, [FRS 102.21.11C], and Section 28 – Employee Benefits – for the recognition of any termination benefits. [FRS 102.28.31]. In subsequent interim periods any significant changes, including reversals, to restructuring provisions will require disclosure. [FRS 104.15B(c)].

4.2.1 Location of the specified disclosures in an interim financial report

FRS 104 defines an ‘interim financial report’ as ‘a financial report containing either a complete set of financial statements or a set of condensed financial statements for an interim period’. [FRS 104 Appendix I]. Therefore, since an interim financial report contains the interim financial statements, it is clear that these are two different concepts. Accordingly, an entity is not required to disclose the information listed at 4.1 and 4.2 above in the interim financial statements themselves, as long as a cross reference is provided from the financial statements to the location of the information included in another part of the interim financial report. [FRS 104.15B, 16A].

4.3 Segment information

If an entity has presented segment information in accordance with IFRS 8 in its most recent annual financial statements, certain segment disclosures are required in its interim financial report.

An entity applying IFRS 8 in its most recent annual financial statements should include the following information in its interim financial report about its reportable segments: [FRS 104.16A(g)]

  1. revenues from external customers (if included in the measure of segment profit or loss reviewed by or otherwise regularly provided to the chief operating decision maker);
  2. intersegment revenues (if included in the measure of segment profit or loss reviewed by or otherwise regularly provided to the chief operating decision maker);
  3. a measure of segment profit or loss;
  4. a measure of total assets and liabilities for a particular reportable segment if such amounts are regularly provided to the chief operating decision maker and if there has been a material change from the amount disclosed in the last annual financial statements for that reportable segment;
  5. a description of differences in the basis of segmentation or in the basis of measurement of segment profit or loss from the last annual financial statements; and
  6. a reconciliation of the total profit or loss for reportable segments to the entity's profit or loss before income taxes and discontinued operations. However, if an entity allocates such items as income taxes to arrive at segment profit or loss, the reconciliation can be to the entity's profit or loss after those items. The entity should separately identify and describe all material reconciling items.

4.4 Fair value disclosures for financial instruments

If an entity would be required to make equivalent disclosures in its annual financial statements, FRS 104 requires that an entity should include the following in its interim financial report in order to help users evaluate the significance of financial instruments measured at fair value: [FRS 104.16A(j)]

  1. For all financial assets and financial liabilities measured at fair value, the entity shall disclose the basis for determining fair value, e.g. quoted market price in an active market or a valuation technique. When a valuation technique is used, the entity shall disclose the assumptions applied in determining fair value for each class of financial assets or financial liabilities. For example, if applicable, an entity discloses information about the assumptions relating to prepayment rates, rates of estimated credit losses, and interest rates or discount rates. [FRS 102.11.43]. See Chapter 10 at 8.1.
  2. For financial instruments at fair value through profit or loss that are not held as part of a trading portfolio and are not derivatives, any difference between the fair value at initial recognition and the amount that would be determined at that date using a valuation technique, the aggregate difference yet to be recognised in profit or loss at the beginning and end of the period, and a reconciliation of the changes in the balance of this difference. [FRS 102.11.48A(e)]. See Chapter 10 at 8.1.
  3. For financial instruments held at fair value in the statement of financial position, a financial institution shall disclose for each class of financial instrument, an analysis of the level in the fair value hierarchy (as set out in paragraph 11.27) into which the fair value measurements are categorised. [FRS 102.34.22]. See Chapter 10 at 11.2.

The inclusion of the above disclosure requirement among the items required by the Standard to be given ‘in addition to disclosing significant events and transactions’, [FRS 104.16A], distinguishes it from the items listed at 4.1 above, which are disclosed to update information presented in the most recent annual financial report. [FRS 104.15]. Therefore, disclosure of the above information is required for each interim reporting period, subject only to a materiality assessment in relation to that interim report, i.e. an entity could consider it unnecessary to disclose the above information on the grounds that it is not relevant to an understanding of its financial position and performance in that specific interim period. [FRS 104.25]. In making that judgement care would need to be taken to ensure any omitted information would not make the interim financial report incomplete and therefore misleading.

4.5 Disclosure of compliance with FRS 104

If an interim financial report complies with the requirements of FRS 104, this fact should be disclosed. Furthermore, an entity that makes a statement of compliance with FRS 104 shall comply with all of its provisions. FRS 104 does not need to be applied to immaterial items. [FRS 104.3, 19].

5 ENTITIES REPORTING UNDER FRS 101

As noted at 2 above, FRS 104 is intended for use by entities that prepare annual financial statements in accordance with FRS 102. However it can also be used by entities that report under FRS 101, and in those circumstances references included in FRS 104 to FRS 102 should be read as references to the equivalent requirements in EU-adopted IFRS as amended by paragraph AG1 of FRS 101. [FRS 104.2A].

The references to FRS 102 fall into three main categories:

  • disclosure of significant events and transactions (see 5.1 below);
  • business combinations (see 5.2 below); and
  • financial instruments (see 5.3 below).

While there are references to FRS 102 in other paragraphs of FRS 104, we do not expect that these will give rise to any significant differences in the application of FRS 104 between FRS 101 and FRS 102 reporters. These references are in financial statement presentation, materiality, recognition and changes in accounting policy. [FRS 104.7, 8B-8C, 9, 16B, 24, 31, 30, 33, 43-44].

In respect of changes in accounting policies, refer to 8.1.2 below with references to FRSs being read as references to IFRSs.

5.1 Disclosure of significant events and transactions

As discussed at 4.1 above, FRS 104 requires entities to include, in their interim financial statements, an explanation of events and transactions that are significant to an understanding of changes in the financial position and performance of the entity since the end of the previous reporting period. FRS 104 sets out a non-exhaustive list of the types of transactions and events entities might include. [FRS 104.15, 15B].

FRS 104 refers to individual sections of FRS 102 for guidance on disclosure requirements for many of the items on the list referred to above. [FRS 104.15C]. For entities reporting under FRS 101, this reference should be amended to the relevant standard under EU-adopted IFRS as amended by FRS 101. For example, for guidance on the disclosure requirements in respect of the acquisitions and disposals of items of property, plant and equipment, entities should refer to IAS 16 – Property, Plant and Equipment – rather than Section 17 – Property, Plant and Equipment – of FRS 102. For further discussion on any significant differences in disclosure between the relevant section of FRS 102 and the equivalent standard under EU-adopted IFRS, refer to the key differences section of the relevant chapter in this publication.

5.2 Business combinations

Paragraph 16A(i) of FRS 104 requires entities to include in their interim financial statements details of the effect of changes in the composition of the entity during the interim period including business combinations, obtaining or losing control of subsidiaries and long-term investments, restructurings and discontinued operations. In particular, entities are required to disclose the information set out in paragraphs 25 and 25A of FRS 102 Section 19 – Business Combinations and Goodwill. For FRS 101 reporters we believe the equivalent requirements under EU-adopted IFRS are those set out in paragraph 16A(i) of IAS 34, which cross-refer to the requirements in paragraphs 59-63 and B64-67 of IFRS 3 – Business Combinations.

5.3 Financial instruments

FRS 104 requires entities to include in their interim financial statements disclosures that help users to evaluate the significance of financial instruments measured at fair value. [FRS 104.16A(j)]. In particular, entities are required to give the disclosures set out in paragraphs 43 and 48A(e) of Section 11 – Basic Financial Instruments – and paragraph 22 of Section 34 – Specialised Activities.

For FRS 101 reporters we believe the equivalent requirements under EU-adopted IFRS are those set out in paragraphs 91-93(h), 94-96, 98 and 99 of IFRS 13 – Fair Value Measurement – and paragraphs 25, 26 and 28-30 of IFRS 7 – Financial Instruments: Disclosures.

The IFRS 13 disclosures above will only be required if an entity has financial instruments which (after initial recognition) are measured at fair value on a recurring or non-recurring basis.

FRS 101 allows qualifying entities that are not financial institutions (see Chapter 2 at 2.1 and 6.4 for the definitions of a qualifying entity and a financial institution, respectively) to take advantage of exemptions to disclose information required by IFRS 7 and paragraphs 91 to 99 of IFRS 13 in their annual financial statements, provided that equivalent disclosures are included in the consolidated financial statement of the group in which the entity is consolidated. If such disclosure exemptions are reasonably expected to be taken by the qualifying entity when preparing its annual financial statements, there is no requirement to disclose such information in the entity's interim financial report.

6. PERIODS FOR WHICH INTERIM FINANCIAL STATEMENTS ARE REQUIRED TO BE PRESENTED

Irrespective of whether an entity presents condensed or complete interim financial statements, the components of its interim financial reports should include information for the following periods: [FRS 104.20]

  1. a statement of financial position as of the end of the current interim period and a comparative statement of financial position as of the end of the immediately preceding financial year;
  2. a statement of profit or loss and other comprehensive income for the current interim period and, if different, cumulatively for the current financial year-to-date, with comparative statements of profit or loss and other comprehensive income for the comparable interim periods (current and, if different, year-to-date) of the immediately preceding financial year;
  3. a statement of changes in equity cumulatively for the current financial year-to-date period, with a comparative statement for the comparable year-to-date period of the immediately preceding financial year; and
  4. a statement of cash flows cumulatively for the current financial year-to-date, with a comparative statement for the comparable year-to-date period of the immediately preceding financial year.

The requirement in paragraph (d) does not apply to entities that will not present a statement of cash flows in their next annual financial statements.

An interim financial report may present for each period either a single statement of ‘profit or loss and other comprehensive income’, or separate statements of ‘profit or loss’ and ‘comprehensive income’, consistent with the basis of preparation applied in its most recent annual financial statements. Accordingly, if the entity presents a separate statement for items of profit or loss in its annual financial statements, it should present a separate condensed statement of profit or loss in the interim financial report. [FRS 104.8A]. If an entity's business is highly seasonal, then the standard encourages reporting additional financial information for the twelve months up to the end of the interim period, and comparative information for the prior twelve-month period, in addition to the financial statements for the periods set out above. [FRS 104.21].

An entity that presents a single condensed statement of income and retained earnings in place of the statement of comprehensive income and statement of changes in equity shall present a single condensed statement of income and retained earnings for the periods for which interim financial statements are required to be presented. [FRS 104.20A].

An entity that presents an income statement, or a statement of comprehensive income in which the ‘bottom line’ is labelled ‘profit or loss’ shall present an income statement or a statement of comprehensive income on that basis for the periods for which interim financial statements are required to be presented. [FRS 104.20B].

The examples below illustrate the periods that an entity is required and encouraged to disclose under FRS 104. [FRS 104 Appendix II].

6.1 Other comparative information

For entities presenting condensed financial statements under FRS 104, there is no explicit requirement that comparative information be presented in the explanatory notes. Nevertheless, where an explanatory note is required by the standard (such as for inventory write-downs, impairment provisions, segment revenues etc.) or otherwise determined to be needed to provide useful information about changes in the financial position and performance of the entity since the end of the last annual reporting period, [FRS 104.15], it would be appropriate to provide information for each period presented. However, in certain cases it would be unnecessary to provide comparative information where this repeats information that was reported in the notes to the most recent annual financial statements. [FRS 104.15A]. For example, it would only be necessary to provide information about business combinations in a comparative period when there is a revision of previously disclosed fair values. See Chapter 17 at 4.1.

For entities presenting complete financial statements, whilst FRS 104 sets out the periods for which components of the interim report are included, it is less clear how these rules interact with the requirement in FRS 102 to report comparative information for all amounts in the financial statements. [FRS 102.3.14]. In our view, a complete set of interim financial statements should include comparative disclosures for all amounts presented.

6.2 Change in financial year-end

The requirement in FRS 104 to present a comparative statement of profit or loss and other comprehensive income ‘for the comparable interim periods (current and year-to-date) of the immediately preceding financial year’ can give rise to diversity in practice in the case of an entity that changes its annual financial reporting date. For example, an entity changing its reporting date from 31 December to 31 March would change its half-yearly reporting date from 30 June to 30 September and therefore present its first half-yearly report after its new annual reporting date for the six month period from 1 April to 30 September. A ‘comparable’ comparative interim period in this scenario could be taken to mean the six months ended 30 September in the prior year, as illustrated in Example 34.4 below. [FRS 104.20].

The entity in the example above does not show information for the half-year ended 30 June 2018 as the comparative period, notwithstanding the fact that this period would have been the reporting date for the last published half-yearly report.

However, given the lack of clarity in FRS 104 as to the meaning of ‘comparable’ in the case where the current financial year runs for a period that is different to ‘the immediately preceding financial year’, other interpretations are possible.

7 MATERIALITY

In making judgements on recognition, measurement, classification, or disclosures in interim financial reports, the overriding goal in FRS 104 is to ensure that an interim financial report includes all information relevant to understanding an entity's financial position and performance during the interim period. [FRS 104.25]. The standard draws from Section 2 – Concepts and Pervasive Principles – of FRS 102 which defines an item as material if its omission or misstatement could influence the economic decisions of users of the financial statements, but does not contain quantitative guidance on materiality. [FRS 102.2.6]. FRS 104 requires materiality to be assessed based on the interim period financial data. [FRS 104.23].

Therefore, decisions on the recognition and disclosure of unusual items, changes in accounting policies or estimates, and errors are based on materiality in relation to the interim period figures to determine whether non-disclosure is misleading. [FRS 104.25].

Neither the previous year's financial statements nor any expectations of the financial position at the current year-end are relevant in assessing materiality for interim reporting. However, the standard adds that interim measurements may rely on estimates to a greater extent than measurements of annual financial data. [FRS 104.23].

8 RECOGNITION AND MEASUREMENT

The recognition and measurement requirements in FRS 104 arise mainly from the requirement to report the entity's financial position as at the interim reporting date, but also require certain estimates and measurements to take into account the expected financial position of the entity at year-end, where those measures are determined on an annual basis (as in the case of income taxes). Many preparers misinterpret this approach as representing some form of hybrid of the discrete and integral methods to interim financial reporting. This could cause confusion in application.

In requiring the year-to-date to be treated as a discrete period, FRS 104 prohibits the recognition or deferral of revenues and costs for interim reporting purposes unless such recognition or deferral is appropriate at year-end. As with a set of annual financial statements complying with FRS 102, FRS 104 requires changes in estimates and judgements reported in previous interim periods to be revised prospectively, whereas changes in accounting policies and corrections of material prior period errors are required to be recognised by prior period adjustment. However, FRS 104 allows looking beyond the interim reporting period, for example in estimating the tax rate to be applied on earnings for the period, when a year-to-date approach does not.

The recognition and measurement requirements of FRS 104 apply regardless of whether an entity presents a complete or condensed set of financial statements for an interim period, [FRS 104.7], and are discussed below.

8.1 Same accounting policies as in annual financial statements

The principles for recognising assets, liabilities, income and expenses for interim periods are the same as in the annual financial statements. [FRS 104.29]. Accordingly, an entity uses the same accounting policies in its interim financial statements as in its most recent annual financial statements, adjusted for accounting policy changes that will be reflected in the next annual financial statements. [FRS 104.28]. However, FRS 104 also states that the frequency of an entity's reporting (annual, half-yearly or quarterly) do not affect the measurement of its annual results. To achieve that objective, measurements for interim reporting purposes are on a year-to-date basis. [FRS 104.28A].

8.1.1 Measurement on a year-to-date basis

Measurement on a year-to-date basis acknowledges that an interim period is a part of a full year and allows adjustments to estimates of amounts reported in prior interim periods of the current year. [FRS 104.29].

The principles for recognition and the definitions of assets, liabilities, income and expenses for interim periods are the same as in the annual financial statements. [FRS 104.29, 31]. Therefore, for assets, the same tests of future economic benefits apply at interim dates as at year-end. Costs that, by their nature, do not qualify as assets at year-end, do not qualify for recognition at interim dates either. Similarly, a liability at the end of an interim reporting period must represent an existing obligation at that date, just as it must at the end of an annual reporting period. [FRS 104.32]. An essential characteristic of income and expenses is that the related inflows and outflows of assets and liabilities have already occurred. If those inflows or outflows have occurred, the related income and expense are recognised; otherwise they are not recognised. [FRS 104.33].

FRS 104 lists several circumstances that illustrate these principles:

  • inventory write-downs, impairments, or provisions for restructurings are recognised and measured on the same basis as at a year-end. Later changes in the original estimate are recognised in the subsequent interim period, either by recognising additional accruals or reversals of the previously recognised amount; [FRS 104.30(a)]
  • costs that do not meet the definition of an asset at the end of an interim period are not deferred in the statement of financial position, either to await information on whether it meets the definition of an asset, or to smooth earnings over interim periods within a year. [FRS 104.30(b)]. For example, costs incurred in acquiring an intangible asset before the recognition criteria in FRS 102 are met are expensed under Section 18 – Intangible Assets other than Goodwill. Only those costs incurred after the recognition criteria are met can be recognised as an asset; there is no reinstatement as an asset in a later period of costs previously expensed because the recognition criteria were not met at that time; [FRS 102.18.17] and
  • income tax expense is ‘recognised in each interim period based on the best estimate of the weighted-average annual income tax rate expected for the full financial year, using the tax rates and laws that have been enacted or substantively enacted at the end of an interim reporting period. Amounts accrued for income tax expense in one interim period may have to be adjusted in a subsequent interim period of that financial year if the estimate of the annual income tax rate changes’. [FRS 104.30(c)].

8.1.2 New accounting pronouncements and other changes in accounting policies

As noted at 8.1 above, an entity uses the same accounting policies in its interim financial statements as in its most recent annual financial statements, adjusted for accounting policy changes that will be reflected in the next annual financial statements. [FRS 104.28].

FRS 104 requires that a change in accounting policy, other than where the transition rules are specified by FRS 102, should be reflected by: [FRS 104.43]

  1. restating the financial statements of prior interim periods of the current year and the comparable interim periods of any prior financial years that will be restated in the annual financial statements under Section 10 – Accounting Policies, Estimates and Errors – of FRS 102; or
  2. when it is impracticable to determine the cumulative effect at the beginning of the year of applying a new accounting policy to all prior periods, adjusting the financial statements of prior interim periods of the current year and comparable interim periods of prior years to apply the new accounting policy prospectively from the earliest date practicable.

Therefore, regardless of when in a financial year an entity decides to adopt a new accounting policy, it has to be applied from the beginning of the current year. [FRS 104.44]. For example, if an entity that reports on a quarterly basis decides in its third quarter to change an accounting policy, it must restate the information presented in earlier quarterly financial reports to reflect the new policy as if it had been applied from the start of the annual reporting period. Disclosures regarding the restatement can be presented on the face of the financial statements or disclosed in the notes to the financial statements.

8.1.2.A Accounting policy changes becoming mandatory during the current year

One objective of the year-to-date approach, described at 8.1.2 above, is to ensure that a single accounting policy is applied to a particular class of transactions throughout an entire financial year. [FRS 104.44]. To allow accounting policy changes to be reflected as of an interim date would mean applying different accounting policies to a particular class of transactions within a single year. This would make interim allocation difficult, obscure operating results, and complicate analysis and understandability of the interim period information. [FRS 104.45].

Accordingly, when preparing interim financial information, consideration is given to which amendments to FRSs are mandatory in the next (current year) annual financial statements. The entity generally adopts these amendments in all interim periods during that year.

While FRS 104 generally prohibits an entity from reflecting the adoption of a new accounting policy as of an interim date, it makes an exception for those accounting policy changes for which FRS 102 specifically requires transition during the financial year. [FRS 104.43].

The disclosure requirements with respect to amendments which are effective for the entity's next annual financial statements, but which do not contain specific disclosure requirements under FRS 104, are not clear. In some cases, it might be determined that an understanding of an amendment is material to an understanding of the entity, in which case the entity discloses this fact, as well as information relevant to assessing the possible impact of the amendment on the entity's financial statements. [FRS 102.10.13]. In other cases, an entity might conclude that a particular amendment is not material to an understanding of its interim financial report, and thus not disclose information about the issuance of the amendment, or its possible impact on the entity.

8.1.2.B Voluntary changes of accounting policy

An entity can also elect at any time during a year to apply an amendment to an FRS before it becomes mandatory, or otherwise decide to change an accounting policy voluntarily. However, before voluntarily changing an accounting policy, consideration should be given to the interaction of the requirements of Sections 2 and 10 of FRS 102 which only permit an entity to change an accounting policy if the information results in information that is ‘reliable and more relevant’ to the users of the financial statements. [FRS 102.10.8(b)].

When it is concluded that a voluntary change in accounting policy is permitted and appropriate, its effect is generally reflected in the first interim report the entity presents after the date on which the entity changed its policy. The entity generally restates amounts reported in earlier interim periods as far back as is practicable. [FRS 104.44]. One exception to this principle of retrospective adjustment of earlier interim periods is when an entity changes from the cost model to the revaluation model under Section 17 or Section 18. These are not changes in accounting policy that are covered by FRS 102 in the usual manner, but instead are required to be treated as a revaluation in the period. [FRS 102.10.10A]. Therefore, the general requirements of FRS 104 do not override the specific requirements of Section 10 of FRS 102 to treat such changes prospectively.

However, to avoid using two differing accounting policies for a particular class of assets in a single financial year, consideration should be given to changing from the cost model to the revaluation model at the beginning of the financial year. Otherwise, an entity will end up depreciating based on cost for some interim periods and based on the revalued amounts for later interim periods.

8.1.3 Change in going concern assumption

Another situation in which an entity applies different accounting policies in its interim financial statements as compared to its most recent annual financial statements is when the going concern assumption is no longer appropriate.

Although FRS 104 does not specifically address the issue of going concern, the general requirements of Section 3 of FRS 102 apply to both a complete set and to condensed interim financial statements. Section 3 states that when preparing financial statements, management assesses an entity's ability to continue as a going concern, and that the financial statements are prepared on a going concern basis unless management either intends to liquidate the entity or cease trading, or has no realistic alternative but to do so. [FRS 102.3.8]. The going concern assessment is discussed in more detail in Chapter 6 at 9.3.

Under Section 3, the going concern assessment is made based on all available information about the future, which at a minimum is twelve months from the date when the financial statements are authorised for issue. [FRS 102.3.8]. Therefore, with respect to interim reporting under FRS 104, the minimum period for management's assessment is also at least twelve months from the date when the interim report is authorised for issue; it is not limited, for example, to one year from the authorisation date of the most recent annual financial statements.

If management becomes aware, in making its assessment, of material uncertainties related to events or conditions that may cast significant doubt upon the entity's ability to continue as a going concern, the entity should disclose those uncertainties. If the entity does not prepare financial statements on a going concern basis, it should disclose that fact, together with the basis on which it prepared the financial statements and the reason why the entity is not regarded as a going concern. [FRS 102.3.9].

8.1.4 Voluntary changes in presentation

In some cases, the presentation of the interim financial statements might be changed from that used in prior interim reporting periods. However, before changing the presentation used in its interim report from that of previous periods, management should consider the interaction of the requirements of FRS 104 to include in a set of condensed financial statements the same headings and sub-totals as the most recent annual financial statements, [FRS 104.10], and to apply the same accounting policies as the most recent or the next annual financial report, [FRS 104.28], and the requirements of Section 3 of FRS 102 as they will relate to those next annual financial statements. Section 3 states that an entity should retain the presentation and classification of items in the financial statements, unless it is apparent following a significant change in the nature of operations or a review of the financial statements that another presentation is more appropriate, or unless the change is required by FRS 102, or another applicable FRS. [FRS 102.3.11].

If a presentation is changed, the entity should also reclassify comparative amounts for both earlier interim periods of the current financial year and comparable periods in prior years. [FRS 104.43(a)]. In such cases, an entity should disclose the nature of the reclassifications, the amount of each item (or class of items) that is reclassified, and the reason for the reclassification. [FRS 102.3.12].

8.2 Seasonal businesses

Some entities do not earn revenues or incur expenses evenly throughout the year, for example, agricultural businesses, holiday companies, domestic fuel suppliers, or retailers who experience peak demand at Christmas. The financial year-end is often chosen to fit their annual operating cycle, which means that an individual interim period would give little indication of annual performance and financial position.

An extreme application of the integral approach would suggest that they should predict their annual results and contrive to report half of that in the half-year interim financial statements. However, this approach does not portray the reality of their business in individual interim periods, and is, therefore, not permitted under the year-to-date approach adopted in FRS 104. [FRS 104.28A].

8.2.1 Revenues received seasonally, cyclically or occasionally

FRS 104 prohibits the recognition or deferral of revenues that are received seasonally, cyclically or occasionally at an interim date, if recognition or deferral would not be appropriate at year-end. [FRS 104.37]. Examples of such revenues include dividend revenue, royalties, government grants, and seasonal revenues of retailers; such revenues are recognised when they occur. [FRS 104.38].

FRS 104 also requires an entity to explain the seasonality or cyclicality of its business and the effect on interim reporting. [FRS 104.16A(b)]. If businesses are highly seasonal, FRS 104 encourages reporting of additional information for the twelve months up to the end of the interim period and comparatives for the prior twelve-month period (see 6 above). [FRS 104.21].

8.2.2 Costs incurred unevenly during the year

FRS 104 prohibits the recognition or deferral of costs for interim reporting purposes if recognition or deferral of that type of cost is inappropriate at year-end, [FRS 104.39], which is based on the principle that assets and liabilities are recognised and measured using the same criteria as at the year-end. [FRS 104.29, 31]. This principle prevents smoothing of costs in seasonal businesses. Furthermore the recognition of assets or liabilities at the interim date would not be appropriate if they would not qualify for recognition at the end of an annual reporting period.

For direct costs, this approach has limited consequences, as the timing of recognising these costs and the related revenues is usually similar. However, for indirect costs, the consequences may be greater, depending on which section of FRS 102 an entity follows.

For example, manufacturing entities that use fixed production overhead absorption rates recognise an asset in respect of attributable overheads based on the normal capacity of the production facilities in accordance with Section 13 – Inventories. Any variances and unallocated overheads are expensed. [FRS 102.13.9].

The implications are unclear for professional service companies that recognise revenue under Section 23 – Revenue – using the percentage of completion method. On one hand, Section 23 includes the same guidance on the percentage of completion method for both construction contracts and service provision, [FRS 102.23.21], implying that both types of entity can defer costs and the related variances at the end of an interim reporting period. On the other hand, service providers might also follow the guidance in Section 13 which gives guidance for the cost of inventories of a service provider, and which results in expensing such costs and variances at the end of the reporting period. [FRS 102.13.14]. However, these are issues that an entity would also face at the end of an annual reporting period. What is clear is that an entity should not diverge from these requirements just because information is being prepared for an interim period.

9 EXAMPLES OF THE RECOGNITION AND MEASUREMENT PRINCIPLES

Appendix II of FRS 104 provides several examples that illustrate the recognition and measurement principles in interim financial reports. [FRS 104.40].

9.1 Property, plant and equipment and intangible assets

9.1.1 Depreciation and amortisation

Depreciation and amortisation for an interim period is based only on assets owned during that interim period and does not consider asset acquisitions or disposals planned for later in the year. [FRS 104 Appendix II.26].

An entity applying a straight-line method of depreciation (amortisation) does not allocate the depreciation (amortisation) charge between interim periods based on the level of activity. However, under Sections 17 and 18, an entity may use a ‘unit of production’ method of depreciation, which results in a charge based on the expected use or output (see Chapter 15 at 3.5.6.C and Chapter 16 at 3.4.3.B). An entity can only apply this method if it most closely reflects the expected pattern of consumption of the future economic benefits embodied in the asset. The chosen method should be applied consistently from period to period unless there is a change in the expected pattern of consumption of those future economic benefits. Therefore, an entity cannot apply a straight-line method of depreciation (amortisation) in its annual financial statements, while allocating the depreciation (amortisation) charge to interim periods using a ‘unit of production’ based approach.

9.1.2 Impairment of assets

Section 27 – Impairment of Assets – of FRS 102 requires an entity to recognise an impairment loss if the recoverable amount of an asset declines below its carrying amount. [FRS 104 Appendix II.37]. An entity should apply the same impairment testing, recognition, and reversal criteria at an interim date as it would at year-end. [FRS 104 Appendix II.38].

However, FRS 104 states that an entity is not required to perform a detailed impairment calculation at the end of each interim period. Rather, an entity should perform a review for indications of significant impairment since the most recent year-end to determine whether such a calculation is needed. [FRS 104 Appendix II.38]. Nevertheless, an entity is not exempt from performing impairment tests at the end of its interim periods. For example, an entity that recognised an impairment charge in the immediately preceding year, may find that it needs to update its impairment calculations at the end of subsequent interim periods because impairment indicators remain.

9.1.3 Recognition of intangible assets

An entity should apply the same definitions and recognition criteria for intangible assets, as set out in Section 18 of FRS 102, in an interim period as in an annual period. Therefore, costs incurred before the recognition criteria are met should be recognised as an expense. [FRS 104 Appendix II.10]. Expenditures on intangibles that are initially expensed cannot be reinstated and recognised as part of the cost of an intangible asset subsequently (e.g. in a later interim period). [FRS 102.18.17]. Furthermore, ‘deferring’ costs as assets in an interim period in the hope that the recognition criteria will be met later in the year is not permitted. Only costs incurred after the specific point in time at which the criteria are met should be recognised as part of the cost of an intangible asset. [FRS 104 Appendix II.10].

9.2 Employee benefits

9.2.1 Employer payroll taxes and insurance contributions

If employer payroll taxes or contributions to government-sponsored insurance funds are assessed on an annual basis, the employer's related expense should be recognised in interim periods using an estimated average annual effective rate, even if it does not reflect the timing of payments. A common example is an employer payroll tax or insurance contribution subject to a certain maximum level of earnings per employee. Higher income employees would reach the maximum income before year-end, and the employer would make no further payments for the remainder of the year. [FRS 104 Appendix II.3].

9.2.2 Year-end bonuses

The nature of year-end bonuses varies widely. Some bonus schemes only require continued employment whereas others require certain performance criteria to be attained on a monthly, quarterly, or annual basis. Payment of bonuses may be purely discretionary, contractual or based on years of historical precedent. [FRS 104 Appendix II.7]. A bonus is recognised for interim reporting if, and only if: [FRS 104 Appendix II.8]

  1. the entity has a present legal or constructive obligation to make such payments as a result of past events; and
  2. a reliable estimate of the obligation can be made.

A present obligation exists only when an entity has no realistic alternative but to make the payments. [FRS 102.21.6]. Section 28 of FRS 102 gives guidance on accounting for profit sharing and bonus plans (see Chapter 25 at 3.3).

In recognising a bonus at an interim reporting date, an entity should consider the facts and circumstances under which the bonus is payable, and determine an accounting policy that recognises an expense reflecting the obligation on the basis of the services received to date. Several possible accounting policies are illustrated in Example 34.6 below.

9.2.3 Pensions

Section 28 requires an entity to determine the present value of defined benefit obligations and the fair value of plan assets at the end of the reporting period. While Section 28 does not require an entity to involve a professionally qualified actuary in the measurement of the obligations, nor to undertake a comprehensive annual actuarial valuation, we expect that in practice most entities will do so.

For interim reporting purposes, the defined benefit obligation can often be reliably measured by extrapolation of the latest actuarial valuation adjusted for changes in employee demographics such as number of employees and salary levels. [FRS 104 Appendix II.42].

If there are significant changes to pension arrangements during the interim period (such as changes resulting from a material business combination or from a major redundancy programme) then entities may wish to consider whether they should obtain a new actuarial valuation of scheme liabilities. Similarly, if there are significant market fluctuations, such as those arising from changes in corporate bond markets, the validity of the assumptions in the last actuarial estimate, such as the discount rate applied to scheme liabilities, should be reviewed and revised as appropriate.

Market values of plan assets as at the interim reporting date should be available without recourse to an actuary and in normal circumstances, companies will not necessarily go through the full process of measuring pension liabilities at interim reporting dates, but rather will look to establish a process to assess the impact of any changes in underlying parameters (e.g. through extrapolation). As with all estimates, the appropriateness in the circumstances should be considered.

9.2.4 Vacations, holidays and other short-term paid absences

Section 28 distinguishes between accumulating and non-accumulating paid absences. [FRS 102.28.6-7]. Accumulating paid absences are those that are carried forward and can be used in future periods if the current period's entitlement is not used in full. Section 28 requires an entity to measure the expected cost of and obligation for accumulating paid absences at the amount the entity expects to pay as a result of the unused entitlement that has accumulated at the end of the reporting period (see Chapter 25 at 3.3). FRS 104 requires the same principle to be applied at the end of interim reporting periods. Conversely, an entity should not recognise an expense or liability for non-accumulating paid absences at the end of an interim reporting period, just as it would not recognise any at the end of an annual reporting period. [FRS 104 Appendix II.12].

9.3 Inventories and cost of sales

9.3.1 Inventories

The recognition and measurement principles of Section 13 are applied in the same way for interim financial reporting as for annual reporting purposes. At the end of any financial reporting period an entity would determine inventory quantities, costs and net realisable values. However, FRS 104 does comment that to save cost and time, entities often use estimates to measure inventories at interim dates to a greater extent than at annual reporting dates. [FRS 104 Appendix II.27].

Net realisable values are determined using selling prices and costs to complete and dispose at the end of the interim period. A write-down should be reversed in a subsequent interim period only if it would be appropriate to do so at year-end. See Chapter 11 at 3.4.2. [FRS 104 Appendix II.28].

9.3.2 Contractual or anticipated purchase price changes

Both the payer and the recipient of volume rebates, or discounts and other contractual changes in the prices of raw materials, labour, or other purchased goods and services should anticipate these items in interim periods if it is probable that these have been earned or will take effect. However, discretionary rebates and discounts should not be recognised because the resulting asset or liability would not meet the recognition criteria in FRS 102. [FRS 104 Appendix II.25].

9.3.3 Interim period manufacturing cost variances

Price, efficiency, spending and volume variances of a manufacturing entity should be recognised in profit or loss at interim reporting dates to the same extent that those variances are recognised at year-end. It is not appropriate to defer variances expected to be absorbed by year-end, which could result in reporting inventory at the interim date at more or less than its actual cost. [FRS 104 Appendix II.30]. See 8.2.2 above for a discussion on this topic as it applies to costs incurred by service providers.

9.4 Taxation

Taxation is one of the most difficult areas of interim financial reporting, primarily because FRS 104 does not clearly distinguish between current income tax and deferred tax, referring only to ‘income tax expense’. This causes tension between the approach for determining the expense and the asset or liability in the statement of financial position. In addition, the standard's provisions combine terminology, suggesting an integral approach with guidance requiring a year-to-date basis to be applied. The integral method is used in determining the effective income tax rate for the whole year, but that rate is applied to year-to-date profit in the interim financial statements. In addition, under a year-to-date basis, the estimated rate is based on tax rates and laws that are enacted or substantively enacted by the end of the interim period. Changes in legislation expected to occur before the end of the current year are not recognised in preparing the interim financial report. The assets and liabilities in the statement of financial position, at least for deferred taxes, are derived solely from a year-to-date approach, but sometimes the requirements of the standard are unclear, as discussed below.

9.4.1 Measuring interim income tax expense

FRS 104 states that income tax expense should be accrued using the tax rate applicable to expected total annual earnings, by applying the estimated weighted-average annual effective income tax rate to pre-tax income for the interim period. [FRS 104 Appendix II.14]. However, this is not the same as estimating the total tax expense for the year and allocating a proportion of that to the interim period (even though it might sometimes appear that way), as demonstrated in the discussion below.

Because taxes are assessed on an annual basis, using the integral approach to determine the annual effective income tax rate and applying it to year-to-date actual earnings is consistent with the basic concept in FRS 104, that the same recognition and measurement principles apply in interim financial reports as in annual financial statements. [FRS 104 Appendix II.15].

In estimating the weighted-average annual income tax rate, an entity should consider the progressive tax rate structure expected for the full year's earnings, including changes in income tax rates scheduled to take effect later in the year that are enacted or substantively enacted as at the end of the interim period. [FRS 104 Appendix II.15]. This situation is illustrated in Example 34.7 below which is based on the example in paragraph 17 of Appendix II to FRS 104.

In the above example, it might look as if the interim income tax expense is calculated by dividing the total expected tax expense for the year (10,000) by the number of interim reporting periods (4). However, this is only the case in this example because profits are earned evenly over each quarter. The expense is actually calculated by determining the effective annual income tax rate and multiplying that rate to year-to-date earnings, as illustrated in Example 34.8 below which is based on the example in paragraph 18 of Appendix II to FRS 104.

The above example shows how an expense is recognised in periods reporting a profit and a credit is recognised when a loss is incurred. This result is very different from allocating a proportion of the expected total income tax expense for the year, which in this case is zero.

If an entity operates in a number of tax jurisdictions, or where different income tax rates apply to different categories of income (such as capital gains or income earned in particular industries), the standard requires that to the extent practicable, an entity: [FRS 104 Appendix II.16]

  • estimates the average annual effective income tax rate for each taxing jurisdiction separately and applies it individually to the interim period pre-tax income of each jurisdiction; and
  • applies different income tax rates to each individual category of interim period pre-tax income.

This means that the entity should perform the analysis illustrated in Example 34.8 above for each tax jurisdiction and arrive at an interim tax charge by applying the tax rate for each jurisdiction to actual earnings from each jurisdiction in the interim period. However, the standard recognises that, whilst desirable, such a degree of precision may not be achievable in all cases and allows using a weighted-average rate across jurisdictions or across categories of income, if such rate approximates the effect of using rates that are more specific. [FRS 104 Appendix II.16].

By performing a separate analysis for each jurisdiction, the entity determines an interim tax expense of £977,000, giving an effective average tax rate of 26.2% (£97,000 ÷ £370,000). Had the entity used a weighted-average rate across jurisdictions, using the expected annual earnings, it would have determined an effective tax rate of 28.7% (£215,000 ÷ £750,000), resulting in a tax expense for the interim period of £106,190 (370,000 @ 28.7%). Whether the difference of over £9,000 lies within the range for a reasonable approximation is a matter of judgement.

9.4.2 Changes in the effective tax rate during the year

9.4.2.A Enacted changes for the current year that apply after the interim reporting date

As noted above, the estimated income tax rate applied in the interim financial report should reflect changes that are enacted or substantively enacted as at the end of the interim reporting period, but scheduled to take effect later in the year. [FRS 104 Appendix II.15]. Tax rates can be regarded as substantively enacted when the remaining stages of the enactment process historically have not affected the outcome and are unlikely to do so. In particular, a UK tax rate is regarded as having been substantively enacted if it is included in: [FRS 104 Appendix I]

  • a Bill that has been passed by the House of Commons and is awaiting only passage through the House of Lords and Royal Assent; or
  • a resolution having statutory effect that has been passed under the Provisional Collection of Taxes Act 1968.

A Republic of Ireland tax rate can be regarded as having been substantively enacted if it is included in a Bill that has been passed by the Dáil.

For example, assume that the 30% tax rate (on earnings above £20,000) in Example 34.7 was substantively enacted as at the second quarter reporting date and applicable before year-end. In that case, the estimated income tax rate for interim reporting would be the same as the estimated average annual effective income tax rate computed in that example (i.e. 25%) after considering the higher rate, even though the entity's earnings are not above the required threshold at the half-year.

If legislation is enacted only after the end of the interim reporting period but before the date of authorisation for issue of the interim financial report, its effect is disclosed as a non-adjusting event. [FRS 102.32.11(h)]. Under Section 32 – Events after the End of the Reporting Period – of FRS 102 estimates of tax rates and related assets or liabilities are not revised. [FRS 102.32.6].

9.4.2.B Changes to previously reported estimated income tax rates for the current year

FRS 104 requires an entity to re-estimate at the end of each interim reporting period the estimated average annual income tax rate on a year-to-date basis. [FRS 104 Appendix II.15]. Accordingly, the amounts accrued for income tax expense in one interim period may have to be adjusted in a subsequent interim period if that estimate changes. [FRS 104.30(c)]. FRS 104 requires disclosure in interim financial statements of material changes in estimates of amounts reported in prior interim periods of the current financial year or changes in estimates of amounts reported in prior financial years. [FRS 104.16A(d)].

Accordingly, just as the integral approach does not necessarily result in a constant tax charge in each interim reporting period, it also does not result in a constant effective tax rate when circumstances change.

9.4.2.C Enacted changes applying only to subsequent years

In many cases, tax legislation is enacted that takes effect not only after the interim reporting date but also after year-end. Such circumstances are not addressed explicitly in the standard. As FRS 104 does not clearly distinguish between current income tax and deferred tax, combined with the different approaches taken in determining the expense recognised in profit or loss compared to the statement of financial position, these issues can lead to confusion in this situation.

On the one hand, the standard states that the estimated income tax rate for the interim period includes enacted or substantively enacted changes scheduled to take effect later in the year. [FRS 104 Appendix II.15]. This implies that the effect of changes that do not take effect in the current year is ignored in determining the appropriate rate for current tax. On the other hand, FRS 104 also requires that the principles for recognising assets, liabilities, income and expenses for interim periods are the same as in the annual financial statements. [FRS 104.29]. In annual financial statements, deferred tax is measured at the tax rates expected to apply to the period when the asset is realised or the liability is settled, based on tax rates (and tax laws) enacted or substantively enacted by the end of the reporting period, as required by FRS 102. [FRS 102.29.12]. Therefore, an entity should recognise the effect of a change applying to future periods if this change is enacted by the end of the interim reporting period.

These two requirements seem to be mutually incompatible. FRS 104 makes sense only in the context of calculating the effective current tax rate on income earned in the period. Once a deferred tax asset or liability is recognised, it should be measured under Section 29 – Income Tax. Therefore, an entity should recognise an enacted change applying to future years in measuring deferred tax assets and liabilities as at the end of the interim reporting period. One way to treat the cumulative effect to date of this remeasurement is to recognise it in full, by a credit to profit or loss or to other comprehensive income, depending on the nature of the temporary difference being remeasured, in the period during which the tax legislation is enacted, in a similar way to the treatment shown in Example 34.10 above, and as illustrated in Example 34.11 below.

Alternatively, if the effective current tax rate is not distinguished from the measurement of deferred tax, it could be argued that FRS 104 allows the reduction in the deferred tax liability of 16 (300 – 284) to be included in the estimate of the effective income tax rate for the year. Approach 2 in Example 34.14 below applies this argument. In our view, because FRS 104 does not distinguish between current and deferred taxes, either approach would be acceptable provided that it is applied consistently.

9.4.3 Difference in financial year and tax year

If an entity's financial year and the income tax year differ, the income tax expense for the interim periods of that financial year should be measured using separate weighted-average estimated effective tax rates for each of the income tax years applied to the portion of pre-tax income earned in each of those income tax years. [FRS 104 Appendix II.19]. In other words, an entity should compute a weighted-average estimated effective tax rate for each income tax year, rather than for its financial year.

9.4.4 Tax loss and tax credit carrybacks and carryforwards

FRS 104 repeats the requirement in Section 29 of FRS 102 that for carryforwards of unused tax losses, a deferred tax asset should be recognised to the extent that it is probable that they will be recovered against the reversal of deferred tax liabilities or other future taxable profits. [FRS 104 Appendix II.23]. In assessing whether future taxable profit is available, the criteria in Section 29 are applied at the interim date. If these criteria are met as at the end of the interim period, the effect of the tax loss carryforwards is included in the estimated average annual effective income tax rate.

This result is consistent with the general approach for measuring income tax expense in the interim report, in that any entitlement for relief from current tax due to carried forward losses is determined on an annual basis. Accordingly, its effect is included in the estimate of the average annual income tax rate and not, for example, by allocating all of the unutilised losses against the earnings of the first quarter to give an income tax expense of zero in the first quarter and 4,000 thereafter.

In contrast, the year-to-date approach of FRS 104 means that the benefits of a tax loss carryback are recognised in the interim period in which the related tax loss occurs, [FRS 104 Appendix II.22], and are not included in the assessment of the estimated average annual tax rate, as shown in Example 34.8 above. This approach is consistent with Section 29 of FRS 102 which requires the benefit of a tax loss that can be carried back to recover current tax already incurred in a previous period to be recognised as an asset. [FRS 102.29.4]. Therefore, a corresponding reduction of tax expense or increase of tax income is also recognised. [FRS 104 Appendix II.22].

Where previously unrecognised tax losses are expected to be utilised in full in the current year, it seems intuitive to recognise the recovery of those carried forward losses in the estimate of the average annual tax rate, as shown in Example 34.12 above. However, where the level of previously unrecognised tax losses exceeds expected taxable profits for the current year, a deferred tax asset should be recognised for the carried forward losses that are now expected to be utilised, albeit in future years.

The examples in FRS 104 do not show how such a deferred tax asset is created in the interim financial report. In our view, two approaches are acceptable, as shown in Example 34.14 below.

Approach 1 is consistent with the requirements of Section 29 as it results in recognising the full expected deferred tax asset as soon as it becomes ‘probable that they will be recovered against the reversal of deferred tax liabilities or other future taxable profits’. [FRS 102.29.7]. However, given that FRS 104 does not specifically address this situation, and is unclear about whether the effective tax rate reflects changes in the assessment of the recoverability of carried forward tax losses, we also believe that Approach 2 is acceptable.

9.4.5 Tax credits

FRS 104 also discusses in more detail the treatment of tax credits, which may for example be based on amounts of capital expenditures, exports, or research and development expenditures. Such benefits are usually granted and calculated on an annual basis under tax laws and regulations and therefore are reflected in the estimated annual effective income tax rate used in the interim report. However, if tax benefits relate to a one-time event, they should be excluded from the estimate of the annual rate and deducted separately from income tax expense in that interim period. [FRS 104 Appendix II.21].

9.5 Foreign currency translation

9.5.1 Foreign currency translation gains and losses

An entity measures foreign currency translation gains and losses for interim financial reporting using the same principles that Section 30 – Foreign Currency Translation – of FRS 102 requires at year-end (see Chapter 27). [FRS 104 Appendix II.31]. An entity should use the actual average and closing foreign exchange rates for the interim period (i.e. it may not anticipate changes in foreign exchange rates for the remainder of the current year in translating at an interim date). [FRS 104 Appendix II.32]. When Section 30 requires translation adjustments to be recognised as income or expense in the period in which they arise, the same approach should be used in the interim report. An entity should not defer some foreign currency translation adjustments at an interim date, even if it expects the adjustment to reverse before year-end. [FRS 104 Appendix II.33].

9.5.2 Interim financial reporting in hyperinflationary economies

Interim financial reports in hyperinflationary economies are prepared using the same principles as at year-end. [FRS 104 Appendix II.34]. Section 31 – Hyperinflation – of FRS 102 requires that the financial statements of an entity that reports in the currency of a hyperinflationary economy be stated in terms of the measuring unit current at the end of the reporting period, and the gain or loss on the net monetary position be included in profit or loss. In addition, comparative financial data reported for prior periods should be restated to the current measuring unit (see Chapter 28). [FRS 104 Appendix II.35]. As shown in Examples 34.2 and 34.3 above, FRS 104 requires an interim report to contain many components, which are all restated to the current measuring unit at every interim reporting date.

The measuring unit used is that as of the end of the interim period, with the resulting gain or loss on the net monetary position included in that period's net income. An entity may not annualise the recognition of gains or losses, nor may it estimate an annual inflation rate in preparing an interim financial report in a hyperinflationary economy. [FRS 104 Appendix II.36].

While it is highly unlikely for a UK company to have the functional currency of a hyperinflationary economy, a UK based group may prepare consolidated financial statements under FRS 102 with a subsidiary that operates in, and has a functional currency of, a country subject to hyperinflation.

9.6 Provisions, contingencies and accruals for other costs

9.6.1 Provisions

FRS 104 requires an entity to apply the same criteria for recognising and measuring a provision at an interim date as it would at year-end. [FRS 104 Appendix II.6]. Hence, an entity should recognise a provision when it has no realistic alternative but to transfer economic benefits because of an event that has created a legal or constructive obligation. [FRS 104 Appendix II.5]. FRS 104 emphasises that the existence or non-existence of an obligation to transfer benefits is a question of fact, and does not depend on the length of the reporting period. [FRS 104 Appendix II.6].

The obligation is adjusted upward or downward at each interim reporting date, if the entity's best estimate of the amount of the obligation changes. The standard states that any corresponding loss or gain should normally be recognised in profit or loss. [FRS 104 Appendix II.5]. However, an entity applying IFRIC 1 – Changes in Existing Decommissioning, Restoration and Similar Liabilities – under the hierarchy in Section 10 (see Chapter 15 at 3.4.3) might instead need to adjust the carrying amount of the corresponding asset rather than recognise a gain or loss.

9.6.2 Other planned but irregularly occurring costs

Many entities budget for costs that they expect to incur irregularly during the year, such as advertising campaigns, employee training and charitable contributions. Even though these costs are planned and expected to recur annually, they tend to be discretionary in nature. Therefore, it is generally not appropriate to recognise an obligation at the end of an interim financial reporting period for such costs that are not yet incurred, as they do not meet the definition of a liability. [FRS 104 Appendix II.13].

As discussed at 8.2.2 above, FRS 104 prohibits the recognition or deferral of costs incurred unevenly throughout the year at the interim date if recognition or deferral would be inappropriate at year-end. [FRS 104.39]. Accordingly, such costs should be recognised as they are incurred and an entity should not recognise provisions or accruals in the interim report to adjust these costs to their budgeted amount.

9.6.3 Major planned periodic maintenance or overhaul

The cost of periodic maintenance, a planned major overhaul, or other seasonal expenditures expected to occur after the interim reporting date should not be recognised for interim reporting purposes unless an event before the end of the interim period causes the entity to have a legal or constructive obligation. The mere intention or necessity to incur expenditures in the future is not sufficient to recognise an obligation as at the interim reporting date. [FRS 104 Appendix II.4]. Similarly, an entity may not defer and amortise such costs if they are incurred early in the year, but do not satisfy the criteria for recognition as an asset as at the interim reporting date.

9.6.4 Contingent lease payments

Contingent lease payments can create legal or constructive obligations that are recognised as liabilities. If a lease includes contingent payments based on achieving a certain level of annual sales (or annual use of the asset), an obligation can arise in an interim period before the required level of annual sales (or usage) is achieved. If the entity expects to achieve the required level of annual sales (or usage), it should recognise a liability as it has no realistic alternative but to make the future lease payment. [FRS 104 Appendix II.9].

9.6.5 Levies charged by public authorities

When governments or other public authorities impose levies on entities in relation to their activities, as opposed to income taxes, it is not always clear when the liability to pay a levy arises and a provision should be recognised. As there is no specific guidance on accounting for such provisions under FRS 102, entities may, under the hierarchy set out in Section 10, refer to the guidance in IFRIC 21 – Levies – in formulating an appropriate accounting policy for these obligations.

9.7 Earnings per share

As noted at 3.3 above, FRS 104 requires that where an entity has presented EPS information in accordance with IAS 33 – Earnings per Share (as adopted in the EU) in its most recent annual financial statements, then it will present basic and diluted EPS in its interim financial statements. [FRS 104.11]. EPS in an interim period is computed in the same way as for annual periods. However, IAS 33 does not allow diluted EPS of a prior period to be restated for subsequent changes in the assumptions used in those EPS calculations. [IAS 33.65]. This approach might be perceived as inconsistent to the year-to-date approach which should be followed for computing EPS for an interim period. For example, if an entity, reporting quarterly, computes diluted EPS in its first quarter financial statements, it cannot restate the reported diluted EPS subsequently for any changes in the assumptions used. However, following a year-to-date approach, the entity should consider the revised assumptions to compute the diluted EPS for the six months in its second quarter financial statements, which, in this case would not be the sum of its diluted EPS for first quarter and the second quarter.

10 USE OF ESTIMATES

FRS 104 requires that the measurement procedures followed in an interim financial report should be designed to ensure that the resulting information is reliable and that all material financial information that is relevant to an understanding of the financial position or performance of the entity is appropriately disclosed. Whilst estimation is necessary in both interim and annual financial statements, the standard recognises that preparing interim financial reports generally requires greater use of estimation methods than at year-end. [FRS 104.41]. Consequently, the measurement of assets and liabilities at an interim date may involve less use of outside experts in determining amounts for items such as provisions, contingencies, pensions or non-current assets revalued at fair values. Reliable measurement of such amounts may simply involve updating the previously reported year-end position. The procedures may be less rigorous than those at year-end. The example below is based on Appendix II to FRS 104. [FRS 104 Appendix II.39-47].

Although an entity is not required to use professionally qualified valuers at interim reporting dates, and may only update the previous year-end position, the entity is required to recognise impairments in the appropriate interim period.

11 FIRST-TIME PRESENTATION OF INTERIM REPORTS COMPLYING WITH FRS 104

FRS 104 defines ‘interim period’ as a financial reporting period shorter than a full financial year, [FRS 104 Appendix I], and requires the format of condensed financial statements for an interim period to include each of the headings and subtotals that were included in the entity's most recent annual financial statements. [FRS 104.10].

However, FRS 104 provides no guidance for an entity that chooses to issue condensed interim financial statements before it has prepared a set of FRS 102 compliant annual financial statements. This situation will arise in the entity's first year of existence. Whilst FRS 104 does not prohibit the entity from preparing a condensed set of interim financial statements, it does not specify how an entity would interpret the minimum disclosure requirements of FRS 104 when there are no annual financial statements to refer to.

The entity should consider making additional disclosures to recognise that a user of this first set of interim financial statements does not have the access otherwise assumed to the most recent annual financial report of the entity. Accordingly, the explanation of significant events and transactions and changes in financial position in the period should be more detailed than the update normally expected in FRS 104. [FRS 104.15]. In the absence of any specific regulatory requirements to which the entity is subject, the following are examples of additional considerations that would apply:

  • since it is not possible to make a statement that the same accounting policies and methods of computation have been applied, [FRS 104.16A(a)], the entity should disclose all those accounting policies and methods of computation in the same level of detail as it would in a set of annual financial statements. When the entity issues interim reports on a quarterly basis, the first quarter interim report should provide the abovementioned details; subsequent quarterly reports could refer to the details included in the first quarter report;
  • similarly, the disclosure of the nature and amount of changes in estimates of amounts reported in prior periods will have to go into more detail than just the changes normally required to be disclosed; [FRS 104.16A(d)]
  • more extensive disclosure than simply the changes since the last report date will be required for contingent liabilities and contingent assets; [FRS 104.15B(m)] and
  • in the absence of a complete set of annual financial statements complying with FRS 102, the entity should include each of the headings and subtotals in the condensed financial statements that it would expect to include in its first financial statements prepared under FRS 102.

Entities that have transitioned from another financial reporting framework to FRS 102 and have not yet published FRS 102 annual financial statements are required to make additional disclosures when presenting interim reports in accordance with FRS 104: [FRS 104.16B]

  • a description of the nature of each change in accounting policy;
  • a reconciliation of its equity determined in accordance with its previous financial reporting framework to its equity determined in accordance with the new financial reporting framework for the following dates:
    • the date of transition to the new financial reporting framework; and
    • at the end of the comparable year to date period of the immediately preceding financial year; and
  • a reconciliation of profit or loss determined in accordance with its previous financial reporting framework for the comparable interim period (current and if different year-to-date) of the immediately preceding financial year.

If an entity becomes aware of errors made under its previous financial reporting framework, the reconciliations above shall, to the extent practicable, distinguish the correction of those errors from changes in accounting policies. For an entity converting to FRS 102 in their next annual financial statements, the requirements of Section 35 – Transition to this FRS –should be applied. Those requirements, which include the reconciliations above, are discussed in Chapter 32.

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