SEC now: Revenue 2025 comment letter trends

In this final episode of our SEC-focused series, we discuss SEC comments on revenue. Revenue is the top line for a reason; it’s closely watched by investors and therefore the SEC staff as well. From performance obligations to disaggregated revenue disclosures, we discuss the issues most frequently raised by the SEC staff and offer advice to preparers for getting it right the first time.

In this episode, we discuss:

• 1:34 – An overview of SEC comment letter trends related to revenue
• 6:22 – Performance obligations
• 10:48 – Variable consideration
• 17:07 – Principal versus agent considerations
• 26:00 – Disaggregated revenue disclosures

In case you missed it, check out the previous episodes in this SEC-focused series:

• SEC now: MD&A 2025 comment letter trends
• SEC now: Segments 2025 comment letter trends
• SEC now: 2025 comment letter trends on transactions
• SEC now: Non-GAAP 2025 comment letter trends
• SEC now: Today’s landscape and recent developments

For more on the SEC, listen to our recent episodes:

• Key takeaways from the AICPA & CIMA Conference
• SEC to revisit quarterly reporting: Pros, cons, and what’s ahead

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About our guests

Mike Coleman is a partner in PwC's National Office who specializes in accounting for revenue and software arrangements and has served technology clients for much of his career. In addition, Mike has represented the firm on the AICPA Software Task Force.

Ryan Spencer is a partner at PwC's National Office specializing in SEC reporting matters both for US domestic issuers and some of the world’s largest foreign SEC registrants. He has over 25 years of experience serving clients and is a frequent contributor to PwC’s publications and communications.

About our guest host

Kyle Moffatt is PwC’s Professional Practice leader, leading a team responsible for working with standard setters and regulators as well as delivering brand-defining thought leadership and educational materials. He also consults with engagement teams and audit clients on SEC reporting matters. Before PwC, Kyle spent almost 20 years with the SEC, most recently as Chief Accountant and Disclosure Program Director in the Division of Corporation Finance.

Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to us_podcast@pwc.com

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