Every state and local government is heading toward the same deadline: fiscal years ending June 30, 2026 must report under GASB Statement No. 103, the first overhaul of the financial reporting model since 1999. Buried inside the MD&A, budgetary, and proprietary fund changes is a quieter shift that compliance officers cannot ignore — capital asset activity now has to be explained, not just restated, and disposals, leases, intangibles, and subscription-based IT assets each carry their own disclosure trail under the companion standard GASB 104. A spreadsheet updated once a year before the audit can no longer keep up with reporting that now expects a continuously current picture. Governments that treat their capital asset register as a living record, maintained through CMMS-based asset tracking, are the ones walking into FY 2026 audits with answers instead of scrambling for them.
Compliance Officer Guide · GASB 103 · FY 2026
GASB 103 Capital Asset Reporting: What Governments Must Fix Before FY 2026
GASB 103 asks for a capital asset story that updates itself, not a spreadsheet reconstructed at audit season. Here is what changed, what auditors will check, and how to keep your register audit-ready year-round.
1999
last year the financial reporting model changed this significantly, before GASB 103
5
required components now mandated inside every MD&A narrative
4
separate capital asset categories GASB 104 requires governments to disclose apart
FY 2026
first fiscal year-end this reporting model applies to, starting June 30, 2026
Where Capital Asset Reporting Breaks Down at Audit Time
Most agencies do not fail GASB 103 because they lack asset data — they fail because that data lives in five disconnected places and gets reconciled once a year. These are the gaps auditors flag most often.
Issue
Scattered Spreadsheet Registers
Capital asset ledgers sit in disconnected spreadsheets across departments with no single source of truth, so reconciliation only happens once, right before fieldwork begins.
Issue
Lease and Intangible Assets Grouped Together
GASB 104 requires lease assets, intangible right-to-use assets, and subscription-based IT arrangements to be disclosed as separate categories, not lumped into one general capital asset line.
Issue
Held-for-Sale Status Reviewed Too Late
GASB 104 expects every reporting period to confirm whether an asset still meets held-for-sale criteria, something a spreadsheet reviewed annually simply cannot track.
Issue
Boilerplate MD&A Language
GASB 103 specifically discourages repeating prior-year wording. Capital asset changes must be explained with reasons, not just restated as numbers or percentages.
Building a GASB 103 and 104 Ready Capital Asset Register
1
Centralize the Register
Bring land, buildings, equipment, leases, and intangible assets into one continuously updated register instead of parallel department spreadsheets.
2
Tag Assets by Governing Standard
Classify each asset as a GASB 87 lease, GASB 94 intangible right-to-use, GASB 96 subscription IT arrangement, or other intangible so footnote categories build themselves.
3
Log Disposals as They Happen
Record disposal gains, losses, and dates in real time so nonoperating revenue and expense classification under GASB 103 is accurate at year-end, not reconstructed from memory.
4
Review Held-for-Sale Status Every Period
Flag assets management intends to sell and confirm the one-year sale probability test each reporting cycle rather than once before the audit.
5
Feed the MD&A Narrative Directly
Pull real acquisition, disposal, and condition data straight into management's discussion instead of writing generic year-over-year commentary.
Capital Asset Disclosure Categories Under GASB 104
| Asset Category | Governing Standard | What Must Be Disclosed Separately | Review Frequency |
|---|---|---|---|
| Leased Capital Assets | GASB 87 | Footnote disclosure apart from owned capital assets | Every period |
| Intangible Right-to-Use Assets | GASB 94 | Separated from owned intangible asset classes | Every period |
| Subscription-Based IT Arrangements | GASB 96 | Own major class within the capital asset footnote | Every period |
| Other Intangibles (easements, software, water rights) | GASB 104 | Reported apart from lease and subscription IT assets | Every period |
| Assets Held for Sale | GASB 104 | Historical cost, accumulated depreciation, carrying amount, pledged debt | Evaluated each period |
See a Live GASB 103 and 104 Ready Asset Register
Oxmaint keeps every capital asset — owned, leased, intangible, and subscription-based — tagged, current, and export-ready for MD&A and footnote disclosures, all year long.
Spreadsheet Tracking vs a Living Capital Asset Register
Spreadsheet-Based Tracking
Capital asset data lives in disconnected spreadsheets maintained by different departments
Disposal gains and losses are reclassified manually, often caught only during audit fieldwork
Lease, intangible, and subscription IT assets are grouped together, forcing rework for GASB 104
Held-for-sale status is reviewed once a year instead of every reporting period
MD&A narrative is rewritten from memory each cycle, risking repeated boilerplate wording
Living Register in Oxmaint
Every capital asset — owned, leased, intangible, subscription-based — sits in one continuously updated record
Disposals and transfers are logged the moment they happen, ready for nonoperating classification
Assets are tagged by governing standard, so GASB 104 footnote categories are already separated
Held-for-sale criteria can be reviewed and flagged every single reporting period
Acquisition and disposal history exports directly into MD&A-ready summaries
Compliance Perspective
The hardest part of GASB 103 is not learning the new rules — it is proving, asset by asset, that the register behind the numbers was current all year, not patched together the week before fieldwork starts. A register that updates itself the moment an asset moves, retires, or gets leased removes that entire scramble.
Compliance Officer, County Public Finance Office
Frequently Asked Questions
What does GASB 103 actually change for capital asset reporting?
GASB 103 requires MD&A to explain capital asset and financing activity with real reasons, not just amounts, and reclassifies disposal gains and losses as nonoperating revenue and expense. Paired with Oxmaint's asset register, that narrative and classification data stays current all year.
When do governments need to comply with GASB 103?
GASB 103 applies to fiscal years beginning after June 15, 2025, meaning most governments must reflect it starting with fiscal year-end June 30, 2026. Preparation should already be underway well before that close date.
How is GASB 104 different from GASB 103 for capital assets?
GASB 103 reshapes the overall reporting model, while GASB 104 focuses specifically on capital asset footnotes, requiring separate disclosure for leases, intangible right-to-use assets, subscription IT arrangements, and assets held for sale. Both take effect for the same fiscal year.
Can a CMMS-based asset register support GASB 103 and 104 compliance?
Yes — a CMMS that tracks acquisition, condition, transfer, and disposal events in real time gives finance teams a continuously current capital asset record. Book a demo to see how that record maps directly to GASB disclosure categories.
What happens if our capital asset records are not ready by FY 2026 year-end?
Incomplete or inconsistent capital asset records typically surface as audit findings, delayed reporting, or restated disclosures the following year. Starting the register cleanup now avoids a compressed, high-risk scramble right before fieldwork begins.
Get Your Capital Asset Register Ready for FY 2026
Oxmaint keeps every capital asset tagged, current, and disclosure-ready — so GASB 103 and GASB 104 reporting is a data pull, not a fire drill.
