Standards-anchored reference to primary IFRS and FASB text. Not accounting advice.
AI Capitalisation
US GAAP / source of record

ASU 2025-06 Targeted Improvements to Internal-Use Software

Head note

ASU 2025-06 amends ASC 350-40. It removes the project-stage references and replaces the capitalisation trigger with a probable-to-complete recognition threshold: capitalisation begins when management has authorised and committed funding and it is probable the project will be completed and the software used as intendedS5. It is effective for annual periods beginning after 15 December 2027, with early adoption permitted.

1

What the update replaces

The prior guidance keyed capitalisation to sequential project stages, a model that fitted waterfall development but not agile or iterative AI work. ASU 2025-06 removes the preliminary, application-development and post-implementation stage references and makes recognition neutral to development methodologyASU 2025-06S5.

2

The probable-to-complete threshold

Under the amended guidance, an entity begins capitalising software costs when both conditions hold: management has authorised and committed to funding the project, and it is probable that the project will be completed and the software will be used to perform the function intended S5. Both conditions are required; funding alone is not enough.

3

The significant-development-uncertainty condition

Capitalisation is deferred while significant development uncertainty remains. That uncertainty exists where the software has novel, unique or unproven functionality with unresolved uncertainty after coding and testing, or where the performance requirements are not yet defined or remain subject to major revisionS5. This is the condition that most directly affects frontier AI models, and it can block capitalisation even after funding is committed.

4

Effective date and transition

ASU 2025-06 is effective for all entities for annual reporting periods beginning after 15 December 2027, with early adoption permitted S5. For a reporting period before adoption, the ASC 350-40 stage model still governs, so a controller should confirm which basis applies to the period being reported.

Sources of record
  1. S5ASU 2025-06 on internal-use software costs, BDO (US GAAP). https://arch.bdo.com/new-asu-on-internal-use-software-costs-guidance
  2. S4FASB Accounting Standards Codification, PwC Viewpoint (US GAAP). https://viewpoint.pwc.com/dt/us/en/fasb/GAAP/Codification/Codification/228073.html
  3. S2Handbook: Software and website costs (ASC 350-40 internal-use software), KPMG (US GAAP). https://kpmg.com/us/en/frv/reference-library/2026/handbook-software-website-costs.html
Standards-anchored reference · not accounting adviceRevised 2026-07-24