Leases
Whether a lessee puts leased assets and lease obligations on the balance sheet, how the P&L charge is shaped, and what off-balance commitments must be disclosed.
| Facet | A · IFRS | B · US GAAP | C · Dutch GAAP | D · TFRS / BOBİ FRS | E · HGB | F · FRS 102 |
|---|---|---|---|---|---|---|
Scope What the standard covers and what it excludes | ||||||
Recognition When something goes on the balance sheet or into P&L | ||||||
Measurement Initial and subsequent amounts | ||||||
Presentation Where it sits in the statements | ||||||
Disclosure What the notes must say |
Status is relative to IFRS (column A). Click a cell for the full treatment and its sources. DRAFT cells are AI-written from the standards and not yet reviewed.
Framework by framework
IFRS 16 applies a single lessee model: every lease longer than twelve months, other than low-value assets, produces a right-of-use (ROU) asset and a lease liability at commencement, with depreciation and interest replacing rent expense. Lessors keep the IAS 17 dual model and classify each lease as finance or operating at inception. Effective for periods beginning on or after 1 January 2019.
ASC 842 puts both finance and operating leases on the lessee's balance sheet, but keeps the classification. A finance lease yields amortisation plus interest (front-loaded); an operating lease yields a single straight-line lease cost, with the ROU asset measured as a plug off the liability. Operating and finance lease balances must be presented separately and operating lease liabilities are commonly treated as operating, not debt. Effective for public business entities from fiscal years beginning after 15 December 2018, other entities after 15 December 2021.
RJ 292 keeps the pre-IFRS 16 model: a lessee capitalises finance leases and expenses operating leases straight-line off balance sheet, with the commitment disclosed under art. 2:381 lid 1 BW. Since financial years beginning on or after 1 January 2020 (earlier application permitted) an entity may instead apply IFRS 16 in full as an accounting policy choice (RJ 292.101), reconfirmed by RJ-Uiting 2023-5. Cells below describe the default RJ 292 model; the IFRS 16 option removes the difference where taken.
Two tiers. Public-interest entities (KAYİK) apply TFRS 16, a verbatim adoption of IFRS 16 with identical paragraph numbers, effective 1 January 2019. Other audited entities apply BOBİ FRS (2021 Sürümü), whose Bölüm 15 keeps the finance versus operating lease (faaliyet kiralaması) split: operating lease payments are expensed straight-line and stay off balance sheet. **Status in each cell follows the BOBİ FRS tier**, because the TFRS tier is aligned with IFRS in every facet and each cell says so explicitly.
HGB has no lease standard and no right-of-use model. § 246 Abs. 1 Satz 2 HGB attributes an asset to its economic owner (wirtschaftlicher Eigentümer), and practice decides economic ownership of leased assets by the tax Leasingerlasse (BMF letters of 19 April 1971 and 22 December 1975 for full and partial amortisation of movables, with parallel letters for immovables). Under a conforming contract the lessor capitalises and depreciates the asset and the lessee expenses rent; the lessee's future rentals appear only as sonstige finanzielle Verpflichtungen under § 285 Nr. 3a HGB (§ 314 Abs. 1 Nr. 2a for groups).
Post Periodic Review 2024, for periods beginning on or after 1 January 2026, Section 20 puts lessees on an IFRS 16-style on-balance-sheet ROU model with short-term and low-value exemptions and some simplifications, notably an obtainable borrowing rate where the rate implicit in the lease is not readily determinable. Lessor accounting remains largely unchanged (operating versus finance split). Pre-2026, lessees applied the IAS 17 model and operating leases were off balance sheet with a straight-line charge; that rule still governs comparatives and late adopters.
Standard-setter changes on this topic
- 2024-03-27FRS 102Lessees move to an on-balance-sheet right-of-use model aligned with IFRS 16, with short-term and low-value exemptions and simplified discount-rate guidance; lessor accounting is largely unchanged. Effective for periods beginning on or after 1 January 2026, modified retrospective transition. Effective 2026-01-01.
- 2023-04-11Dutch GAAPThe RJ evaluated the option to apply IFRS 16 in full instead of RJ 292 and confirmed it remains available unchanged; finalised without amendment at the RJ meeting of 17 May 2023. The effective date shown is that of the option itself (financial years from 1 January 2020), not of the evaluation. Effective 2020-01-01.
- 2022-09-22IFRSAdds subsequent-measurement requirements for the lease liability arising from a sale and leaseback so that the seller-lessee does not recognise a gain or loss relating to the right of use it retains. Effective for periods beginning on or after 1 January 2024. Effective 2024-01-01.