What Is IAS 38?
IAS 38 Intangible Assets is the International Accounting Standard that prescribes how companies recognise, measure, and disclose intangible assets in their financial statements. It applies to all intangible assets except those specifically dealt with by other standards — such as goodwill arising from business combinations (covered by IFRS 3), financial assets, mineral rights, and insurance contracts.
IAS 38 has been in force since 1998, with amendments in 2004 aligning it with the broader IFRS framework. For over two decades it has been the primary standard governing intangible asset accounting globally — and for over two decades, practitioners have debated whether its recognition criteria are fit for purpose in an economy where intangible investment far exceeds tangible.
IAS 38
Intangible Assets standard (effective since 1998)
3
recognition criteria must be met
£185.5B
UK intangible investment (2021) — mostly expensed
★ Key Takeaway
IAS 38 sets a high bar for recognising intangible assets on the balance sheet. Most internally generated intangible assets — including brands, customer relationships, and human capital — do not qualify for recognition, creating a systematic gap between reported book value and economic reality.
The Three Recognition Criteria
Under IAS 38, an intangible asset is recognised on the balance sheet only if it meets all three of the following criteria simultaneously:
1. Identifiability
The asset must be identifiable — either separable (capable of being sold, transferred, or licensed independently) or arising from contractual or legal rights. This distinguishes intangible assets from goodwill, which is not identifiable.
2. Control
The entity must have the power to obtain the future economic benefits flowing from the asset and restrict others' access to those benefits. Control usually arises from legal rights (patents, copyrights) but can also arise from other means.
3. Future economic benefits
It must be probable that the expected future economic benefits attributable to the asset will flow to the entity, and the cost of the asset must be measurable reliably.
Why the criteria are difficult to meet
The control criterion is the most challenging for many intangible assets. Consider:
- Human capital — a company cannot control its employees; they are free to leave. Therefore, workforce expertise and training investment cannot be recognised as an asset under IAS 38 (unless acquired in a business combination as part of a broader contract)
- Customer relationships — without a binding contract, the entity lacks sufficient control over the customer to recognise the relationship as an asset
- Brand equity — internally generated brands are specifically prohibited from recognition under IAS 38 (paragraph 63), even when they clearly generate economic value
✔ Example
A technology company invests £5M annually in employee training, building deep expertise in AI and machine learning. This investment creates significant competitive advantage and drives revenue growth. Under IAS 38, none of this investment is capitalised — it is expensed as incurred. The company's balance sheet shows no asset, yet the economic value of this workforce capability may exceed the company's tangible assets.
How Intangible Assets Are Measured
For assets that meet the recognition criteria, IAS 38 prescribes different measurement rules depending on how the asset was obtained.
Separately acquired intangible assets
When an intangible asset is purchased in an arm's-length transaction, it is initially measured at cost — the purchase price plus any directly attributable costs of preparing the asset for its intended use.
Intangible assets acquired in a business combination
Under IFRS 3, intangible assets acquired in a business combination are measured at fair value on the acquisition date. This is the more complex measurement and typically requires specialist valuation using methods such as Relief-from-Royalty, MPEEM, or the Cost Approach.
Internally generated intangible assets
This is where IAS 38 is most restrictive. The standard divides internal generation into two phases:
Research Phase
- All expenditure is expensed as incurred
- No capitalisation permitted
- Includes: original investigation, search for alternatives, formulation of options
Development Phase
- Expenditure is capitalised if all six criteria are met
- Otherwise expensed
- Includes: design, construction, testing of prototypes and production systems
The Six Development Capitalisation Criteria
For development expenditure to be capitalised as an intangible asset, the entity must demonstrate all six of the following:
| # |
Criterion |
Practical Meaning |
| 1 |
Technical feasibility |
The project can be completed to a usable state |
| 2 |
Intention to complete |
Management intends to finish and use or sell the asset |
| 3 |
Ability to use or sell |
The entity has the resources and capability to deploy it |
| 4 |
Future economic benefits |
There is a market or internal use that will generate returns |
| 5 |
Adequate resources |
Financial and technical resources are available to complete development |
| 6 |
Reliable cost measurement |
Expenditure attributable to the asset during development can be measured reliably |
Practical application to software development
Software capitalisation is the most common application of the development capitalisation criteria. The challenge is determining when a project transitions from research to development.
ℹ Note
In practice, many companies either over-capitalise (capitalising speculative R&D to inflate assets) or under-capitalise (expensing everything to be conservative). Neither approach complies with IAS 38. The standard requires a genuine assessment of whether the six criteria are met, documented at the time the determination is made — not retrospectively.
What cannot be capitalised
IAS 38 explicitly prohibits the capitalisation of:
- Internally generated brands — even if the brand has significant market value
- Internally generated mastheads — newspaper and magazine titles
- Internally generated customer lists — even if compiled at significant cost
- Internally generated goodwill — by definition not identifiable
- Start-up costs — costs of establishing a new business or operation
- Training costs — investments in workforce development
- Advertising and promotional costs — brand-building expenditure
- Relocation and reorganisation costs — operational restructuring
This list encompasses many of the most valuable intangible assets in a modern business. The gap between what IAS 38 permits on the balance sheet and what drives economic value is the central problem that Opagio addresses through its Intangible Asset Valuator and growth accounting framework.
Subsequent Measurement: Amortisation and Impairment
After initial recognition, intangible assets are carried at either cost less accumulated amortisation and impairment (the cost model) or at a revalued amount (the revaluation model, rarely used in practice due to the absence of active markets for most intangible assets).
Finite useful life
Assets with a finite useful life are amortised systematically over that life. The amortisation method should reflect the pattern in which the asset's economic benefits are consumed — but in practice, most entities use the straight-line method.
Indefinite useful life
Assets with an indefinite useful life are not amortised but must be tested for impairment at least annually. An indefinite useful life does not mean infinite — it means there is no foreseeable limit to the period over which the asset will generate cash flows.
Amortisation periods — market practice
| Asset Type |
Typical Range |
Notes |
| Software |
3-7 years |
Shorter for fast-evolving technology |
| Patents |
Remaining legal life |
Maximum 20 years from filing |
| Customer relationships |
8-15 years |
Based on historical retention data |
| Brands (finite) |
10-20 years |
If contract or market-limited |
| Technology |
5-10 years |
Based on obsolescence risk |
| Databases |
5-10 years |
Depends on data refresh requirements |
IAS 38 vs Economic Reality: The Measurement Gap
The most significant criticism of IAS 38 is the gap it creates between balance sheet values and economic reality.
90%+
of S&P 500 value not on the balance sheet
6x
average price-to-book ratio for technology companies
The ONS estimates that UK businesses invested £185.5 billion in intangible assets in 2021 — yet the vast majority of this investment was immediately expensed under IAS 38 rather than capitalised. The result is that the most valuable companies in the economy carry balance sheets that systematically understate their true asset base.
This has practical consequences:
- Lending decisions based on balance sheet assets exclude the majority of company value
- Investment analysis must look through reported financials to assess true intangible value
- Management decisions about R&D, training, and brand investment lack balance sheet visibility
- Tax planning opportunities are missed when amortisable intangible assets go unrecognised
★ Key Takeaway
IAS 38 was designed for an industrial economy where value was predominantly tangible. In today's intangible-intensive economy, the standard's recognition criteria exclude the majority of corporate value from balance sheets. Understanding this gap is essential for anyone making investment, lending, or strategic decisions.
IAS 38 vs FRS 102 (UK Comparison)
For UK companies not reporting under full IFRS, FRS 102 provides an alternative framework with some notable differences.
| Feature |
IAS 38 |
FRS 102 (Section 18) |
| Development capitalisation |
Mandatory if 6 criteria met |
Choice: capitalise or expense |
| Useful life cap |
No cap (indefinite permitted) |
10-year cap (rebuttable) |
| Revaluation |
Permitted if active market |
Not permitted |
| Goodwill amortisation |
Not amortised (impairment only) |
Amortised (max 10 years default) |
| Internally generated brands |
Prohibited |
Prohibited |
ℹ Note
The FRS 102 rebuttable presumption of a 10-year maximum useful life for intangible assets (including goodwill) is a significant simplification. Under full IFRS, goodwill is not amortised at all — it is tested for impairment annually, which can lead to large impairment charges when performance declines.
Practical Guidance for CFOs
If you are a CFO or finance director applying IAS 38, focus on these priorities:
- Establish a capitalisation policy — document the criteria and internal thresholds for determining when development expenditure qualifies for capitalisation
- Train project managers — the research/development phase determination is made by project leaders, not accountants; they need to understand the criteria
- Maintain an intangible asset register — track all capitalised intangible assets with their cost, useful life, amortisation method, and carrying amount
- Review useful lives annually — IAS 38 requires that the useful life and amortisation method be reviewed at each financial year-end
- Understand the gap — use tools like the Opagio Questionnaire to identify the intangible assets that IAS 38 does not capture but that drive your company's value
Further Reading
About the Author
Tony Hillier is an Advisor at Opagio with 30 years of experience in structured finance, M&A advisory, and accounting standards application. He advises companies and investors on intangible asset recognition, valuation, and the practical implications of IAS 38 and IFRS 3. Meet the team.