The Headline Difference
IFRS 36: Compare carrying amount to recoverable amount (the higher of fair value less costs and value-in-use). If carrying exceeds recoverable, impair the difference.
ASC 350: Step 1: Compare fair value of reporting unit to carrying amount (including goodwill). If fair value exceeds carrying, no impairment. Step 2: If fair value is less, compare carrying amount of goodwill to implied fair value of goodwill. If carrying exceeds implied, impair.
Key insight: IFRS allows value-in-use (management's internal projections, often higher). ASC requires market fair value (market-based, often lower, especially in down markets). Result: IFRS goodwill often survives; ASC goodwill gets written down.
IFRS 36: The One-Step Test
Step 1: Determine Recoverable Amount
Recoverable amount = Higher of:
- Fair value less costs of disposal (FVLCD): What a third party would pay for the unit, less costs to sell
- Value-in-use (VIU): PV of cash flows management expects to generate from continued use
Step 2: Compare and Impair
If carrying amount > recoverable amount, impair the difference to goodwill.
Reference: IFRS 36 paragraphs 18— 5.
ASC 350: The Two-Step Test
Step 1: Compare Fair Value to Carrying Amount
Fair value of reporting unit > Carrying amount (including goodwill)? → No impairment.
Fair value of reporting unit < Carrying amount? → Proceed to Step 2.
Step 2: Calculate Implied Goodwill Value
Implied goodwill = Fair value of reporting unit − Fair value of identifiable net assets.
If carrying amount of goodwill > implied goodwill value, impair the difference.
Reference: ASC 350-20-35-3 onwards.
Value-in-Use vs Fair Value: Why It Matters
Value-in-use (IFRS): Uses entity-specific assumptions (growth rates, margins, terminal values based on management's budget). Often reflects optimistic internal views. Can be higher than market fair value.
Fair value (ASC): Market-based (what a willing buyer would pay). Reflects current market conditions, not management's view. Often conservative.
In a down market: Fair value drops 20— 0%; VIU may drop only 10% (because management believes a recovery is coming). This divergence creates audit risk.
Worked Example: Acquisition Impairment
Scenario: Software Company Acquired for £50M
Acquisition details (Jan 2024):
- Purchase price: £50M
- Fair value of identifiable net assets: £30M
- Goodwill recognised: £20M
Impairment testing (Dec 2025, Year 2 of ownership): Market downturn; software spending falling. Carrying amount of reporting unit: £50M (assume no depreciation for simplicity).
Fair value estimate: £40M (market comparables, likely buyer interest).
Fair value of identifiable net assets: £32M (updated valuations).
IFRS 36 Analysis:
- FVLCD = £40M − £1M (disposal costs) = £39M
- VIU = PV of cash flows (5-year forecast + terminal): £38M (management assumes 8% growth, 3-year recovery)
- Recoverable amount = Higher of £39M and £38M = £39M
- Carrying amount of unit: £50M
- Impairment: £50M − £39M = £11M goodwill write-down
ASC 350 Analysis:
- Step 1: Fair value (£40M) < Carrying amount (£50M) → Proceed to Step 2
- Step 2: Implied goodwill = £40M − £32M = £8M
- Carrying goodwill: £20M
- Impairment: £20M − £8M = £12M goodwill write-down
Outcome: Both standards result in significant write-downs (£11M vs £12M), but IFRS is marginally more lenient because VIU is £38M (management's view) vs fair value £40M (market). If management is really optimistic (VIU £42M), IFRS impairment drops to £9M, while ASC stays at £12M.
Cash-Generating Units vs Reporting Units
IFRS 36: Tests goodwill at the cash-generating unit (CGU) level — the smallest group of assets generating independent cash inflows.
ASC 350: Tests at the reporting unit level — typically aligns with operating segments.
Audit implication: IFRS may result in more granular impairment testing (more CGUs = more write-downs if individual units underperform). ASC is more lenient (larger reporting units can offset underperformers).
Discount Rate Assumptions
IFRS 36: Uses a pre-tax discount rate reflecting the asset-specific risks (WACC adjusted for risk).
ASC 350: Uses post-tax discount rate (or pre-tax, but adjusted differently).
Small differences in discount rate produce large differences in VIU/impairment amounts. A 1% difference in discount rate can move impairment by £1— M for a £20M goodwill balance.
Audit Implications and Red Flags
For auditors:
- Challenge VIU assumptions: Growth rates, terminal values, margins. Are they backed by external data or just management optimism?
- Fair value benchmarking: If fair value is higher than VIU, question why. Market should reflect reality better than internal models.
- Discount rate: Build-up from scratch; don't accept management's rate without challenge. Small changes matter.
- IFRS vs ASC divergence: If testing under both standards, document why results differ. Market fair value should generally be stricter.
- Subsequent quarters: If impairment was avoided in Year 1 but conditions deteriorated, push harder in Year 2. Auditors often challenge deferred write-downs.
For controllers and CFOs:
- Document your impairment model thoroughly. Auditors will rebuild it from scratch.
- If you are IFRS, don't rely solely on VIU. Benchmark to market fair value. Auditors will question if you ignore the market.
- If underperforming post-acquisition, proactively consider impairment. Delaying a write-down signals weak controls to auditors.
Need help with goodwill impairment testing?
Use GAAP Compare to research IFRS 36 vs ASC 350 treatment, or bring your acquisition to the Meeting Room for an expert walkthrough.
Try GAAP Compare Free →Frequently Asked Questions
What is the main difference between IFRS 36 and ASC 350 goodwill impairment?
IFRS 36 uses one-step test (fair value or value-in-use). ASC 350 uses two-step test (fair value → implied goodwill). IFRS allows value-in-use (often higher); ASC requires market fair value (often lower).
What is value-in-use?
PV of future cash flows the asset is expected to generate, using the entity's discount rate. Management-specific; often higher than market fair value.
Can IFRS 36 and ASC 350 produce different impairment amounts?
Yes. IFRS can use value-in-use (higher); ASC uses fair value (lower). In down markets, ASC write-downs are typically larger.
This guide is simplified for educational purposes. Goodwill impairment testing is complex; outcomes depend on specific facts, assumptions, and judgments. Consult IFRS 36 and ASC 350 full text, and your own advisors, before finalising impairment treatment.
Real-Life Case Study: Testing Goodwill Under IAS 36 vs ASC 350
Scenario. A dual reporter tests a reporting unit / CGU carrying £50m of goodwill after a downturn.
The difference. IAS 36 tests at the CGU level using recoverable amount (higher of FVLCD and value in use), a one-step test. US GAAP (ASC 350, as simplified) compares the reporting unit's fair value to its carrying amount and books the shortfall directly. Because value in use (an entity-specific measure) can exceed fair value, the frameworks can produce a different impairment, or one may impair while the other does not.
Takeaway. The measurement base differs (recoverable amount vs fair value) and the unit of account differs (CGU vs reporting unit). Neither framework allows a goodwill-impairment reversal, but they can still disagree on the loss itself.
Illustrative composite scenario for educational purposes. Figures are indicative and do not represent any specific company.