frequently asked questions

We are a SaaS company — should we apply ASC 350-40 or ASC 985-20?

For most SaaS companies, ASC 350-40 is the applicable standard — not ASC 985-20. Under a SaaS model, the customer does not take possession of the software; instead, the company hosts the software and provides access to the customer as a service. Because there is no transfer of a software license, ASC 985-20 — which applies to software sold, leased, or otherwise marketed to customers — typically does not apply. ASC 350-40 governs the capitalization of costs incurred to develop the hosted software. That said, if your company has hybrid arrangements — some hosted, some licensed — the analysis may yield different answers for different product lines.

When does technological feasibility occur under ASC 985-20?

Under ASC 985-20, technological feasibility is established when the company has completed all planning, designing, coding, and testing activities necessary to establish that the product can be produced to meet its design specifications — including functions, features, and technical performance requirements. In practice, technological feasibility is often established very late in the development process, which means the period during which costs are capitalized under ASC 985-20 is frequently short. This is one reason why many technology companies find that the costs capitalized under ASC 985-20 are not material.

How should we account for the cost of implementing a cloud-based ERP system?

Implementation costs for a cloud-based ERP (a hosting arrangement that is a service contract) are accounted for under the ASC 350-40 framework as extended by ASU 2018-15. Costs incurred in the preliminary project stage are expensed. Costs incurred in the application development stage — including configuration, customization, coding, and testing — are capitalized and subsequently amortized over the term of the hosting arrangement, including reasonably certain renewal periods. And costs incurred in the post-implementation stage, including training and data migration, are expensed.

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