If you are a public business entity, eight new accounting standards take effect for annual periods beginning after December 15, 2026. For a calendar-year filer that is January 1 — eight weeks from today.

If you are not, the number is six. One of the others arrives a year later. And the one you have heard the most about does not apply to you at all.

That inversion is the reason for this issue. Expense disaggregation has had the coverage, the webinars and the readiness checklists, and it deserves them. It is also the single standard on this list that a large part of this readership can stop thinking about entirely — while six others, which have had almost no attention, apply to you on exactly the same date as everyone else.

Start here, because it eliminates most of the list for most readers.

Expense disaggregation applies only to public business entities. Most private companies are not in scope — not deferred, not phased, not a reduced version. Out entirely. But check the definition before you relax, because a private company is caught if it is pursuing an IPO, if its financial statements are included in another entity's SEC filing, or if it is a target in an S-4, a proxy or a SPAC transaction. If none of those is true of you, a 2027 plan built around DISE readiness is work you do not need to do.

Hedge accounting is deferred a full year. ASU 2025-09 takes effect for public business entities for annual periods beginning after December 15, 2026, and for all other entities a year later, after December 15, 2027.

Six of the eight apply to every entity on the same date — ASU 2025-03, 2025-04, 2025-07, 2025-08, 2025-12 and 2026-01. That is not an inference from a silent table. Each of the six says "all entities" in its own effective-date text, and in four of them the Board explicitly considered a separate private-company date and decided against it.

And note that "public business entity" is a defined term that is broader than "publicly traded." It captures some private companies with public debt, and some whose financial statements are included in another entity's public filing. If you have assumed you are outside it, that assumption is worth checking rather than carrying into January.

This is the distinction that should drive your plan, and it is not the one most readiness checklists use.

Four of the eight are measurement changes that mostly sit dormant until you do a specific kind of transaction. ASU 2025-03 changes how you identify the accounting acquirer when you buy a variable interest entity with equity rather than cash — which can turn what used to be a forward acquisition into a reverse one, changing whose assets get stepped up and whether goodwill arises at all. ASU 2025-04 covers equity issued to customers as a purchase incentive, and also removes the option to account for forfeitures on those awards as they occur. ASU 2025-07 narrows derivative accounting for contracts whose triggers are specific to one party — a milestone, a regulatory approval, a change of control — though not for change-of-control features in your own equity instruments, and not for puts and calls on debt, both of which stay exactly where they are. ASU 2026-01 requires paid-in-kind dividends on equity-classified preferred to be measured initially at the stated rate rather than fair value.

If you never do those transactions, three of the four ask nothing of you. The exception is 2025-04. If you have customer awards outstanding and you currently account for forfeitures as they occur, that election disappears on adoption and you book a cumulative-effect adjustment to opening equity without entering a single new transaction. Two others are worth a look now rather than later. Anyone carrying embedded derivatives from milestone or regulatory triggers should inventory those contracts before adopting 2025-07, because modified retrospective transition carries a one-time, instrument-by-instrument fair value election you cannot revisit. And any issuer with PIK preferred outstanding should establish whether their current method is the stated rate or fair value, because if it is fair value, adoption moves reported equity and earnings per share.

Two more are effectively industry standards. ASU 2025-08 extends the gross-up treatment to purchased seasoned loans, eliminating the double count where an acquirer booked both a credit-loss expense and a purchase discount. It applies to all entities, but in practice it is a banking and specialty-finance standard, and it changes the earnings presentation of a 2027 portfolio purchase or bank acquisition materially enough to model now. ASU 2025-09 matters only if you elect hedge accounting.

Which leaves two that deserve actual work: expense disaggregation, if you are a public business entity, and the one nobody is looking at.

ASU 2025-12 is titled Codification Improvements. It contains 33 amendments — numbered to 34, because one was dropped before issuance — and it is the kind of document that gets skimmed and filed.

One of those 33 is not housekeeping.

Issue 4 changes how earnings per share is calculated when you have a loss from continuing operations and a contract that may be settled in stock or cash. You must now adjust the numerator as though that contract were equity-classified and then test the combined numerator and denominator effect, rather than treating potential shares as antidilutive because there is a loss. The old guidance conflicted with itself on this point, so practice varied. It is now settled, and settled in the direction of more dilution rather than less.

Here is the part that matters. Every other issue in the update can be adopted prospectively or retrospectively, elected issue by issue. Issue 4 is the exception: it is mandatorily retrospective to each prior period presented, where the adjustment is dilutive.

So a company with convertible instruments settleable in cash or stock, and loss years in its comparatives, can find itself restating prior-period diluted EPS — a headline metric that investors track — on adoption of a standard marketed as cleanup. Biotech, technology, and anyone who issued convertible debt in the 2020 and 2021 window should check this before January rather than after.

Eight weeks is not enough to build a system. It is enough to do three things.

It is enough to establish which of the eight apply to your entity type, which is a morning's work.

It is enough to sort the applicable ones into data problems and treatment problems. A standard that needs information you do not capture is a systems project. A standard that changes a measurement when a transaction occurs is a memo and a trigger. Resourcing them the same way is how the real project gets starved.

And it is enough to tell your auditor what you concluded, in writing, before they tell you. A scoping conclusion documented in November is a different conversation from one reconstructed in March.

Your inbox is flooded with newsletters. Your feed is chaos. Somewhere in that noise are the insights that could transform your work—but who has time to find them?

The Deep View solves this. We read everything, analyze what matters, and deliver only the intelligence you need. No duplicate stories, no filler content, no wasted time. Just the essential AI developments that impact your industry, explained clearly and concisely.

Replace hours of scattered reading with five focused minutes. While others scramble to keep up, you'll stay ahead of developments that matter. 600,000+ professionals at top companies have already made this switch.

Join them today, for free.

We ended last week's issue with a specific thing to watch: whether the ten-year stayed at or below 5% after Wednesday's decision, and we said a hold with hawkish guidance that pushed it back above 5.15% would tell you more about your 2027 discount rate than the decision itself.

Part of that happened. The part we actually named did not, and it is worth being exact about which.

The Fed held at 3.75–4.00% on October 28, in a 10-2 vote — not a unanimous one. The ten-year closed at 5.05% that day, back above 5%. But it never reached the 5.15% we set as the marker, and it did not stay up: 4.98% on October 29, 4.94% on October 30, and roughly 4.92% on Monday, a seven-week low and the lowest since mid-September.

So we had the direction right and the magnitude wrong. One close above 5%, ten basis points below the level we flagged, and back under within a day. A threshold is only worth publishing if we hold ourselves to it afterward.

Here is what is actually worth your attention. The December odds did not move. Futures put a December increase at 75.2%, against roughly three in four when we wrote last week — flat, through a hold, two dissents and a falling long end.

That is the combination that matters, and it survives the correction above. The ten-year is down about thirteen basis points since the decision and roughly thirty-five across October, while the expected policy rate has not budged. If the market had changed its mind about the Fed, December would have repriced. It did not. What moved was the term premium — the compensation demanded for holding duration — and that is precisely the component we said was doing the damage to valuations and deal pricing.

So the easing in the long end is not a bet on a softer Fed. It is a separate repricing, and it is the one that matters for your discount rate.

What to watch now: December 9, and whether the ten-year holds under 5% through it. The dot plot arrives with that meeting, and a hike delivered into a falling long end would be an unusual combination worth watching closely.

Three things every CFO needs to know this week.

· Your peers say the constraint is the balance sheet, not the price. We asked last week what would bind if an acquisition landed on your desk this quarter. Of 50 responses, 44% said balance sheet capacity and 26% said price — an eighteen-point gap. Only 16% named their own ability to integrate it, which was the question our own playbook argued gets skipped. Fifty self-selected responses is a signal, not a survey. But it is worth noting that the thing readers say constrains them is capacity to fund, in a market we described last week as turning buyer-favorable. Cheap assets you cannot finance are not cheap assets.

· Our earnings call is holding so far, and the beats keep getting thinner. Last week we passed on FactSet's expectation that third-quarter growth would land above 35% once companies beat, and said that on the observed magnitude it would not. With 60% of the S&P 500 now reported, blended growth sits at 30.2% — up from 29.5%, with 40% of the index still to come. Blended growth does climb through a season, so 35% is not arithmetically dead. But the number that matters moved the wrong way: the aggregate beat narrowed from 2.1% to 1.9%, against a five-year average of 7.5% and a ten-year average of 8.0%. So 82% of companies are beating estimates by roughly a quarter of the usual margin, and beats that thin do not close a five-point gap. One correction we owe you: we said health care was the only sector reporting an outright earnings decline. It no longer is. All eleven sectors are now reporting year-over-year growth.

· If you are public, your first expense-disaggregation disclosure is later than you think. ASU 2024-03 is effective for annual periods beginning after December 15, 2026 — but the interim requirement does not begin until annual periods beginning after December 15, 2027. For a calendar-year public business entity, that means the first disclosure appears in the FY2027 annual report filed in early 2028, not in the first-quarter 2027 filing. That is a year of relief on presentation. It is not a year of relief on data collection, because the annual disclosure still needs twelve months of 2027 expense data captured the right way starting January 1.

1. Establish your entity type in writing, once. Public business entity is a defined term and it is broader than "publicly traded" — it captures some private companies with public debt or those whose financial statements are included in a public filing. Get the conclusion documented, because it determines which of the eight you are even reading about. This is the step that saves the most work.

2. Sort the applicable standards into data problems and treatment problems. A standard that requires information you do not currently capture is a systems and process project. A standard that changes how you measure something when it happens is a memo and a trigger. Do not resource them the same way.

3. Check whether you have the transactions at all. Several of the eight are narrow. If you have no variable interest entity acquisitions, no share-based consideration payable to customers, no purchased loans and no equity-classified preferred stock with PIK dividends, a meaningful part of the list is noise for you. Confirm that rather than assuming it.

4. Look at early adoption where it buys you something. All eight permit early adoption, but only some are worth taking. Hedge accounting has permitted it since the standard was issued on November 25, 2025, and adopting it carries a one-time opportunity to modify certain critical terms of existing hedging relationships without dedesignating them. If you run a hedging program, price that window before it closes. For the standards that add disclosure rather than remove friction, there is no prize for arriving early.

SPONSOR THIS NEWSLETTER

Your name, in front of the CFOs and senior finance leaders who read The CFO Desk every Tuesday. The primary slot is available for Q4. Write to [email protected].

The reason eight standards landing on one date is a problem is not that any one of them is hard.

It is that the work of figuring out which ones apply to you is itself the work, and it is invisible on a project plan. Nobody puts "determine scope" on a readiness timeline, so it gets done in February by whoever notices first, usually under audit pressure, and usually after someone has already spent a quarter preparing for a standard that was never in scope.

Eight weeks is enough to do the scoping properly. It is not enough to do the scoping twice.

One question before you go: how many of the eight have you confirmed apply to your entity?

One click. And if you have a view on why, reply — we read everything.

The Editors hold no position in any company mentioned.

— The CFO Desk
[email protected] · thecfodesk.com
CAPITAL · FINANCE · LEADERSHIP