FRS 102 Scope and Status
FRS 102 has been the UK-adopted GAAP standard since January 2015 (replacing old UK GAAP). It's based on IFRS for SMEs but incorporates additional UK-specific requirements and disclosure concessions for smaller entities.
Current status (2026): FRS 102 remains the standard for UK companies not required to report under IFRS. The FCA requires IFRS for listed companies; unlisted entities use FRS 102 unless they are micro-entities (FRS 105).
Who Applies FRS 102?
Mandatory FRS 102 Users
- Private companies: Most UK private companies (by definition, unlisted)
- Public unlisted companies: UK-listed entities NOT on the Premium segment (often use IFRS, but could choose FRS 102)
- Charities: Many charities use FRS 102 (though some follow Charities SORP)
- Large unlisted groups: May voluntarily adopt FRS 102 unless group consolidated over thresholds
Exemptions
- Micro-entities (FRS 105): Turnover <£6.5m, assets <£3.26m, employees <10 (small entity exemption available)
- Listed entities: Must use IFRS (FCA requirement for premium listing)
- Banking/insurance: Specific sector standards may override
Small Entities Exemption (SE Regime)
FRS 102 includes significant disclosure and measurement reliefs for entities meeting size thresholds:
Qualification Thresholds (2 of 3)
- Turnover ≤ £10.2m (previously £8.8m; increased 2023)
- Balance sheet assets ≤ £5.1m (previously £4.4m)
- Employees ≤ 50
Small Entity Exemptions
- Cash flow statement: Not required
- Related party disclosures: Minimal (only key management)
- Segmental reporting: Not required
- Fair value measurements: Simplified (cost may be proxy; no fair value for investment property if no market)
- Deferred tax: No recognition of DTA (simplifies provision estimates)
FRS 102 vs IFRS: Key Differences
1. Financial Instruments
| Aspect | IFRS 9 | FRS 102 |
|---|---|---|
| Classification | SPPI test; business model test | Simpler: Available-for-Sale (AFS), Loans & Receivables, FVPL |
| Impairment | ECL model (3-stage; SICR triggers) | Simpler: Incurred loss model; indicators of impairment |
| Fair value option | FVPL allowed; strict criteria | FVPL more readily available for equities; AFS if no control |
2. Leases (IFRS 16 vs FRS 102)
- IFRS 16: All leases > 12 months capitalized as ROU assets
- FRS 102: Operating vs finance lease distinction (narrower capitalization)
3. Property Revaluation
- IFRS: Revaluation through OCI (or P&L); reversals matched by reversals
- FRS 102: Revaluation through P&L (simpler); reversal to P&L only
FVPL Investments in FRS 102
FRS 102 permits more liberal use of FVPL for equity investments, especially when held as part of a trading portfolio or when fair value is readily available.
When FVPL is Permitted
- Investments held for trading: Re-measured at fair value each period
- Investments in associates (no significant influence): Can use FVPL instead of equity method
- Financial liabilities: FVPL available for derivatives and fair value hedges
Fair Value Measurement
FRS 102 uses simpler fair value hierarchy (quoted prices > observable inputs > unobservable), but less detailed than IFRS 13.
FRS 102 2026/27 Amendments
Amendment 1: Lease Accounting Alignment
Ongoing harmonization with IFRS 16 principles (though full alignment may not occur; finance lease tests tightening).
Amendment 2: Climate-Related Disclosures
New guidance on climate risk disclosures (in line with UK TCFD requirements); applies to larger entities.
Amendment 3: Going Concern & Liquidity
Enhanced guidance on assessing going concern beyond 12 months and liquidity disclosures (especially post-pandemic volatility).
Transition from IFRS to FRS 102
Some entities (e.g., de-listing) move from IFRS to FRS 102. Key audit areas:
Asset Reclassifications
- PP&E: Revaluation to cost-only (if using revaluation model under IFRS)
- Investment property: Reclassification if no active market
- Financial instruments: AFS/FVPL reclassification
Provision Adjustments
- IFRS 37 restructuring provisions may not meet FRS 102 criteria (no liability if plan not finalized)
- Deferred tax: May not be recognized (simplification)
Audit Red Flags: FRS 102 Conversions
Red Flag 1: IFRS Revaluations Not Reversed
Finding: Entity transitions from IFRS (used revaluation model for PP&E) to FRS 102 (cost model). Carrying values remain at revalued amounts without reversal.
Auditor action: Decide on deemed cost method (retain revalued amount as new cost) or actual reversal. Impact goodwill/impairment testing.
Red Flag 2: Investment Property Fair Value Estimates Unsupported
Finding: Investment property valued at £5m under IFRS (fair value hierarchy, market approach). Under FRS 102, no active market exists; valuation becomes cost-based, significantly lower.
Auditor action: Reassess fair value basis; if cost is more appropriate, write down; recognize impairment loss.
Red Flag 3: Provisions Overstated
Finding: Under IFRS, £10m restructuring provision recognized (IFRS 37, detailed plan). Transitioning to FRS 102, no finalized board approval for restructuring; FRS 102 does not require provision.
Auditor action: Reverse provision; adjust P&L; reclassify to contingent liability (if probable outflow).
Red Flag 4: Deferred Tax Not De-Recognized
Finding: Deferred tax of £3m (on temporary differences) carried forward from IFRS. FRS 102 micro/small entities exemption exempts DTA recognition.
Auditor action: Reverse DTA; adjust retained earnings; no tax expense adjustment (simplified).
Real-Life Case Study: A Company Reporting Under FRS 102
Scenario. A mid-sized UK manufacturer (turnover £30m) prepares its accounts under FRS 102, the main UK GAAP standard.
Key differences from IFRS it must manage. Goodwill and intangibles are amortised over a finite life (default up to 10 years if unreliable estimate) rather than impairment-only; development costs may be capitalised but need not be; and it takes the reduced disclosure regime available to qualifying entities. Investment property, though, is still at fair value through P&L, much like IFRS.
Takeaway. FRS 102 is "IFRS-lite" but not IFRS: the goodwill-amortisation difference alone changes the profit profile of any acquisitive group. Know which specific sections diverge before assuming an IFRS answer applies.
Illustrative composite scenario for educational purposes. Figures are indicative and do not represent any specific company.
• FRS 102 Small Entities Exemption: Disclosure & Measurement Relief
• FRS 102 Transition from IFRS: Accounting Changes & Restatement
• FRS 102 Financial Instruments: Classification, Measurement & Impairment