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IFRS 16 after the dust has settled and what still causes confusion

Robert R. Hickey by Robert R. Hickey
August 1, 2026
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IFRS 16 has been in use for several years, so it would be easy to assume that lease accounting is now a settled topic.

The basic model is certainly familiar. A lessee normally recognises a right-of-use asset and a lease liability rather than recording a simple operating lease expense. Yet the difficult parts of IFRS 16 were never really the basic entries.

The confusion sits around judgement.

How long is the lease term? Which payments belong in the liability? What discount rate should be used? Is a change a lease modification or a reassessment? Has a sale and leaseback actually produced a sale?

These are exactly the areas that can turn a straightforward-looking ACCA SBR requirement into a difficult one.

The key is not to memorise every paragraph of the standard. It is to understand the decisions that management must make and explain how those decisions affect the financial statements.

Candidates looking for structured support from an ACCA SBR tutor should expect lease accounting to be taught through scenarios and judgement, rather than calculations alone.

Why IFRS 16 is still a relevant current issue

The initial impact of IFRS 16 was obvious.

Lease liabilities appeared on balance sheets. Right-of-use assets were recognised. Operating lease expenses were replaced by depreciation and interest for many lessees.

The longer-term issues are less dramatic, but more difficult.

Companies must maintain large volumes of lease data. They must review changes in contracts, indexes, rates, options and expected lease terms. They must decide whether a change requires a remeasurement, a modification or no adjustment at all.

The accounting model may be established, but its application continues to require significant judgement.

That makes IFRS 16 particularly useful in SBR. It allows an examiner to test technical knowledge, professional judgement, financial statement analysis and communication within the same scenario.

Start with the basic lessee model

Before dealing with the confusing areas, candidates need a secure understanding of the core accounting.

At the commencement date, a lessee normally recognises:

A right-of-use asset representing its right to use the underlying asset.

A lease liability representing its obligation to make lease payments.

The lease liability is initially measured at the present value of relevant lease payments. The right-of-use asset normally starts with the amount of the lease liability, adjusted for items such as payments made at or before commencement, initial direct costs, lease incentives and restoration obligations.

After commencement, the lease liability increases because of interest and decreases when lease payments are made.

The right-of-use asset is normally depreciated and may also need to be tested for impairment.

That model is not usually the hardest part of an SBR question. The difficult marks are normally attached to deciding what goes into the calculation and how the accounting changes when circumstances develop.

Confusion one identifying whether a contract contains a lease

Not every contract involving the use of an asset is a lease.

A contract contains a lease when it gives the customer the right to control the use of an identified asset for a period of time in exchange for consideration.

There are two important parts to this assessment.

First, there must be an identified asset.

Second, the customer must control how and for what purpose that asset is used during the period.

The asset may be explicitly identified in the contract, such as a particular vehicle, aircraft or floor of an office building. It may also be implicitly identified if the supplier can only fulfil the contract using a particular asset.

However, an apparently identified asset may not create a lease if the supplier has a substantive substitution right.

A substitution right is substantive when the supplier has the practical ability to substitute the asset and would benefit economically from doing so.

This is where candidates often become too mechanical.

They see a specific asset number in the contract and immediately conclude that a lease exists. That is not enough. The commercial substance must also be considered.

A strong SBR answer should explain the relevant facts.

Can the supplier realistically substitute the asset?

Would substitution provide an economic benefit?

Does the customer make the important decisions about the asset’s use?

Has the use of the asset already been predetermined, and if so, does the customer operate it or design it in a way that determines its use?

The answer should not simply repeat the definition. It should use the scenario to reach a conclusion.

Confusion two separating lease and non-lease components

Many contracts provide more than the right to use an asset.

A property arrangement may include maintenance, cleaning and security. A vehicle contract may include servicing and breakdown cover. An equipment arrangement may include technical support.

The lease component and service components may need to be separated.

The consideration is allocated using relative stand-alone prices, with the lease component accounted for under IFRS 16 and the service components accounted for under the relevant standards.

This can become difficult when stand-alone prices are not directly observable.

Management may need to estimate them using observable information.

There is also a practical expedient that may allow a lessee to elect, by class of underlying asset, not to separate non-lease components from lease components. Instead, the combined component is accounted for as a lease.

In an exam answer, the candidate should not assume that every amount paid under a lease contract is automatically part of the lease liability.

The contract should be broken down first.

Confusion three deciding the lease term

The lease term is one of the most judgement-heavy parts of IFRS 16.

It includes the non-cancellable period of the lease, together with optional periods when the lessee is reasonably certain to exercise an extension option or reasonably certain not to exercise a termination option.

The phrase “reasonably certain” matters.

An option appearing in a contract does not automatically mean the optional period is included. Management must consider whether there is a significant economic incentive to exercise or avoid exercising the option.

Relevant factors may include:

  • significant leasehold improvements, favourable rental terms, relocation costs, operational dependency, the availability of alternative assets and the strategic importance of the location or equipment

This is the only bullet list in the post, because the important point is not to memorise a checklist. It is to apply the commercial facts.

Imagine a retailer has a five-year property lease with an option to extend for another five years.

If the retailer has spent heavily fitting out the location, the site is commercially important and suitable alternatives are limited, it may be reasonably certain that the extension option will be exercised.

The lease term may therefore be ten years rather than five.

By contrast, if the property is easily replaceable, the fit-out is minor and the extension rent will reset to an uncertain market rate, the conclusion may be different.

A strong SBR answer explains both the judgement and its accounting impact.

A longer lease term normally increases the initial lease liability and right-of-use asset. It also affects depreciation, finance costs and the maturity profile disclosed to users.

Confusion four choosing the discount rate

The lease payments must be discounted.

If the interest rate implicit in the lease can be readily determined, that rate is used. In many lessee arrangements, however, the information needed to determine the implicit rate is not available.

The lessee then uses its incremental borrowing rate.

This is not simply the company’s average borrowing rate.

It should reflect the rate the lessee would have to pay to borrow, over a similar term and with similar security, the funds necessary to obtain an asset of similar value in a similar economic environment.

That definition creates several areas of judgement.

The rate may need to reflect the lease term, currency, country, security, asset value and the credit characteristics of the entity.

A group-wide borrowing rate may therefore be inappropriate for every subsidiary and every lease.

A small subsidiary operating in a different country may not have the same borrowing profile as the parent. A ten-year property lease may not have the same rate as a three-year equipment lease.

In an SBR answer, candidates should avoid producing a long theoretical discussion of discount rates. The better approach is to identify why the proposed rate may not reflect the specific lease and explain the effect.

Using a rate that is too low overstates the lease liability and right-of-use asset at commencement.

Using a rate that is too high understates them.

The choice also affects subsequent interest expense and the pattern of reported profit.

Confusion five deciding which variable payments enter the liability

Variable lease payments do not all receive the same treatment.

Payments that depend on an index or rate are generally included in the initial lease liability using the index or rate at the commencement date.

For example, lease payments linked to a consumer price index are initially measured using the index at commencement.

Payments based on future sales or usage are normally excluded from the initial lease liability and recognised as an expense when the event or condition that triggers them occurs.

This distinction can be difficult in practice.

Candidates must distinguish between:

A payment linked to an index or rate.

A genuinely variable payment linked to future performance or use.

An in-substance fixed payment that appears variable but is effectively unavoidable.

Suppose a retailer pays fixed rent plus two per cent of store revenue.

The fixed rent enters the lease liability. The sales-based payment is normally recognised as the related sales occur.

However, imagine the contract says the retailer must pay either £100,000 or £120,000 depending on which of two operational conditions occurs, and at least £100,000 will always be paid.

The unavoidable £100,000 may be an in-substance fixed payment.

This is why simply searching a scenario for the word “variable” is not enough. Candidates must understand the economics of the payment.

Confusion six remeasurement after an index or rate changes

A lease liability is not necessarily fixed for the full lease term.

It may need to be remeasured when future lease payments change because of a movement in an index or rate used to determine those payments.

The updated cash flows are generally reflected when the contractual payments change.

The adjustment is normally recorded against the right-of-use asset.

This area can become confusing because candidates mix up three separate ideas:

A routine payment of the existing lease liability.

A reassessment or remeasurement under the existing contract.

A lease modification involving a change to the contractual scope or consideration.

The label matters because it affects the accounting method and sometimes the discount rate.

A good answer should first identify what has changed before attempting any calculation.

Confusion seven reassessing extension and termination options

The lease term may need to be reassessed when a significant event or change in circumstances occurs that is within the control of the lessee and affects whether it is reasonably certain to exercise an option.

For example, a company may initially expect to leave a property after five years.

Three years later, it makes major improvements to the premises that have a useful life extending well beyond the original lease period. Those improvements may create a new economic incentive to exercise an extension option.

If the lease term changes, the lease liability is remeasured using revised lease payments and an updated discount rate.

The right-of-use asset is normally adjusted for the remeasurement.

Candidates often make one of two mistakes here.

They assume the lease term is never changed after commencement.

Or they change the lease term whenever management changes its mind.

Neither approach is correct.

There must be a relevant significant event or change in circumstances, and the reassessment criteria must be met.

Confusion eight distinguishing a modification from a reassessment

A lease modification is a change in the scope of a lease or its consideration that was not part of the original terms and conditions.

Examples include adding the right to use more space, removing part of an asset from the arrangement or extending the contractual period through a renegotiation.

The first question is whether the modification should be accounted for as a separate lease.

It is normally a separate lease when the modification increases the scope by adding the right to use one or more underlying assets and the consideration increases by an amount consistent with the stand-alone price of that additional right.

If those conditions are not met, the existing lease is remeasured.

Where the scope of the lease decreases, the carrying amount of the right-of-use asset may need to be reduced and a gain or loss recognised.

This is different from reassessing an option that already existed in the original contract.

A useful exam technique is to ask:

Was the change already contemplated by the original contract?

If yes, it may be a reassessment under the existing terms.

If the parties have renegotiated the contract to change its scope or consideration, it is more likely to be a modification.

Confusion nine impairment of the right-of-use asset

A right-of-use asset is not protected from impairment simply because it arises from a lease.

It is subject to the relevant impairment requirements.

This is particularly important when a leased property, shop, factory or piece of equipment is underperforming.

Suppose a retailer closes several stores before the end of their lease terms. The company may still have lease liabilities, but the economic benefits expected from the right-of-use assets may have fallen significantly.

The assets may need to be included within the relevant cash-generating units and tested for impairment.

In an SBR scenario, the strongest answers connect the lease accounting to the wider business problem.

Poor trading, falling customer demand, operational closures or restructuring plans may create impairment indicators.

The candidate should then explain the impact on the right-of-use asset and reported profit.

Confusion ten sale and leaseback transactions

Sale and leaseback accounting remains one of the more difficult parts of IFRS 16 because it requires interaction with the revenue recognition requirements.

The first question is whether the transfer of the asset qualifies as a sale.

If it does not qualify as a sale, the seller-lessee continues to recognise the asset and records a financial liability for the proceeds received.

The buyer-lessor records a financial asset rather than recognising the transferred asset.

If the transfer does qualify as a sale, the seller-lessee recognises only the amount of any gain or loss relating to the rights transferred to the buyer-lessor.

It retains a right-of-use asset representing the rights it continues to hold through the leaseback.

Candidates often recognise the full disposal gain as though the asset had been sold without any continuing right of use.

That is usually the mistake the examiner wants them to identify.

A strong answer should explain that the seller-lessee has not transferred all economic rights in the asset because it continues to use it.

The gain must therefore reflect only the rights transferred.

Confusion eleven rent concessions and payment forgiveness

Lease arrangements may change because a lessor agrees to waive, delay or reduce payments.

The accounting depends on the precise nature of the concession.

A simple deferral may change the timing of payments without changing the total consideration.

A forgiveness of payments may reduce the contractual obligation.

A broader renegotiation may amount to a lease modification.

This is an area where candidates should avoid jumping immediately to an entry.

The scenario must be analysed first.

What has the lessor agreed to?

Have payments been waived or only delayed?

Has the scope of the lease changed?

Was the concession already contemplated by the original contract?

Does another standard affect the treatment of the liability?

A professional answer acknowledges that the accounting depends on the legal and commercial substance of the agreement.

Confusion twelve presenting lease cash flows clearly

IFRS 16 affects more than the statement of financial position.

Lease payments must also be presented appropriately in the statement of cash flows.

The principal portion of lease payments is generally classified within financing activities.

The treatment of the interest portion follows the entity’s policy for interest paid under the cash flow reporting requirements.

Payments for short-term leases, low-value asset leases and variable lease payments excluded from the lease liability are generally presented within operating activities.

This can make lease cash flow information difficult for users to follow, particularly when different elements appear in different parts of the statement.

In an SBR answer, it is useful to explain the commercial message rather than simply listing classifications.

Users need to understand the total cash committed to leases, how much relates to recognised liabilities and how lease payments affect operating and financing cash flows.

Why the disclosures still matter

Recognising a lease liability does not automatically give users all the information they need.

The disclosures should help users understand the amount, timing and uncertainty of lease-related cash flows.

Boilerplate explanations are not enough when significant judgement has been used.

Where lease terms depend heavily on extension options, management should explain the judgements that matter.

Where variable payments are significant, users may need information about future exposure that is not captured in the lease liability.

Where a company has major sale and leaseback arrangements, the notes should explain the transactions and their financial effects clearly.

This creates a useful SBR discussion point.

Compliance is not only about including required tables. The disclosures should communicate the economic substance of the lease portfolio.

How to structure an IFRS 16 SBR answer

Candidates often lose marks because they write everything they know about lease accounting before addressing the specific problem.

A better structure is:

Identify the accounting issue.

State the relevant IFRS 16 principle briefly.

Apply the principle to the contractual and commercial facts.

Explain the effect on assets, liabilities, profit and cash flow where relevant.

Reach a clear conclusion.

For example:

“The five-year extension period should be included in the lease term because the significant fit-out costs and operational importance of the site create a strong economic incentive for the company to exercise the option. The lease liability and right-of-use asset should therefore be measured using a ten-year lease term.”

That paragraph is far stronger than several paragraphs describing every possible type of lease option.

Common mistakes candidates should avoid

A candidate can understand the standard and still lose marks through poor application.

Common problems include treating every contract involving an asset as a lease, automatically including every possible extension period, using a generic corporate borrowing rate without considering the lease terms, including every variable payment in the liability and confusing modifications with reassessments.

Another common mistake is stopping after the technical conclusion.

SBR questions often require candidates to explain the financial statement effect, advise management or discuss why the treatment matters to users.

The answer should therefore go one step further.

Do not only say that the lease liability must be remeasured.

Explain whether the right-of-use asset is adjusted, whether profit is affected and whether clearer disclosure is needed.

Why IFRS 16 is a good professional marks topic

Lease accounting involves contracts, estimates, controls and communication.

That gives candidates opportunities to demonstrate professional skills.

A board-ready answer may recommend that management maintains a complete lease register, assigns responsibility for reporting contractual changes, reviews extension options regularly and ensures that significant judgements are documented.

It may also explain the risks created by poor lease data.

Missing a lease can understate assets and liabilities.

Using an inappropriate discount rate can distort measurement.

Failing to record a modification promptly can create incorrect depreciation and interest charges.

Weak disclosures can prevent users from understanding the company’s future cash commitments.

These are practical reporting consequences, not abstract technical points.

How to revise IFRS 16 efficiently

Do not spend all your time repeating the initial recognition calculation.

Build practice around the judgement areas.

Take short scenarios and decide whether a lease exists. Practise lease term decisions involving extension and termination options. Compare index-linked payments with sales-based payments. Work through modifications, reassessments and sale and leaseback arrangements.

Most importantly, practise explaining the answers in words.

SBR is not a calculation exam with a few comments added at the end. Candidates must communicate the reasoning behind the treatment.

A structured ACCA SBR course should therefore include scenario practice, written feedback and timed answers, rather than relying entirely on lectures and technical notes.

What candidates should take from the current debate

The broad lease accounting model is not about to disappear.

Bringing most leases onto lessee balance sheets has become an established part of financial reporting.

The continuing debate is more practical.

How can companies apply the measurement requirements without unnecessary cost?

Can remeasurements be made more efficient?

Can discount rates be determined more consistently?

How should unusual concessions and changing payment arrangements be handled?

Those questions show why IFRS 16 remains relevant to SBR.

A mature standard does not become an easy standard. Once the basic accounting is familiar, exam questions can move towards the harder areas of judgement, interaction with other standards and communication to users.

What to do now

Revise IFRS 16 as a decision-making topic rather than a list of journal entries.

Make sure you can explain:

Whether a contract contains a lease.

How the lease term is determined.

Which payments enter the lease liability.

Why the discount rate must reflect the specific arrangement.

When a liability is remeasured.

How a modification differs from a reassessment.

Why sale and leaseback gains are restricted.

How the accounting affects profit, cash flow and disclosure.

If you can explain those areas clearly and apply them to a scenario, IFRS 16 becomes far more manageable.

The dust may have settled around the basic model, but the marks now sit in the areas where judgement still matters.

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