ASU 2018-15 Cloud Computing Arrangement Implementation Costs
ASU 2018-15 governs a hosting arrangement that is a service contract, which is what most rented model access and subscribed AI platforms are. The subscription fee itself is a service, expensed over the term. Implementation costs to configure and integrate the hosted service are capitalized using the same application-development-stage test as internal-use software ASC 350-40-25, then amortized over the arrangement term.
What it covers for cloud AI
When you rent access to a model or an AI platform you do not control, you are in a cloud computing arrangement that is a service contract. ASU 2018-15 confirms that the hosting fee is a service expensed as received, and that only the implementation costs, the work to configure, integrate and make the service usable, are eligible for capitalization on the same basis as an internal-use software build.
Which implementation costs are capitalizable
- Configuration and integration coding performed in the application-development stage is capitalized ASC 350-40-25.
- Data conversion, training and ongoing operation are expensed.
- The capitalized implementation asset is amortized over the term of the hosting arrangement, including reasonably certain renewals.
The distinction that drives the posting is service contract vs software license. If the arrangement conveys a license to software the customer controls, it is not a CCA and different guidance applies. The service-contract test is set out on the ASC 350-40 internal-use page and worked through in the mechanics.
Questions this posts answers
- Does ASU 2018-15 let me capitalize my OpenAI or Anthropic API bill?
- No. The metered access fee is a service expensed as received. Only distinct implementation work to integrate the hosted model can be capitalized.
Instruments and mechanics this standard decides
Primary sources
- [S2] KPMG: Cloud computing implementation costs post ASU 2018-15 (US GAAP)
- [S1] KPMG: Hot Topic: Accounting for internal-use software (ASC 350-40) (US GAAP)
Ledger current as of 2026-07-24. A position and a citation, not accounting advice. See how we cite.