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 in South Africa — IFRS 16 (as adopted by FRSC)
South Africa adopted IFRS 16 through the Financial Reporting Standards Council (FRSC), effective for annual periods beginning on or after 1 January 2019. South Africa applies IFRS as issued by the IASB without modification for companies listed on the Johannesburg Stock Exchange (JSE) and other public interest entities. The Independent Regulatory Board for Auditors (IRBA) oversees audit quality, while the JSE sets listing requirements that include financial reporting obligations. South Africa's higher interest rate environment (relative to European markets) significantly impacts IFRS 16 lease liability measurements.
Regulatory Context — Independent Regulatory Board for Auditors (IRBA) / Johannesburg Stock Exchange (JSE)
The IRBA has included IFRS 16 in its audit inspection focus areas. Key IRBA findings include: insufficient challenge of management's IBR in a volatile interest rate environment, inadequate consideration of the impact of South African exchange controls on foreign currency leases, and insufficient documentation of lease term judgments for commercial and industrial properties. The JSE has issued guidance on IFRS 16 disclosure expectations for listed entities.
Practical Guidance for South Africa
For South African entities, the IBR must reflect the significantly higher interest rate environment compared to European markets. Reference SA Government bond yields (R186, R2048 benchmarks) for the risk-free component, plus entity-specific credit spreads. The South African Reserve Bank (SARB) repo rate provides the policy rate anchor. Commercial property leases in South Africa typically run for 3–10 years with escalation clauses of 7–10% per annum (reflecting historical inflation). These high escalation rates create substantial lease liabilities when future escalated payments are included in the present value calculation.
Audit Expectations
South African registered auditors follow ISA as adopted by the IRBA. IRBA inspection findings have highlighted the unique challenges of IFRS 16 in the South African context, including the impact of high discount rates on lease liability sensitivity, the treatment of load-shedding equipment leases (generators, UPS systems), and the assessment of BEE (Black Economic Empowerment) implications of significant lease commitments.
South Africa-Specific Considerations
South Africa-specific considerations include the B-BBEE (Broad-Based Black Economic Empowerment) implications of significant lease portfolios. The ownership element of the B-BBEE scorecard may be affected by IFRS 16 changes to total assets and equity. The South African tax treatment of leases is governed by the Income Tax Act 58 of 1962 — Section 11(a) allows deduction of lease payments incurred in the production of income. IFRS 16 does not change the tax treatment. For South African entities with USD-denominated leases (common for equipment imported from the US), the IAS 21 foreign currency retranslation of the lease liability at each reporting date creates P&L volatility given ZAR/USD exchange rate movements.
Common Inspection Findings
IBR not adequately assessed in the context of SARB rate changes and ZAR yield curve
High annual escalation clauses (7-10%) not correctly modelled in lease liability calculations
Load-shedding equipment leases (generators, UPS) not included in lease population
Foreign currency lease liabilities (USD-denominated) not retranslated at reporting date
B-BBEE implications of IFRS 16 balance sheet changes not considered