ASC 350-40
What is ASC 350-40?
ASC 350-40 is the US GAAP standard for internal-use software. It sets the rules for when software development and implementation costs are capitalized as assets or expensed as incurred.
Updated November 2026 · 5 min read
ASC 350-40 is the section of the FASB Accounting Standards Codification that governs the accounting for internal-use software in the United States. It determines which costs of developing, buying or customizing software for an organization's own use can be capitalized as an asset and amortized over time, and which must be expensed immediately. Because nearly every organization builds or configures software for internal use, ASC 350-40 affects a large share of technology spending.
The standard matters to IT financial management because it shapes how technology investments appear in financial statements. Capitalized costs are spread over the software's useful life, while expensed costs reduce profit in the period they occur. The balance between the two affects reported earnings, budgets and the way technology projects are funded and evaluated. The standard was significantly updated by ASU 2025-06, which changes when capitalization begins.
Definition of ASC 350-40
ASC 350-40, titled Intangibles, Goodwill and Other, Internal-Use Software, applies to software acquired, internally developed or modified solely to meet an entity's internal needs, with no substantive plan to market it externally during development. Examples include custom business applications, internal platforms and significant customizations of purchased systems.
Software developed to be sold, leased or marketed falls under a different standard, ASC 985-20. Hosting arrangements, such as SaaS contracts where the customer does not take possession of the software, are generally service contracts, although the implementation costs of these arrangements are assessed using the ASC 350-40 framework.
What Can Be Capitalized
Costs that can typically be capitalized include external direct costs of materials and services used to develop or obtain the software, payroll costs for employees directly working on development, and certain interest costs. These costs relate directly to creating the software asset.
Costs that are generally expensed include training, data conversion (except for software needed for the conversion), general and administrative overhead, and maintenance after the software is in use. Upgrades and enhancements that add functionality can be capitalized, while routine maintenance cannot.
When Capitalization Begins and Ends
Historically, ASC 350-40 tied capitalization to project stages. Costs in a preliminary project stage were expensed, qualifying costs in an application development stage were capitalized, and costs in a post-implementation stage were expensed. ASU 2025-06 removes these stages, effective for annual periods beginning after December 15, 2027.
Under the updated guidance, capitalization begins when management has authorized and committed to funding the project and it is probable the project will be completed and the software used as intended, with capitalization deferred while significant development uncertainty exists. Capitalization ends when the software is substantially complete and ready for its intended use, at which point amortization begins.
Importance of ASC 350-40 in IT Financial Management
Internal software development is one of the largest technology investments many organizations make. How those costs are treated under ASC 350-40 affects profit, assets and key financial metrics, and it influences how technology investments are planned and justified.
IT finance teams need to understand the standard to forecast accurately, explain the gap between cash spending and reported expense, and support the controls and documentation that auditors expect.
Effects on Financial Statements
Capitalizing software costs moves them from the income statement to the balance sheet, increasing assets and reducing current-period expense. The costs then reach the income statement gradually through amortization, usually on a straight-line depreciation style basis over the software's useful life.
This affects metrics such as operating income and EBITDA, which excludes amortization. Two companies spending the same cash on software can report different profits depending on how much they capitalize, which is why consistent application of the standard matters for comparability.
Budgeting and Planning
Because capitalized costs are funded through a capital budget and expensed costs through an operating budget, ASC 350-40 influences how technology projects are funded. Many organizations have separate approval processes for capital and operating spending, which makes the classification of software costs an important planning question. It also shapes the capex vs opex mix that leadership reviews when setting the annual IT budget, since a project can look very different depending on which side of that line its costs fall.
Forecasting must also account for future amortization. A large capitalized project creates amortization expense for years after it goes live, which reduces operating budgets in those years. IT finance teams that model this early avoid surprises when new systems come into use.
How to Apply ASC 350-40
Applying the standard requires clear policies, reliable tracking of costs and time, and documentation that supports each capitalization decision.
Finance, IT finance and engineering teams typically work together, since the data needed to support capitalization comes largely from project and engineering systems.
Policies and Thresholds
Organizations set a capitalization policy defining which projects qualify, which costs are eligible and the minimum size of project to capitalize. Small projects are often expensed for simplicity, using a materiality threshold set with auditors.
The policy should also define useful lives for different types of software, commonly three to five years, and how upgrades and enhancements are treated. With ASU 2025-06, policies need to describe how management authorization, funding commitment and development uncertainty are documented.
Tracking Labor and Costs
Labor is usually the largest capitalizable cost, so organizations need reliable records of the time developers spend on qualifying work. Many use time tracking linked to projects or work items, or estimates based on team allocation, supported by evidence such as project plans and release records.
External costs, such as contractor invoices and purchased components, are tracked by project through procurement and accounts payable. Bringing these sources together each period produces the capitalized amount and the supporting documentation auditors review. Organizations that rely on estimates rather than detailed time records should document how the estimates are made and review them regularly against actual project activity, since auditors often focus on the reasonableness of these assumptions.
Examples of ASC 350-40 in IT Financial Management
The examples below are simplified illustrations of how the standard applies. Organizations should apply the guidance with their own auditors.
Both show how the treatment of costs affects the timing of expense recognition.
Building an Internal Platform
A company spends $3 million building an internal data platform: $2.4 million in developer salaries and contractors for qualifying development work, $300,000 for training and data conversion and $300,000 for early planning and vendor evaluation before the project was authorized.
The $2.4 million is capitalized and amortized over five years, adding $480,000 of amortization expense each year once the platform goes live. The $600,000 of training, conversion and pre-authorization costs is expensed as incurred.
Maintenance Versus Enhancement
After go-live, the platform team spends $500,000 a year. About $350,000 goes to fixing bugs, applying patches and supporting users, which is maintenance and is expensed.
The remaining $150,000 builds a new module that adds significant functionality. If it meets the capitalization criteria, it is capitalized and amortized over its own useful life, separate from the original platform.
Conclusion
ASC 350-40 is the US GAAP standard for internal-use software. It determines which development and implementation costs are capitalized and amortized, and which are expensed, with ASU 2025-06 replacing the old project stages with a probable-to-complete threshold.
For IT financial management, the standard shapes how software investments affect profit, budgets and metrics. Clear policies, reliable tracking of labor and costs and early modeling of future amortization help organizations apply it consistently and plan their technology investments with confidence.
Related terms
ASU 2025-06
ASU 2025-06 is a FASB accounting update that modernizes how companies capitalize internal-use software costs under ASC 350-40. It replaces project stages with a probable-to-complete threshold.
Straight-Line Depreciation
Straight-line depreciation is a method that spreads an asset's cost evenly over its useful life, recording the same depreciation expense each period after subtracting any expected salvage value.
Capital Budget
A capital budget is an organization's plan for investments in long-term assets over a period, such as hardware, facilities and capitalized software. It sets how much will be spent and on which projects.
Operating Budget
An operating budget is a plan for the revenue and day-to-day expenses an organization expects over a period, usually a year. It covers recurring costs such as salaries, rent, subscriptions and services.