A checklist to prepare for the FRS 102 amendments

Before diving into the technicalities of the amendments to FRS 102, I recommend taking a step back to establish a robust conversion project plan. It should cover all affected areas and stakeholders across your business, rather than focusing solely on the finance function.
 
This will allow you to:

• prioritise actions effectively, ensuring critical tasks receive timely attention and nothing falls through the cracks.
• clarify how individual activities are interdependent, helping you to spot where delays or complications in one area may impact progress elsewhere.
• more easily identify where extra resource or specialist input is needed, whether in-house or from external advisers.

The first step to preparing this conversion project plan is to understand what the updates mean for your business. The changes will have the most impact on earnings before interest, tax, depreciation and amortisation (EBITDA), but they will create waves far beyond the debts and credits.

If you haven’t explored all of these areas yet, you’re in good company. Our April 2026 survey of 500+ UK CFOs shows many are still only part way through assessing the full breadth of the amendments. Only 3% tell us they have already assessed every area.

At a high-level, the impacts span six areas:

• Debt covenants based on EBITDA or interest cover
• Earn-out calculations due to be paid post 1 January 2026
• Employee incentive schemes based on EBITDA
• Delivery and pricing structure of long-term revenue contracts
• Budgeting and forecasting systems and approach
• Intercompany trading balances and transfer pricing

Once you are clear on which parts of your business will be most impacted, the next step is to assess your current readiness with a conversion impact assessment. 

Use the checklist below to understand where you are in the process and identify outstanding actions to prioritise:

The checklist above should cover the fundamentals. If you can check them off, you will have led a well-managed, compliant transition. But a robust project plan should aim to do more than just ‘remain compliant’.

The FRS 102 amendments also offer an opportunity to sharpen your finance function’s system capabilities and processes.

Reflect on:

• Are your forecasting and management information truly giving you what you need to drive decisions?
• Could you make better use of lease accounting software or other automation tools streamline the process and free up your team’s time for more value-add activities, and less manual reconciliations?
• Are there any opportunities to simplify or align accounting treatments across entities for greater consistency and insight?

Having approached the amendments through this broader business lens, you can factor changes directly into your conversion project plan; embedding improvements that deliver long-term efficiency, not just compliance.

For businesses scaling through acquisitions, this is also a key point in time to proactively strengthen group governance, ensuring consistent application of accounting policies across entities and addressing challenges in integrating newly acquired entities with limited lease data to avoid future audit friction.

A robust project plan is the foundation for a successful transition under the first year of the FRS 102 amendments. By actively engaging all stakeholders throughout the journey - from sales teams to procurement to your external auditors, you build alignment, foster transparency, and minimise the risk of unwelcome surprises at the finish line.

While no plan can predict every twist and turn, a well-structured approach will ensure you have the space to adapt, respond proactively, and keep your objectives on track, even when the unexpected arises.

Clear ownership for post‑implementation reviews, judgement updates and future compliance should also be agreed before go‑live, so FRS 102 doesn’t become a one‑off project but a sustainable, repeatable process.