applying ifrs power-utilities

8/10/2019 Applying IFRS Power-Utilities

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12011 Europe, Middle East, India and Africa

tax policy outlook

Applying IFRS in Power & Utilities

The revised revenue

recognition proposal power and utilities

March 2012

IASB proposed standard


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What you need to know

The IASB and the FASB have issued a second exposure draft of

their converged revenue model that is closer to current IFRS

and US GAAP than their 2010 proposal.

The proposed model would apply to revenue from contracts with

customers and would replace all the revenue standards and

interpretations in IFRS, including IFRIC 18 Transfers of Assets

from Customers

Although the proposed model is not expected to have a

signicant impact on many transactions within the industry,

the effect on certain arrangements that are common for P&U

entities is still unclear.

The proposal will signicantly increase the volume of nancial

statement disclosures.

The IASB and FASB will hold outreach events to gather

feedback. P&U entities should review the proposal and share

any concerns with the IASB and FASB.

The revised revenue recognition proposal issued by the

International Accounting Standards Board (IASB) and the

Financial Accounting Standards Board (FASB) (collectively, the

Boards) could result in changes in current practice for the timing

and amount of revenue recognition for power and utilities (P&U)

entities. In particular, we focus on the following key areas in this

publication:

Accounting for contract modications

Assessing whether goods and services are distinct andidentifying separate performance obligations

Allocating the transaction price for power purchase

arrangements and other long-term utility contracts

Take-or-pay arrangements

The issues discussed here are intended to provoke thought and

to assist entities in formulating ongoing feedback to the Boards

that can help in the development of a high-quality nal

standard. Nevertheless, these discussions do not represent

our nal or formal views as the elements of the Exposure Draft

(ED) are subject to change and additional issues may be

identied on further deliberations by the Boards before a nal

standard is issued.

This publication supplements the more comprehensive analysis

of the revised revenue recognition proposal, which is discussed

in our publication entitled Revenue from contracts with

customers the revised proposal (general Applying IFRS). Our

general Applying IFRS also highlights some issues for entities

to consider in evaluating the impact of the ED and some of the

expected changes to current IFRS.

Introduction


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3Applying IFRS in Power & Utilities The revised revenue recognition proposal power and utilities

Contents

Overview and scope 3

Contracts in the scope of multiple IFRSs 3

Collaborative arrangements 4

Step 1: Identify the contract(s) with a customer 4

Existence of a contract 4

Contract modications 5

Step 2: Identify the separate performance obligations 8

Green or renewable certicates 8

Long-term service arrangements 9

Step 3: Determine the transaction price 9

Variable consideration 9

Contributions from customers and upfront fees 10

Time value of money 11

Step 4: Allocate the transaction price to separate performance obligations 11

Determining the standalone selling price 11

Contingent consideration 14

Step 5: Recognise revenue when the entity satises each performance obligation 15

Performance obligations satised over time 15

Constraining the cumulative amount of revenue recognised 16

Other recognition and measurement concerns 16

Take or pay arrangements 16

Onerous performance obligations 18

Disclosures 18

Next steps 18


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Applying IFRS in Power & Utilities The revised revenue recognition proposal power and utilities3

Overview and scopeThe Boards proposal species the accounting for all revenue

arising from contracts with customers and affects all entities that

enter into contracts to provide goods or services to their

customers, unless those contracts are in the scope of other IFRS

requirements.

The principles in the proposed standard would be applied using the

following ve steps:

1. Identify the contract(s) with a customer

2. Identify the separate performance obligations in the

contract(s)

3. Determine the transaction price

4. Allocate the transaction price to the separate performance

obligations

5. Recognise revenue when the entity satises each

performance obligationThe proposed standard would also apply to the measurement and

timing of the recognition of gains and losses on the sale of certain

non-nancial assets, such as property, plant and equipment.

Under the proposal, entities would need to exercise judgement

when considering specic facts and circumstances reected in the

written and implied terms of contracts with customers. Entities

would also have to apply the requirements of the proposal

consistently to contracts with similar characteristics and in similar

circumstances. A complete discussion of the proposed standard

related to accounting for contract(s) with a customer can be found

inApplying IFRS: Revenue from contracts with customers the

revised proposal(January 2012) (general Applying IFRS).1

The Boards are proposing that entities adopt the new standard

retrospectively for all periods presented in the period of adoption,

although the ED provides some limited relief from full retrospective

adoption. We expect the effective date would be no earlier than

annual periods beginning on or after 1 January 2015. The Boards

will determine the exact date of adoption during further

redeliberations.

Contracts in the scope of multiple IFRSs

P&U entities often enter into transactions that would be partially

within the scope of the proposed revenue recognition standard and

partially within the scope of another standard (i.e., embedded

derivatives, leases and service concessions).

Generally, entities entering into transactions that fall within the

scope of multiple accounting standards currently separate those

transactions into the individual elements to account for them under

the respective standard(s). The ED does not propose to change this

practice. However, the ED does clarify that any separation and

measurement guidance in other applicable IFRSs takes precedence

over the model in this ED. Accordingly, if the other standard does

not specify how to separate and/or initially measure any parts of

the contract, the entity would apply the proposed standard to

separate and/or initially measure those parts of the contract.

A further consideration is the interaction between the proposed

revenue recognition model and the proposed lease model. Although

the criteria for determining what is or is not a lease are not

expected to change signicantly under the proposed leasing ED,

this assessment will take on increased importance as operating

leases are moved onto the balance sheet.

The current accounting for operating leases and service contracts

is often similar. Therefore, entities may not have differentiated

arrangements which were service contracts and operating leases.

Consequently, it is possible that not all embedded leases that exist

within arrangements have been identied, extracted and/or

accounted for as such.

Given the proposed accounting for operating leases is expected

to be completely different from current standards, the

assessment of whether an arrangement is a service contract or

an operating lease will have signicantly different accounting

implications. As a result, P&U entities may need to evaluate

current and future contracts more closely.

How we see it

1Available at ey.com/ifrs.


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Applying IFRS in Power & Utilities The revised revenue recognition proposal power and utilities 4

Collaborative arrangements

The ED also explains that a counterparty to a contract may not

always be a customer. Instead, the counterparty may be a

collaborator or partner that shares in the risks and benets of

developing a product to be sold. Contracts with collaborators or

partners are sometimes observed in the P&U industry. For example,

where two parties collaborate in the development and operation of

a power plant and one of the parties in the arrangement purchasesan amount of the power produced.

The Boards indicated that revenue could be recognised from

transactions with partners or participants in a collaborative

arrangement only if the other party to the arrangement meets the

denition of a customer. However, the Boards decided not to

provide further guidance to clarify whether parties to these

arrangements would meet the denition of a customer.

In the Basis for Conclusions to the ED, the Boards explain that it

would not be possible to provide application guidance that applies

to all collaborative arrangements. Therefore, the parties to

the arrangement would need to consider all of the facts and

circumstances to determine whether a supplier/customer

relationship exists that would be subject to the proposed standard.

Step 1: Identify the contract(s)with a customerTo apply the proposed model, an entity must rst identify the

contract, or contracts, to provide goods and services to its

customer. Any contracts that create enforceable rights and

obligations would fall within the scope of the proposed standard.The enforceable rights and obligations may be written, oral or

implied by the entitys customary business practice.

Generally, the step for identifying the contract with the customer

would not differ signicantly from current practice in

the P&U industry. For example, the proposed requirement for

combining two or more contracts entered into with the same

customer at, or near, the same point in time into a single contract

for accounting purposes is consistent with existing standards.

However, there could be differences for P&U entities in determining

whether a contract exists, as well as the accounting for contract

modications.

Existence of a contract

Termination clauses are an important consideration when

determining whether a contract exists for the P&U industry. Any

arrangement in which the vendor has not provided any of the

contracted goods or services and has not received, or is not entitled

to receive, any of the contracted consideration is considered to be

a wholly unperformed contract. If each party has the unilateral

right to terminate a wholly unperformed contract without

compensating the counterparty, then the ED states that a contract

does not exist and its accounting and disclosure requirements

would not apply.

The proposed standard is clear that contracts amongst

collaborators in which the counterparty is not a customer

are out of the scope of the proposed standard. As no

new application guidance is being provided for these

arrangements, we believe that entities will likely reach similar

conclusions as today about whether a contract is a revenue-

generating transaction or an arrangement with a collaborator

or a partner. Many entities account for those transactions inaccordance with, or by analogy to, the current revenue

recognition standards. However, it is not clear if the removal

of these transactions from the scope of the revenue standard

would prohibit companies from using the revenue standard

by analogy.

How we see it

If each party has the unilateral right to terminate a whollyunperformed contract without compensating the counterparty,

then the proposed standard states that a contract does not existand its accounting and disclosure requirements would not apply.


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Contract modifications

Contract modications are a common occurrence in the P&U

industry. In many cases, the modication will extend the period

of the contract combined with changing the contract price. For

example, a P&U entity might decide to extend the period of a

contract and create a blended price for the remaining units of the

extended contract period. In some cases, this blended price would

reect the pricing for the remaining undelivered units in the

original contract combined with a separate price for the additional

units added to the contract. In other cases, there may be additional

factors used in determining the modied contract price.

When a contract is modied, entities would rst need to determine

if the contract modication represents a separate contract or a

modication of the existing contract when additional goods or

services are to be provided. A contract modication is deemed to

be a separate contract if both of the following criteria are met:

The additional goods or services are distinct

And

The price of the additional goods or services reects the

standalone selling price and any appropriate adjustments to that

price to reect the circumstances of the particular contract

If it is determined that the modication is not a separate contract,

an entity would account for the effects of these modications

differently, depending on which of the following scenarios is

most applicable:

1. The goods and services not yet provided are distinct from the

goods and services provided before the modication of the

contract.

2. The goods and services not yet provided are not distinct from

the goods and services provided before the modication of thecontract (i.e., all promised goods are part of a single

performance obligation).

3. The goods and services not yet provided are a combination of

1 and 2 above.

Contract modications that modify or remove previously agreed to

goods and services would not be treated as separate contracts.

However, as long as the modied goods and services are distinct

from the goods and services provided before the modication, the

entity would treat the contract modication as the termination of

the old contract and the creation of a new contract for all remaining

unsatised performance obligations.

Although this may sound straight forward, the assessment of

modications could require the application of judgement,

particularly in determining whether the additional consideration

reects the standalone selling price of the additional goods or

services. This is illustrated in the example on the following page.

Illustration 1 Wholly unperformed supply contractEntity A enters into a one-year contract to supply electricity

to Customer B at a monthly xed price per megawatt hour

(MWh). If the contract does not include a minimum contracted

volume that Customer B is required to purchase, and there is

no penalty within the contract for non-delivery by Entity A or

non-purchase from Customer B, then the contract would be

considered to be a "wholly unperformed" contract.

Illustration 2 Supply contract with obligation to

performEntity A enters into a one year contract to supply electricity

to Customer B at a monthly xed price per MWh. Entity A is

obligated to provide electricity to Customer B if it should

request these volumes. However, Customer B is obligated to

pay a signicant penalty if it changes electricity providers.

As Entity A does not have the unilateral right to terminate the

contract and Customer B is required to pay compensation for

termination, the contract would be in scope of the ED.


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Entity C has a contract to supply 100,000 MWh of energy per year to Customer D for the next 10 years at a xed price of CU 55/MWh.

After 5 years have elapsed, Entity C and Customer D agree to extend the contract by an additional 5 years. The price per unit for the

remaining 10 years of the modied contract will now be CU 65/MWh.

Entity C has determined that each individual MWh is a distinct performance obligation under the original contract and the current spot

price represents the separate standalone selling price for each unit delivered (see Steps 2 and 4 below for further discussion).

Scenario 1: The modied price was based on blending the original contract price for the remaining years 6 to 10 (CU 55/MWh) with the

market price for the additional volumes from years 11 to 15 (CU75/MWh).

Years 6-10 pricing: 100,000 MWh x 5 years x CU 55/MWh CU 2,750,000

Years 11-15 pricing: 100,000 MWh x 5 years x CU 75/MWh CU 3,750,000

CU 6,500,000

The remaining contract consideration of CU6,500,000 is divided by the undelivered volumes in the modied contract of 1,000,000 MWh

(100,000 x 10 years) resulting in the revised contract price of 65/MWh.

In this scenario, the modication results in additional volumes of 500,000 MWh (100,000 x 5 years) for the added period of years 11-15

and additional consideration of CU 3,750,000. The additional consideration resulting from the modication reects the market price of

the additional goods to be delivered. As such, the entity could view this additional consideration to represent the standalone selling price

of the additional 500,000 MWh to be delivered as a result of the modication. Under this view, the modication would be accounted foras a separate contract.

This would result in the following revenue recognition prole (ignoring the impact of the time value of money discussed in Step 3 below):

Contract period

Volumes(10,000 x 5 years)

Allocatedprice (CU/MWh)

Revenuerecognised (CU)

Contract cashow (CU)

Accrued (deferred)revenue (CU)

Years 1-5 500,000 55 27,500,000 27,500,000

Years 6-10 500,000 55 27,500,000 32,500,000 (5,000,000)

Years 11-15 500,000 75 37,500,000 32,500,000

1,500,000 92,500,000 92,500,000

Scenario 2: The additional consideration resulting from the contract modication was not based on the standalone selling price of the

additional units, but instead, the pricing includes a discount for other factors (i.e., a discount in recognition of the signicant volumes

that will be delivered under the modied contract). In this scenario, the modication would not be considered a separate contract. In

effect, the entity would account for the contract modication as a termination of the original contract and the creation of a new contract.

This would result in the following revenue recognition prole for Entity C:

Contract period

Volumes(10,000 x 5 years)

Allocatedprice (CU/MWh)

Revenuerecognised (CU)

Contractcash ow (CU)

Accrued (deferred)revenue (CU)

Years 1-5 500,000 55 27,500,000 27,500,000

Years 6-10 500,000 65 32,500,000 32,500,000

Years 11-15 500,000 65 32,500,000 32,500,000

1,500,000 92,500,000 92,500,000

Illustration 3: Energy contract extension


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The scenarios on the previous page illustrate when the contract

modication relates to goods and services that are distinct from

those previously provided under the contract and each individual

MWh is a separate performance obligation. If the goods or services

in the modied contract are not distinct from goods or services

previously provided under the contract, an entity must account

for the modication as if it were part of the original contract.

The result would be allocating a portion of the change in

compensation from the modied contract to goods or services that

have already been provided (i.e., changing the amount of revenue

previously recognised). This could mean recording a cumulative

catch-up entry to either increase or decrease prior period revenue

recognised, depending on whether the modied contract

compensation is higher or lower than the original contract.

Another modication that could occur for P&U entities is when the

parties change the contract pricing for the remaining contract

period without modifying the goods or services to be delivered

under the contract (i.e., no changes in the scope of the contract).

This type of modication may involve a payment from the

counterparty as a result of the modication.

While the amounts allocated to performance obligations would be

updated to reect changes in the estimated transaction price as

goods and services are delivered, the standalone selling prices used

to perform the allocation would not be updated to reect changes

in the standalone selling prices after contract inception. This means

that changes in the total transaction price would be allocated to the

separate performance obligations on the same basis as the initial

allocation.

The proposed model would require contingent consideration

associated with a modication to be allocated entirely to a distinct

good or service if certain criteria are met. This can have signicant

implications depending on how the contract is modied.

The following example illustrates some of the considerations that

would be made when only the transaction price of a contract is

modied.

In practice, there are a number of other considerations that could

make the analysis of contract modications complex. These

include: contracts that deliver volumes over time at a xed price

per unit with variable volumes required to be delivered; contracts

that are originally priced on a variable price per unit; and contracts

that are bundled with other goods or services. As such, the

individual facts and circumstances of each contract modication

need to be carefully considered under the proposed standard.

There is variability in how the contract modication rules within the

ED should be applied by P&U entities. Basic considerations, such as

determining the performance obligation within the contract, could

signicantly impact the accounting. In addition, signicantjudgement would need to be applied in determining whether the

additional consideration resulting from the modication reects

the entitys standalone selling price for the additional volumes (plus

any appropriate adjustments to that price to reect the facts and

circumstances of that particular contract).

How we see it

Illustration 4 Modification of the pricing of a power

contractEntity E enters into a 10-year power purchase arrangement

with Customer F to deliver 100,000 MWh/year at a xed price

of CU 60/MWh. Assume that Entity E determines that each

individual MWh is a distinct performance obligation under the

original contract and the standalone selling price is determined

based on the spot rate (see Steps 2 and 4 below for further

discussion). As a result, each MWh is allocated CU 60 of the

transaction price.

After 5 years, Entity E has delivered 500,000 MWh (100,000

MWh x 5 years) and recognised revenue of CU 30,000,000

(500,000 MWh x CU 60/MWh) under the contract. Customer F

decides that it would like to unwind its xed price power

purchase arrangement to change to a market price. Entity E

agrees to modify the contract so that the pricing willbe based on the market price for power. Customer F pays

CU 5,000,000 to compensate Entity E as the xed price of the

original contract is currently higher than the market price.

The modied price per MWh is now based on a highly variable

market price and Entity E concludes that this would be

considered contingent consideration that can be allocated

directly to the undelivered 500,000 MWh in the modied

contract (refer to Contingent considerationSection in Step 4

below). However, the payment of CU 5,000,000 would be

treated as a change in the transaction price. As a result,

Entity E would need to allocate this amount to the total units

to be delivered under the contract based on the originalstandalone selling price (i.e., CU 2,500,000 would be allocated

to the units already delivered and CU 2,500,000 would be

allocated to the undelivered units).


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Step 2: Identify the separateperformance obligationsThe goods or services promised in a customer contract (either

explicitly stated in the contract or implied by customary business

practices) are referred to as performance obligations in the ED.

Goods and services would be accounted for as separate

performance obligations when they are distinct, meaning they are

sold separately or the customer can benet from the good or

service on its own or together with other resources that are readily

available to the customer. These resources can be offered by the

entity or by another entity. If a good or service is not distinct, it

would be combined with other goods or services until a distinct

performance obligation is formed.

Once an entity determines whether the individual goods and

services would be distinct, the entity would have to consider the

manner in which the goods and services have been bundled in an

arrangement. The manner in which the goods and services havebeen bundled may lead an entity to determine that it is appropriate

to account for otherwise distinct goods or services as a single

performance obligation.

To account for a bundle of goods and services as one performance

obligation: (a) the goods and services must be highly interrelated

and transferring the goods and services to the customer requires a

signicant service of integrating the goods or services into the

combined item(s) for which the customer has contracted; and

(b) the bundle of goods and services is signicantly modied or

customised to full the contract.

The Boards also provided a practical expedient whereby an entity

could choose to account for two or more distinct goods or services

in a contract as a single performance obligation, if those goods or

services have the same pattern of transfer to the customer. It is our

understanding that consecutive delivery would likely meet the

criteria of having the same pattern of transfer (i.e., delivery of a

specic number of units of production over a period of time to the

customer until the full contracted volumes are delivered). The

potential impact of applying the practical expedient would depend

on the individual contracts. We will discuss some of these

considerations below in Step 4.

Green or renewable certificates

Some countries have schemes to promote electricity production

from renewable sources. This is often achieved by the government

granting certicates to the producers of green energy, which may

be referred to as green certicates, renewable energy certicates(RECs), tradable renewable certicates or renewable obligation

certicates. Usually, P&U entities that distribute electricity must

demonstrate that a certain percentage of power delivered to

customers is obtained from renewable sources. A distributor must

obtain and remit green certicates for the required amount of

renewable energy. Green or renewable certicates are either

purchased directly from the generator of renewable energy or from

the market in locations where a market exists.

As the schemes for green or renewable credits vary signicantly

from country to country, the specic terms and conditions need

to be carefully considered, particularly in those areas where the

green or renewable certicates cannot be sold separately fromthe energy.

It is important to note that the revised ED has a broader denition

of 'distinct' than the original ED that would allow entities to

consider whether the customer can benet from the good or

service on its own or together with other resources that are readily

available to the customer. This means that, provided the green

or renewable credit can be expected to provide a benet to the

customer (e.g., a refund from the government) that is separate

from the benet the customer receives from consuming/

distributing the energy, it could be considered a separate

performance obligation.

Based on the criteria provided by the Boards for determining

separate performance obligations, we believe that individual

units of production delivered in many power and utility

arrangements would be considered to be separate performance

obligations.

However, by virtue of the practical expedient provided, webelieve that, as these performance obligations are transferred

consecutively with a similar pattern of transfer to the customer,

multiple performance obligations could be combined into one

performance obligation. This grouping could be applied to any

number of discrete time periods (e.g., weeks, months, years) or

to the entire contract.

How we see it

Properly identifying performanceobligations within a contract would

be a critical component of theproposed revenue standard.


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For many transactions, this would result in the green or renewable

certicates being treated as a separate performance obligation.

However, there could still be issues when the customer in the

contract is an intermediary who is, in turn, required to sell the

combined product to the end user of the energy. In this case, the

customer cannot benet from the good or service on its own. It is

unclear whether an entity would look through the contract when

the customer in the contract is an intermediary.

Although the determination of whether green or renewable

certicates are separate performance obligations will likely not

impact the revenue recognition in the majority of transactions,

there could still be differences. One difference may result when

there is a delay in transfer of the title of the certicates (e.g., as a

result of government certication) which could indicate that control

has not yet passed to the customer and therefore revenue cannot

yet be recognised. Refer to our general Applying IFRS publication

for further discussion of the transfer of control.

Long-term service arrangements

It is common for entities in the P&U industry to enter intoarrangements to provide services on a long-term basis, such as

multi-period operating arrangements. Under the ED, there appears

to be exibility on how an entity could identify the performance

obligations in those arrangements. For example, a three-year

operating agreement could be considered a single performance

obligation representing the entire contractual period, or it could be

divided into smaller periods (i.e., daily, monthly or yearly).

In long-term service agreements when the consideration is xed,

the accounting generally will not change regardless of whether a

single performance obligation or multiple performance obligations

are identied. However, in arrangements involving variable

consideration, this issue could have a signicant effect, especiallyif the entity believes it is appropriate to allocate the variable

consideration to a single performance obligation. See Step 4

below for further discussion on allocating variable consideration.

Step 3: Determine thetransaction priceThe ED denes the transaction price as the amount of

consideration to which an entity expects to be entitled in

exchange for transferring promised goods or services to a

customer, excluding amounts collected on behalf of third parties(for example, sales taxes). In some cases, the transaction price is

readily determined because the entity receives payment at the

same time it transfers the promised goods or services and the

price is xed.

Determining the transaction price may be more challenging when it

is variable in amount, when payment is received at a time different

from when the entity provides goods or services or when payment

is in a form other than cash.

Variable consideration

The transaction price reects an entitys expectations about the

consideration it will be entitled to from the customer. A portion of

the transaction price could vary in amount and timing due to

discounts, rebates, refunds, credits, incentives, bonuses, penalties,

contingencies or concessions. For example, a portion of the

transaction price would be variable at contract inception if it

requires meeting specied performance conditions and there is

uncertainty regarding the outcome of such conditions.

When a contract contains variable consideration, an entity would

estimate the transaction price using whichever of the following two

methods better predicts the ultimate consideration to which the

entity will be entitled:

Expected value approach the entity would identify the possibleoutcomes of a contract and the probabilities of those outcomes

Or

Most likely outcome approach the entity would predict the

most likely outcome

The entity would apply the selected method consistently

throughout the contract and would update the estimated

transaction price at each balance sheet date.

Given the potentially signicant effect the determination of

separate performance obligations can have on the allocation and

recognition of variable consideration, we believe the Boards

should provide further clarity on how an entity should make this

determination for long-term service arrangements.

How we see it


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10Applying IFRS in Power & Utilities The revised revenue recognition proposal power and utilities

For the P&U industry, variable consideration does not just refer to

charging a different price per unit delivered or linking the price to a

variable reference price, but would also include variability in the

transaction price based on the number of units that will ultimately

be delivered under the contract.

Contributions from customers and upfront fees

P&U entities may receive items of property, plant and equipmentfrom their customers, or cash from their customers to acquire or

construct specic assets. These assets are often used to connect

customers to a network and/or provide them with ongoing access

to a supply of goods and/or services such as electricity, gas

or water. These contributions are currently in the scope of

IFRIC 18 Transfers of Assets from Customers, except when they

relate to government grants (IAS 20Accounting for Government

Grants and Disclosure of Government Grants) or service

concessions (IFRIC 12 Service Concession Arrangements). The ED

would replace IFRIC 18 and transactions that include contributions

from customers that are outside the scope of IAS 20 and IFRIC 12

would be accounted for under the ED.Under the ED, when an entity receives, or expects to receive,

non-cash consideration, the transaction price is equal to the fair

value of the non-cash consideration. This would only apply to

transactions that are in the scope of the ED (i.e., contracts with

customers). An entity would measure the fair value of the non-cash

consideration in accordance with IFRS 13 Fair Value Measurement

when a reliable estimate of fair value can be made.

Transactions in which the customer contributes goods or services

(such as property, plant or equipment) to facilitate the fullment of

the contract are common in the P&U industry. In these transactions,

if the entity obtains control of the contributed goods or services, it

should consider them as non-cash consideration and account for

that consideration as described above. This is consistent with

current treatment under IFRIC 18.

In many cases, the asset or consideration transferred is an upfrontfee in exchange for the delivery of services. These upfront fees are

often related to connecting a customer to a transmission network

and/or providing ongoing access to a supply of goods or services.

Upfront fees may also be paid to grant access to or a right to use a

facility, product or service. Often the upfront amounts paid by the

customer are non-refundable.

Entities must evaluate whether non-refundable upfront fees relate

to the transfer of a good or service that needs to be identied as

a separate performance obligation (based on the criteria to be

considered a distinct good or service in Step 2 above). In most

situations, the upfront fee does not relate to any transfer of a

goods or services. Instead, it is an advance payment for futuregoods or services.

Additionally, the existence of a non-refundable upfront fee may

indicate that the arrangement includes a renewal option for future

goods and services at a reduced price (if the customer renews the

agreement without the payment of an additional upfront fee). For

example, if the upfront fee is associated with an arrangement that is

month to month, the entity may determine that the ability to renew

each subsequent month without having to pay any connection fee

represents a material right. The up-front payment would be

recognised over the period when those goods and services are

provided (i.e., the customer relationship period in this case).

The treatment of variable consideration under the ED couldrepresent a change from current practice for certain contracts in

the P&U industry.

Currently, IFRS preparers often defer measurement of variable

consideration until revenue is reliably measurable, which could

be when the uncertainty is removed or when payment is due.

The ED would require entities to estimate variable consideration

at contract inception and only provides a restriction on

recognising variable amounts that are not reasonably assured.

How we see it

Determining the transaction price may be more challengingwhen it is variable in amount, when payment is receivedat a time different from when the entity provides goods orservices, or when payment is in a form other than cash.


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11 Applying IFRS in Power & Utilities The revised revenue recognition proposal power and utilities

Time value of money

For certain transactions, the timing of the payment does not match

the timing of the transfer of goods or services to the customer

(e.g., the consideration is prepaid or is paid well after the services

are provided). While the time value of money would have to be

considered in an arrangement, the Boards tried to reduce the

number of contracts to which that provision would apply. Under the

ED, the time value of money would be considered only when thereis a signicant nancing component in an arrangement. In addition,

an entity would not be required to assess whether the arrangement

contains a signicant nancing component unless the period

between the customers payment and the entitys satisfaction of

the performance obligation is greater than one year.

IAS 18 does not explicitly address time value of money. It is

implicitly incorporated in the requirement to recognise revenue

at the fair value of the amount to be received. However, there is

divergence in practice of incorporating the impact of the time value

of money. For additional guidance on accounting for the time value

of money, see Section 4.2 of our general Applying IFRS publication.

Step 4: Allocate thetransaction price to separateperformance obligationsOnce the performance obligations are identied and the

transaction price has been determined, the ED would require an

entity to allocate the transaction price to the performance

obligations, generally in proportion to their standalone selling

prices (i.e., on a relative standalone selling price basis).

Determining the standalone selling price

To allocate the transaction price on a relative selling price basis, an

entity must rst determine the standalone selling price for each

performance obligation. Under the ED, the standalone selling price

would be the price at which an entity would sell a good or service

on a standalone basis at contract inception. Although this is not

explicitly stated in the ED, we believe a single good or service could

have more than one standalone selling price that is, the entitymay be willing to sell a performance obligation at different prices to

different customers.

The ED indicates that, when available, the observable price of a

good or service sold separately provides the best evidence of

standalone selling price. When the standalone selling price is

not observable, the ED provides some examples of alternative

techniques that may be used. When an entity must estimate the

standalone selling price, the ED is clear that the entity should not

presume that a contractually stated price or a list price for a good

or service is the standalone selling price. Further discussion can be

found in Section 5 of our general Applying IFRS publication.

One thing that is not clear in the ED is how to determine the

standalone selling price at contract inception when there is only

one type of good (e.g., a unit of energy), and the contract requires

selling multiple units of that good in succession. Specically, should

the standalone selling price of one MWh of energy to be sold/

delivered today be different to a MWh of energy which you expect

to sell/deliver at a future date (e.g., forward price in two, ve or

even 10 years' time)? Using the spot price for all performance

obligations would result in an identical standalone selling price for

each performance obligation (i.e., each unit delivered). The forward

price would result in a different standalone selling price for each

performance obligation. This could impact the allocation of the

transaction price (increasing the complexity of applying Step 4 of

the model) and ultimately the pattern of revenue recognition. The

following examples illustrate some of the complexities and potential

differences in outcomes between using a spot price and a forward

price as the standalone selling price.


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Illustration 5: Estimating the standalone selling prices

For simplicity, the scenarios below use yearly pricing for purposes of estimating the standalone selling price for the forward prices.

We also assume the practical expedient has been applied to group distinct goods together into one-year performance obligations as

discussed above in Step 2.

Scenario 1: Fixed price contract

Entity G enters into a three year xed price contract with Customer H to deliver 1,000,000 units of electricity each year for axed price of CU65/MWh. There is an active market for electricity and the forward prices are as follows at contract inception:

Year 1 CU60/MWh, Year 2 CU70/MWh, Year 3 CU75/MWh.

Fixed price contract

YearCurrent

practice (CU)

Spot price(i.e., same standalone selling price for each unit)

Forward price(i.e., different standalone selling price for each unit)

Calculation1 Revenue (CU) Selling price % of priceallocated2

Revenue (CU)

1 65,000,000 1,000,000 x CU 65 65,000,000 1,000,000 x CU 60 29% 56,550,000

2 65,000,000 1,000,000 x CU 65 65,000,000 1,000,000 x CU 70 34% 66,300,000

3 65,000,000 1,000,000 x CU 65 65,000,000 1,000,000 x CU 75 37% 72,150,000

195,000,000 195,000,000 195,000,000

Note 1 For the spot price-based standalone selling price, the transaction price is allocated based on the average price per unit of

CU 195,000,000 / 3,000,000 units

Note 2 For the forward price-based standalone selling price, the percentage calculated to allocate the transaction price of

CU 195,000,000 is based on the standalone selling price for the year divided by the total standalone selling price of the entire

contract.

As can be seen in this scenario, the assumption that each unit delivered has the same standalone selling price would result in the same

accounting currently used in practice.


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Illustration 5 (continued): Estimating the standalone selling prices

Scenario 2: Stepped price contract

Entity I enters into a three-year xed price contract with Customer J to deliver 1,000,000 units of electricity each year with the

following xed prices: Year 1 CU 60/MWh, Year 2 CU 70/MWh, Year 3 CU 75/MWh. The contract pricing is also equal to the

forward prices in the active market at contract inception.

Stepped price contract

YearCurrent

practice (CU)

Spot price(i.e., same standalone selling price for each unit)

Forward price(i.e., different standalone selling price for each unit)

Calculation1 Revenue (CU) Selling price % of priceallocated2

Revenue (CU)

1 60,000,000 1,000,000 x CU 68.33 68,333,333 1,000,000 x CU 60 29% 60,000,000

2 70,000,000 1,000,000 x CU 68.33 68,333,333 1,000,000 x CU 70 34% 70,000,000

3 75,000,000 1,000,000 x CU 68.33 68,333,333 1,000,000 x CU 75 37% 75,000,000

205,000,000 205,000,000 205,000,000

Note 1 For the spot price-based standalone selling price, the transaction price is allocated based on the average price per unit of

CU 205,000,000 / 3,000,000 units.

Note 2 For the forward price-based standalone selling price, the percentage calculated to allocate the transaction price of

CU 205,000,000 is based on the standalone selling price for the year divided by the total standalone selling price of the entire

contract.

As can be seen in this scenario, assuming that each unit delivered has the same standalone selling price would result in different

accounting compared to current accounting practice. In this scenario, a similar revenue recognition prole to current practice would be

achieved using a forward price as the standalone selling price because (for simplicity) we have assumed that the forward prices of

energy have been built into the pricing of the contract.


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It is important to note that the revenue recognised will depend

signicantly upon how the performance obligations are

determined. An entity could also apply the practical expedient to

the entire contract (i.e., to treat multiple units with the same

pattern of transfer as one combined performance obligation). As a

result, the pricing would be smoothed such that each unit delivered

would have an equal amount of revenue allocated. For Scenario 1,

using the practical expedient to treat the entire contract as one

performance obligation would result in the same revenue

recognition as IAS 18 (regardless of whether a spot or forward

price is used to determine the standalone selling price).

Contingent consideration

The Boards proposed an exception to the relative selling price

method of allocating the transaction price that would require

contingent consideration to be allocated entirely to a single

performance obligation when both of the following criteria are met:

The contingent payment terms for the distinct good or service

relate specically to the entitys efforts to transfer that good or

service (or to a specic outcome from transferring that good or

service).

And

Allocating the contingent amount of consideration entirely to

the distinct good or service is consistent with the overall

principle for allocating consideration (i.e., the amount ultimately

allocated to each separate performance obligation results in an

amount that depicts the amount of consideration to which the

entity expects to be entitled in exchange for satisfying each

separate performance obligation).

This proposed approach for contingent consideration would also

apply to subsequent changes in the transaction price. A common

example of a P&U contract that would likely fall under this exception

is a production contract with pricing that is based entirely on a

reference or market price (e.g., price based on the average spot

price for the month in which the product is delivered). In this case,

each unit delivered would likely be determined to be a distinct

good. Therefore, when each unit is delivered and the transaction

price is known, the model would allow the entity to allocate that

known part of the transaction price entirely to that distinct good. It

would not be required to allocate that known transaction price over

the total number of performance obligations. The result is that

revenue would be recognised consistently with current IAS 18 for

these contracts.

Even when the practical expedient is applied and the performance

obligations are bundled into one performance obligation, the

individual goods (e.g., units of energy delivered) would still be

distinct. As such, we believe the provisions relating to allocation of

a variable transaction price to distinct goods could still be applied in

this situation.In addition to contracts with entirely variable per unit pricing, P&U

entities may enter into contracts that have per unit pricing with

both a xed and variable element. For example, an entity could

enter into a xed price contract to deliver energy that includes an

adjustment for ination (i.e., contract price is xed plus an ination

index in following years) in each of the subsequent years of the

contract. As the ination adjustment can be linked directly to the

distinct performance obligations in these separate years, the

impact of ination would not be required to be allocated to energy

delivered in other years of the contract.

How we see it

The examples above demonstrate how decisions about the

identication of the performance obligations within a contract

and how the standalone selling price is determined can

signicantly impact the complexity of applying the model and the

revenue recognition prole. For example, stepped price contracts

could end up with smoothed revenue proles; or xed price

contracts could end up with gradually increasing recognitionproles depending on whether a spot price or a forward price is

used.

Given this, we believe the Boards should provide additional

guidance and clarity on these key decisions in the nal standard.

How we see itThe changes that have been made to the ED regarding the

allocation of contingent consideration could result in the

contract price allocated to each individual performance

obligation (e.g., unit of energy delivered) better reecting the

underlying economics of the contract than what was proposed

in the original ED. However, this may not be the case when

estimates of these market costs (e.g., adjustments for

consumer price index) are embedded as a xed price in the

contract at inception, potentially resulting in economically

similar contracts having different revenue recognition proles.

Decisions about the identication of the performanceobligations within a contract and how the standalone sellingprice is determined can signicantly impact the complexityof applying the model and the revenue recognition prole.


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Step 5: Recognise revenuewhen the entity satises each

performance obligationUnder the ED, an entity would recognise revenue when each

performance obligation is satised. This would occur when thegoods or services are transferred to the customer and the customer

obtains control. The ED indicates that certain performance

obligations are satised as of a point in time. Therefore, revenue

would be recognised at that point in time. However, other

performance obligations are satised over time. As such, the

associated revenue would be recognised over the period the

performance obligation is satised (e.g., the monthly facilities

service contract). Section 6 of our general Applying IFRS

publication outlines the relevant considerations for assessing

when control has passed.

Performance obligations satisfied over timeFor performance obligations satised over time, an entity will need

to decide how it will measure its progress towards complete

satisfaction of those performance obligations. Two appropriate

methods of measuring progress provided in the ED include output

methods and input methods. Output methods recognise revenue on

the basis of the value to the customer of the goods or services

transferred to date (e.g., units produced or delivered, milestones

reached). Input methods recognise revenue based on the entitys

efforts or inputs to the satisfaction of a performance obligation

(e.g., resources consumed, labour hours expended, costs incurred)

relative to the total expected inputs.

For power purchase arrangements and other contracts to deliverunits of production, in which each unit delivered is treated as a

separate performance obligation, we believe these would be

considered to be satised at a point in time. However, when an

entity elects to apply the practical expedient and treat all units

to be delivered under the contract as one single performance

obligation or separate annual (or weekly, monthly, quarterly)

performance obligations, we believe these would be considered

to be satised over time.

Given the nature of unit purchase arrangements (e.g., power

purchase arrangements), the output method would likely be chosen

by many entities to measure progress towards satisfaction of this

performance obligation in the case where the entity treats these as

an obligation settled over time. For example, an entity could choose

to measure progress as units delivered to date as compared to total

units to be delivered under the contract.

In addition, the ED states that if an entity has a right to invoice acustomer in an amount that corresponds directly with value to the

customer of the entitys performance completed to date, the entity

would recognise revenue in the amount to which the entity has a

right to invoice. For example, we would expect a contract to deliver

units based on a market price to meet the criteria of the invoice

amount directly corresponding to the value to the customer of units

delivered to date. The result is a simplied approach to accounting

for these contracts if the practical expedient is taken and an entity

chooses to apply the invoicing output method.

However, it is unclear how the value to the customer of the entitys

performance completed to date is meant to be interpreted in other

cases. Is this meant to be fair value, the standalone selling pricethat would otherwise be allocated or some other consideration?

Also, at what date would this value be determined? For example,

fair value of a unit delivered in year 5 of a contract would be

different at contract inception as compared to the point in year 5

when the unit is actually delivered.

How we see it

Using the invoicing method as a measure of progress towards

satisfying a performance obligation in unit based delivery

contracts that an entity has elected to treat as a combined

performance obligation that is satised over time, would greatly

simplify the accounting for these contracts. However, it is

unclear in the ED under what circumstances the invoicing

method could be applied.


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Constraining the cumulative amount of revenue

recognised

Although an entity is required to estimate the total transaction

price, the amount of revenue the entity could recognise may be

constrained in certain circumstances. The ED states that the

cumulative amount of revenue an entity would be able to recognise

for a satised performance obligation is limited to the amount to

which the entity is reasonably assured to be entitled (refer toSection 6.3 of our general Applying IFRS publication for further

guidance on determining when the amount to which an entity

expects to be entitled is reasonably assured).

The examples cited in the ED relate to assessing the types of

variable consideration in which an entity would not be reasonably

assured to be entitled are sales-based royalties associated with

the licence to use intellectual property and asset management

fees based on the value of the underlying assets at a dened

measurement date in the future. In addition to those examples,

we believe settlement of long-term commodity supply

arrangements based on market prices at the future delivery date

would also be variable consideration in which an entity is notreasonably assured to be entitled to the payment.

Other recognition andmeasurement concerns

Take or pay arrangements

A take-or-pay contract is a supply agreement between a customer

and a supplier in which the price is set for a specied minimum

quantity of a particular good or service and the price is payable

irrespective of whether the good or service is taken by the

customer. Take-or-pay contracts are commonly used in the P&U

industry and may involve the supply of gas, transmission capacity

or electricity. These contracts can be long-term in nature and

contain terms and conditions with varying degrees of complexity

(e.g., xed or stepped volumes; simple xed, stepped or variable

pricing). Several of the issues under the ED for these complex

terms are discussed above under Step 4.

The initial 'contract' to be accounted for in a take-or-pay

arrangement would often be the minimum amount specied in

the contract, as this is generally the only enforceable part of the

arrangement. However, this may not always be the case and an entity

needs to carefully consider these potential additional volumes when

identifying its performance obligations in Step 2 above.

There may be instances in which the option to obtain additional

volumes provides a material right to the customer that it would notreceive without entering into that contract. The ED notes that such

a right would be material only if it results in a discount that the

customer would not otherwise receive (e.g., a discount that is

incremental to the range of discounts typically given for those

goods or services to that class of customer in that geographical

area or market). If the option does provide a material right to the

customer, the option would be accounted for as a separate

performance obligation in the original contract. Further details on

identifying the contract and accounting for these options, can be

found in Section 2 and Section 3.7 our general Applying IFRS

publication.

In addition, terms related to payments made for volumes not taken(i.e., when the customer does not take the minimum quantities

specied) can vary. For example, some take-or-pay arrangements

might include a clause that allows the customer to 'make up' the

volumes not taken at a later date. The ability to make up the

unused volumes means that consideration has been received in

advance by the producer for a product that has not yet been

delivered. Alternatively, the contract may contain a 'use it or lose it'

clause, under which the customer cannot make up the unused

volumes in the future. In such a situation, this payment would be

more akin to a type of penalty payment.

The ED discusses the concept that in certain industries customers

may pay for goods or services in advance, but may not ultimatelyexercise all of their rights to these goods and services either

because they choose not to or are unable to. The ED refers to these

unexercised rights as breakage.


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In take-or-pay contracts, the unexercised rights are effectively

breakage. However, it is not clear if the proposed requirements on

breakage would be applicable. If they do apply, the unexercised

rights would be accounted for as follows:

If an entity is reasonably assured of a breakage amount, the

entity should recognise the expected breakage as revenue in

proportion to the pattern of transfer of goods or services to the

customer.

If an entity is not reasonably assured of a breakage amount, it

should recognise the expected breakage as revenue when the

likelihood of the customer exercising his or her rights on

remaining balances becomes remote.

It is also important to note that there is some uncertainty in the

ED as to how the requirements for recognising breakage amounts

would be applied when they are considered to be reasonably

assured. The ED requires that the entity would recognise the

breakage amount as revenue "... in proportion to the pattern of

rights exercised by the customer." This suggests that the entity

would have to take into account either:

The rights already exercised by the customer to date compared

with those the entity expects the customer will still exercise.

This would allocate the breakage amounts to all performance

obligations (satised and still to be satised) in the contract.

Or

Only the rights that have been exercised in the contract. This

would lead to full recognition of the breakage amount when

reasonable assurance is achieved (or when the likelihood of the

customer exercising the rights when reasonable assurance is not

achieved).

In take-or-pay contracts, in which payments received for unused

volumes can be applied to future volumes, the seller has received

consideration in advance for an unsatised performance obligation.

This amount represents a contract liability, which will differ from

current treatment under which such amounts are referred to as

deferred or unearned revenue.

When determining how to account for the contract liability

on make-up volumes, the ED requires that the transaction price ina contract must be adjusted to reect the time value of money if

the contract has a nancing component that is signicant to the

contract.

How we see it

The ED could have practical implications for, and may increase

the complexity of, accounting for take-or-pay contracts. This

complexity arises on determining the performance obligations

(whether to combine these using the practical expedient),

determining the standalone selling price (spot or a forward price)

and taking into consideration the unexercised rights.

In addition, the ED is unclear on how or whether the

requirements for recognising breakage amounts would be

applied in take-or-pay contracts, which could lead to divergence

in practice. As such, we recommend the Boards clarify what is

meant by recognising revenue "in proportion to the pattern of

rights exercised by the customer".

The proposed revenue recognitionmodel could have practical implicationsfor, and may increase complexity of, theaccounting for take-or-pay contracts.


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Onerous performance obligations

The ED would require an entity to recognise a liability and a

corresponding expense when certain performance obligations

(that is, performance obligations satised over time and that time

period is greater than one year) become onerous. Section 7.2 of

the general Applying IFRS publication provides further details on

applying the onerous contract provisions of the ED.

As mentioned, the onerous contract performance obligation

assessment would be required only when performance obligations

are satised over time. As such, an entitys determination of the unit

of account for long-term contracts may impact the onerous test.

Another important aspect to consider in connection with the

onerous performance obligation assessment is the cost of settling

the performance obligation. Under the ED, a performance

obligation is deemed onerous when the lesser of the following

costs exceeds the allocated transaction price:

The costs directly related to satisfying the performance

obligation (i.e., direct costs)

The amount the entity would pay to exit the performance

obligation

P&U entities that identify performance obligations that are settled

over time may have difculty determining the costs that are

directly related to satisfying the specic performance obligations.

In some cases, there is no direct link between costs and a specic

revenue contract (or the individual performance obligations within

that contract). For example, an entity may produce electricity

from several power plants (with different cost structures) into a

grid that fulls multiple customer contracts.

DisclosuresIn response to criticism that the current revenue recognition

disclosures are inadequate, the Boards have tried to create a

comprehensive and coherent set of disclosures. As a result,

the ED includes an overall objective that the revenue recognition

disclosures should enable users of the nancial statements to

understand the amount, timing and uncertainty of revenue andcash ows arising from contracts with customers. The ED states

that preparers would meet that objective by providing both

qualitative and quantitative disclosures about:

Contracts with customers These disclosures would include

disaggregation of revenue, reconciliation of contract asset and

liability balances (including liabilities due to onerous

performance obligations) and information about an entitys

performance obligations.

Signicant judgements(including changes in those judgements)

This would include disclosures about judgements that

signicantly affect the determination of the transaction price,the allocation of the transaction price to performance obligations

and the determination of the timing of revenue recognition.

Assets recognisedresulting from costs incurred to obtain or

full a contract.

The Boards have claried that the disclosures they listed in the ED

are not intended as a checklist of minimum requirements. Instead,

entities would have to determine which disclosures are relevant to

them. Entities also would not have to disclose items that are not

material.

Next stepsGiven the potential consequences, we encourage P&U entities to

gain an understanding of the ED and how it may affect their

particular facts and circumstances and provide the Boards with

feedback. Although comments are due by 13 March 2012,

the Boards also plan various outreach efforts to gather more

feedback. Entities that would like to participate should express

their interest to the Boards.

Entities should also continue to consider the impact the changes

may have on their business and discuss these potential changes

with their Audit Committee, the Board of Directors and auditors.


20/20

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EYG no. AU1108

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Expiry date: 6 January 2013

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