Ind AS 114 is available only to a first-time adopter of Ind AS that recognised regulatory deferral account balances under its previous GAAP, and it permits those balances — the right to recover, or obligation to repay, amounts from customers resulting from rate regulation — to continue to be recognised using previous GAAP accounting policies, subject to minor adjustments; it is not available to an entity adopting it on a standalone basis without that prior recognition. The audit must first confirm eligibility actually exists before testing any balance recognised under it.
What to test on each regulatory deferral account balance
- 01Trace the balance to the specific tariff order or regulatory determination creating itA deferral balance representing a cost the regulator has agreed the entity may recover in a future tariff period must be supported by that regulator's actual order, rate schedule, or similar binding determination — not management's own projection of a future tariff outcome that has not yet been approved.
- 02Test the movement for the periodAdditions, amounts recovered/repaid during the period, and any impairment of the right to recover should each be separately tracked and reconciled to actual billing and collection data where recovery has started.
- 03Assess recoverability where the regulatory framework has changedA change in tariff policy, a new regulator, or a dispute over the recoverability of a previously recognised balance is an impairment indicator requiring an explicit recoverability assessment, not a roll-forward of the prior year balance unchanged.
- 04Confirm presentation is separate from other assets/liabilitiesRegulatory deferral account debit and credit balances are required to be presented as separate line items, not merged into other receivables or provisions, and the related movement in profit or loss is also required to be shown as a separate line.
This is practical guidance written for audit teams, not an authoritative statement of any standard or statute. Standards, forms and timelines change. Check the current text issued by the ICAI and the relevant authority before relying on anything here in an audit file.
Related resources
- Audit documentationInd AS 1: presentation of financial statements, and what a complete set actually requiresFour statements plus notes isn't optional structure — Ind AS 1 defines exactly what counts as a complete set, and a financial statement missing one piece isn't compliant regardless of how good the other three look.
- Audit documentationInd AS 37: provisions, contingent liabilities and contingent assets — the three-way splitThree categories, three completely different treatments — recognise it, disclose it, or say nothing. Getting the category wrong is the whole misstatement.
- Audit workflow & automationSA 540: auditing accounting estimates, where judgment replaces a verifiable numberAn estimate can't be vouched to a source document the way an invoice can. SA 540 is about what replaces vouching when there's no single right answer to check against.
- Audit documentationInd AS 20: government grants, and why they're never recognised as equityA grant is income, recognised over the period it's meant to compensate for — not a windfall credited to reserves the day it's received.
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