| Revenue
Recognition Issues in a Digital Economy
By
Eugene F. DeMark
Many traditional
business models have been modified or discarded in the face
of technological advances. New business models also raise
significant accounting questions concerning revenue recognition,
or determining the proper time to book a sale and its related
expenses. Many
cases are simple: Revenue is recognized when the goods are
delivered or the services are performed. But the issue often
gets more complicated, particularly in the high-tech sector,
because of a practice called “bundling,” which
occurs when a company packages a principal product (e.g.,
a cellphone or satellite dish) with ancillary products or
ongoing services (e.g., providing the wireless service or
maintaining a signal to the dish receiver).
Bundling
not only augments revenues but also extends the contract
between the company and its customers beyond the traditional
point of sale. This leads to an accounting issue: If a business
bundles multiple revenue-generating activities into a single
transaction, when is it appropriate to account for the entire
arrangement as a single transaction (and recognize the revenue
in the period of the initial sale), and when is it necessary
to unbundle the transaction into individual elements (the
delivery of a product, service, or other right to use assets)
for revenue recognition purposes, possibly deferring all
or a portion of the revenue (and associated expenses) to
future periods?
Identifying
individual products or services in multiple-element arrangements
can be complicated. For example, some Internet portal companies
provide electronic storefronts for their customers on a
network of websites in exchange for a monthly fee. This
appears to be a single element but such companies often
deliver a variety of services to their customers over an
extended period of time, including designing and setting
up the original website, managing data and content, and
performing fulfillment and order processing.
The
facts and circumstances of each arrangement must be analyzed
to determine if these ancillary services constitute separate
elements that may call for separate accounting. This subject
is being considered by FASB’s Emerging Issues Task
Force (EITF). In the absence of a FASB pronouncement, the
SEC has indicated that it would not object to an accounting
treatment for multiple-element arrangements that includes
the following conditions:
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To be considered a separate element, the deliverable must
represent a separate earnings process. In general, this
is indicated by the vendor’s ability to sell the
element by itself. For example, while a health club may
charge a separate fee for membership initiation, a customer
will typically pay that fee only in connection with the
right to use the club on an ongoing basis. In this case,
the health club’s initiation fee would likely not
be considered a separate element.
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Revenue must be allocated among the elements based upon
their fair value. Fair value should be reliable, verifiable,
and objectively determinable. The evidence, however, generally
does not have to meet the standards of “vendor-specific”
objective evidence (which require the company to sell
each element on a stand-alone basis to establish fair
value of the individual elements) unless the transaction
includes the sale or license of software. Therefore, in
nonsoftware transactions, a company may allocate fees
to elements based on other information, such as competitor
prices for similar products or renewal prices for services.
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If an undelivered element is essential to the functionality
of a delivered element, no revenue can be recognized until
the essential element is also delivered. The following
indicators suggest that one element is essential to the
functionality of another: the undelivered element is available
only from the company and may not be purchased from a
third party; the customer’s requirement to pay under
the arrangement coincides with the delivery of all the
elements, or with the delivery of the last element; and
the customer’s ability to use a delivered element
depends upon, or is significantly affected by, the delivery
of another element. Consider, for example, an enterprise
software package (license) that a customer purchases along
with implementation services. Although the customer may
regard the implementation services as an essential element,
they may still be accounted for separately from the software
package, if the implementation services are easily obtainable
from a third party and if the obligation to pay for the
software license does not depend upon the seller providing
the implementation services.
Eugene
F. DeMark, CPA, is the northeast partner in charge
of KPMG’s information communications and entertainment.
He is located in the firm’s New York City office.
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