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Pre-Audit Self-Assessment for ASC 842 Compliance

John J. Meedzan

Co-Founder and Managing Partner, iLease Management LLC

Questions this article answers

  • What is a pre-audit self-assessment for ASC 842 compliance?
  • What steps are involved in an ASC 842 pre-audit self-assessment?
  • How can I prepare for an ASC 842 audit?
  • What are the common challenges during an ASC 842 pre-audit self-assessment?
  • How does a pre-audit self-assessment improve ASC 842 compliance?

Complete Your ASC 842 Pre-Audit Evaluation

A pre-audit self-assessment is a review a company runs on itself. It tests the same assertions an auditor will test, while there is still time to fix what it finds. ASC 842, Leases, made a major change in how companies account for their leases: most leases now sit on the balance sheet. That shift brought new disclosure requirements, more complex calculations, and closer scrutiny from auditors. A sound pre-audit self-assessment shows that the company has applied ASC 842 correctly and is ready for the external audit.

Skip the review, and the company risks material misstatements, audit delays, and findings of non-compliance. Those can hurt financial reporting and investor confidence. Done early, the review finds and fixes issues before they become costly audit exceptions. That means a smoother ASC 842 audit process and confirms that the financial disclosures are complete.

For a complete breakdown, see our ASC 842 compliance guide.

What Auditors Assess in an ASC 842 Audit

Auditors approach an ASC 842 audit with a focus on a few key assertions, mainly completeness, accuracy, and presentation. They want to know that every lease has been identified and recorded. They also want the financial statements to show the entity's lease obligations and rights-of-use as they truly are. In an audit of a public company, PCAOB standards require the auditor to evaluate whether "the accounting principles selected and applied by the company's management are appropriate in the circumstances" (PCAOB AS 2810.30A). A private company's audit is not conducted under PCAOB standards, but its auditor tests the same lease assertions, because ASC 842-20-50-1(b) requires the entity to disclose the significant judgments made in applying the standard.

✅ Best Practice: Auditors expect a well-documented process for lease identification, classification, measurement, and disclosure. That means a detailed audit trail for every lease decision.

In practice, auditors perform lease audit procedures to test:

  • Completeness: Have all leases, including embedded leases, been identified?
  • Accuracy: Are lease liabilities and right-of-use (ROU) assets correctly calculated and measured?
  • Classification: Are leases properly classified as operating or finance leases?
  • Disclosure: Are all required ASC 842 disclosures complete and accurate?
  • Controls: Are internal controls over lease accounting designed and operating effectively?

Deloitte's Roadmap: Leases notes that "readily determinable" is a high threshold for the rate implicit in the lease, so most lessees fall back on the incremental borrowing rate, and that using a single rate across all leases would generally be inappropriate. Auditors look hard at the method used to identify leases and to set key inputs such as discount rates 1. They expect to see evidence of strong internal controls across the whole lease lifecycle.

Key Audit Focus Areas

Audit AreaAuditor's ObjectiveEvidence Reviewed
Lease IdentificationVerify all contracts containing a lease are capturedContract inventory, contract review policies, system outputs
Lease ClassificationConfirm correct operating vs. finance lease determination (ASC 842-10-25-2)Lease schedules, classification templates, management judgments
MeasurementAssess accuracy of ROU assets and lease liabilitiesDiscount rate support, payment schedules, remeasurement calculations
DisclosureEnsure compliance with the lessee disclosure requirements of ASC 842-20-50 2Financial statement footnotes, MD&A, management representations
System & ControlsTest whether the lease accounting system and related controls workSystem access logs, control narratives, exception reports

Q: How do auditors test pre-audit self-assessment?

A: Auditors will typically review the organization's self-assessment documentation, test key controls identified during the assessment, and sample calculations and judgments to confirm their accuracy and completeness, comparing outcomes to ASC 842 requirements.

The Cost of Skipping a Pre-Audit Self-Assessment

Skipping a thorough pre-audit self-assessment exposes a company to real risk. One of the most common is an incomplete lease population: leases the company never identified. Ask "what are the risks of incomplete lease population?" and the answer is not just financial misstatement. It is also a breakdown in internal controls and a possible restatement.

⚠️ Risk Alert: A common audit finding: the company overlooked service contracts with embedded leases, so its lease liabilities and ROU assets are understated.

Here are concrete risks and why they matter:

  • Incomplete Lease Identification: This may be the greatest risk. If contracts that contain leases are missed, all of the ASC 842 financial reporting is incomplete and inaccurate. That goes straight to the completeness assertion: the auditor's aim to verify that every transaction and account that should be recorded is in the financial statements.
  • Incorrect Discount Rate Application: Pick the wrong incremental borrowing rate, or fail to document the inputs, and you can get material miscalculations of lease liabilities and ROU asset audit values. Under ASC 842, a right-of-use (ROU) asset is an asset that represents a lessee's right to use an underlying asset for the lease term (ASC 842 Master Glossary).
  • Embedded Lease Oversight: Many contracts that are not labeled as leases, such as service, supply and outsourcing agreements, convey the right to control the use of an identified asset, and under ASC 842-10-15-3 a contract that conveys that right for a period of time in exchange for consideration is or contains a lease. Skip embedded lease discovery and large omissions follow. An embedded lease is a lease component inside a larger contract that may not be explicitly identified as a lease.
  • Inadequate Documentation: Without clear, auditable documentation of judgments (e.g., lease term, optional payments, discount rates), auditors cannot easily verify management's conclusions. The result is a long list of audit questions and possible adjustments.
  • Ineffective Internal Controls: Controls over the lease accounting process may be poorly designed or not operating. Either one can lead to calculation errors, data integrity issues, and a higher risk of material misstatement.

Example Scenario: Missed Embedded Leases

Scenario: A manufacturing company has a contract with an IT vendor for managed services. The contract says the vendor will provide dedicated servers at the client's premises, and the client has the right to control how those servers are used, including changing operating parameters. The accounting team at first recorded this only as an IT service expense. The servers are an identified asset dedicated to this client, so the client obtains substantially all of the economic benefits from their use (ASC 842-10-15-4(a)). The client can also direct how they are used, so it has the right to direct their use (ASC 842-10-15-4(b)). Both are required. That second fact separates this contract from ASC 842-10-55 Example 10 Case A, where the supplier retains that right and no lease exists.

ComponentIssueAudit Impact
Contract ReviewNo formal process for embedded lease reviewSignificant gap in completeness.
Lease IdentificationDedicated servers not identified as an assetUnderstated ROU assets and lease liabilities.
Financial ReportingExpensed services rather than capitalizedMisstated balance sheet and income statement; if the embedded lease is a finance lease, the statement of cash flows is also misclassified, because ASC 842-20-45-5 puts finance lease principal in financing activities while operating lease payments stay in operating activities.
Total ImpactMaterial MisstatementRequired audit adjustments, potential restatement, control deficiencies identified.

Key Takeaway: Reviewing contracts for embedded leases before the audit is essential. That often means working with the procurement and legal departments.

Practical Checklist for Pre-Audit Self-Assessment

To prepare well for an ASC 842 audit, a company should follow a set structure. The pre-audit self-assessment is a detailed review of processes, contracts, and calculations.

💡 Key Takeaway: A full pre-audit self-assessment finds and fixes likely issues early, which cuts audit effort and findings sharply.

What should I include in my ASC 842 audit readiness checklist?

A sound ASC 842 audit readiness checklist should cover lease identification, classification, measurement, and disclosure. It should also assess internal controls and documentation practices. This structured review follows the guidance on how to ensure lease completeness for ASC 842 compliance.

Pre-Audit Self-Assessment Checklist

Checklist ItemAction RequiredDocumentation / Evidence
1. Lease Population CompletenessBuild and carry out a plan to review every contract.Contract inventory, review log, embedded lease policy.
2. Lease Data CaptureMake sure every critical lease data point is captured correctly in one central system.Lease abstract templates, lease accounting system data.
3. Lease Classification ReviewReview every lease again for proper operating vs. finance classification.Classification matrix, narrative of judgments.
4. Discount Rate ValidationDocument the discount rate conclusion for each lease: whether the rate implicit in the lease was readily determinable, the incremental borrowing rate inputs if it was not, and, for a lessee that is not a public business entity, any risk-free rate election, which ASC 842-20-30-3 makes by class of underlying asset.Rate calculations, external support for rates, internal policy.
5. ROU Asset & Lease Liability CalculationVerify calculations for initial measurement and subsequent remeasurements (ASC 842-20-25-1, ASC 842-20-30-1, ASC 842-20-35-4).Lease schedules, reconciliation to GL, calculation models.
6. Journal Entry VerificationConfirm all lease-related journal entries are accurate and timely.JEs, supporting workings, recurring entry schedules.
7. Disclosure PreparationDraft and review all required ASC 842 financial statement disclosures.Disclosure checklist, draft footnotes, management review.
8. Internal Control AssessmentEvaluate design and operating effectiveness of controls over lease accounting.Control narratives, process flowcharts, control testing results.
9. Policy & Procedures UpdatesMake sure lease accounting policies and procedures reflect ASC 842 requirements.Updated accounting policies, training materials.

An ASC 842 close process checklist can make your self-assessment more complete.

Testing the Self-Assessment, Not Just Completing It

Validation is what makes a pre-audit self-assessment work. It goes beyond filling in a checklist; it means testing the output, and the processes behind it, in depth. For lease identification audit purposes, the accounting team must provide proof, which an auditor can verify, that its method is sound.

🚨 Critical: Failing to validate the lease population or key calculations well enough is a frequent cause of auditor findings and adjustments.

Validation Steps and Documentation

  1. Reconciliation to General Ledger (GL): Reconcile the lease accounting system's outputs to the general ledger accounts for ROU assets, lease liabilities, interest expense, and amortization. Investigate and fix every difference. This step often turns up data entry or system setup errors.
  2. Sample Testing of Lease Data: Pick a representative sample of leases, including those with complex features or large values. Re-perform the calculations for initial measurement, modifications, and remeasurements. This confirms that the underlying data is accurate and that the accounting policy was applied.
  3. Review of Key Judgments: Document and critically review every significant judgment made: lease term, optional periods, discount rates, and whether a contract has an identified asset and control over it (the test that finds embedded leases in contracts). That means challenging the assumptions behind each judgment. FASB ASC 842-10-15 sets out the criteria for identifying a lease.
  4. Cross-functional Interviews: Talk to the people in procurement, legal, and operations. Learn how they manage contracts, and look for any possible leases that never reached central accounting. This matters most for identifying embedded leases.
  5. Benchmarking Disclosures: Compare the draft ASC 842 disclosures with the public filings of peer companies to check for completeness and industry-standard presentation. This lines up with the ASC 842 disclosure requirements.
  6. Control Walkthroughs: Walk through the key internal controls over lease accounting to confirm they are designed properly and operate as intended. This also gives auditors evidence that the controls are effective.

For more on sound validation, see the guides on how to ensure lease completeness for ASC 842 compliance, especially the one on audit readiness.

Underestimating the Time a Self-Assessment Takes

Even with hard work, a few common pitfalls get in the way of a good pre-audit self-assessment. Knowing these mistakes helps you avoid them early, which helps the whole lease accounting compliance effort.

📢 Warning: Many companies underestimate the time and resources a full pre-audit self-assessment needs. The result is rushed work and missed issues.

Q: What documentation is required for pre-audit self-assessment for asc 842 compliance?

A: Required documentation includes a complete lease contract inventory, lease abstracts, classification narratives, discount rate policies, remeasurement calculations, general ledger reconciliations, and draft financial statement disclosures.

Common Mistakes vs. Best Practices

Common MistakeExplanation / ImpactBest Practice
1. Underestimating ComplexityBelieving ASC 842 is only a balance sheet presentation change.Recognize the full impact on systems, processes, and people; allow enough resources.
2. Inadequate Lease InventoryRelying on existing fixed asset lists or general ledger accounts.Run a thorough, bottom-up review of every contract across the company with legal and procurement input.
3. Manual Spreadsheets for CalculationsHigh risk of error, no audit trail, hard to manage remeasurements.Use lease accounting software built for the task, so calculations and reporting are automated.
4. Ignoring Embedded LeasesMissing leases within service or supply contracts.Set up a formal process to find and review every contract for embedded leases.
5. Lack of Cross-Functional CollaborationAccounting team working on its own, apart from procurement, legal, and operations.Have the relevant departments talk regularly and run joint reviews.
6. Poor Documentation of JudgmentsArbitrary lease terms or discount rates without clear rationale.Document every significant judgment, with its assumptions, inputs, and reasons, for audit review.
7. Delayed Disclosure PreparationWaiting until year-end to draft footnotes.Prepare disclosures every quarter or half-year to find data gaps early.

Q: What findings does a pre-audit self-assessment usually surface?

A: Common audit findings include undisclosed embedded leases, incorrect discount rate application, errors in calculating ROU assets or lease liabilities, and insufficient documentation of management's judgments, highlighting the need for vigilance.

For more on avoiding these common errors, see the top 10 year-end lease accounting challenges.

Signs Your Self-Assessment Is Working

Companies that do the pre-audit self-assessment well share a few traits that make the external audit go faster. Strong execution means fewer auditor questions, fewer audit adjustments, and in the end a faster, less stressful audit cycle.

✅ Best Practice: Early engagement with auditors and a transparent, well-documented process are the marks of strong lease accounting compliance.

A well-run self-assessment means the accounting team has already worked out what the auditors will ask and has the evidence ready. That includes:

  • Comprehensive Lease Data: One central, accurate, up-to-date record of every lease and its critical data points.
  • Automated Calculations: Using lease accounting software for accurate, auditable calculations of ROU assets, lease liabilities, interest, and amortization.
  • Robust Internal Controls: Controls over lease data input, classification, measurement, and reporting that are in place and operate the same way every time.
  • Detailed Documentation: All judgments (e.g., lease term, discount rates, short-term lease elections) are clearly stated and supported.
  • Proactive Issue Resolution: Finding and fixing differences or complex accounting issues before the auditors arrive.

Example: A Pre-Assessment Success Story

Illustration (hypothetical): suppose a manufacturer's review of every service contract surfaces embedded leases that had never been recorded. The company puts in ASC 842 software and assigns a cross-functional team to its pre-audit self-assessment, starting well before the year-end audit. The team reviews every contract, records the embedded leases, and documents the key judgments.

  • Outcome 1: The embedded leases in service contracts are recorded, and the adjustment to ROU assets and lease liabilities is booked before the audit rather than as an audit finding.
  • Outcome 2: The auditors can test complete, accurate lease data against supporting documentation.
  • Outcome 3: Audit time spent on lease accounting goes to testing rather than to chasing missing leases and undocumented judgments.

The illustration shows that strong lease accounting compliance takes more than applying the standard. It also takes a plan for getting ready and for ongoing management.

Turning the Self-Assessment Into an Annual Routine

To improve your pre-audit self-assessment and build a sound audit readiness plan, measure your current processes against industry best practices. Ongoing team training on the finer points of ASC 842, plus the right tools, can improve both speed and accuracy. Talking with the auditors early can also bring useful insight and cut last-minute surprises.

Related Articles

Sources and further reading

  1. Deloitte, Roadmap: Leases, 7.2 Determination of the discount rate ↩

  2. Deloitte, Roadmap: Leases, Chapter 15 Disclosure ↩