ASIC review of 30 June 2019 financial reports

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ASIC has announced the results from its review of the 30 June 2019 full-year financial reports of 200 entities.

Arising from the review, ASIC has made inquiries of 47 entities on 80 matters. The largest number of inquiries continue to relate to impairment of non-financial assets and inappropriate accounting treatments. Directors and auditors should continue to focus on values of assets and accounting policy choices in 31 December 2019 financial reports.

Directors and auditors need to focus on impairment of non-financial assets in financial reports to ensure that the market is properly informed about asset values and the expected future performance implied by those values. We continue to find instances where companies have made unrealistic and unsupportable assumptions about future cash flows. ASIC issued Information Sheet 203 Impairment of non-financial assets: Materials for directors (INFO 203) in June 2015 to assist directors and audit committees in considering whether the value of non-financial assets shown in a company’s financial report continues to be supportable.

Directors and auditors should also focus on the impact of the newer accounting standards on revenue, financial instruments, and leases, which can materially affect reported financial position and results.

ASIC’s risk-based surveillance of the financial reports of public interest entities for reporting periods ended 30 June 2010 to 31 December 2018 has led to material changes to 4 to 5% of the financial reports of public interest entities reviewed by ASIC. The main changes related to impairment of assets, revenue recognition and expense deferral.

Inquiries made by ASIC from reviews of 30 June 2019 financial reports related to the following matters:

Matter

Number of inquiries

Impairment and other asset values

25

Revenue recognition

23

Tax accounting

9

Provisions

4

Expense deferral

4

Business combinations

4

Consolidation accounting and equity accounting

2

Other matters

9

Total

80

Public announcements of material changes

ASIC publicly announces when a company makes material changes to information previously provided to the market following inquiries by ASIC. In addition to improving the level of market transparency, these announcements are intended to make directors and auditors of other companies more aware of ASIC’s concerns so that they might avoid similar issues.

Since the last release on ASIC findings, on 8 August 2019, ASIC has had cause to issue media releases in relation to changes by Botai Technology Limited, InvoCare Limited, Pental Limited, PS&C Limited, Range International Limited, Tempo Australia Limited, iSignthis Limited, Wollongong Coal Limited, THC Global Limited, Generation Development Group Limited, West Wits Mining Limited, Eco Energy Group Limited and The Environmental Group Limited. The total adjustments to profit for these entities was more than $590 million.

Background

Inquiries of individual entities will not necessarily lead to material restatements. Matters involving 12 of the entities have been concluded without any changes to their financial reporting.

More information about the findings from ASIC’s recent reviews of the financial reports of listed entities and of unlisted entities with larger numbers of users is provided in the Attachment to this release.

ASIC’s focus areas for 31 December 2019 financial reports highlight the need to focus on the newer accounting standards that can materially affect reported assets, liabilities and profits, and can be found in ASIC media release Financial reporting focuses for 31 December 2019 (19-341MR).

Findings from 30 June 2019 financial reports

1. Asset values and impairment testing

ASIC continues to identify concerns regarding assessments of the recoverability of the carrying values of assets, including goodwill, exploration and evaluation expenditure, and property, plant and equipment.

Findings include:

(a) Reasonableness of cash flows and assumptions: There continue to be cases where the cash flows and assumptions used by entities in determining recoverable amounts are not reasonable or supportable having regard to matters such as historical cash flows, economic and market conditions, and funding costs.

In particular, ASIC found cases where:

(i)  assumptions derived from external sources were not assessed for consistency and relevance; and

(ii) the entity’s forecast cash flows did not appear reasonable and had exceeded actual cash flows for a number of reporting periods.

(b)  Determining the carrying amount of cash generating units: There are cases where entities appear to:

(i) have identified cash generating units (CGUs) at too high a level despite cash inflows being largely independent, resulting in cash flows from one asset or part of the business being incorrectly used to support the carrying values of other assets;

(ii) have not included all assets that generate the cash inflows in the carrying amount of a CGU, such as inventories and trade receivables and tax balances; and

(iii)  have incorrectly deducted liabilities from the carrying amount of a CGU.

(c) Use of fair value: ASIC still sees entities using discounted cash flow techniques to estimate fair value where the calculations are dependent on a large number of management inputs. Where it is not possible to reliably estimate the value that would be received to sell an asset in an orderly transaction between market participants, the entity may need to use the asset’s value in use as its recoverable amount.

(d)        Impairment indicators: Some entities are not having sufficient regard to impairment indicators, such as significant adverse changes in market conditions, and reported net assets exceeding market capitalisation.

(e)        Disclosures: ASIC still finds a number of entities not making necessary disclosure of:

(i)      sensitivity analysis where there is limited excess of an asset’s recoverable amount over the carrying amount and where a reasonably possible change in one or more assumptions could lead to impairment;

(ii)     key assumptions, including discount rates and growth rates; and

(iii)    for fair values, the valuation techniques and inputs used.

These disclosures are important to investors and other users of financial reports given the subjectivity of these calculations/assessments. They enable users to make their own assessments about the carrying values of the entity’s assets and risk of impairment given the estimation uncertainty associated with many asset valuations.

This item includes matters arising from the finalisation of impairment matters identified in our reviews of 30 June 2018 and 31 December 2018 financial reports.

2. Revenue recognition

ASIC has followed up 23 matters concerning the recognition of revenue, particularly contracts that involve multiple performance obligations (e.g. sale of goods and provision of services) where one or more obligation is still to be met.

ASIC also identified instances where revenue was not disaggregated with regard to how the nature, amount, timing and uncertainty of revenue and cash flows are affected by economic factors. There were also instances where the accounting policy for revenue recognitions needed to be more clearly described.

3. Tax accounting

ASIC has made inquiries of nine entities concerning their accounting for income tax, including the adequacy of tax expense and whether it is probable that future taxable income will be sufficient to enable the recovery of deferred tax assets relating to tax losses.

4. Provisions

ASIC has enquired with four entities on the adequacy of provisions for rehabilitation, warranty claims and onerous contracts.

5. Expense deferral

ASIC has made enquiries of four entities to ascertain whether amounts deferred as assets should have been charged to the income statement as expenses.

6. Business combinations

ASIC has made enquiries of four entities in relation to accounting for business combinations, including one instance where business acquisitions contain significant deferred consideration.  In another instance, the entity did not provide the required disclosures for the acquisition and the entity has since reissued its financial report. 

7. Consolidation accounting and equity accounting

ASIC has made enquiries of two entities on the non-consolidation of other entities or not equity accounting for an interest where there are indicators of possible significant influence.

8. Newer accounting standards

ASIC has observed that some entities could have provided a better explanation of the impact of adopting the new accounting standard on leases. This includes the nature and cause of any changes.

9. Estimates and accounting policy judgements

ASIC observed instances where entities needed to improve the quality and completeness of disclosures in relation to estimation uncertainties, and significant judgments in applying accounting policies. The disclosure requirements are principle-based and should include all information necessary for investors and others to understand the judgements made and their effect. This may include key assumptions, reasons for judgements, alternative treatments, and appropriate quantification.

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