ASC 842-980
Regulated Operations
842 Leases
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This Subtopic addresses how rate-regulated entities account for leases when the regulator's rate-making treatment differs from Topic 842. Lease classification for financial reporting follows Topic 842 regardless of how the regulator treats the lease, but the timing of expense (or income) recognition is modified to conform to the rate treatment, with timing differences capitalized or accrued as regulatory assets or liabilities. Sale-and-leaseback timing differences are handled either as part of a phase-in plan under Subtopic 980-340 or by conforming recognition to the Regulated Operations Topic.
Key points (7)
- Regulated entities must classify leases in accordance with Topic 842; the regulator's treatment of a finance lease as an operating lease for rate-making does not change classification, because the regulator cannot eliminate an obligation it did not impose (842-980-45-1 through 45-2).
- For a finance lease, the nature of the expense elements (amortization of the right-of-use asset and interest on the lease liability) is unchanged, but amortization of the ROU asset is modified so that total interest plus amortization equals the lease expense allowed for rate-making purposes (842-980-45-3).
- Such regulatory treatment for newly completed plants could constitute a phase-in plan as defined in Subtopic 980-340 (842-980-45-3).
- Sale and leaseback timing differences between Subtopic 842-40 and rate-making treatment are accounted for under Subtopic 980-340 if they are all or part of a phase-in plan; otherwise recognition timing is modified to conform to the Regulated Operations Topic (842-980-25-2).
- A non-phase-in timing difference on a sale and leaseback accounted for as a financing is capitalized or accrued as a separate regulatory-created asset or liability if it meets the criteria of the Regulated Operations Topic (842-980-25-3).
- If a sale and leaseback is accounted for as a financing but the sale is recognized for rate-making purposes, imputed interest under the interest method plus depreciation of the underlying asset is modified to equal total lease expense and the gain or loss allowable for rate-making purposes (842-980-35-1).
- Interest expense and ROU asset amortization need not be separate income statement line items (842-20-45-4), but they must be included in the total interest cost disclosure under Subtopic 835-20 and the finance lease disclosures under Section 842-20-50 (842-980-45-4; 842-980-55-1).
For students. The key takeaway is the split between classification and timing: rate regulation never changes whether a lease is a finance lease, but it does reshape the pattern of expense recognition, with the difference parked in a regulatory asset or liability. Students commonly err by assuming a regulator's operating-lease treatment lets a utility report the lease as an operating lease for GAAP.
regulated operationsrate-making purposesallowable costregulatory assetphase-in planfinance lease classificationsale and leaseback financingright-of-use asset amortization
Machine-generated study aid for ASC 842-980. Check the source paragraphs below.
842-980-00Status
Source downloaded: .Record version 0f8f6b65e208. Effective date must be checked in the source.
842-980-00-1
The following table identifies the changes made to this Subtopic.
| Paragraph | Action | Accounting Standards Update | Date |
| Allowable Costs | Added | Accounting Standards Update No. 2016-02 | 02/25/2016 |
| Phase-In Plan | Added | Accounting Standards Update No. 2016-02 | 02/25/2016 |
| 980-842-05-1 | Added | Accounting Standards Update No. 2016-02 | 02/25/2016 |
| 980-842-15-1 | Added | Accounting Standards Update No. 2016-02 | 02/25/2016 |
| Added | Accounting Standards Update No. 2016-02 | 02/25/2016 | |
| 980-842-35-1 | Added | Accounting Standards Update No. 2016-02 | 02/25/2016 |
| Added | Accounting Standards Update No. 2016-02 | 02/25/2016 | |
| 980-842-55-1 | Added | Accounting Standards Update No. 2016-02 | 02/25/2016 |
842-980-05Overview and Background
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842-980-05-1
This Subtopic provides guidance on accounting for leases for entities with regulated operations.
842-980-15Scope and Scope Exceptions
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Overall Guidance
842-980-15-1
This Subtopic follows the same Scope and Scope Exceptions as outlined in the Overall Subtopic, see Section 980-10-15.
842-980-25Recognition
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Sale and Leaseback Transactions
842-980-25-1
Accounting for sale and leaseback transactions in accordance with the guidance in Subtopic 842-40 may result in a difference between the timing of income and expense recognition required by that Subtopic and the timing of income and expense recognition for rate-making purposes.
842-980-25-2
That difference shall be accounted for as follows:
- a If the difference in timing of income and expense recognition constitutes all or a part of a phase-in plan, it shall be accounted for in accordance with Subtopic 980-340.
- b Otherwise, the timing of income and expense recognition related to the sale and leaseback transaction shall be modified as necessary to conform to the Regulated Operations Topic. That modification required for a transaction that is accounted for as a financing is further described in the following paragraph and paragraphs .
842-980-25-3
The difference between the amount of income or expense recognized for a transaction that is not part of a phase-in plan and that is accounted for as a financing under Subtopic 842-40 and the amount of income or expense included in allowable cost for rate-making purposes shall be capitalized or accrued as a separate regulatory-created asset or liability, as appropriate, if that difference meets the criteria of the Regulated Operations Topic.
842-980-35Subsequent Measurement
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Sale and Leaseback Transactions
842-980-35-1
If the sale and leaseback transaction is accounted for as a financing and the sale is recognized for rate-making purposes, the total of interest imputed under the interest method for the financing and the depreciation of the underlying asset shall be modified to equal the total lease expense and the gain or loss allowable for rate-making purposes.
842-980-45Other Presentation Matters
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Treatment of Leases for Rate-Making Purposes
842-980-45-1
Topic 842 specifies criteria for classification of leases and the method of accounting for each type of lease. For rate-making purposes, a lease may be treated as an operating lease even though the lease would be classified as a finance lease under those criteria. In effect, the amount of the lease payment is included in allowable costs as rental expense in the period it covers.
842-980-45-2
For financial reporting purposes, the classification of the lease is not affected by the regulator's actions. The regulator cannot eliminate an obligation that was not imposed by the regulator (see paragraph 980-405-40-1). Also, by including the lease payments as allowable costs, the regulator sets rates that will provide revenue approximately equal to the combined amount of the right-of-use asset and interest on the lease liability over the term of the lease and, thus, provides reasonable assurance of the existence of an asset (see paragraph 980-340-25-1). Accordingly, regulated entities shall classify leases in accordance with Topic 842.
842-980-45-3
The nature of the expense elements related to a finance lease (amortization of the right-of-use asset and interest on the lease liability) is not changed by the regulator's action; however, the timing of expense recognition related to the lease would be modified to conform to the rate treatment. Thus, amortization of the right-of-use asset shall be modified so that the total of interest on the lease liability and amortization of the right-of-use asset shall equal the lease expense that was allowed for rate-making purposes. For newly completed plants such regulatory treatment could result in a phase-in plan as defined in Subtopic 980-340.
842-980-45-4
Paragraph 842-20-45-4 states that an entity is not required to classify the interest expense and amortization of the right-of-use asset in a finance lease as separate items in an income statement. For example, the amounts of amortization of the right-of-use asset and interest on the related lease liability could each be combined with other costs and presented in a manner consistent with how the entity presents depreciation or amortization of similar assets and other interest expense. However, the disclosure of total interest cost incurred, required by Subtopic 835-20, shall include the interest on that lease liability, and the disclosure of the total amortization of the entity's right-of-use assets arising under a finance lease and interest on finance lease liabilities, required by Section 842-20-50, shall include amortization of that right-of-use asset and interest on that lease liability.
842-980-55Implementation Guidance and Illustrations
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Implementation Guidance
842-980-55-1
Paragraph 842-20-45-4 states that an entity is not required to classify the interest expense and amortization of the right-of-use asset in a finance lease as separate items in an income statement. However, that paragraph also states that the interest expense and the amortization of the right-of-use asset in a finance lease should be presented in a manner consistent with how the entity presents depreciation or amortization of similar assets and other interest expense. For example, the amounts of amortization of the right-of-use asset and interest on the related lease liability could each be combined with other costs and presented in a manner consistent with how the entity presents depreciation or amortization of similar assets and other interest expense. However, in that circumstance, the disclosure of total interest cost incurred, required by Subtopic 835-20, would include the interest on that lease liability, and the disclosure of the total amortization of the entity's right-of-use assets arising under a finance lease and interest on finance lease liabilities, required by Section 842-20-50, would include amortization of that right-of-use asset and interest on that lease liability.