Subsequent Events in 2026: ASC 855 Type I vs Type II With Disclosure Playbook
Decision Tree
Condition at BS date? → Yes → Adjust (e.g., AR collectability info, settlement confirming estimate). Arose after? → Disclose if material (e.g., fire, acquisition, financing).
Pair with Year-End Close, Going Concern, PBC, and Related Party.
Date Discipline
- Lock subsequent review to report date, not fieldwork end.
- Re-perform cash tie to issuance — see Bank Rec.
- Update debt/covenant memo — see Debt.
- Representation letter dated to report — retain per Audit Procedures.
Disclosure Draft
Nature, date, amount or range, and action. Coordinate with Audit Committee before issuance.
Type I vs Type II: Worked Cases
| Event | Type | Treatment |
|---|---|---|
| Major customer files bankruptcy Feb 10; year-end Dec 31; AR was already doubtful with partial reserve | Type I | Adjust: bankruptcy confirms the year-end collectability estimate — true-up the reserve, don’t just disclose |
| Warehouse fire destroys inventory Jan 22, after year-end | Type II | Disclose: condition (fire) arose after BS date; no adjustment, describe loss range if estimable |
| Lawsuit settled Feb 15 for $400k where year-end accrual was $250k on same claim | Type I | Adjust to $400k — settlement evidences the year-end obligation |
| Series B closes Feb 28 at 3× prior valuation | Type II | Disclose: material capital event; no adjustment to year-end equity |
| Fraud discovered in March in year-end revenue | Type I | Adjust and expand scope: restatement risk, control failure — see Fraud Prevention |
The dating question decides everything: did the underlying condition exist at the balance-sheet date, or did it arise after? Document the timeline explicitly in the memo — “existed at” vs “arose after” with evidence dates — because auditors will re-perform this judgment.
Procedures Calendar (Through Report Date)
| Procedure | When | Evidence |
|---|---|---|
| Minutes (board + committees) to issuance | Weekly sweep | Signed minutes or drafts with review note |
| Subsequent cash receipts/disbursements | To report date | Bank activity tie — see Bank Rec |
| Debt/equity changes, waivers, covenants | To report date | Agreements, waiver letters — see Debt |
| Litigation updates from counsel | Inquiry letter + update calls | Counsel responses |
| Management representation letter | Dated to report date | Signed, aligned to report |
The classic failure: fieldwork ends March 10, report issues March 28, and nothing in the file covers March 10–28. A covenant breach or lost customer in that window with no procedure is a review note at best and a reporting failure at worst. Schedule the subsequent sweep as a calendar event on the report date itself — see Q1 Prep.
Disclosure Drafting That Satisfies Review
Each disclosed event gets four lines: nature (what happened), date (when), amount or range (or “not yet determinable — why”), and action (what management is doing). Coordinate wording with counsel and the audit committee before issuance — see Audit Committee. Vague boilerplate (“the Company is monitoring events”) with a material unquantified acquisition draws comments; a dated, quantified note with the financing terms does not.
FAQ
Do interim periods need subsequent review?
Yes to report date for each issuance — scale procedures to risk.
What is the fastest miss?
Unreviewed minutes and cash after fieldwork. Run to issuance.
Next Steps
- Calendar subsequent procedures to report date now.
- Freeze disclosure draft with counsel/auditor.
- File evidence to issuance, not year-end.