Published: October 1, 2025 | Bryan Joseph Alfonso
Think fast – accounting rules are finally keeping pace with the fast development of technology.
In September 2025, the Financial Accounting Standards Board (FASB) released ASU 2025-06, a sweeping update to ASC 350-40 on Internal-Use Software. For nearly three decades, ASC 350-40 has guided how businesses account for the costs of software they build for their own use. The core question it answered was simple but consequential: should software costs be treated as an investment or written off as an expense?
Back in 1998, when the rule was first drafted, software development looked a lot like building a house. You drew the plans, laid the foundation, and only once the entire structure was complete could you move in. Accounting rules mirrored that linear progression, with rigid stages—preliminary design, development, and implementation—marking when costs could be capitalized.
But software no longer grows brick by brick. It's released in bursts, tested, tweaked, and re-released—more like a living organism than a finished structure. The old accounting framework couldn't keep pace. Enter ASU 2025-06, a modernization built for today's agile, iterative software world.
This shift means finance teams need to focus less on labeling stages and more on proving that risks have been cleared and management is fully behind the project.
While the structure has changed, some fundamentals remain untouched. ASU 2025-06 does not alter:
In other words, the update sharpens the recognition model for internal projects, but leaves other long-standing rules in place.
For companies, this update trades rigid stage-based rules for a principles-based test. That means more flexibility, but also more responsibility. The line between expense and asset now depends on how well management can document both its commitment and the project's likelihood of success.
In practice, though, this means finance leaders will need to strengthen governance over IT initiatives, align more closely with project managers, and keep clear records that auditors can follow.
For agile and fast-moving organizations, the new model may actually better mirror reality – but it requires sharper judgment and better controls to get right.
For our clients, the implications are even clearer. You'll likely see more questions from auditors, more documentation requirements during project reviews, and potentially shifts in how quickly costs hit the balance sheet. Projects that rely on cutting-edge features, or that pivot frequently, may stay in the “expense” column longer than before.
That's where Unified Global comes in. Our dedicated Technical Accounting & Assurance Group (TAAG) is ready to help you navigate these new thresholds: assessing when costs qualify for capitalization, advising on adoption methods, and ensuring your project governance is airtight.
Ultimately, ASU 2025-06 recognizes that software development is no longer linear, and accounting shouldn't be either. Moving forward, companies that embrace this shift early will have cleaner reporting, stronger controls, and fewer surprises down the line.
At Unified Global, this is an opportunity to help our clients turn a regulatory update into a competitive advantage. By modernizing your accounting policies now, you can align them with your business's existing approach: fast, flexible, and forward-looking.