Lease Terms
IFRS 16 Lease Audit Working Paper Template & Checklist — free PDF
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IFRS 16.26 — At the commencement date, a lessee shall measure the lease liability at the present value of the lease payments that are not paid at that date.
IFRS 16.23–24 — At the commencement date, a lessee shall measure the right-of-use asset at cost.
ISA 500 — Sufficient appropriate audit evidence for the lease liability as independent audit evidence.
ISA 540 — Auditing accounting estimates — applies to the IBR determination and lease term judgment.
IFRS 16 for Banking & Finance — Practical Guidance
For banks and financial institutions, IFRS 16 creates a unique intersection of accounting standards and prudential regulation. While the balance sheet impact of recognising lease liabilities is proportionally smaller for banks than for retailers or airlines (given the already large balance sheet), the regulatory capital implications are significant. Under the Capital Requirements Regulation (CRR/Basel III), ROU assets attract a 100% risk weight under the standardised approach, directly reducing Common Equity Tier 1 (CET1) capital ratios. The European Banking Authority (EBA) has issued specific guidance on the prudential treatment of IFRS 16 leases.
Measurement Considerations for Banking & Finance
Banking lease portfolios are dominated by branch premises and office space, with smaller portfolios of IT equipment, vehicles, and ATM locations. The discount rate for bank leases is particularly nuanced — while most entities struggle to determine an IBR, banks have ready access to market interest rate data and their own cost of funds. However, the IBR must reflect the specific terms of the lease (secured borrowing, similar term, similar currency), not the bank's unsecured wholesale funding cost. For branch leases, the IBR should approximate the rate the bank would pay for a secured property loan of equivalent term.
ROU Asset Depreciation for Banking & Finance
Branch network rationalisation creates ongoing lease modification accounting under IFRS 16. As banks close branches and shift to digital channels, early termination of branch leases triggers derecognition of the ROU asset and lease liability, with any gain or loss recognised in profit or loss. For leases being restructured (reduced space, shortened term), the standard lease modification accounting in IFRS 16.44–46 applies. Banks must remeasure the lease liability at the modification date using a revised discount rate.
Industry-Specific Considerations
The interaction between IFRS 16 and regulatory capital frameworks requires careful management. Under the CRR standardised approach, ROU assets receive a 100% risk weight, increasing risk-weighted assets (RWA) and reducing capital ratios. Banks using internal ratings-based (IRB) approaches must consider the appropriate treatment. The EBA has confirmed that the transitional arrangements under CRR Article 473a (which mitigate the CET1 impact of IFRS 9 expected credit losses) do not extend to IFRS 16. Banks should also consider the impact on the leverage ratio, where ROU assets increase the total exposure measure.
Worked Example: 10-Year Bank Branch Lease
A retail bank leases a branch premises for 10 years commencing 1 January 2025. Monthly rent is €15,000 payable in arrears. The bank determines an IBR of 3.8% based on its secured property borrowing rate adjusted for lease term. Initial direct costs (legal, due diligence) total €12,000. The bank estimates restoration costs of €45,000 to reinstate the premises at lease end.
Audit Considerations
Bank auditors should consider the interaction between IFRS 16 and regulatory capital when assessing materiality. Errors in lease liability measurement directly affect CET1 ratios, which are subject to regulatory minimum requirements. ISA 250 (Revised) requires consideration of laws and regulations, including prudential requirements. Engagement teams should coordinate with regulatory capital specialists when auditing significant lease portfolios.