1. What does IAS 36 actually require, and why does the unit of account decide everything downstream?
IAS 36 requires that no asset is carried at more than its recoverable amount, being the higher of fair value less costs of disposal and value in use. Any excess is written off immediately to profit or loss. Everything else in the standard exists to answer two questions: what the asset is worth, and what counts as the asset.
"The objective of this Standard is to prescribe the procedures that an entity applies to ensure that its assets are carried at no more than their recoverable amount. An asset is carried at more than its recoverable amount if its carrying amount exceeds the amount to be recovered through use or sale of the asset. If this is the case, the asset is described as impaired and the Standard requires the entity to recognise an impairment loss."
Two words in that paragraph do the work. "Use or sale" is the reason recoverable amount has two limbs rather than one: the entity is not required to write down an asset it can still use profitably merely because nobody would pay much for it, nor to write one down because it is unprofitable in use if it could be sold for more. And "carried at more than" fixes the direction. IAS 36 is a ceiling test only. It never writes an asset up above cost, and outside the reversal rules in IAS 36.114 to 36.123 it never writes one up at all.
"If, and only if, the recoverable amount of an asset is less than its carrying amount, the carrying amount of the asset shall be reduced to its recoverable amount. That reduction is an impairment loss." The loss is recognised immediately in profit or loss, unless the asset is carried at revalued amount under another standard, in which case IAS 36.60 treats it as a revaluation decrease.
The "if, and only if" is not decorative. It removes any scope for a general or precautionary write-down, and it removes any scope for smoothing a loss across periods. An impairment is recognised in full in the period in which recoverable amount falls below carrying amount, and it is measured by that shortfall, not by management's assessment of how much of the shortfall is permanent.
"After the recognition of an impairment loss, the depreciation (amortisation) charge for the asset shall be adjusted in future periods to allocate the asset's revised carrying amount, less its residual value (if any), on a systematic basis over its remaining useful life."
This is the step that gets skipped. The impairment journal is posted to the ledger, the fixed asset register keeps the original depreciation profile, and the following year's charge is wrong on every impaired asset. It also has a presentation consequence. Where the impairment charge is presented as an adjusting or non-underlying item, the depreciation saving it creates in later years flows through underlying profit unless it is tracked, which flatters every subsequent period by exactly the amount the write-down was supposed to cost.
Why the unit of account is the whole game
An impairment test on a single machine is arithmetic. An impairment test on a division is a negotiation, and almost every asset in a real business is tested as part of a division rather than on its own. IAS 36.22 is the switch: recoverable amount is determined for an individual asset unless it does not generate cash inflows largely independent of other assets, in which case the test moves to the cash-generating unit.
The consequence is that the outcome is usually fixed before any discounting happens. Draw the unit around a single failing store and it fails. Draw it around the region the store sits in and it passes, because the profitable stores absorb it. Neither answer is arithmetically wrong. Only one of them is supportable on the facts of how the business generates and stops generating cash, and IAS 36.68 to 36.72 is the only place to look for that reasoning.
| Step | What it does | What it inherits from the unit decision |
|---|---|---|
| Carrying amount | IAS 36.75 and 36.76 fix what is being tested | Which assets, and which liabilities if any, sit on the carrying side |
| Value in use | IAS 36.30 to 36.57 discount the cash flows | Whose cash flows, and therefore whether losses in one operation are offset by profits in another |
| Goodwill | IAS 36.80 allocates goodwill to units or groups of units | Whether the goodwill can ever fail, since a larger unit carries more headroom |
| Allocation of the loss | IAS 36.104 and 36.105 spread the loss | Which individual assets carry the charge and therefore future depreciation |
| Disclosure | IAS 36.130 and 36.134 describe the unit | The population being described, and the sensitivity that has to be published |
Local FAQs
Is impairment the same as accelerated depreciation? No. Depreciation spreads a cost the entity always expected to consume. Impairment recognises that the expectation itself was wrong. IAS 36.63 links them, because the write-down changes the depreciation base, but the two arise for different reasons and the second is news while the first is not.
Can an impairment loss ever bypass profit or loss? Only for a revalued asset, and only to the extent of the revaluation surplus held for that same asset (IAS 36.60). For an asset held under the cost model the answer is always profit or loss.
Does IAS 36 allow a partial write-down where recovery is uncertain? No. The loss is the shortfall between carrying amount and recoverable amount, measured in full. Uncertainty about recovery belongs in the estimate of recoverable amount, not in a decision to recognise only part of the difference.
Potential risks
The recurring failure at this level is treating impairment as an annual event owned by the goodwill process. Assets in scope with no goodwill attached, in particular right-of-use assets, capitalised development costs and investments in subsidiaries in the parent's own accounts, sit outside the annual goodwill routine and are reviewed only if somebody runs the IAS 36.9 assessment properly. The second risk is the depreciation reset in IAS 36.63, which is a fixed asset register task rather than a technical accounting task, and therefore falls between two teams.
2. Which assets are inside the scope of IAS 36, and which are impaired under another standard?
IAS 36 applies to all assets except a defined list: inventories, IFRS 15 contract assets and contract costs, deferred tax assets, employee benefit assets, IFRS 9 financial assets, investment property at fair value, biological assets at fair value less costs to sell, IFRS 17 insurance contract assets, and assets held for sale. Investments in subsidiaries, associates and joint ventures are explicitly inside.
"This Standard shall be applied in accounting for the impairment of all assets, other than: (a) inventories (see IAS 2); (b) contract assets and assets arising from costs to obtain or fulfil a contract that are recognised in accordance with IFRS 15; (c) deferred tax assets (see IAS 12); (d) assets arising from employee benefits (see IAS 19); (e) financial assets that are within the scope of IFRS 9; (f) investment property that is measured at fair value (see IAS 40); (g) biological assets related to agricultural activity within the scope of IAS 41 that are measured at fair value less costs to sell; (h) contracts within the scope of IFRS 17 that are assets and any assets for insurance acquisition cash flows as defined in IFRS 17; and (i) non-current assets (or disposal groups) classified as held for sale in accordance with IFRS 5."
IAS 36.3 explains why the list exists: each of those items sits in a standard that already contains its own recognition and measurement requirements. The practical value of the list is therefore negative. It tells you what not to test, and it is the answer to a large share of the questions people ask about impairment, because most of them are about receivables, loans or inventory and none of those is an IAS 36 question.
IAS 36.4 states that the Standard applies to financial assets classified as subsidiaries under IFRS 10, associates under IAS 28 and joint ventures under IFRS 11, adding that "For impairment of other financial assets, refer to IFRS 9."
That is the inclusion people miss. An investment in a subsidiary held in the parent's separate financial statements looks like a financial asset and is not tested like one. It is tested as an individual asset under IAS 36 against its recoverable amount, and IAS 36.12(h) gives it an indicator that exists for nothing else in the standard. Where a parent has been taking dividends out of a subsidiary faster than the subsidiary earns them, that alone is an indicator.
IAS 36.5 brings revalued assets in as well, noting that the only difference between an asset's fair value and its fair value less costs of disposal is the direct incremental cost of disposal. If disposal costs are negligible, a revalued asset's recoverable amount is necessarily close to or above its revalued amount, so impairment is unlikely. Where disposal costs are significant, a revalued asset can still be impaired.
| Asset | Impairment model | Reference |
|---|---|---|
| Property, plant and equipment, right-of-use assets, intangibles, goodwill | IAS 36 | Default for non-financial assets |
| Investment in a subsidiary, associate or joint venture in separate financial statements | IAS 36, tested as an individual asset | IAS 36.4 |
| Trade receivables, loans, debt instruments at amortised cost or FVOCI | IFRS 9 expected credit loss | IAS 36.2(e) |
| Inventory | IAS 2, net realisable value | IAS 36.2(a) |
| Contract assets and capitalised contract costs | IFRS 15.101 to 15.104 and IFRS 9 | IAS 36.2(b) |
| Investment property carried at fair value | IAS 40 fair value model | IAS 36.2(f) |
| Investment property carried at cost | IAS 36 | Not excluded by IAS 36.2(f) |
| Non-current assets and disposal groups held for sale | IFRS 5, lower of carrying amount and fair value less costs to sell | IAS 36.2(i) |
Local FAQs
Does IAS 36 apply to investment property? Only where it is carried at cost. IAS 36.2(f) excludes investment property measured at fair value, because remeasurement already runs through profit or loss. Property under the cost model in IAS 40 stays in scope.
What happens the moment an asset is classified as held for sale? IAS 36 stops applying and IFRS 5 measurement takes over. An IAS 36 test run on a disposal group already classified as held for sale produces a different and wrong number, because IFRS 5 has no value in use limb.
Are capitalised development costs in scope? Yes, and an intangible not yet available for use is one of the three categories tested annually under IAS 36.10 whether or not an indicator exists. Capitalised development that has not yet reached the market is the most common example of an asset carrying a mandatory annual test that nobody runs.
Potential risks
Two failure modes, and they are opposite. Testing something that is out of scope, most often a disposal group that has already met the IFRS 5 criteria, produces an unsupportable measurement. Failing to test something that is in scope, most often an investment in a subsidiary in the parent's own accounts or capitalised development not yet in use, produces an unrecognised loss. Both are found in file review rather than in the model, because the model looks internally consistent either way.
3. When does IAS 36 require an impairment test to be performed?
Two obligations run in parallel. IAS 36.9 requires an indicator assessment at the end of every reporting period, with a full test where an indicator exists. IAS 36.10 separately requires an annual test, regardless of indicators, for goodwill, intangible assets with an indefinite useful life and intangible assets not yet available for use.
"An entity shall assess at the end of each reporting period whether there is any indication that an asset may be impaired. If any such indication exists, the entity shall estimate the recoverable amount of the asset." (IAS 36.9)
IAS 36.10 then adds the annual tests, and specifies that the annual test of an indefinite life intangible or an intangible not yet available for use "may be performed at any time during an annual period, provided it is performed at the same time every year", with different intangibles tested at different times. An intangible first recognised in the current annual period must be tested before the end of that period.
IAS 36.11 explains the logic for the third category: an intangible not yet available for use carries more uncertainty about generating enough benefit to recover its carrying amount than one already in use, which is why it earns a mandatory annual test even though it has no goodwill attached.
IAS 36.15 applies the ordinary materiality filter: an indicator that would not lead to a material adjustment does not force a full calculation of recoverable amount. This is a real relief and it is regularly over-claimed. The materiality judgement is against the effect on the financial statements, not against the cost or inconvenience of running the model.
IAS 36.17 carries a requirement that is not about impairment at all and is missed more often than any other sentence in the standard. Even where no impairment loss is recognised, the presence of an indicator signals that the remaining useful life, the depreciation or amortisation method, and the residual value may need to be reviewed and adjusted under the standard applicable to the asset. An indicator that produces no write-down should still produce a review.
| Asset type | Test when an indicator exists | Test annually regardless of indicators | Reference |
|---|---|---|---|
| Goodwill | Yes | Yes | IAS 36.10(b), 36.90 |
| Intangible with an indefinite useful life | Yes | Yes | IAS 36.10(a) |
| Intangible not yet available for use | Yes | Yes | IAS 36.10(a), 36.11 |
| All other assets in scope | Yes, plus a review of useful life, method and residual value | No | IAS 36.9, 36.17 |
Why the annual test date is not the whole answer
The annual test may sit anywhere in the year. The indicator assessment sits at every reporting date. A group that runs its goodwill test at 30 September on a December year end has satisfied IAS 36.10, and still has to ask at 31 December whether anything has happened since. A fourth quarter collapse in trading is exactly the event that falls into that gap, and it is exactly the event that produces a write-down in the following year that should have been recognised in this one.
The same applies at interim reporting dates. An interim period is a reporting period, so IAS 36.9 applies to it. That is the route by which a half-year impairment arises, and it matters because of what IFRIC 10 then does with it, covered in unit 14.
Local FAQs
Can we roll forward last year's goodwill calculation? Only if all three conditions in IAS 36.99 are met: the assets and liabilities making up the unit have not changed significantly since the last calculation, that calculation gave a substantial headroom, and the likelihood of recoverable amount now falling below carrying amount is remote. In any year where somebody is asking the question, the third condition usually fails.
Do we have to test at the half year? You must assess indicators at the half year. If an indicator exists, the full test follows at that date. If none exists, no test is required unless the annual test date falls in the period.
Can different units be tested at different times? Yes for the annual goodwill test under IAS 36.96, provided each unit is tested at the same time each year. A staggered timetable is normal in large groups and it is not a weakness, as long as the indicator assessment still runs at every period end.
Potential risks
The indicator assessment is documented as an assertion rather than an assessment. The typical file contains one sentence confirming that management considered indicators and found none, with no record of what was considered. That is not testable, and it is precisely where a regulator reading the strategic report and the viability statement alongside the impairment note will find an inconsistency the file cannot answer.
4. What counts as an indicator of impairment under IAS 36.12?
IAS 36.12 lists four external indicators, being a significant unexpected decline in value, adverse change in the technological, market, economic or legal environment, rising market rates, and net assets above market capitalisation, and three internal ones, being obsolescence or damage, an asset becoming idle or scheduled for earlier disposal, and internal reporting showing worse performance than expected. The list is a minimum.
The external indicators are: "(a) there are observable indications that the asset's value has declined during the period significantly more than would be expected as a result of the passage of time or normal use. (b) significant changes with an adverse effect on the entity have taken place during the period, or will take place in the near future, in the technological, market, economic or legal environment in which the entity operates or in the market to which an asset is dedicated. (c) market interest rates or other market rates of return on investments have increased during the period, and those increases are likely to affect the discount rate used in calculating an asset's value in use and decrease the asset's recoverable amount materially. (d) the carrying amount of the net assets of the entity is more than its market capitalisation."
Indicator (c) is the one that catches companies out in a rising rate environment, because nothing has happened to the business at all. The forecast is unchanged, the assets are unchanged, and the test still fails because the denominator moved. Indicator (d) is the one that is hardest to act on, because it is an observation about the whole entity while the test is performed on units.
The internal indicators are evidence of obsolescence or physical damage, significant adverse changes in the extent or manner in which an asset is or is expected to be used, which IAS 36.12(f) expands to include "the asset becoming idle, plans to discontinue or restructure the operation to which an asset belongs, plans to dispose of an asset before the previously expected date, and reassessing the useful life of an asset as finite rather than indefinite", and internal reporting indicating that economic performance is or will be worse than expected.
IAS 36.14 gives the internal reporting evidence content: cash flows for acquiring, operating or maintaining the asset significantly higher than budgeted; actual net cash flows or operating results significantly worse than budgeted; a significant decline in budgeted net cash flows; or operating losses or net cash outflows when current period amounts are aggregated with budgeted future amounts.
The last of those deserves attention. It is not "the unit lost money this year". It is the aggregation of the current year with the budget, which means a unit forecasting a recovery is still caught if the recovery does not cover the losses already incurred.
A separate indicator applies to an investment in a subsidiary, joint venture or associate: the investor recognises a dividend from the investment and evidence is available that either "the carrying amount of the investment in the separate financial statements exceeds the carrying amounts in the consolidated financial statements of the investee's net assets, including associated goodwill", or "the dividend exceeds the total comprehensive income of the subsidiary, joint venture or associate in the period the dividend is declared".
In plain terms, taking cash out of a business faster than the business earns it is a statement about the value of the investment. This indicator sits in the parent's own accounts, where nobody usually looks, and it triggers on a transaction the group treats as routine.
| Indicator | Reference | What it looks like in practice |
|---|---|---|
| Significant unexpected decline in value | 36.12(a) | A comparable transaction, broker valuation or index showing a fall beyond normal use |
| Adverse change in the technological, market, economic or legal environment | 36.12(b) | New legislation, a competitor product shift, loss of a licence, a customer preference change |
| Increase in market rates of return | 36.12(c) | The discount rate rises and the model fails with no change to the business |
| Net assets above market capitalisation | 36.12(d) | Market to book below one, sustained rather than momentary |
| Obsolescence or physical damage | 36.12(e) | Plant damage, a technology superseded, a site incident |
| Idle, discontinued, restructured or disposed early | 36.12(f) | A decarbonisation commitment shortening an asset's life, a site mothballed, a product line stopped |
| Internal reporting shows worse performance | 36.12(g), 36.14 | Actual against budget variance reporting, aggregated current and forecast losses |
| Dividend from a subsidiary, JV or associate | 36.12(h) | A dividend exceeding the investee's total comprehensive income for the period |
How do you move from a market capitalisation shortfall to testing a specific unit?
The market capitalisation indicator is an observation about the whole entity and the test is performed on units, so a bridge is needed. Grant Thornton works this through in its Insights into IAS 36 series and the sequence is worth borrowing. Before concluding that a market to book shortfall requires testing, consider how much of the gap relates to assets and liabilities outside IAS 36's scope, for example where the fair value of net debt differs materially from its carrying value, whether a control premium or a liquidity discount is relevant, how thinly the shares trade, how volatile the price has been, how long the shortfall has persisted, and whether the market knows what management knows.
If a test is then required, the second question is which units. Units carrying goodwill are being tested anyway. For the rest, an entity-level shortfall rarely identifies which unit is the problem on its own, and the judgement has to be made and documented.
Do climate commitments create impairment indicators?
Yes, and they arrive through the existing list rather than through a new one. KPMG's guidance on climate-related matters and impairment makes the point that climate factors are not named in IAS 36 but map onto paragraph 12 without difficulty. A shift in customer preference toward a competitor's lower carbon product is an adverse change in the market environment under 12(b). Emissions legislation that raises a unit's production costs is the same indicator. Investors demanding a higher return from a carbon-exposed sector is 12(c). A voluntary commitment to decarbonise that will see plant abandoned earlier than planned is an internal indicator under 12(f) and 12(g), for the plant and for the unit it sits in.
That last one is the awkward one, because the commitment is usually announced in the front half of the annual report months before anyone in finance treats it as an accounting event.
Real filer: Vodafone Group Plc on the German cash-generating unit
Vodafone recognised a goodwill impairment of EUR 4,350 million against its Germany cash-generating unit for the year ended 31 March 2025, reducing goodwill allocated to Germany from EUR 20,335 million to EUR 15,985 million. The company attributed the charge to significantly lower EBITDAaL performance and reduced medium term growth expectations, with materially higher competitive intensity in the German mobile market identified as the underlying cause. A further EUR 165 million was recognised in Romania, where the drivers were an increase in the discount rate and a downward revision to the five-year business plan. Recoverable amount was determined on a value in use basis, built on the group's five-year formal plans.
The Romanian charge is the more instructive of the two for indicator purposes. Nothing happened to the assets. The rate moved under IAS 36.12(c) and the plan moved under IAS 36.12(g), and that combination was enough.
Vodafone Group Plc, Annual Report 2025, impairment note and auditor's report.Local FAQs
Is the IAS 36.12 list exhaustive? No. IAS 36.12 says an entity "shall consider, as a minimum" those indications, and IAS 36.13 confirms the list is not exhaustive. Anything that makes an earlier expectation about an asset look optimistic is an indicator, whether or not it is named.
Does an indicator always mean an impairment? No. It means a calculation is required. It is entirely normal for an indicator to be present and recoverable amount to exceed carrying amount comfortably, and IAS 36.17 then still requires the useful life, method and residual value to be reviewed.
How long does a market to book shortfall need to persist? The standard sets no period. A shortfall on a single day in a volatile market is weak evidence. A shortfall sustained across a reporting period, particularly one that widens, is difficult to explain away, and the explanation belongs in the file rather than in the conclusion.
Potential risks
The risk here is not missing an obvious indicator, because obvious indicators get found. It is inconsistency across the annual report. A strategic report describing a difficult market, a viability statement modelling a severe downside, and an impairment note reporting no indicators are individually defensible and collectively a finding. The FRC has named exactly that pattern, and it is visible from outside the company without any access to the model.
5. What is recoverable amount, and do you have to calculate both measures?
Recoverable amount is the higher of fair value less costs of disposal and value in use (IAS 36.18). You do not need both. IAS 36.19 stops the exercise as soon as either one exceeds carrying amount, because the asset cannot then be impaired whatever the other measure shows.
"This Standard defines recoverable amount as the higher of an asset's or cash-generating unit's fair value less costs of disposal and its value in use." IAS 36.19 then adds: "It is not always necessary to determine both an asset's fair value less costs of disposal and its value in use. If either of these amounts exceeds the asset's carrying amount, the asset is not impaired and it is not necessary to estimate the other amount."
IAS 36.19 saves more audit and preparer time than any other sentence in the standard, and it is the reason a well-run impairment process starts by asking which of the two measures is easier to support rather than by building a discounted cash flow model by reflex. For a property-heavy unit with a recent valuation, fair value less costs of disposal answers the question in an afternoon.
IAS 36.20 permits value in use alone to serve as recoverable amount where fair value less costs of disposal cannot be measured "because there is no basis for making a reliable estimate of the price at which an orderly transaction to sell the asset would take place between market participants at the measurement date under current market conditions".
IAS 36.21 permits the opposite where there is no reason to believe value in use materially exceeds fair value less costs of disposal, and notes this "will often be the case for an asset that is held for disposal", because the value in use of such an asset consists mainly of the net disposal proceeds anyway.
Note what IAS 36.20 does not say. It does not permit fair value less costs of disposal to be ignored because measuring it is difficult, or because no valuation has been commissioned. The condition is that there is no basis for a reliable estimate, which is a statement about the market rather than about the entity's budget for valuers.
Local FAQs
Which measure should we start with? Whichever is cheaper to support on the facts. A unit with recent comparable transactions or a current property valuation is faster through fair value less costs of disposal. A unit with no observable market has no realistic alternative to value in use.
Can we change basis between years? Yes, and IAS 36.130(e) requires you to disclose which basis was used. A change with no explanation invites the reader to conclude the first measure stopped giving the answer management wanted, which is sometimes fair and sometimes not. One sentence of explanation removes the question.
Does value in use include the eventual sale of the asset? Yes. IAS 36.39(c) includes the net cash flows to be received or paid on disposal at the end of the asset's useful life. Value in use is use plus eventual disposal, not use alone.
Potential risks
The risk is a silent switch of basis. Fair value less costs of disposal is not constrained by IAS 36.44, so a market participant's expectations about restructuring or expansion can be reflected in it where a buyer would pay for them. That makes it a legitimate route to a higher recoverable amount, and it also makes an unexplained move from value in use to fair value less costs of disposal look like a route around the IAS 36.44 restrictions. Where the switch is genuine, say why.
6. What is a cash-generating unit, and how low do you have to go?
A cash-generating unit is the smallest identifiable group of assets that generates cash inflows largely independent of the inflows from other assets or groups of assets (IAS 36.6). IAS 36.22 moves the test to unit level whenever an individual asset does not produce largely independent inflows, which is the position for most assets in most businesses.
"Recoverable amount is determined for an individual asset, unless the asset does not generate cash inflows that are largely independent of those from other assets or groups of assets. If this is the case, recoverable amount is determined for the cash-generating unit to which the asset belongs." IAS 36.22 then gives two exits: the individual test can still be used where the asset's fair value less costs of disposal is higher than its carrying amount, or where value in use can be estimated to be close to fair value less costs of disposal and the latter can be measured.
IAS 36.67 explains when the individual test fails: where value in use cannot be estimated to be close to fair value less costs of disposal, for example because the asset's continuing use generates cash inflows that are not largely independent, or where the asset does not generate largely independent inflows at all.
"As defined in paragraph 6, an asset's cash-generating unit is the smallest group of assets that includes the asset and generates cash inflows that are largely independent of the cash inflows from other assets or groups of assets. Identification of an asset's cash-generating unit involves judgement."
The standard's own example, sitting immediately after IAS 36.68, is the cleanest illustration in the document. A bus company operates five routes under a contract with a municipality requiring a minimum service on each. Assets and cash flows for each route are separately identifiable, and one route runs at a significant loss. Because the entity has no option to curtail any single route, the lowest level of largely independent inflows is the five routes together, and the cash-generating unit for each route is the bus company as a whole.
Read that carefully, because it is easy to invert. Separate revenue data does not create a separate unit. What creates a separate unit is the ability to generate, or to stop generating, cash independently. IAS 36.69 adds that inflows means inflows from parties external to the entity, and directs attention to how management monitors operations, by product line, business, individual location, district or region, and how it makes decisions about continuing or disposing of assets and operations.
IAS 36.70 deals with internal markets: where an active market exists for the output produced by a group of assets, that group is a cash-generating unit even if some or all of the output is used internally, and the cash flows are built on management's best estimate of arm's length prices.
IAS 36.72 requires units to be "identified consistently from period to period for the same asset or types of assets, unless a change is justified". Where the aggregation changes and a loss is recognised or reversed, IAS 36.130(d)(iii) requires disclosure of the current and former way of aggregating assets and the reasons for the change.
Those two paragraphs together are the control on the single most effective way of avoiding an impairment, which is redrawing the unit. It is rarely deliberate, because the wider unit usually corresponds to a genuine management reporting line that has itself changed. The disclosure requirement makes it visible anyway.
| Business | Typical unit | The deciding fact |
|---|---|---|
| Retail chain | Individual store, sometimes a cluster | Whether a single store can be closed without the others losing their inflows |
| Bus operator under a minimum service contract | The whole operation | No option to curtail one route (IAS 36.68 example) |
| Multi-product manufacturer | Production line or plant | Whether the line's output has an external market or an arm's length internal price (IAS 36.70) |
| Hotel group | Individual hotel | Independent bookings and the ability to sell one property |
| Integrated mine and smelter with no external market for concentrate | Mine and smelter together | No external market for the intermediate output |
| Telecoms network | Country or licence area | The network cannot be sold or shut down by region |
Real filer: Burberry Group plc on store-level cash-generating units
Burberry treats each individual retail store as a separate cash-generating unit, comprising that store's right-of-use asset and its property, plant and equipment, and compares value in use, built on pre-tax cash flow projections from each store's own financial plan, with net book value at the balance sheet date. For the year ended 29 March 2025 it recognised GBP 10 million of impairment against property, plant and equipment across 17 retail cash-generating units whose total recoverable amount was GBP 17 million, and GBP 32 million against right-of-use assets, of which GBP 31 million related to 18 retail units with a total recoverable amount of GBP 53 million. A further GBP 4 million was charged against computer software.
Store-level units are the granular end of the range and the conclusion is right, because a store can be closed independently. The consequence is worth noticing: with units this small, impairments and reversals appear every year as individual stores move in and out of headroom, and the note has to explain movement in both directions rather than a single event.
Burberry Group plc, preliminary results announcement for the 52 weeks ended 29 March 2025, 14 May 2025.Local FAQs
Can a cash-generating unit be larger than a legal entity? Yes. Legal structure is irrelevant to the definition in IAS 36.6. Independence of external cash inflows is the only test, and units routinely cut across statutory entities.
What if two units share a factory? Either the factory and both operations form one larger unit, or the factory is a corporate asset allocated across units on a reasonable and consistent basis under IAS 36.100 to 36.102. Both can be defensible. Pick one, document why, and apply it consistently.
Do we have to test every unit every year? Only units carrying goodwill or indefinite life intangibles. Other units are tested when an indicator arises, and the indicator assessment still has to be run for them at every reporting date.
Can the unit change when the business reorganises? Yes, and IAS 36.72 anticipates it. What it does not allow is a change that is not justified, and IAS 36.130(d)(iii) requires the old and new basis to be disclosed where a loss or reversal is recognised.
Potential risks
Drawing the unit wide enough that a failing operation sits inside a profitable one is the most effective way to avoid a write-down and it almost never looks like manipulation, because the wider unit usually matches a real reporting line. The useful challenge is not "is this unit wrong" but "what changed since last year, and why". The FRC specifically flagged lack of clarity in cash-generating unit disclosures in its 2024/25 review, which is what makes that challenge difficult to run from outside the company.
7. What goes into the carrying amount of a cash-generating unit?
IAS 36.75 requires the carrying amount of a unit to be determined on a basis consistent with the way its recoverable amount is determined. IAS 36.76 includes only assets attributable directly, or allocable on a reasonable and consistent basis, that will generate the inflows used in value in use, and excludes recognised liabilities.
"The carrying amount of a cash-generating unit shall be determined on a basis consistent with the way the recoverable amount of the cash-generating unit is determined." IAS 36.76 then specifies that the carrying amount "includes the carrying amount of only those assets that can be attributed directly, or allocated on a reasonable and consistent basis, to the cash-generating unit and will generate the future cash inflows used in determining the cash-generating unit's value in use", and "does not include the carrying amount of any recognised liability, unless the recoverable amount of the cash-generating unit cannot be determined without consideration of this liability".
This is the symmetry rule, and it is the single sentence in IAS 36 that is broken most often. Every argument about what belongs in the carrying amount is in substance an argument about what is in the cash flows. Get the two out of step and the comparison is meaningless, in either direction: an asset in the carrying amount whose cash flows are excluded produces a false impairment, and a liability deducted from carrying amount whose payments stay in the cash flows produces a false pass.
IAS 36.78 sets out the exception. Where the disposal of a unit would require the buyer to assume a liability, and only one measure of recoverable amount is available for the unit and the liability together, the liability is deducted from both sides. The standard's own illustration is a mine with a legal obligation to restore the site: a buyer would not take the mine without the obligation, so the fair value less costs of disposal of the unit is measured net of it, and the restoration provision is deducted from the carrying amount too.
IAS 36.79 adds a practical concession for the same problem in reverse: for practical reasons, recoverable amount is sometimes determined after considering assets that are not part of the unit, such as receivables, or liabilities that have been recognised, such as payables or pensions, and in those cases the carrying amount is increased or decreased by the same amounts.
Both paragraphs say the same thing in different directions. Adjust both sides or neither.
Where the firms answer differently: lease liabilities in the unit
IAS 36 was drafted before IFRS 16 put a right-of-use asset and a lease liability on every balance sheet, and it never addresses the pair directly. The standard leaves the gap and firm guidance has filled it in two different ways.
Grant Thornton states it as a rule. Lease payments are financing cash flows excluded from value in use by IAS 36.50, so the lease liability is excluded from the unit's carrying amount while the right-of-use asset is included. Include the asset, exclude the liability, exclude the payments.
KPMG makes it conditional on what a market participant buyer would do. Where a buyer of the unit would assume the lease liability, KPMG's guidance deducts the carrying amount of the liability from both the unit's carrying amount and its value in use, and identifies further variations where the recognition exemptions in IFRS 16 are applied, in which case the lease payments do belong in the cash flow forecasts.
Where that leaves the preparer. Both approaches respect IAS 36.75 symmetry, so both can be applied without breaching the standard, and on the same facts they produce different headroom. For a retailer with long store leases the difference is not marginal. The position I would take is to follow the approach that matches how the unit would actually be sold, state which one has been applied in the accounting policy, and never mix the two across units in the same group. The error that gets found is not choosing the less common approach. It is deducting the liability from carrying amount while leaving the payments in the cash flows, which double counts the lease and understates the impairment.
Grant Thornton UK, IFRS 16 and impairment; KPMG International, lease assets and assessing recoverability.Local FAQs
Does working capital belong in the unit? Only if the cash flows are built on a basis that reflects movements in it. Receivables and payables sitting in the carrying amount alongside a forecast built on operating profit before working capital movements is the same asymmetry as the lease problem, in a place nobody looks.
What about a pension deficit attributable to the unit? IAS 36.79 allows it to be deducted from carrying amount where recoverable amount has been determined after considering it. The condition is that both sides move together, not that the deficit relates to the unit's employees.
Should the carrying amount be tested before or after other individual asset write-downs? Before the unit test. IAS 36.98 requires an asset within the unit that has its own indicator to be tested and written down first, and only then is the unit containing the goodwill tested. The same bottom-up order applies between a unit and a group of units.
Potential risks
Beyond leases and working capital, the third recurring asymmetry is head office. Central costs are charged into the unit's forecast cash flows while the head office asset sits outside every unit and is never tested at the higher level required by IAS 36.102. The unit is then carrying the cost without the asset, and the corporate asset is carrying neither.
8. How is value in use calculated, and what has to be left out of the cash flows?
Value in use is the present value of the cash flows expected from the asset in its current condition. IAS 36.33 caps the approved budget period at five years and caps the terminal growth rate at long-run average growth. IAS 36.44 and 36.50 exclude uncommitted restructuring, enhancement of performance, financing cash flows and tax.
IAS 36.30 requires five elements to be reflected: "(a) an estimate of the future cash flows the entity expects to derive from the asset; (b) expectations about possible variations in the amount or timing of those future cash flows; (c) the time value of money, represented by the current market risk-free rate of interest; (d) the price for bearing the uncertainty inherent in the asset; and (e) other factors, such as illiquidity, that market participants would reflect in pricing the future cash flows."
IAS 36.32 then makes the practical point that elements (b), (d) and (e) can be reflected either as adjustments to the cash flows or as adjustments to the discount rate. That is the origin of the double-counting problem in unit 9. Risk goes in one place or the other. Putting a conservative haircut on the cash flows and a risk premium in the rate charges for the same risk twice, and the result is an impairment the standard does not require.
"In measuring value in use an entity shall: (a) base cash flow projections on reasonable and supportable assumptions that represent management's best estimate of the range of economic conditions that will exist over the remaining useful life of the asset. Greater weight shall be given to external evidence. (b) base cash flow projections on the most recent financial budgets/forecasts approved by management, but shall exclude any estimated future cash inflows or outflows expected to arise from future restructurings or from improving or enhancing the asset's performance. Projections based on these budgets/forecasts shall cover a maximum period of five years, unless a longer period can be justified. (c) estimate cash flow projections beyond the period covered by the most recent budgets/forecasts by extrapolating the projections ... using a steady or declining growth rate for subsequent years, unless an increasing rate can be justified. This growth rate shall not exceed the long-term average growth rate for the products, industries, or country or countries in which the entity operates, or for the market in which the asset is used, unless a higher rate can be justified."
Three separate constraints sit in that one paragraph. The starting point must be the approved budget, not a model built for the impairment test. The explicit period is capped at five years. The terminal growth rate is capped at long-run average growth. All three are breachable with justification, and very few justifications survive contact with an audit file. A terminal growth rate above long-run growth for the relevant market is a claim that the unit outgrows its economy in perpetuity, and that claim needs evidence rather than a footnote.
IAS 36.34 adds the discipline nobody applies: management should assess the reasonableness of its current assumptions "by examining the causes of differences between past cash flow projections and actual cash flows".
"Future cash flows shall be estimated for the asset in its current condition. Estimates of future cash flows shall not include estimated future cash inflows or outflows that are expected to arise from: (a) a future restructuring to which an entity is not yet committed; or (b) improving or enhancing the asset's performance."
IAS 36.45 makes both limbs symmetrical: value in use does not reflect the cost savings or benefits expected from an uncommitted restructuring, and it does not reflect the outflows that would improve performance or the inflows expected to arise from them.
The enhancement rule is the one the FRC named in its 2024/25 review. You are valuing the asset you own today, not the asset the investment plan will eventually create. Maintenance capital expenditure stays in, because it sustains the current standard of performance. Growth capital expenditure comes out, and the growth comes out with it.
Preparers find this hard for a structural reason. IAS 36.33(b) requires the approved budget as the starting point, and the approved budget is almost always a growth plan. The adjustment from board budget to IAS 36 cash flows is therefore a real reconciliation, and it should exist as a document rather than as an assertion that the budget was adjusted.
IAS 36.39 defines what is in: inflows from continuing use, outflows necessarily incurred to generate those inflows including outflows to prepare the asset for use, and the net cash flows on disposal at the end of the useful life. IAS 36.50 defines what is out: "(a) cash inflows or outflows from financing activities; or (b) income tax receipts or payments."
IAS 36.51 explains why: "Estimated future cash flows reflect assumptions that are consistent with the way the discount rate is determined. Otherwise, the effect of some assumptions will be counted twice or ignored. Because the time value of money is considered by discounting the estimated future cash flows, these cash flows exclude cash inflows or outflows from financing activities. Similarly, because the discount rate is determined on a pre-tax basis, future cash flows are also estimated on a pre-tax basis."
IAS 36.40 completes the consistency set for inflation. A nominal discount rate requires nominal cash flows. A real rate requires real cash flows, which still carry specific price increases and decreases even though general inflation has been stripped out.
Worked example 1: how much of the answer comes from the terminal value?
Figures in GBP thousands. A manufacturing cash-generating unit has a carrying amount of 33,000 at the year end. Management's approved five-year plan gives pre-tax operating cash flows of 4,200, 4,000, 3,800, 3,600 and 3,500. Beyond year five, the year five cash flow is grown at 2.0 per cent into perpetuity. The pre-tax discount rate is 12.0 per cent.
| Year | Pre-tax cash flow | Discount factor at 12.0% | Present value |
|---|---|---|---|
| 1 | 4,200 | 0.8929 | 3,750 |
| 2 | 4,000 | 0.7972 | 3,189 |
| 3 | 3,800 | 0.7118 | 2,705 |
| 4 | 3,600 | 0.6355 | 2,288 |
| 5 | 3,500 | 0.5674 | 1,986 |
| Explicit five-year period | 13,917 | ||
| Terminal value at end of year 5 | 3,500 x 1.02 / (0.12 - 0.02) = 35,700 | 0.5674 | 20,257 |
| Value in use | 34,174 |
Result. Value in use of 34,174 exceeds the carrying amount of 33,000, so no impairment is recognised. Headroom is 1,174, which is 3.6 per cent of carrying amount.
Where the value came from. The terminal value contributes 20,257 of the 34,174, just under 60 per cent. The five years of detailed budget that took three weeks to build account for 41 per cent. Two assumptions nobody argued about, the 2.0 per cent growth rate and the 12.0 per cent discount rate, are carrying the decision.
Sensitivity. Rerun the model twice. At a discount rate of 13.0 per cent with growth unchanged, value in use is 31,206 and the unit is impaired by 1,794. At a discount rate of 12.0 per cent with terminal growth of 1.0 per cent, value in use is 32,152 and the unit is impaired by 848.
Working backwards, the headroom disappears at a discount rate of approximately 12.4 per cent, an increase of about 0.4 percentage points, or at a terminal growth rate of approximately 1.4 per cent, a fall of about 0.6 percentage points. Both are reasonably possible changes on any sensible reading, so IAS 36.134(f) requires disclosure of the headroom of 1,174, the assumed values of 12.0 per cent and 2.0 per cent, and the change in each that would eliminate the headroom.
What to take from this. A unit that passes its test by 3.6 per cent of carrying amount has not really passed. It has moved the question from the impairment line to the disclosure note, where IAS 36.134(f) requires it to be quantified.
Practitioner note
The fastest way to test whether a value in use model has been thought about is to ask for the schedule comparing the last three years of impairment model forecasts against what actually happened. IAS 36.34 asks management to do exactly that, and it is the single most useful working paper in an impairment file. It is also the one almost nobody prepares, which means that on most engagements the first person to build it finds something.
Local FAQs
Can we forecast for longer than five years? Yes if it can be justified, and IAS 36.134(d)(iii) then requires the justification to be disclosed. Long asset lives, contracted revenue streams and regulated returns are justifications that hold. An internal ten-year planning cycle is not one, because the constraint is about the reliability of the estimate rather than about internal process.
Do we include the cost of a major overhaul? Yes if the overhaul maintains the asset's current standard of performance. No if it lifts performance above that standard, because that is enhancement under IAS 36.44(b).
Can we include a restructuring we have announced? Only once the entity is committed. The IAS 37 test for recognising a restructuring provision is the practical anchor, and where no provision has been recognised it is difficult to argue commitment for IAS 36 purposes.
Does value in use include cash flows from an asset the unit does not yet own? No. The unit is valued in its current condition, which excludes both the acquisition of new assets and the returns they would generate.
Potential risks
Hockey sticks. The first budget year is realistic because it will be compared against actual results within twelve months. Years three to five drift upward, and the terminal year takes whichever number the model needed. The second risk is more subtle: risk reflected in both the cash flows and the rate, which IAS 36.32 and 36.56 both warn against, and which produces an impairment the standard does not require. Overstating a loss is a misstatement in the same way as understating one.
9. What discount rate does IAS 36 require, and why must it be pre-tax?
IAS 36.55 requires a pre-tax rate reflecting current market assessments of the time value of money and the risks specific to the asset for which the cash flows have not been adjusted. IAS 36.A20 requires a post-tax starting point such as a WACC to be adjusted to a pre-tax rate, and does not say how.
"The discount rate (rates) shall be a pre-tax rate (rates) that reflect(s) current market assessments of: (a) the time value of money; and (b) the risks specific to the asset for which the future cash flow estimates have not been adjusted."
IAS 36.56 defines that rate as "the return that investors would require if they were to choose an investment that would generate cash flows of amounts, timing and risk profile equivalent to those that the entity expects to derive from the asset", estimated from the rate implicit in current market transactions for similar assets, or from the weighted average cost of capital of a listed entity holding a similar single asset or portfolio. It closes with the warning: the rate "shall not reflect risks for which the future cash flow estimates have been adjusted. Otherwise, the effect of some assumptions will be double-counted."
Appendix A gives the practical route. IAS 36.A17 permits the entity's weighted average cost of capital determined using techniques such as the capital asset pricing model, its incremental borrowing rate, or other market borrowing rates as a starting point. IAS 36.A18 requires those rates to be adjusted to reflect how the market would assess the specific risks of the asset's cash flows and to exclude risks not relevant to them or already reflected in the cash flows, naming country risk, currency risk and price risk.
IAS 36.A19 states that the rate "is independent of the entity's capital structure and the way the entity financed the purchase of the asset". A company with cheap debt does not get an easier impairment test.
IAS 36.A20 is the sentence that causes all the trouble: "Paragraph 55 requires the discount rate used to be a pre-tax rate. Therefore, when the basis used to estimate the discount rate is post-tax, that basis is adjusted to reflect a pre-tax rate." It requires an adjustment. It does not specify the method.
IAS 36.A21 permits a single rate normally, and separate rates for different future periods where value in use is sensitive to a difference in risk across periods or to the term structure of interest rates.
Worked example 2: what happens if you gross up a post-tax rate?
Figures in GBP thousands. A unit generates pre-tax cash flows of 1,000 a year for five years and nothing thereafter. To keep the illustration clean, assume tax is charged at 25 per cent on that same amount in the same year, so post-tax cash flow is 750 a year. The post-tax discount rate is 9.0 per cent.
- The post-tax model. The five-year annuity factor at 9.0 per cent is 3.8897. Value in use is 750 x 3.8897 = 2,917.
- The simple gross-up. 9.0 per cent divided by (1 minus 0.25) gives 12.0 per cent. Discounting pre-tax flows of 1,000 at 12.0 per cent gives an annuity factor of 3.6048 and a value in use of 3,605, which is 688 higher than the post-tax model on the same unit on the same day.
- The rate that actually reconciles. Solve for the rate at which 1,000 a year for five years has a present value of 2,917. The required annuity factor is 2.9172, which sits between 21.0 per cent (2.9260) and 21.5 per cent (2.8945). The implied pre-tax rate is approximately 21.1 per cent, not 12.0 per cent.
Why the gap is so wide. Grossing up the rate assumes tax behaves as a constant proportional drag on the discount rate. It does not. Tax takes a proportion of every cash flow, and the relationship between that and the rate depends on the timing and shape of the flows. This illustration has no tax depreciation and no timing differences, and the two answers are still nowhere near each other. Add real capital allowances, loss relief and a terminal period and the gap moves again.
The practical consequence. The pre-tax rate is an output of the valuation, not an input to it. It is the rate reported after the model has been run, not the rate the model started with.
Where the firms and the regulator answer differently: deriving the pre-tax rate
IAS 36.A20 requires an adjustment and specifies no method, so practice has divided along a materiality line rather than a principle.
Grant Thornton takes the pragmatic route. It accepts that computing a true pre-tax rate is complex because it needs information about the specific timing of tax cash flows, and states that a gross-up approach may provide a reasonable approximation in some circumstances, particularly where the simplified calculation still produces a value in use comfortably above carrying amount so that impairment is unlikely either way. Where the outcome is close, it points to running a post-tax model on post-tax cash flows and then goal-seeking the pre-tax rate that reproduces the same value in use, and warns explicitly that the pre-tax rate is not the post-tax rate grossed up at the standard rate of tax.
The FRC is firmer, and as a regulator it outranks firm guidance. Its thematic review of discount rates, published in May 2022, found that companies typically start from a WACC, which is a post-tax rate, and that simply grossing it up fails to reflect either differing tax rates or varying cash flows over time. Where a post-tax model is used, the FRC expects the company to demonstrate that the result is not materially different from a pre-tax calculation and to disclose the equivalent pre-tax rates, together with an explanation of how they were determined, how the method has changed and what the effect was, and how the rates differ between units.
Where that leaves the preparer. There is no divergence on the principle, only on how much work is proportionate. A gross-up is defensible as a screening tool where headroom is wide. Once a unit is anywhere near its carrying amount, the goal-seek is the only method that survives review, and the pre-tax rate disclosed has to be the one the model actually implies. Disclosing 12.0 per cent when the model implies 21.1 per cent is not a rounding difference. It tells the reader something untrue about how demanding the test was.
Grant Thornton, Insights into IAS 36, value in use and applying the appropriate discount rate; Financial Reporting Council, thematic review of discount rates, May 2022.Local FAQs
Can different units use different rates? Yes, and usually they should. The rate reflects the risks of that unit's cash flows. A group applying one rate across units in different countries and industries is asserting that those risks are identical, which is a claim worth challenging and which the FRC expects to see explained.
Can we use different rates for different years? Yes, where value in use is sensitive to differences in risk across periods or to the term structure of interest rates (IAS 36.A21). It is rare in practice but it is available, and it is the right answer where a long-dated asset faces materially different risk in its later years.
Does the entity's actual borrowing cost matter? No. IAS 36.A19 makes the rate independent of capital structure and of how the asset was financed. The entity's own cost of debt is a starting point under IAS 36.A17, not the answer.
Potential risks
Two. The first is a disclosed pre-tax rate that was never derived, which is a disclosure misstatement even where the impairment conclusion happens to be right. The second is double counting, where a risk premium is loaded into the rate for a risk that has already been taken out of the cash flows. IAS 36.56 prohibits it in terms, and it produces an overstated impairment, which is a misstatement in the same way an understated one is.
10. When is fair value less costs of disposal the better measure?
Fair value less costs of disposal is fair value measured under IFRS 13 less the direct incremental costs of disposal (IAS 36.28). It is stronger where observable market evidence exists, because it uses market participant assumptions and is not constrained by IAS 36.44. It is weaker where it collapses into a Level 3 model that mirrors value in use.
IAS 36.28 defines costs of disposal as the direct incremental costs attributable to the disposal of the asset, excluding finance costs and income tax expense, and excludes costs already recognised as liabilities so that they are not deducted twice. Fair value itself is measured under IFRS 13, which means market participant assumptions rather than the entity's own intentions.
That distinction is the point of having two measures. Value in use is entity-specific and captures synergies and plans that only this entity has. Fair value less costs of disposal is what a buyer would pay, and it is not constrained by IAS 36.44, so a market participant's expectations about restructuring or expansion can be reflected where a buyer would price them in. Those are genuinely different questions with genuinely different answers, and the standard takes the higher.
Where recoverable amount is fair value less costs of disposal, IAS 36.130(f) requires the level of the IFRS 13 fair value hierarchy in which the measurement falls, the valuation technique used for Level 2 and Level 3 measurements, and any change in technique with the reasons. IAS 36.134(e) adds, for units carrying significant goodwill or indefinite life intangibles, each key assumption, how management determined it, and whether it reflects past experience or external sources.
Those requirements are what stop the fair value route being a way of disclosing less. A Level 3 fair value less costs of disposal model built on management's own budget with a market participant label attached is the version that does not survive scrutiny, and the disclosure requirements are drafted precisely to expose it.
Local FAQs
Can a recent offer for the business be used? A binding sale agreement is strong evidence of fair value less costs of disposal. An indicative offer is weaker and IFRS 13 requires market participant assumptions rather than one buyer's assumptions, but an offer well below carrying amount is at minimum an indicator under IAS 36.12(a).
Are disposal costs the same as costs to sell under IFRS 5? The concepts are close. Both capture direct incremental costs of disposal. IAS 36.28 excludes finance costs and income tax expense, and excludes costs already recognised as liabilities.
Does fair value less costs of disposal allow the growth capital expenditure that IAS 36.44 excludes? It allows what a market participant would assume, which may include an expansion a buyer would pay for. It does not allow management's own plan simply relabelled. The evidence has to be about the market, not about the board pack.
Potential risks
The unexplained switch. Moving from value in use to fair value less costs of disposal is often a move away from the IAS 36.44 restrictions, which is a legitimate reason and is worth stating plainly. Where the basis changes between years with no explanation, IAS 36.130(e) has still been complied with in form, and the reader is left to draw the obvious inference. One sentence closes the gap.
11. How is an impairment loss recognised and allocated across a cash-generating unit?
IAS 36.104 allocates the loss first against goodwill allocated to the unit, then across the other assets pro rata on their carrying amounts. IAS 36.105 then stops any individual asset being written below the highest of its own fair value less costs of disposal, its own value in use and zero, and reallocates any blocked amount across the remaining assets.
"An impairment loss shall be recognised for a cash-generating unit (the smallest group of cash-generating units to which goodwill or a corporate asset has been allocated) if, and only if, the recoverable amount of the unit (group of units) is less than the carrying amount of the unit (group of units). The impairment loss shall be allocated to reduce the carrying amount of the assets of the unit (group of units) in the following order: (a) first, to reduce the carrying amount of any goodwill allocated to the cash-generating unit (group of units); and (b) then, to the other assets of the unit (group of units) pro rata on the basis of the carrying amount of each asset in the unit (group of units)."
The order is not a presentational convention. Because IAS 36.124 prohibits reversal of a goodwill impairment, the sequence determines how much of the loss is permanently locked in. A unit that takes its loss entirely against goodwill can never recover any of it, whatever happens next. The same unit taking the same loss against plant can recover up to the IAS 36.117 ceiling.
"In allocating an impairment loss in accordance with paragraph 104, an entity shall not reduce the carrying amount of an asset below the highest of: (a) its fair value less costs of disposal (if measurable); (b) its value in use (if determinable); and (c) zero. The amount of the impairment loss that would otherwise have been allocated to the asset shall be allocated pro rata to the other assets of the unit (group of units)."
IAS 36.106 explains why the pro rata mechanism exists at all: where it is not practicable to estimate the recoverable amount of each individual asset, the standard accepts an arbitrary allocation between the assets of the unit other than goodwill, because all assets of a unit work together. The allocation is therefore not a valuation of each asset. It is a convention, with a protective floor bolted on.
The floor is the step most often skipped, and skipping it produces a file where the total loss is right and every individual line is wrong. That survives review because the control total ties, and it corrupts the depreciation charge on every affected asset for the rest of its life.
Worked example 3: how does the loss land across the assets of a unit?
Figures in GBP thousands. A cash-generating unit has the following carrying amounts at the year end, and a recoverable amount of 10,400. The property carries a recent open market valuation supporting fair value less costs of disposal of 5,600. No other asset has a separately measurable recoverable amount.
| Asset | Carrying amount | Share of 12,000 | Provisional allocation |
|---|---|---|---|
| Goodwill | 3,000 | Step 1 | 3,000 |
| Brand, indefinite life | 2,000 | 16.7% | 267 |
| Property | 6,000 | 50.0% | 800 |
| Plant and equipment | 4,000 | 33.3% | 533 |
| Total | 15,000 | 4,600 |
The impairment loss is 15,000 less 10,400 = 4,600. Goodwill absorbs 3,000 and goes to nil, leaving 1,600 to spread across carrying amounts of 12,000.
Step 3 changes the answer. The provisional allocation would take the property to 6,000 less 800 = 5,200, below its fair value less costs of disposal of 5,600. IAS 36.105 blocks that. The property can absorb only 400, and the excess 400 is reallocated across the brand and plant pro rata on their carrying amounts of 2,000 and 4,000, giving 133 to the brand and 267 to plant.
| Asset | Before | Impairment | After |
|---|---|---|---|
| Goodwill | 3,000 | (3,000) | nil |
| Brand, indefinite life | 2,000 | (400) | 1,600 |
| Property | 6,000 | (400) | 5,600 |
| Plant and equipment | 4,000 | (800) | 3,200 |
| Total | 15,000 | (4,600) | 10,400 |
| Account | Dr | Cr |
|---|---|---|
| Impairment loss (profit or loss) | 4,600 | |
| Goodwill | 3,000 | |
| Intangible assets, brand | 400 | |
| Property | 400 | |
| Plant and equipment | 800 |
What step 3 changed. Plant took 800 instead of 533 and the brand took 400 instead of 267. Depreciation and amortisation for every future period move with them. Ignoring the floor produces the correct total and the wrong figure on every line, and because the total ties, the error is invisible on review.
Real filer: Anglo American plc on De Beers
Anglo American recognised a pre-tax impairment of USD 2.3 billion in relation to De Beers for the year ended 31 December 2025, contributing to a loss attributable to equity shareholders of USD 3.7 billion for the year. It was the third consecutive year in which De Beers was written down, against continued weakness in rough diamond trading conditions, and De Beers remained within continuing operations for accounting purposes rather than being measured under IFRS 5.
Three write-downs in three years is the pattern worth noticing. An impairment is a statement that the previous forecast was too optimistic. Repeating it annually is a statement that the forecasting method has not been corrected, and that is a question for the audit committee rather than for the valuation model.
Anglo American plc, full year 2025 results announcement.Local FAQs
Can we allocate the loss to the asset that has actually fallen in value? Not unless that asset has its own indicator, in which case IAS 36.98 requires it to be tested and written down first, before the unit test runs. Within the unit allocation itself, IAS 36.104(b) requires pro rata on carrying amount and permits no ranking by asset type.
What if the loss cannot be fully allocated? IAS 36.108 leaves the unallocated amount unrecognised unless another standard requires a liability. That is the one place where the unit is not written down to recoverable amount in the accounts, and it should be explained in the note rather than left as an unexplained difference.
Does the charge go in operating profit? IAS 36.126(a) requires the line item containing the loss to be disclosed, and IAS 1 and IFRS 18 govern where it sits. The presentational trap is excluding the charge from an underlying measure while later years quietly enjoy the reduced depreciation inside that same measure.
Potential risks
Two beyond the floor. First, the fixed asset register keeps the pre-impairment depreciation profile, so IAS 36.63 is breached silently from the following month. Second, the impairment sits in an adjusting column while the depreciation saving it creates does not, which flatters every subsequent period by exactly the amount the write-down was meant to cost.
12. How is goodwill allocated to cash-generating units and tested for impairment?
Goodwill generates no cash of its own, so IAS 36.80 allocates it from the acquisition date to the units or groups of units expected to benefit from the synergies of the combination. Each must be the lowest level at which goodwill is monitored internally, and no larger than an operating segment before aggregation. Those units are tested annually and on indicators.
"For the purpose of impairment testing, goodwill acquired in a business combination shall, from the acquisition date, be allocated to each of the acquirer's cash-generating units, or groups of cash-generating units, that is expected to benefit from the synergies of the combination, irrespective of whether other assets or liabilities of the acquiree are assigned to those units or groups of units. Each unit or group of units to which the goodwill is so allocated shall: (a) represent the lowest level within the entity at which the goodwill is monitored for internal management purposes; and (b) not be larger than an operating segment as defined by paragraph 5 of IFRS 8 Operating Segments before aggregation."
The two conditions pull in opposite directions and that tension is the design. The internal monitoring test pushes the level down to wherever management actually watches the acquisition. The operating segment ceiling stops it being pushed up into a group so large that no acquisition could ever fail. IAS 36.81 explains why groups of units are permitted at all: goodwill often contributes to the cash flows of several units and sometimes cannot be allocated to individual units on a non-arbitrary basis.
IAS 36.82 adds a point that is useful in a conversation with management: applying paragraph 80 results in goodwill being tested at the level that reflects the way the entity manages its operations, so the development of additional reporting systems is typically not necessary. If the answer requires a new reporting system, the level is probably wrong.
Note also the phrase "irrespective of whether other assets or liabilities of the acquiree are assigned". Goodwill from an acquisition can and often should sit in a legacy unit that benefits from the synergies, even though none of the acquired assets went there.
IAS 36.84 requires the initial allocation to be completed before the end of the first annual period beginning after the acquisition date where it cannot be completed in the year of acquisition itself. IAS 36.86 deals with disposals: where an operation within a unit is disposed of, the goodwill associated with that operation is included in the carrying amount of the operation when determining the gain or loss, measured on relative values unless the entity can demonstrate a better method. IAS 36.87 requires goodwill to be reallocated on a relative value basis when an entity reorganises its reporting structure in a way that changes the composition of units.
Those two paragraphs are the maintenance requirements, and they are the ones that decay. Goodwill from an acquisition eight years ago, in a group reorganised twice since, with no reallocation on either occasion, sits in a unit that is now large enough that it can never fail. Nothing in the accounts flags that, because each individual year looks unremarkable.
IAS 36.90 sets the test: "A cash-generating unit to which goodwill has been allocated shall be tested for impairment annually, and whenever there is an indication that the unit may be impaired, by comparing the carrying amount of the unit, including the goodwill, with the recoverable amount of the unit."
IAS 36.88 covers unallocated goodwill: where goodwill relates to a unit but has not been allocated to it, that unit is tested first without the goodwill whenever an indicator exists, and the larger group of units including the goodwill is then tested as well.
IAS 36.98 fixes the order of testing within a unit. Where there is an indication that an individual asset inside the unit is impaired, that asset is tested and written down first, before the unit containing the goodwill is tested. The same bottom-up sequence applies between a unit and a group of units. Getting the order wrong shelters an impaired asset behind the unit's headroom.
IAS 36.96 permits the annual test at any time in the year provided it is at the same time each year, with different units tested at different times. IAS 36.99 allows a prior period calculation to be reused only where the assets and liabilities of the unit have not changed significantly, the last calculation gave a substantial margin, and the likelihood that a current calculation would fall below carrying amount is remote.
| Question | Requirement | Reference |
|---|---|---|
| Where does the goodwill sit? | Units or groups of units expected to benefit from the synergies, whether or not acquired assets went there | 36.80 |
| How low? | Lowest level at which goodwill is monitored internally | 36.80(a) |
| How high? | No larger than an operating segment before aggregation | 36.80(b) |
| By when? | Before the end of the first annual period beginning after acquisition | 36.84 |
| What if we reorganise? | Reallocate on a relative value basis | 36.87 |
| What if we sell part of it? | Include the associated goodwill in the carrying amount of the operation disposed of | 36.86 |
| What if an asset inside the unit is impaired? | Test and write down that asset first, then the unit | 36.98 |
| Can we reuse last year's calculation? | Only if all three conditions are met | 36.99 |
| Can a goodwill impairment be reversed? | Never, including one recognised at an interim date | 36.124, IFRIC 10.8 |
What happens where the non-controlling interest is measured at its proportionate share?
Where an entity measures a non-controlling interest at its proportionate share of net assets rather than at fair value, the goodwill recognised relates only to the parent's interest. IAS 36.C4 requires that goodwill to be grossed up notionally to include the amount attributable to the non-controlling interest before the unit is tested, and the resulting impairment loss to be split between the amount relating to recognised goodwill and the amount relating to the notional goodwill, with only the first recognised. It is a mechanical adjustment and it is easy to omit, with the result that a partly owned unit appears less impaired than it is.
Real filer: Vodafone Group Plc on the size of a single goodwill balance
Vodafone carried EUR 15,985 million of goodwill allocated to its Germany cash-generating unit at 31 March 2025, out of total group goodwill of EUR 20,514 million, after the EUR 4,350 million charge in the year. Total goodwill fell from EUR 24,956 million to EUR 20,514 million across the same period.
The concentration is the point. A single unit holding roughly three quarters of the group's goodwill is squarely within the IAS 36.134 disclosure population, and the sensitivity requirement in IAS 36.134(f) is doing most of the work for a reader, because a small movement in the German plan or in the discount rate moves a very large number.
Vodafone Group Plc, Annual Report 2025, goodwill and impairment note.Local FAQs
Can goodwill be tested at group level? Only where the group is a single operating segment and that is genuinely the lowest level at which goodwill is monitored. For most groups this fails both limbs of IAS 36.80, and ESMA has restated the operating segment ceiling in its enforcement priorities, which tells you what enforcers are finding.
What happens to goodwill when part of a unit is sold? A proportion leaves with the disposal under IAS 36.86, normally on relative values. Leaving the whole balance behind overstates the gain on disposal and loads the remaining unit with goodwill it no longer supports.
Does goodwill have to be allocated to a unit that received acquired assets? No. IAS 36.80 follows the synergies, not the assets. A common and correct answer is that some of the goodwill sits in the acquirer's existing units.
Is an annual test required even where the unit has obvious headroom? Yes, subject only to the narrow reuse relief in IAS 36.99. The test is mandatory under IAS 36.10(b) and 36.90 regardless of how comfortable the answer looks.
Potential risks
The allocation decays quietly. Reorganisations happen, IAS 36.87 reallocation does not, and after several years the goodwill sits at a level where failure is arithmetically impossible. The second risk is the disclosure population: IAS 36.135 permits an aggregate disclosure where no individual allocation is significant, and it is occasionally used as a route to avoid unit-level disclosure by declaring nothing significant. That paragraph exists for genuinely diffuse goodwill, not for concentrated goodwill nobody wants to describe.
13. How are corporate assets and head office brought into the test?
Corporate assets generate no independent cash inflows and cannot be fully attributed to one unit. IAS 36.102 requires the portion that can be allocated on a reasonable and consistent basis to be tested with the unit, and where it cannot be allocated, the unit is tested alone and then again as part of the smallest group of units to which the corporate asset can be allocated.
"Corporate assets include group or divisional assets such as the building of a headquarters or a division of the entity, EDP equipment or a research centre. The structure of an entity determines whether an asset meets this Standard's definition of corporate assets for a particular cash-generating unit. The distinctive characteristics of corporate assets are that they do not generate cash inflows independently of other assets or groups of assets and their carrying amount cannot be fully attributed to the cash-generating unit under review."
IAS 36.102 sets the two-branch test. Where a portion of the carrying amount can be allocated to the unit on a reasonable and consistent basis, allocate it and compare the enlarged carrying amount with recoverable amount. Where it cannot, compare the unit's carrying amount with its recoverable amount without the corporate asset, identify the smallest group of units that includes the unit and to which the corporate asset can be allocated on a reasonable and consistent basis, and then compare the carrying amount of that group, including the allocated portion, with its recoverable amount.
The structure mirrors the unallocated goodwill test in IAS 36.88, for the same reason. An asset serving several units has to be tested against all of them, and the second comparison can produce a loss the first did not.
Local FAQs
Is a shared ERP system a corporate asset? Usually yes, and IAS 36.100 names EDP equipment expressly. The question is whether a portion of its carrying amount can be allocated to a unit on a reasonable and consistent basis, which for a system with per-user or per-transaction usage data is often achievable.
What is a reasonable and consistent allocation basis? The standard does not prescribe one. Revenue, headcount, floor area and usage are all defensible where they correlate with the benefit the unit receives. What matters is that the same basis is applied to the asset and, where relevant, to the costs in the cash flow forecasts.
Can a head office be impaired on its own? Only where management has decided to dispose of it, which gives it a recoverable amount of its own (IAS 36.101). Otherwise it is tested only as part of a unit or group of units.
Potential risks
The head office is excluded from every unit and never tested at the higher level, so a group with several failing units still carries an unimpaired head office. The mirror error is allocating the head office to units on headcount while the head office costs in the forecast cash flows are allocated on revenue. Both sides have to move on the same basis, which is IAS 36.75 again in a different disguise.
14. When can an impairment loss be reversed, and how far?
For assets other than goodwill, IAS 36.114 permits reversal only where the estimates used to determine recoverable amount have changed since the loss was recognised. IAS 36.117 caps the increase at the carrying amount that would have applied, net of depreciation, had no impairment ever been recognised. IAS 36.124 prohibits reversal of goodwill outright.
"An entity shall assess at the end of each reporting period whether there is any indication that an impairment loss recognised in prior periods for an asset other than goodwill may no longer exist or may have decreased. If any such indication exists, the entity shall estimate the recoverable amount of that asset."
IAS 36.111 mirrors the impairment indicators in reverse: observable indications that value has increased significantly, favourable changes in the technological, market, economic or legal environment, decreases in market interest rates likely to increase recoverable amount materially, favourable changes in the extent or manner in which the asset is used, and internal evidence that economic performance is or will be better than expected.
The obligation is symmetrical and it is regularly ignored. Companies that impaired quickly during a downturn are often slow to run the reversal assessment when conditions recover, and IAS 36.110 gives them no discretion about whether to look.
"An impairment loss recognised in prior periods for an asset other than goodwill shall be reversed if, and only if, there has been a change in the estimates used to determine the asset's recoverable amount since the last impairment loss was recognised."
IAS 36.115 gives examples of what counts: a change in the basis for recoverable amount, a change in the amount or timing of estimated cash flows or in the discount rate where value in use was used, or a change in a component of fair value less costs of disposal.
What does not count is the passage of time. Unwinding of the discount increases present value mechanically as the cash flows come closer, and IAS 36.116 confirms that this alone does not support a reversal even though recoverable amount has technically risen. A reversal booked because the model produced a higher number a year later, with no change in estimate, has no basis.
IAS 36.117 sets the ceiling: "The increased carrying amount of an asset other than goodwill attributable to a reversal of an impairment loss shall not exceed the carrying amount that would have been determined (net of amortisation or depreciation) had no impairment loss been recognised for the asset in prior years." IAS 36.118 explains what happens above the ceiling: that would be a revaluation, accounted for under the standard applicable to the asset.
IAS 36.119 recognises the reversal immediately in profit or loss, unless the asset is carried at a revalued amount, in which case it is treated as a revaluation increase. IAS 36.121 requires the depreciation charge to be adjusted in future periods over the remaining useful life, mirroring IAS 36.63.
For a unit, IAS 36.122 allocates the reversal to the assets of the unit, except goodwill, pro rata with their carrying amounts, and IAS 36.123 caps each asset at the lower of its own recoverable amount if determinable and its own never-impaired carrying amount, reallocating any excess to the other assets except goodwill.
"An impairment loss recognised for goodwill shall not be reversed in a subsequent period." IAS 36.125 gives the reason: IAS 38 prohibits recognising internally generated goodwill, and any increase in the recoverable amount of goodwill after an impairment is likely to be internally generated goodwill rather than a recovery of the acquired goodwill.
IFRIC 10.8 closes the remaining gap: "An entity shall not reverse an impairment loss recognised in a previous interim period in respect of goodwill." A goodwill impairment booked at 30 June cannot be reversed at 31 December of the same year, even where the conditions that caused it have gone completely. That is the deliberate outcome, and it is the reason the sequencing in IAS 36.104 matters so much.
Worked example 4: how far can a reversal go?
Figures in GBP thousands. A machine costing 1,000 is acquired on 1 January 20X1 and depreciated straight line over ten years with no residual value.
- 31 December 20X3. Carrying amount is 700. An indicator arises and recoverable amount is 420. An impairment loss of 280 is recognised in profit or loss. The revised carrying amount of 420 is then depreciated over the remaining seven years at 60 a year, as IAS 36.63 requires.
- 31 December 20X5. Carrying amount is 420 less two years at 60, so 300. Conditions have improved, the estimates have genuinely changed, and recoverable amount is now 560.
The ceiling. Had the impairment never been recognised, the carrying amount at 31 December 20X5 would have been 1,000 less five years at 100, so 500.
The reversal. Limited to 500 less 300 = 200, even though recoverable amount is 560.
| Account | Dr | Cr |
|---|---|---|
| Property, plant and equipment | 200 | |
| Reversal of impairment loss (profit or loss) | 200 |
Depreciation from 20X6 is 500 spread over the remaining five years, so 100 a year, back on the original schedule. The 60 of recoverable amount above the ceiling is never recognised.
The contrast that matters. Had the 280 written off in 20X3 been goodwill rather than machinery, none of it could come back. Not 200, not any part of it, ever. Same facts, same recovery, permanently different answer.
Real filer: Tullow Oil plc on an interim impairment reversed at the year end
Tullow recognised an impairment of USD 35 million against the TEN fields at 30 June 2025 and reversed it in full at the year end, once fair value less costs of disposal came back into line with carrying value following the acquisition of the FPSO. Across the group, 2025 produced a net impairment reversal of USD 4.8 million, with movements at Espoir, Mauritania and the UK unit driven largely by revisions to decommissioning estimates. The TEN pre-tax discount rate was 14 per cent, and the oil price assumption ran from USD 60 per barrel in year one to USD 70 per barrel from year three, inflated at 2 per cent.
This is the reversal rule doing exactly what it was written to do. TEN is a producing asset rather than goodwill, so a genuine change in the estimates could be recognised in both directions inside a single financial year. Had the same USD 35 million been a goodwill charge at the half year, IFRIC 10.8 would have made it permanent regardless of what happened by December.
Tullow Oil plc, 2025 full year results, impairment note.Local FAQs
Does discount unwinding create a reversal? No. IAS 36.114 requires a change in the estimates. Getting a year closer to the same cash flows raises present value mechanically and is not a change in estimate.
Can a reversal be recognised on a unit? Yes, allocated pro rata across the assets except goodwill under IAS 36.122, with each asset capped by IAS 36.123 at the lower of its own recoverable amount and its own never-impaired carrying amount.
Is a reversal recognised for goodwill written down in a unit reversal? No. Goodwill is expressly excluded from the pro rata allocation in IAS 36.122, so a unit whose value recovers restores its other assets and leaves the goodwill at nil.
Where does a reversal appear in profit or loss? IAS 36.119 requires profit or loss unless the asset is revalued. IAS 36.126(b) then requires the amount of reversals recognised in profit or loss to be disclosed by class of asset, with the line item identified.
Potential risks
The risk runs in both directions. Not looking is a breach of IAS 36.110, and it is the more common of the two after a period of write-downs followed by recovery. Looking and finding a reversal that rests on the discount unwinding rather than on a change in estimate is the other, and it is harder to spot because the model output genuinely is higher. The test to apply is simple: name the estimate that changed, and say when it changed.
15. What does IAS 36 actually require you to disclose?
Three layers. IAS 36.126 gives the amounts by class of asset. IAS 36.130 gives the circumstances, amount, unit description and basis of recoverable amount for each material loss or reversal. IAS 36.134 gives the key assumptions and, in 134(f), the sensitivity for units carrying significant goodwill or indefinite life intangibles.
IAS 36.126 requires, for each class of assets, the amount of impairment losses recognised in profit or loss during the period and the line items in which they are included, the amount of reversals recognised in profit or loss and their line items, and the amounts of losses and reversals recognised in other comprehensive income for revalued assets. IAS 36.129 requires the same information by reportable segment where the entity reports segment information under IFRS 8.
This layer is almost always delivered, because it is a schedule rather than a narrative.
For each material impairment loss or reversal on an individual asset, including goodwill, or on a cash-generating unit: the events and circumstances that led to it; the amount; for an individual asset, the nature of the asset and the reportable segment it belongs to; for a unit, a description of the unit such as whether it is a product line, a plant, a business operation, a geographical area or a reportable segment, the amount by class of asset and by reportable segment, and where the aggregation of assets has changed since the previous estimate, a description of the current and former basis and the reasons for the change; the recoverable amount and whether it is fair value less costs of disposal or value in use; and where it is fair value less costs of disposal, the fair value hierarchy level and the valuation technique with any change in technique.
The clause on changed aggregation is the one companies overlook, and it is the disclosure that makes a redrawn cash-generating unit visible to a reader.
IAS 36.134 applies to each unit or group of units for which the carrying amount of goodwill or of indefinite life intangibles allocated to it is significant in comparison with the entity's total. For each such unit it requires the carrying amount of goodwill allocated, the carrying amount of indefinite life intangibles allocated, and the basis on which recoverable amount has been determined. Where value in use is used, it requires each key assumption on which management has based its cash flow projections, a description of management's approach to determining the value assigned to each key assumption and whether that value reflects past experience or external sources and if not how and why it differs, the period over which cash flows have been projected with an explanation where longer than five years, the growth rate used to extrapolate beyond that period with a justification where it exceeds long-run average growth, and the discount rate applied.
IAS 36.134(f) then requires, "if a reasonably possible change in a key assumption on which management has based its determination of the unit's (group of units') recoverable amount would cause the unit's (group of units') carrying amount to exceed its recoverable amount": the amount by which recoverable amount exceeds carrying amount, the value assigned to the key assumption, and the amount by which that value must change, after incorporating any consequential effects on the other variables, for recoverable amount to equal carrying amount.
Read the last limb again. It asks for a number, not a comfort statement. In worked example 1 that number is 0.4 percentage points on the discount rate and 0.6 percentage points on the terminal growth rate, alongside headroom of 1,174.
IAS 36.135 covers the fallback, where goodwill or indefinite life intangibles are spread across multiple units and no individual allocation is significant: disclose that fact together with the aggregate carrying amount. It exists for genuinely diffuse balances, not as a route around unit-level disclosure.
| Layer | Applies to | What it asks for |
|---|---|---|
| IAS 36.126, 36.129 | Every class of asset, and every reportable segment | Amounts of losses and reversals, and the line items containing them |
| IAS 36.130 | Each material loss or reversal | Cause, amount, description of the unit, recoverable amount and its basis, change in aggregation |
| IAS 36.134 | Units carrying significant goodwill or indefinite life intangibles | Key assumptions, how they were set, forecast period, growth rate, discount rate |
| IAS 36.134(f) | The same units, where a reasonably possible change would cause failure | Headroom, the assumption value, and the change that would eliminate the headroom |
| IAS 36.135 | Diffuse goodwill with no significant individual allocation | That fact, and the aggregate carrying amount |
Local FAQs
What counts as a reasonably possible change? The standard does not define it, and that is deliberate. A change within the range of outcomes management itself considered plausible in its own planning and viability work is the practical anchor. A sensitivity that management modelled for the viability statement and did not consider reasonably possible for IAS 36 is an inconsistency a reader can see.
Do we have to disclose the headroom when there is no impairment? Only where IAS 36.134(f) is triggered, meaning a reasonably possible change would cause failure. Where headroom is genuinely wide, no sensitivity disclosure is required and saying so briefly is enough.
Can we disclose a range of discount rates rather than a rate per unit? IAS 36.134(d)(v) requires the discount rate applied to the projections for each unit within the disclosure population. A single range across a diverse group tells the reader very little and the FRC has asked companies to explain how rates differ between units.
Potential risks
The 134(f) disclosure appears as a statement that management considers no reasonably possible change would result in an impairment, in a year when headroom fell by two thirds. That is a conclusion, and IAS 36.134(f) does not ask for a conclusion. It asks for the sensitivity when the condition is met. This is where the FRC's repeated finding about assumptions in the model not matching assumptions disclosed elsewhere is usually located, and it is found by reading the viability statement next to the impairment note.
16. How does IAS 36 differ from US GAAP impairment under ASC 350 and ASC 360?
The structures differ, not just the wording. ASC 360-10 tests long-lived asset groups in two steps beginning with undiscounted cash flows, so an asset group can pass under US GAAP and fail under IAS 36 on identical facts. ASC 350-20 tests goodwill against fair value in one step. US GAAP prohibits reversal of any impairment.
US GAAP splits the problem across three models rather than running one. Goodwill sits in ASC 350-20 and is tested at reporting unit level, being an operating segment or one level below, in a single quantitative step comparing the reporting unit's fair value with its carrying amount, preceded by an optional qualitative screen. Indefinite-lived intangibles sit in ASC 350-30 and are tested individually. Long-lived assets and asset groups sit in ASC 360-10 and are tested in two steps: a recoverability test comparing undiscounted expected future cash flows with carrying amount, and only where that fails, a measurement step using fair value.
The sequence between the three models also matters. Indefinite-lived intangibles are tested before the long-lived asset group, which is tested before goodwill, so a charge taken lower down changes the carrying amount that the goodwill test then works with.
The undiscounted first step has no equivalent anywhere in IAS 36 and it is the single largest source of difference. An asset group whose undiscounted cash flows cover carrying amount is not impaired under ASC 360-10 at all, regardless of what a discounted calculation would produce.
| Point | IAS 36 | US GAAP |
|---|---|---|
| Level of the goodwill test | CGU or group of CGUs, lowest level monitored, no larger than an operating segment (IAS 36.80) | Reporting unit: an operating segment or one level below (ASC 350-20) |
| Goodwill test mechanics | Carrying amount of the unit including goodwill against recoverable amount | Reporting unit carrying amount against fair value, single step, optional qualitative screen |
| Long-lived assets, first test | Recoverable amount, always discounted | Undiscounted cash flow recoverability test, then fair value only if it fails (ASC 360-10) |
| Measure of value | Higher of fair value less costs of disposal and value in use, an entity-specific measure | Fair value only, a market participant measure. No value in use equivalent |
| Discount rate basis | Pre-tax rate applied to pre-tax cash flows (IAS 36.55) | Consistent with the fair value measurement, typically post-tax |
| Order of testing | Individual assets with indicators first, then the unit, then the group (IAS 36.98) | Indefinite-lived intangibles, then the long-lived asset group, then goodwill |
| Reversal of an impairment | Permitted for assets other than goodwill (IAS 36.114), prohibited for goodwill (IAS 36.124) | Prohibited for all assets |
| Amortisation of goodwill | Not permitted | Not permitted, except under the private company accounting alternative |
What this means for a dual-reporting group
The long-lived asset test is easier to pass under US GAAP, because undiscounted cash flows clear a much lower bar than discounted ones. The goodwill test can be harder, because fair value gives no credit for entity-specific synergies that value in use will happily include. Groups reconciling the two frameworks often assume the difference is presentational. It is not, and a reconciliation that does not identify which of the two tests actually bit has not explained anything.
Reference for the US GAAP mechanics described here: KPMG, Impairment of nonfinancial assets handbook, August 2025.
Local FAQs
Can a US GAAP reporter reverse an impairment if conditions recover? No. Reversal is prohibited for all assets, which is a genuine difference from IAS 36.114 rather than a difference of emphasis.
Is a reporting unit the same as a cash-generating unit? No, and it is usually larger. A reporting unit is an operating segment or one level below. An IAS 36 cash-generating unit is the smallest group with largely independent inflows, which is frequently several levels below an operating segment.
Does the ASC 350-20 qualitative screen exist under IFRS? No. There is no step zero in IAS 36. The annual test under IAS 36.10(b) is quantitative, subject only to the narrow reuse relief in IAS 36.99.
Potential risks
For groups reporting under both frameworks, the risk is a single valuation model used for both tests with the labels changed. The cash flow basis, the discount rate basis and the level of the unit are all different, and a model that satisfies one framework will not satisfy the other without genuine adjustment.
What have regulators actually said about impairment?
Impairment was the issue the FRC raised with companies most frequently for the third consecutive year in its September 2025 review. The findings were about consistency and disclosure rather than valuation technique: model assumptions that contradicted the viability statement, enhancement cash flows inside value in use, and cash-generating unit disclosures too vague to follow.
What did the FRC's Annual Review of Corporate Reporting find?
In the Annual Review of Corporate Reporting published on 30 September 2025, the FRC reported that impairment was the issue most frequently raised with companies for the third consecutive year, and that it headed the list of the ten accounting areas generating the most queries, ahead of cash flow statements, financial instruments and presentation of financial statements. The specific findings on IAS 36 were inconsistencies between the assumptions used in impairment models and those disclosed elsewhere in the annual report, particularly in viability statements; the inclusion of cash flows from asset enhancement in value in use, which IAS 36.44(b) prohibits; and a lack of clarity in disclosures about cash-generating units. The FRC also observed that a substantial share of recurring issues would have been identified by a more thorough review before the accounts were signed.
That list is worth reading as an audit programme rather than as commentary. Every one of the three defects is testable by reading the annual report against the model, without any valuation expertise and without access to anything the company has not published.
What did the FRC's thematic review of discount rates conclude?
The FRC's thematic review of discount rates, published in May 2022, found that companies typically start from a weighted average cost of capital, which is a post-tax rate, and that grossing it up fails to reflect either differing tax rates or the varying shape of cash flows over time. Where a company applies a post-tax rate to post-tax cash flows, the FRC expects it to demonstrate that the result is not materially different from a pre-tax calculation, and to disclose the equivalent pre-tax rates alongside a clear explanation of how discount rates were determined, of any change in methodology and its effect, and of how rates differ between cash-generating units.
What is ESMA prioritising for 2025 reporting?
ESMA's European Common Enforcement Priorities for 2025 corporate reporting, published on 14 October 2025, restate the IAS 36.80 constraint that units or groups of units to which goodwill is allocated cannot be larger than an operating segment. ESMA presses issuers to critically review and update both operating and financial assumptions used in cash flow projections for current conditions, naming tariffs, commodity price changes and exchange rate volatility, and stresses that greater weight should be given to external evidence in setting the values assigned to key assumptions. It also expects growth rates, discount rates and the duration of projections to be updated for the geopolitical environment, and the IAS 36.134(f) sensitivity disclosure to be provided wherever the condition is met.
Is IAS 36 about to change?
The IASB published the exposure draft Business Combinations, Disclosures, Goodwill and Impairment in March 2024, proposing amendments to IFRS 3 and to the impairment test in IAS 36. As at August 2026 the Board was still redeliberating the proposals, with no final amendments issued and no effective date set, and the IFRS Foundation work plan showed the next milestone as deciding project direction.
Two consequences follow. Nothing in the proposals may be applied, and no accounting policy should be built on the assumption that the goodwill allocation constraint or the value in use restrictions are about to be relaxed. Prepare on the current text. If amendments are issued, they will come with transition provisions and a lead time.
Freshness note. The regulatory positions above are stated as at 27 August 2026. The FRC and ESMA publications named are the most recent in each series at that date, and the IASB project status was confirmed on the IFRS Foundation work plan. Where a later publication supersedes any of them, the paragraph references to IAS 36 in this guide are unaffected, because no amendment to the standard has been issued.
Ten ways an impairment test goes wrong
- Growth capital expenditure left in the cash flows. The approved budget contains a new line, a new store format or a systems programme, and the benefits land in years three to five. IAS 36.44(b) requires both the spend and the benefit to come out. The FRC named this specifically, and it is the defect that most often turns a pass into a fail when corrected.
- A disclosed pre-tax rate that was never derived. A post-tax WACC divided by one minus the tax rate, presented as though it were the rate the model implies. Worked example 2 shows how far apart the two can be. This is a disclosure misstatement even where the impairment conclusion happens to be right.
- Asymmetry between the carrying amount and the cash flows. Lease liabilities, working capital, restoration provisions and head office costs each break IAS 36.75 in a different place. It is a single sentence in the standard and it is broken more often than any other requirement in it.
- Cash-generating units drawn at the level that gives the answer. Rarely deliberate, because the wider unit usually matches a genuine reporting line. Almost always visible as a change from the prior year without a stated reason, which is precisely what IAS 36.130(d)(iii) requires to be disclosed.
- The IAS 36.105 floor ignored in allocation. The total loss is right and every individual line is wrong, so future depreciation is wrong on every affected asset. It survives review because the control total ties.
- No reversal assessment for assets other than goodwill. IAS 36.110 requires it at every reporting date, in both directions. Companies that impaired quickly are consistently slow to look again.
- Depreciation not rebased after the write-down. IAS 36.63 requires the revised carrying amount to be spread over the remaining useful life. This is a fixed asset register task rather than a technical accounting one, which is why it falls between teams.
- A generic sensitivity statement instead of the IAS 36.134(f) number. The requirement is the amount of change in the assumption that eliminates the headroom, after consequential effects. A sentence saying management considers no reasonably possible change would cause an impairment answers a different question.
- Testing something that is out of scope, or missing something that is in. A disposal group already classified as held for sale is measured under IFRS 5, not IAS 36. An investment in a subsidiary in the parent's separate accounts, and capitalised development not yet available for use, are both in scope and both routinely missed.
- Missing the indicator review at a period end that is not the annual test date. The IAS 36.9 assessment and the IAS 36.10 annual test are separate obligations falling due at different times, and a fourth quarter deterioration lands exactly in the gap between them.
Frequently asked questions on impairment of assets under IAS 36
What is impairment of assets under IAS 36?
Impairment means an asset is carried at more than it is worth. IAS 36.1 sets the objective that assets are carried at no more than recoverable amount, which IAS 36.18 defines as the higher of fair value less costs of disposal and value in use. Where carrying amount exceeds that figure, IAS 36.59 requires the excess to be written off immediately. The test is run whenever an indicator exists under IAS 36.9, and annually regardless of indicators for goodwill, indefinite life intangibles and intangibles not yet available for use under IAS 36.10.
How do you calculate an impairment loss under IAS 36?
Compare the carrying amount of the asset, or of the cash-generating unit it belongs to under IAS 36.22, with its recoverable amount. The shortfall is the impairment loss. Within a unit, IAS 36.104 allocates the loss first against goodwill and then across the remaining assets pro rata on carrying amount. IAS 36.105 then prevents any individual asset being written below the highest of its own fair value less costs of disposal, its own value in use and zero, and reallocates any blocked amount across the other assets.
What are the indicators of impairment in IAS 36.12?
IAS 36.12 lists four external indicators, being an observable significant decline in value, adverse change in the technological, market, economic or legal environment, an increase in market interest rates that will materially reduce value in use, and net assets exceeding market capitalisation. It lists three internal indicators, being obsolescence or physical damage, an asset becoming idle or scheduled for earlier disposal, and internal reporting showing worse economic performance than expected. IAS 36.12(h) adds a dividend indicator for investments in subsidiaries, associates and joint ventures. The list is a minimum, not a limit.
What is a cash-generating unit under IAS 36?
IAS 36.6 defines a cash-generating unit as the smallest identifiable group of assets that generates cash inflows largely independent of the cash inflows from other assets or groups of assets. IAS 36.22 requires recoverable amount to be measured at unit level whenever an individual asset does not generate largely independent inflows, which is the position for most assets. IAS 36.69 confirms that inflows means inflows from parties external to the entity, and points to how management monitors and makes decisions about its operations as evidence of where the boundary falls.
What must be excluded from value in use cash flows?
IAS 36.44 requires cash flows to be estimated for the asset in its current condition, so cash flows from a future restructuring the entity is not yet committed to and cash flows from improving or enhancing the asset's performance are both excluded, together with the related outflows under IAS 36.45. IAS 36.50 excludes cash flows from financing activities and income tax receipts and payments. IAS 36.33(b) caps the budget period at five years unless a longer period can be justified, and IAS 36.33(c) caps the terminal growth rate at long-run average growth.
Why does IAS 36 require a pre-tax discount rate?
IAS 36.51 requires the cash flows and the discount rate to be determined consistently, and because tax is excluded from the cash flows under IAS 36.50(b), IAS 36.55 requires the rate to be pre-tax. IAS 36.A20 requires a post-tax basis such as a weighted average cost of capital to be adjusted to a pre-tax rate. Dividing a post-tax rate by one minus the tax rate is not that adjustment, because tax reduces every cash flow rather than acting as a constant proportional drag on the rate.
Can an impairment loss be reversed under IAS 36?
For assets other than goodwill, IAS 36.114 permits reversal if and only if there has been a change in the estimates used to determine recoverable amount since the last impairment loss was recognised. IAS 36.117 caps the increased carrying amount at the amount that would have been carried, net of depreciation, had no impairment ever been recognised. IAS 36.124 prohibits reversal of a goodwill impairment outright, and IFRIC 10.8 confirms that a goodwill impairment recognised at an interim date cannot be reversed later in the same financial year.
How is goodwill allocated to cash-generating units for impairment testing?
IAS 36.80 requires goodwill acquired in a business combination to be allocated from the acquisition date to each cash-generating unit or group of units expected to benefit from the synergies of the combination, whether or not other acquired assets are assigned there. Each unit or group must represent the lowest level at which goodwill is monitored for internal management purposes and must not be larger than an operating segment as defined in IFRS 8 before aggregation. IAS 36.84 requires the initial allocation to be completed before the end of the first annual period beginning after the acquisition date.
Does IAS 36 apply to receivables, loans and inventory?
No. IAS 36.2 excludes inventories, contract assets and contract costs recognised under IFRS 15, deferred tax assets, employee benefit assets, financial assets within IFRS 9, investment property measured at fair value, biological assets at fair value less costs to sell, IFRS 17 insurance contract assets, and non-current assets or disposal groups classified as held for sale. Receivables and loans are impaired under the IFRS 9 expected credit loss model, and inventory is written down to net realisable value under IAS 2.
How is an investment in a subsidiary tested for impairment?
IAS 36.4 brings investments in subsidiaries, associates and joint ventures held in separate financial statements into the scope of IAS 36, so the investment is tested as an individual asset against its recoverable amount rather than under IFRS 9. IAS 36.12(h) adds a specific indicator: a dividend is recognised and either the carrying amount of the investment in the separate financial statements exceeds the consolidated carrying amount of the investee's net assets including associated goodwill, or the dividend exceeds the investee's total comprehensive income for the period.
How does impairment work for right-of-use assets under IFRS 16?
A right-of-use asset is within the scope of IAS 36 and is normally tested as part of the cash-generating unit it serves, such as an individual retail store. IAS 36.75 requires the carrying amount of the unit to be determined on a basis consistent with its recoverable amount. Because IAS 36.50(a) excludes financing cash flows, the common approach excludes the lease payments from value in use and the lease liability from the unit's carrying amount. Some firm guidance instead deducts the liability from both sides where a market participant buyer would assume it. Either is defensible applied consistently; mixing the two double counts the lease.
How does IAS 36 differ from US GAAP impairment?
ASC 360-10 tests long-lived asset groups in two steps and begins with an undiscounted cash flow recoverability test, so an asset group can pass under US GAAP and fail under IAS 36 on identical facts. ASC 350-20 tests goodwill at reporting unit level, being an operating segment or one level below, against fair value in a single quantitative step with an optional qualitative screen. US GAAP has no value in use equivalent, and reversal of an impairment loss is prohibited for all assets, where IAS 36.114 permits reversal for assets other than goodwill.
What are the IAS 36 disclosure requirements for goodwill?
IAS 36.134 applies to each unit or group of units carrying goodwill or indefinite life intangibles that is significant in comparison with the entity's total, and requires the carrying amount allocated, the basis of recoverable amount, each key assumption and how management determined it, the budget period with justification beyond five years, the terminal growth rate with justification above long-run average growth, and the discount rate. IAS 36.134(f) then requires the headroom, the value assigned to the key assumption and the change in it that would make recoverable amount equal carrying amount, wherever a reasonably possible change would cause the unit to fail.
Do you have to test for impairment at the half year?
IAS 36.9 requires the indicator assessment at the end of each reporting period, and an interim period is a reporting period, so a full test is required at the half year where an indicator exists. The annual test for goodwill and indefinite life intangibles can be performed at any time in the year provided it is at the same time each year under IAS 36.10(a) and 36.96. IFRIC 10.8 prohibits reversal of a goodwill impairment recognised at an interim date, even later in the same financial year.
Is an impairment loss deductible for tax?
Generally not on recognition. Impairment is an accounting measurement, and most tax regimes give relief through capital allowances or on disposal rather than on a book write-down, with goodwill treated separately again. The accounting consequence is a temporary difference under IAS 12, and a deferred tax asset is recognised only where the IAS 12 recognition criteria are met. Treat it as an IAS 12 question, jurisdiction by jurisdiction, rather than as part of the IAS 36 calculation, which is performed before tax in any event.
Is IAS 36 about to change?
Not yet. The IASB published the Exposure Draft Business Combinations, Disclosures, Goodwill and Impairment in March 2024, proposing amendments to IFRS 3 and to the impairment test in IAS 36. As at August 2026 the Board was still redeliberating the proposals, with no final amendments issued and no effective date set. The requirements described in this guide are the ones currently in force, and nothing in the exposure draft may be applied.
Key takeaways
- The arithmetic is not the hard part. IAS 36.22 and 36.68 fix the unit of account and IAS 36.33 fixes the forecast, and both are settled before a single cash flow is discounted. Everything after that is mechanics performed on decisions already taken.
- IAS 36.19 ends the test as soon as either measure of recoverable amount clears carrying amount, so a well-run process starts by asking which measure is cheaper to support rather than by building a discounted cash flow model by reflex.
- IAS 36.75 symmetry is the requirement broken most often. Whatever sits in the cash flows must sit in the carrying amount, and nothing else. Lease liabilities, working capital, restoration provisions and head office each break it in a different place.
- Value in use measures the asset you own today. IAS 36.44 removes uncommitted restructuring and enhancement together with the returns they would produce, and the FRC has named the enhancement failure specifically.
- The pre-tax rate required by IAS 36.55 is an output of the model. A post-tax rate divided by one minus the tax rate is not the adjustment IAS 36.A20 asks for, and the gap can be more than nine percentage points on a simple set of facts.
- Terminal value usually carries most of the answer, which makes the growth rate and the discount rate the two assumptions that deserve the most challenge and the clearest IAS 36.134(f) disclosure.
- Goodwill is a one-way door. IAS 36.104 makes it absorb the loss first, IAS 36.124 prohibits reversal, and IFRIC 10.8 closes the interim gap. The allocation order therefore decides how much of a loss is permanently locked in.
- Regulators are not challenging valuations. They are challenging consistency between the model and the rest of the annual report, and that is fixable before filing rather than after a query.
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