Applying the series guidance
Once the SaaS company has determined the nature of its promise, it should consider whether the AI-enabled SaaS arrangement meets the criteria to be accounted for as a series of distinct goods and services. To make this assessment, the SaaS company should evaluate whether the distinct goods and services in a contract represent separate performance obligations that are substantially the same.
For example, if a SaaS company concludes that the nature of its promise is to provide continuous access to its platform (for example, there is an unspecified quantity of service to be delivered), the SaaS company would evaluate whether each day of service is distinct and substantially the same. However, if a SaaS company concludes that the nature of its promise is to deliver a specified quantity of the underlying service (such as a specified quantity of successful AI-enabled outcomes), then the SaaS company would evaluate whether each quantity of service is distinct and substantially the same.
To qualify as a series, the distinct goods and services in the contract must also have the same pattern of transfer, such as performance obligations satisfied over time using the same measure of progress. Goods and services that meet both criteria must be combined into one performance obligation and accounted for as a series of distinct goods or services. That is, accounting for goods or services as a series is required if the specified criteria are met. This determination is important because it will affect the allocation of variable consideration and the accounting for any future contract modifications.
In general, the EY point of view is that stand-ready obligations will meet the criteria to be accounted for as a series of distinct goods or services. If the nature of the SaaS company’s promise is to deliver the underlying distinct good or service, it will need to evaluate the nature of the underlying distinct goods or services to determine whether those goods or services meet the criteria to be accounted for as a series.
Recognition of revenue in SaaS arrangements
How a SaaS company recognizes revenue in an AI-enabled SaaS arrangement will depend on the nature of its performance obligation and on how fees are structured. Here are five key considerations for how the fee structure in different types of AI-enabled SaaS arrangements could impact revenue recognition.
The promise is a stand-ready obligation
Fixed-fee arrangements
The nature of the performance obligation in an AI-enabled SaaS arrangement may be a stand-ready obligation to provide access to the software platform for a period of time. In these cases, the service is typically provided on a consistent basis from period to period, and the performance obligation is satisfied evenly. It is rare for a SaaS company whose promise is a stand-ready obligation to have a different pattern of performance.
Accordingly, revenue for a fixed-fee SaaS arrangement that is a stand-ready obligation — with no variable consideration — would be recognized ratably over the contractual period. This recognition commences on the date the service is made available to the customer, unless the SaaS company’s performance is not provided consistently from period to period.
Success-based variable fee arrangements
Alternatively, fees in an AI-enabled SaaS arrangement that is a stand-ready obligation may be structured as variable consideration. For example, the consideration in the arrangement is based entirely on successful AI-enabled outcomes from customer usage.
If the success-based fees relate specifically to the SaaS company’s efforts to satisfy the performance obligation to provide access to the platform or to a specific outcome from satisfying its performance obligation, the consideration should be allocated to the period in which the successful AI-enabled usage occurred (assuming that this allocation is consistent with the allocation objective in the standard).
If the success-based fees do not relate specifically to the SaaS company’s efforts to satisfy its performance obligation or to a specific outcome from satisfying its performance obligation, then the variable consideration would be estimated at contract inception and recognized ratably over the contract term. These estimates of variable consideration must be updated at the end of each reporting period.
The promise is for the underlying goods or services
If a SaaS company determined that the nature of its promise to the customer is to provide the underlying good or service — for example, successful AI-enabled outcomes — then the SaaS company should determine how to recognize revenue. This review should carefully consider the enforceable rights and obligations between the parties, including the contract duration; whether the consideration is fixed or variable; and the timing of transfer of the successful AI-enabled outcomes.
Fixed-fee arrangements
If a contract obligated the SaaS company to deliver a specified quantity of goods or services for a fixed price, and the SaaS company determined that the performance obligation was satisfied over time, the SaaS company may determine that an output measure of progress — for example, successful AI-enabled outcomes delivered — faithfully depicts the entity’s performance in transferring control of the goods or services promised to its customer.
Accordingly, revenue for a fixed-fee SaaS arrangement that is a promise to deliver a specified quantity of goods or services would be recognized based on its selected measure of progress, such as when each underlying good or service is delivered.