What the Board heard from stakeholders on GRAP 108 on Statutory Receivables so far

The Accounting Standards Board (the Board) is undertaking a post-implementation review (PIR) to assess if GRAP 108 meets its objectives of providing relevant and useful information to users and to understand preparers’ implementation challenges with applying GRAP 108. For this purpose, [ED 207] was issued with a comment deadline of 27 October 2024.

Feedback received to date

Several engagements were held to date to obtain comment on ED 207. The following high-level comment, among others, was noted:

Comment area Comment detail
Classification of receivables as statutory or contractual

Stakeholders remain uncertain about the classification of receivables as contractual or statutory where transactions are regulated by legislation or similar means, and subsequently initiated by a contract. For example, where a Council adopts electricity tariffs regulated by NERSA and a customer enters into a contract with a municipality to receive electricity services, there is uncertainty about whether the receivable from supplying the electricity service should be classified as statutory or contractual.

It was also observed that in some instances, entities incorrectly classify a receivable as contractual because they perceive the arrangement as entered into willingly. For example, property rates are levied in terms of the Property Rates Act. Because a consumer willingly decides to purchase a property, the property rates receivable are incorrectly classified as a contractual receivable.

Guidance on these areas is included in Frequently Asked Question (FAQ) 11.1 on How do statutory receivables arise?.

Impairment of statutory receivables

With the revised Standard of GRAP on Financial Instruments (GRAP 104 (2019)) becoming effective on 1 April 2025, a new impairment model, namely the expected credit loss (ECL) model, will be introduced. Stakeholders expressed different views on whether the impairment model in GRAP 108, i.e. the incurred loss model, should be replaced with the ECL model. For more information on the difference between the ECL model and the incurred loss impairment model in GRAP 108, please refer to this article [add link to the article on 30 April 2024]

·       Stakeholders supporting the adoption of the ECL model for impairing statutory receivables note that it will be difficult to apply different impairment models for the same debtor when an account comprises of a contractual and statutory receivable component.

·       Stakeholders that support retaining the incurred loss model in GRAP 108 noted that from 1 April 2025, entities will already be required to apply different impairment models to impair a receivable that has a contractual and statutory component. Stakeholders also noted that practice on applying the ECL model should first develop before the Board introduces the model for statutory receivables.

Impairment versus derecognition of statutory receivables Some stakeholders noted that more guidance should be developed to assist entities in assessing whether a statutory receivable is impaired or whether it should be derecognised. For example, where grant funding is allocated through legislation (for example, in the Division of Revenue Act) and subsequently adjusted through an adjustment budget, some entities are unsure if the adjustment should be reflected as an impairment or derecognition.
Presentation of statutory receivables

Entities remain uncertain if, on the face of the statement of financial position, separate line items should be reflected for:

(a)  receivables from exchange and non-exchange transactions, with details on statutory or contractual receivables presented in the notes, or

(b)  statutory and contractual receivables, with details explaining whether the receivables are exchange or non-exchange in nature in the notes.

FAQ 4.8 on When should an entity present revenue and receivables from exchange and non-exchange transactions on the face of the financial statements or in the notes? provides guidance in this area.

Disclosures on exposure to credit and liquidity risks Most stakeholders support the inclusion of a requirement in GRAP 108 to present information on the nature and extent of statutory receivables’ exposure to credit risk and how the entity manages its liquidity risk relating to statutory receivables. These disclosures will be required under GRAP 104 (2019).

How can you share your comment?

Stakeholders can give input on ED 207 by submitting written comment, completing a survey, or participating in roundtable consultations. The surveys are available on the ASB’s website [SurveyPreparers and SurveyUsers].

For more information on the scheduled roundtable consultations, contact Amanda Botha at amandab@asb.co.za.



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