IAS 37 vs ASC 450: provisions and contingencies

Lawsuits, warranties and restructurings can produce different liabilities under IFRS and US GAAP for exactly the same facts. This guide compares IAS 37 with ASC 450, ASC 420 for exit costs, and works through a lawsuit with a range of outcomes.

By Awais Jameel, Chartered Accountant. Reviewed by Muhammad Bilal, Chartered Accountant. 3 minute read.

Short answer

IAS 37 vs ASC 450 differ in when a liability is recognised and how much. IFRS recognises a provision when an outflow is probable, meaning more likely than not, while US GAAP's probable means likely to occur, a higher threshold. When a range of outcomes is equally likely, IFRS uses the midpoint and US GAAP the low end. IFRS discounts provisions when material; US GAAP generally does not. Restructuring, onerous contracts and contingent assets are also treated differently.

At a glance

Probable
More likely than not (IFRS) vs likely (US)
Range, no best estimate
Midpoint (IFRS) vs low end (US)
Discounting
When material (IFRS) vs generally not (US)
Restructuring
Constructive obligation (IFRS) vs incurred (US)
Onerous contracts
General rule (IFRS) vs limited (US)
Contingent assets
Virtually certain (IFRS) vs realised (US)
IAS 37 vs ASC 450: provisions and contingenciesProbable: More likely than not (IFRS) vs likely (US); Range, no best estimate: Midpoint (IFRS) vs low end (US); Discounting: When material (IFRS) vs generally not (US); Restructuring: Constructive obligation (IFRS) vs incurred (US); Onerous contracts: General rule (IFRS) vs limited (US); Contingent assets: Virtually certain (IFRS) vs realised (US).KEY FACTS AT A GLANCEIAS 37 vs ASC 450: provisions and contingenciesProbableMore likely than not(IFRS) vs likely (US)Range, no best estimateMidpoint (IFRS) vs lowend (US)DiscountingWhen material (IFRS) vsgenerally not (US)RestructuringConstructive obligation(IFRS) vs incurred (US)Onerous contractsGeneral rule (IFRS) vslimited (US)Contingent assetsVirtually certain (IFRS)vs realised (US)Tax BakersIAS 37 vs ASC 450: provisions and contingenciesProbable: More likely than not (IFRS) vs likely (US); Range, no best estimate: Midpoint (IFRS) vs low end (US); Discounting: When material (IFRS) vs generally not (US); Restructuring: Constructive obligation (IFRS) vs incurred (US); Onerous contracts: General rule (IFRS) vs limited (US); Contingent assets: Virtually certain (IFRS) vs realised (US).KEY FACTS AT A GLANCEIAS 37 vs ASC 450: provisions andcontingenciesProbableMore likely than not (IFRS) vs likely (US)Range, no best estimateMidpoint (IFRS) vs low end (US)DiscountingWhen material (IFRS) vs generally not (US)RestructuringConstructive obligation (IFRS) vs incurred(US)Onerous contractsGeneral rule (IFRS) vs limited (US)Contingent assetsVirtually certain (IFRS) vs realised (US)Tax Bakers
Key facts at a glance, as set out in this guide.

IAS 37 vs ASC 450: what are the differences?

IAS 37 vs ASC 450 at a glanceIAS 37 vs ASC 450 at a glanceTOPICIFRSUS GAAPProbable meansMore likely than notLikely to occurRange with no best estimateMidpointLow endDiscount provisionsRequiredNot requiredGeneral onerous contract ruleRequiredNot requiredRecognise contingent assetsVirtually certainNot allowed
IFRS recognises more liabilities, at higher amounts, and sooner.
AreaIAS 37ASC 450 and related topics
Recognition thresholdProbable: more likely than notProbable: likely to occur, a higher bar
Measurement, range with no best estimateMidpoint of a continuous range of equally likely outcomesLow end of the range, with disclosure of the reasonably possible additional loss
DiscountingRequired when the effect is materialGenerally not, unless amounts and timing are fixed or reliably determinable
Restructuring costsWhen a constructive obligation exists: detailed plan and announcementASC 420: when the liability is incurred, cost by cost
Onerous contractsProvision for any onerous contractNo general requirement; specific guidance only
Contingent assetsRecognised when virtually certainGain contingencies recognised only when realised
TerminologyProvisions and contingent liabilitiesLoss contingencies, accrued or disclosed

An example: a lawsuit with a range

A company is sued. Its lawyers say a loss is quite likely, about 65%, and that damages would be anywhere between $10 million and $30 million, with no amount in the range more likely than another.

IAS 37ASC 450
Is the threshold met?Yes: more likely than notDepends on judgement: 65% may or may not be "likely"
Amount, if recognised$20 million, the midpoint$10 million, the low end, plus disclosure of up to $20 million more

The IFRS liability is twice the US one, and the US company might recognise nothing if it concludes a 65% chance is not "likely to occur".

How does restructuring differ?

Under IAS 37, a restructuring provision is recognised once a detailed plan has been announced. Under ASC 420, each cost is recognised when the liability is incurred: one-time termination benefits when the plan is communicated to employees, or over the remaining service period if they must work beyond a minimum retention period, and contract termination costs when the contract is terminated. US restructuring charges are often spread over more periods. See restructuring provisions under IAS 37.

Why are onerous contracts different?

IAS 37 requires a provision whenever the unavoidable costs of a contract exceed its benefits. US GAAP has no general onerous contract model; losses on executory contracts are recognised only where specific guidance requires it, such as certain construction or purchase commitments. See onerous contracts.

How do the disclosures differ?

Both require disclosure of contingent liabilities that are possible but not recognised, unless remote. US GAAP also requires disclosure of an estimate of the reasonably possible loss in excess of amounts accrued, or a statement that it cannot be estimated, and the SEC focuses closely on these disclosures. IFRS allows details to be withheld in extremely rare cases where disclosure would seriously prejudice the company's position in a dispute.

Where to go next

See IAS 37 explained and contingent liabilities.

Need help applying the standards?

Our Chartered Accountants help finance teams and students apply IFRS and US GAAP to real transactions.

Questions people ask

What is the difference between IAS 37 and ASC 450?

IFRS recognises a provision when an outflow is more likely than not; US GAAP requires a loss to be likely. Measurement of ranges, discounting, restructuring and onerous contracts also differ.

How is a range of outcomes measured under IFRS and US GAAP?

When no amount in a continuous range is more likely, IFRS uses the midpoint and US GAAP the low end, with disclosure.

Are provisions discounted under US GAAP?

Generally not, unless the amount and timing of payments are fixed or reliably determinable. IFRS discounts when material.

Does US GAAP have onerous contract provisions?

Not as a general rule; only where specific guidance requires losses on certain contracts to be recognised.

Sources

Every fee, date and rule on this page was taken from these official and primary sources.

  1. IFRS Foundation: IAS 37 Provisions, Contingent Liabilities and Contingent Assets
  2. FASB Accounting Standards Codification: Topic 450, Contingencies

Rules and fees change. If you are reading this long after October 4, 2026, confirm the figures with the source before you rely on them.

More in IFRS vs US GAAP

This guide is general information. It is not tax or legal advice for your situation.