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ICAI Guidance Note

Also written ICAI Guidance Note on Accounting for Derivative Contracts · Guidance Note on Accounting for Derivative Contracts · ICAI guidance note 2021 · Revised Guidance Note 2021

ICAI's revised 2021 note on accounting for derivative contracts, effective for accounting periods beginning on or after 1 April 2021, requiring every derivative on the balance sheet at fair value.

In plain language

A commodity futures position is a contract. It is a right, or an obligation, and it has a value. So it has to show up in the accounts.

The ICAI Guidance Note is the rulebook that says how. ICAI is the Institute of Chartered Accountants of India, and it issued a revised note in 2021.

It applies to accounting periods beginning on or after 1 April 2021.

Its central rule is one sentence. Every derivative position must be recognised on the balance sheet and measured at fair value.

Fair value here has a precise meaning. It is the exit price — what you would pay to hand a liability to somebody else, or receive for handing them an asset.

And it applies whether or not the derivative is a hedge. A purely speculative position sits on the balance sheet at fair value just like a hedge does.

How it works

Scope. The note applies to four kinds of contract, whether or not used as hedging instruments:

  1. foreign exchange forward contracts that are hedges of highly probable forecast transactions and firm commitments;
  2. other foreign currency derivative contracts, such as cross currency interest rate swaps, foreign currency futures, options and swaps;
  3. other derivative contracts, such as traded equity index futures, traded equity index options, traded stock futures and option contracts; and
  4. commodity derivative contracts.

Measurement. All derivative positions are recognised on the balance sheet and measured at fair value, because a derivative contract represents a contractual right or an obligation. Fair value is the exit price — the price that would be paid to transfer a liability, or received when transferring an asset, to a knowledgeable, willing counterparty. The extent and availability of collateral must be factored in while arriving at it.

Presentation, current or non-current. Four rules, and they are examined as a set:

DerivativeClassified as
Intended for trading or speculative purposesCurrent assets and liabilities
Hedge of recognised assets or liabilitiesCurrent or non-current, on the duration of the hedge exposure
Hedge of forecasted transactions and firm commitmentsCurrent or non-current, on the settlement or maturity date of the derivative
Having periodic or multiple settlements, such as an interest rate swapNot bifurcated; classified on the predominant portion of its cash flows due for settlement per its contractual terms

Exchange-traded positions need proof of purpose. For futures and options traded on stock exchanges, it must first be demonstrated that the exposures are taken for hedging or risk management purposes. If that is established, the principles of hedge accounting can be used. Nothing about being exchange-traded earns hedge accounting automatically.

Effectiveness. The Guidance Note prescribes no specific testing methodology. It offers examples — regression analysis, the dollar offset test, critical item matching, an economic relationship between the underlying and the hedging instrument, negligible impact of credit risk, and a review of the sources of ineffectiveness. The tests themselves are mandatory: prospective testing at inception and each reporting date, needing an expected offset of nearly 100%, and retrospective testing at each reporting date, needing actual results within 80% to 125%.

A count that does not agree with itself. Section 9.1 says that from the accounting point of view there are three types of hedge — fair value, cash flow and net investment — and section 9.2.3 requires disclosures separately for all three. Section 9.2.2, listing what the Guidance Note recognises, names only two: the fair value hedge model and the cash flow hedge model. Two figures in the workbook means two figures on the page; answer three if asked about accounting hedge types generally, and know that section 9.2.2's list is the shorter one.

A worked example

Pratap Metals Ltd closes its books on 31 March 2026. Four derivative positions are open, and the Guidance Note decides where each one sits.

PositionPurposeFair value (exit price)Presented as
Short 40 lots zinc futures, June 2026 expiry, against 200 MT of zinc stockFair value hedge of a recognised assetLiability Rs 12,00,000On the duration of the hedge exposure — it ends in June 2026, so current
Long 10 lots crude oil futures, no underlying exposureSpeculativeAsset Rs 3,50,000Current, because speculative positions always are
Long aluminium calls hedging a forecast purchase in September 2027Hedge of a forecasted transactionAsset Rs 6,00,000On the derivative's maturity date — beyond twelve months, so non-current
Interest rate swap settling quarterly to 2029Multiple settlementsAsset Rs 9,00,000Not bifurcated; classified on the predominant portion of its cash flows

Where the zinc figure comes from. The workbook's zinc contract has a lot of 5 MT and is quoted per kilogram. Forty lots is 200 MT, or 2,00,000 kilograms. Zinc has risen Rs 6 per kilogram since the short was placed, so the mark-to-market loss is:

2,00,000 x 6 = Rs 12,00,000

That Rs 12,00,000 goes on the balance sheet as a derivative liability at fair value. Note what is not used: neither the price at which the futures were sold, nor the day's traded price. It is the exit price — what it would cost to hand the position over.

One more adjustment the note requires. Pratap has placed Rs 15,00,000 of collateral with the clearing corporation against these positions. The extent and availability of that collateral must be factored in when arriving at fair value, so the liability is not measured as though the counterparty were unsecured.

Finally, purpose has to be proved. The crude oil longs cannot get hedge accounting at all, because Pratap has no crude exposure to demonstrate. They stay at fair value with every movement passing straight through profit and loss.

Why NISM asks about it

Chapter 9 (Accounting and Taxation), section 9.2, which is a stated learning objective of the chapter — knowing the key elements of the guidance note issued by ICAI on the accounting treatment of derivative transactions.

The chapter's own sample question is on this page almost word for word: ICAI's guidance note requires that all derivatives are recognized on the ______ and measured at fair value — the balance sheet. Beyond it, expect the revision year (2021), the effective date (accounting periods beginning on or after 1 April 2021), fair value defined as the exit price, the four-way scope list, and the current-versus-non-current presentation rules, of which the interest rate swap rule is the least intuitive.

Common exam traps

  • 2021 is the revision; 1 April 2021 is the effective date. Two dates in one sentence, and either can be asked.
  • Balance sheet, not income statement. The workbook's own sample question turns on precisely this word.
  • It applies whether or not the derivative is a hedging instrument. A speculative position is not outside the Guidance Note; it is simply always current.
  • Fair value is the exit price, adjusted for collateral. Not the entry price, not the last traded price, and the extent and availability of collateral must be factored in.
  • A multi-settlement derivative is not split. An interest rate swap is classified whole, on the predominant portion of its cash flows — not carved into current and non-current pieces.
  • Hedge accounting for an exchange-traded position must be earned. It must first be demonstrated that the exposure was taken for hedging or risk management purposes.
  • The note prescribes no testing methodology, only examples such as regression, dollar offset and critical item matching. But the prospective and retrospective tests are themselves mandatory, at nearly 100% and 80-125%.
  • The workbook counts the hedge types twice and gets two answers. Section 9.1 and section 9.2.3 say three — fair value, cash flow and net investment. Section 9.2.2 names only two. State three for accounting hedge types generally.

Check yourself

  1. 1.The ICAI guidance note requires that all derivatives are recognised on the ______ and measured at fair value.

    1. a)Balance sheet
    2. b)Income statement
    3. c)Cash flow statement
    4. d)Speculative statement
    Show the answer

    Answer: (a) Balance sheet

    (This is a sample question from the NISM workbook.)

    The reasoning is worth holding on to, because it is what makes the rule inevitable rather than arbitrary. A futures contract may cost nothing to enter — no premium, only margin — yet from the moment it is struck it creates enforceable rights and duties. An accounting system that showed nothing until settlement would leave an entire derivative book invisible to a reader of the accounts.

    And "fair value" has a specific meaning here: ⚠️ "FAIR VALUE in the context of derivative contracts REPRESENTS THE EXIT PRICE — the price that would be PAID TO TRANSFER A LIABILITY or RECEIVED WHEN TRANSFERRING AN ASSET to a knowledgeable, willing counterparty." And "THE EXTENT AND AVAILABILITY OF COLLATERAL SHOULD BE FACTORED IN."

    Note also that recognition is unconditional: the Note applies to its four categories of contract ⚠️ "WHETHER OR NOT USED AS HEDGING INSTRUMENTS." Hedge accounting is an additional, optional treatment on top — not a precondition for the derivative appearing on the balance sheet at all.

  2. 2.What must retrospective hedge effectiveness testing demonstrate?

    1. a)That the entity expects changes in the hedged item to be nearly 100% offset by the hedging instrument
    2. b)That actual results of the hedge are within the value range of 80-125%
    3. c)That the hedge produced a profit over the reporting period
    4. d)That regression analysis was the methodology used
    Show the answer

    Answer: (b) That actual results of the hedge are within the value range of 80-125%

    "RETROSPECTIVE EFFECTIVENESS TESTING is performed AT EACH REPORTING DATE THROUGHOUT THE LIFE OF THE HEDGE, following a methodology set out in the hedge documentation. THE OBJECTIVE IS TO DEMONSTRATE THAT THE HEDGING RELATIONSHIP HAS BEEN HIGHLY EFFECTIVE BY SHOWING THAT ACTUAL RESULTS OF THE HEDGE ARE TO BE WITHIN THE VALUE RANGE OF 80-125%."

    Option (a) is the prospective standard, and the two are deliberately different:

    ⚠️ PROSPECTIVE⚠️ RETROSPECTIVE
    WhenAt INCEPTION and at each subsequent reporting dateAt each reporting date
    Standard⚠️ Expects offset "ALMOST FULLY... i.e. NEARLY 100%"⚠️ Actual results in the 80-125% band

    The asymmetry is not sloppiness. Looking forward, you must design for near-perfect offset — a hedge you expect to work only partly is not a hedge at all. Looking backward, reality is given a wide tolerance, because spot and futures prices "tend to move in tandem" but never "necessarily identically." That residual gap is basis risk, and a rule demanding exactly 100 per cent in hindsight would disqualify every honest hedge ever placed.

    Option (c) misunderstands what a hedge is for. A hedge is not supposed to make a profit — it is supposed to offset. A hedge that made money while the hedged item lost an equal amount is a perfectly effective hedge.

    Option (d) overstates the requirement: "The ICAI Guidance Note DOES NOT PRESCRIBE ANY SPECIFIC TESTING METHODOLOGY" — it merely offers examples including regression analysis, the dollar offset test, critical item matching, economic relationship, negligible impact of credit risk and review of sources of ineffectiveness.

    Both tests are MANDATORY.

Where this is taught

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