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FASB proposes changes to consideration payable to a customer

The proposal would clarify the scope of the consideration payable to a customer in ASC 606.

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The proposed ASU introduces criteria for determining when payments made on behalf of a customer, or to a customer’s customer, are subject to the consideration payable to a customer guidance in ASC 606.

Applicability

  • All entities that make payments on behalf of a customer, or to a customer’s customer, in connection with a revenue contract accounted for under ASC 606

Relevant dates

Proposed ASU issued October 22, 2026

Comments due November 23, 2026

Clarifying consideration payable to a customer

Under ASC 606, payments to an entity’s customer or other parties that purchase the entity’s goods or services from the customer are accounted for under the consideration payable to a customer guidance. These payments reduce revenue unless they are made in exchange for a distinct good or service transferred by the customer.

However, ASC 606 does not explicitly address payments made on a customer’s behalf or payments made to a customer’s customer that are outside the direct distribution chain. As a result, differing interpretations of when these payments should be accounted for as consideration payable to a customer have led to diversity in practice. Consequently, economically similar payments may be recorded either as reductions of revenue or operating expenses.

Proposed scope criteria

Under the proposed ASU, payments made on behalf of a customer or to a customer’s customer would be accounted for as consideration payable to a customer when they are made in connection with the entity satisfying its promise to its customer and either of the following conditions is met:

  • An explicit promise exists for the entity to make the payment; or
  • The customer has a reasonable expectation that the entity will make the payment because an implicit promise exists or the payment is an in-substance price concession. An implicit promise may arise from customary business practices, published policies or specific statements. 

The proposal includes illustrative examples applying the proposed scope criteria, involving a platform operator that provides incentives in the form of end-user credits and a retailer that subsidizes interest-free financing for customers. Although the proposal's examples focus on platform operators and retailers, the amendments are not limited to those entities or industries and could apply to any entity that makes payments on behalf of customers or to their customers' customers. We generally expect payments that are made on behalf of customers or are in-substance price concessions to be accounted for as reductions of revenue, which may differ from current practice for some entities.

The proposed amendments do not change the existing guidance for determining whether a payment is in exchange for a distinct good or service. Rather, the amendments clarify which payments should be evaluated under the consideration payable to a customer framework.

Conforming amendments to ASC 718

The proposed ASU includes conforming amendments to ASC 718 to clarify that share-based consideration granted on behalf of a customer, or to a customer’s customer, is subject to the consideration payable to a customer guidance when the award is granted in connection with the entity satisfying its promise to its customer. As a result, share-based consideration provided in those arrangements would be evaluated under the same proposed scope criteria added to ASC 606 for payments made on behalf of a customer or to a customer's customer.

Proposed effective date and transition

  • The effective date will be determined by the FASB after considering stakeholder feedback on the proposed amendments.
  • Early adoption would be permitted.
  • Entities would be permitted to adopt the amendments using either:
    • a modified prospective basis, under which the amendments would apply to payments made or promised on or after the adoption date; or
    • a modified retrospective basis, under which the amendments would apply to payments made or promised after the beginning of the earliest period presented in the financial statements.
  • Transition disclosures would require entities to explain the nature of and reason for the accounting change and the transition method applied. Entities applying the modified retrospective transition approach would also disclose the effects of the change on affected financial statement line items and per-share amounts for retrospectively adjusted periods.

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Michael Breen
Partner, Dept. of Professional Practice, KPMG U.S.
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Meredith Canady
Partner, Dept. of Professional Practice, KPMG US

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