For twenty-five years, the single-segment footnote was the easiest paragraph in the 10-K: "The Company operates in one reportable segment." Two sentences, maybe a geographic table, done. ASU 2023-07 ended that, deliberately. The FASB wrote into the standard that a public entity with a single reportable segment must provide all the disclosures required by the ASU and all existing ASC 280 disclosures. If your fiscal year began after December 15, 2023, your current 10-K is in scope. Interim disclosures follow for fiscal years beginning after December 15, 2024, and application is retrospective.
Here is what the footnote now has to contain, and where single-segment filers are getting it wrong in the first filing seasons.
What are the required disclosures for a single-segment entity?
Five elements, all new work for a company that previously wrote two sentences:
- The measure of segment profit or loss the CODM uses. For most single-segment companies this is consolidated net income, but not always, if your CODM actually manages on consolidated adjusted EBITDA or operating income, you disclose that measure (at least one disclosed measure must be the one most consistent with GAAP measurement principles).
- Significant segment expenses. The expense categories regularly provided to the CODM and included in the reported measure of segment profit or loss. This is the significant expense principle, and it applies to you even with one segment.
- An "other segment items" line reconciling revenue less disclosed significant expenses to the reported profit measure, with a qualitative description of what is in it.
- The title and position of the CODM, named by role in the footnote, and how the CODM uses the measure to assess performance and decide how to allocate resources.
- Everything ASC 280 already required, interim and annual measures of segment profit and assets, the reconciliations, entity-wide disclosures (products and services, geography, and major customers under ASC 280-10-50-38 through 50-42).
What counts as a "significant expense" if the CODM only sees the consolidated P&L?
This is the live judgment. The significant expense principle keys off what is regularly provided to the CODM and included in the profit measure. If your CODM genuinely reviews only a consolidated income statement, your significant expense categories will look like that income statement's major captions, cost of revenue, R&D, sales and marketing, G&A. That is an acceptable answer if it is true. What is not acceptable: disclosing income-statement captions while the CODM's actual monthly package contains expense detail by function, product line, or cost center. The disclosure is a factual representation about your internal reporting, and it is checkable, the SEC staff's segment comments have always started with "provide us the information the CODM regularly reviews."
Inventory the CODM package first, then derive the disclosure. The free ASC 280 segment reporting tool structures that inventory, what reports, what frequency, what expense granularity, and maps it to the required disclosure so the footnote and the package tell the same story.
Does ASU 2023-07 reopen the question of whether we really have one segment?
In practice, yes, and this is the underrated risk. Preparing the new disclosures forces you to document who the CODM is and what they review, the same evidence that determines whether you have one operating segment or several. Companies that never wrote a rigorous segment memo are discovering discrete product-line P&Ls in the CODM's monthly deck. If discrete financial information exists and the CODM regularly reviews it to allocate resources, ASC 280-10-50-1 gives you multiple operating segments, and the single-segment conclusion has to be re-earned through aggregation (ASC 280-10-50-11) or the quantitative thresholds, not asserted.
Treat the ASU 2023-07 implementation as a forced refresh of the whole determination. It is far cheaper to fix the conclusion yourself in this year's footnote than to fix it in a comment-letter response with recast prior periods. The assessor at app.unfoldingvalues.com runs the full sequence: CODM, operating segments, aggregation, thresholds, before you draft a disclosure that locks in a position.
What does retrospective application mean for the first filing?
You present the new disclosures for all comparative periods in the financial statements, the significant expense categories are based on the categories identified in the period of adoption. For a calendar-year company, that meant the 2024 10-K showed the new disclosures for 2024, 2023, and 2022. There is no transition relief for single-segment entities.
FAQ
Is a single-segment company exempt from any part of ASU 2023-07?
No. The ASU explicitly states that an entity with a single reportable segment must provide all disclosures required by the ASU and all existing ASC 280 segment disclosures. The only accommodation is inherent: with one segment, some disclosures collapse into consolidated amounts.
When did ASU 2023-07 take effect?
Annual periods for fiscal years beginning after December 15, 2023; interim periods within fiscal years beginning after December 15, 2024. Retrospective application to all periods presented, with early adoption permitted.
Do we have to name our CODM?
You disclose the title and position, "the Chief Executive Officer", not the individual's name, plus an explanation of how the CODM uses the reported measure of segment profit or loss in assessing performance and allocating resources.
Can our segment profit measure be adjusted EBITDA?
You may report more than one measure of segment profit or loss, but at least one disclosed measure must be the one most consistent with GAAP measurement principles. A single-segment filer whose CODM manages on adjusted EBITDA typically discloses both that measure and the GAAP-consistent one, with the reconciliation.
Run this on your own numbers
Confirm you really are a single reportable segment, and see the ASU 2023-07 disclosures that still apply, with the free Segment Reporting (ASC 280) tool.
This is general guidance, not advice on your facts. Unfolding Values is not an audit firm and does not provide attest services. For a read on your specific filing, reach out.
Do this with help: a Pre-Filing QC Review puts the eyes of someone who has led finance and accounting for a US-listed public company on your segment disclosure and CODM support before it reaches EDGAR. 10-Q $1,500, 10-K $2,500, fixed.
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