Read this article if you are responsible for preparing or reviewing governmental financial statements for governmental agencies.
The Governmental Accounting Standards Board (GASB) issued Statement No. 105, Subsequent Events to enhance the transparency, consistency, and value of financial reporting related to events that occur after the financial statement date, but before the financial statements are issued. The statement realigns existing guidance by clearly describing the subsequent events' time frame, distinguishing between recognized and non-recognized subsequent events, and providing specific disclosure requirements.
Why GASB issued Statement No. 105
Preceding guidance on subsequent events existed within the GASB literature. However, governmental entities and auditors sometimes differed in their determination of what events should be recognized in the financial statements and what should be disclosed in the notes to the financial statements. Also, there were differing interpretations regarding how long subsequent events should be evaluated. As a result, GASB 105 seeks clarity by establishing clear definitions and precise disclosure requirements, with the intention of improving comparability and transparency for financial statement readers.
Defining subsequent events and the evaluation period
GASB 105 clearly defines subsequent events as transactions or other events that occur after the date of the financial statements, but before the financial statements are available to be issued.
The guidance defines the date the financial statements are available to be issued as the date when:
- The financial statements are complete in form and format that comply with generally accepted accounting principles
- All approvals necessary for issuance have been obtained
This clarification is important because it provides an endpoint for evaluating subsequent events across all governmental entities. GASB 105 also stipulates that governmental entities disclose the date through which subsequent events were evaluated, providing financial statement readers more transparency pertaining to the scope of management review.
Recognized and non-recognized subsequent events
A critical feature of GASB 105 is the clear distinction between recognized and non-recognized subsequent events.
Recognized subsequent events are those that provide additional context about conditions that existed as of the financial statement date. These occurrences impact amounts or estimates reported in the financial statements, and therefore, require adjustments to the financial statements.
Examples may include the following:
- Information received after year-end that confirms the impairment of an asset that existed at the financial statement date
- Outcome of litigation that provides additional evidence about conditions present at year-end
In these cases, the financial statements should be adjusted to reflect the new information.
Non-recognized subsequent events are events that relate to conditions that came about after the financial statement date. These events do not impact the amounts reported in the financial statements for the period being reported. However, it may still be important to financial statement readers.
Examples may include:
- Issuance of long-term debt after year-end
- Major natural disasters occurring after the financial statement date
- Government combinations or disposals completed after year-end
Although these events are not recognized in the financial statement, GASB 105 requires that significant non-recognized subsequent events be disclosed in the notes to the financial statements.
Disclosure requirements for non-recognized events
For non-recognized subsequent events that are significant, GASB 105 requirements specify that the following be disclosed:
- A description of the nature of the event
- An estimate of the financial effect, if such an estimate can be made
- A statement that an estimate cannot be made, if applicable
These disclosure requirements are intended to help financial statement readers receive relevant information about occurrences that could impact their understanding of a government’s financial position or future operations.
What GASB 105 means for governments
Although GASB 105 provides new recognition or measurement concepts, it may require governmental entities to revisit existing financial reporting practices. Specifically, governmental entities should seek to evaluate whether their financial statement preparation, review, and approval processes clearly identify the point at which financial statements are issued. In most cases, internal policies or governing body approval practices may need clarification to provide consistent application of the subsequent events evaluation period.
Governmental entities should help ensure that staff responsible for financial reports understand the distinction between recognized and non-recognized subsequent events and are prepared to identify and document events occurring throughout the evaluation process. The use of an implementation checklist could aid in this process.
What to avoid when implementing GASB 105
As governments implement GASB 105, several common pitfalls may arise:
- Assuming the audit report date defines the subsequent events evaluation period
- Failing to disclose the date through which subsequent events were evaluated
- Treating all subsequent events as disclosure-only items
- Having inadequate documentation supporting the classification of events as recognized or non-recognized
Effective date and transition
The requirements of GASB 105 are effective for fiscal years beginning after June 15, 2026, and for all reporting periods thereafter. Earlier application is encouraged.
Governmental entities that are considering early adoption should evaluate their financial reporting timelines and approval processes so they can appropriately identify and assess subsequent events through the newly defined “available to be issued” date.
Audit considerations
GASB 105 may impact audit planning by extending the period through which subsequent events must be evaluated and documented. Early communication between management and auditors can help support expectations related to timing, documentation, and disclosure of subsequent events.
Governance and oversight implications
Since subsequent events may involve significant financing decisions, legal matters, or operational changes, GASB 105 has implications beyond the accounting function. Governing bodies and oversight officials should be aware that events occurring after year-end but before financial statements are issued may still require evaluation and disclosure. Clear communication between management, governing bodies, and auditors can help ensure that significant events are appropriately identified, evaluated, and disclosed in a timely manner.
Plan for implementation
GASB 105 represents a meaningful refinement of subsequent events guidance for governmental entities. By defining the evaluation period, distinguishing between recognized and non-recognized events, and standardizing disclosure requirements, the statement enhances the usefulness and consistency of governmental financial reporting. Government entities should begin planning now for smooth implementation.
BerryDunn’s team of governmental professionals is well-versed in helping entities implement new GASB standards. We can assist with assessing current processes for identification and evaluation of transactions or other events occurring during the subsequent events' time frame. We can also update financial statement templates so that the required subsequent event note disclosures are included. Contact us to learn how we can support you in preparing for the implementation of GASB 105. Learn more about our team and services.