PwC DISE Guide vs. Deloitte, KPMG, and EY: Which Big-4 Resource Wins?

Every Big-4 firm has published a guide to ASU 2024-03, the FASB's Disaggregation of Income Statement Expenses (DISE) standard. The PwC DISE guide is the most-searched, but it sits behind a login wall. Deloitte's is the most implementation-focused. KPMG's has the best worked examples. EY's is the most concise. If your audit committee is asking whether you're ready for DISE and you need to know which resource to hand your team, this comparison tells you exactly what each guide covers, what it misses, and where to start.

Key takeaway: No single Big-4 guide covers everything. The PwC guide is the authoritative FAQ resource; Deloitte's 2026 Accounting Spotlight is the best implementation roadmap; KPMG's November 2025 Issues in Depth has the clearest worked examples. Use all three together, or use this article as your open-access synthesis.

What Is DISE and Why Does Every Big-4 Firm Have a Guide?

DISE (ASU 2024-03, codified as ASC 220-40) requires all public business entities to add a new tabular footnote disclosure breaking out five specified natural expense categories from each relevant income statement expense caption. The FASB issued the standard in November 2024 in response to longstanding investor requests for more granularity behind functional expense lines like cost of sales and SG&A.

The five mandated natural expense categories are:

1. Purchases of inventory
2. Employee compensation
3. Depreciation
4. Intangible asset amortization
5. DD&A recognized as part of oil-and-gas-producing activities, or other depletion expense

Entities must also disclose total selling expenses at every interim and annual period, and in annual periods must define what they mean by "selling expenses." The standard is purely additive: it does not change how expenses appear on the face of the income statement, only what goes in the footnotes.

For a full definition of what DISE requires, see our DISE disclosure requirements reference guide. This article focuses on comparing how the four major advisory firms have interpreted and packaged that guidance.

The Four Big-4 DISE Guides: A Side-by-Side Comparison

The table below scores each guide across the dimensions that matter most to a CFO or controller preparing for first-time adoption.

PwC DISE Guide (Viewpoint id202406): The Authoritative FAQ Resource

The PwC guide is the most comprehensive FAQ-format resource on DISE and the one most practitioners cite when they need a defensible interpretation. It lives on PwC's Viewpoint platform in two forms: a standalone In-Depth publication (id202406) and as Section 3.11 of PwC's Financial Statement Presentation accounting guide.

PwC has updated the guide twice since the ASU's November 2024 issuance:

• January 2025: Clarified the effective date and transition section (Section 6), reflecting early confusion about the 2026/2027 dates.
• November 2025: Clarified Questions 2-5, 2-6, and 2-11 regarding purchases of inventory, and added Question 5-2 on interim reporting requirements.

The November 2025 inventory update is significant. The purchases-of-inventory category has generated more practitioner questions than any other natural expense category, because the boundary between "purchases of inventory" and other cost-of-sales components is not always obvious. PwC's clarifications to Q2-5, Q2-6, and Q2-11 address specific fact patterns around what counts as a purchase of inventory versus, say, a direct material cost that bypasses the inventory account. If your entity has complex supply chains or consignment arrangements, these clarifications are load-bearing.

PwC also summarises the investor rationale clearly: "Since many entities present income statement expenses by function (e.g., cost of sales; selling, general, and administrative expenses; research and development), investors indicated to the FASB that it should prioritize requiring additional information about expenses by nature."

Where PwC's guide falls short: It is not an implementation roadmap. It does not tell you how to build a cross-functional project team, sequence your ERP gap analysis, or design internal controls for the new disclosures. It also requires a Viewpoint login, which means you cannot share it freely with your audit committee or operations team.

PwC also published a podcast episode, "Disaggregated expense disclosures: Don't roll the DISE," which is a useful 30-minute primer for teams that prefer audio over dense FAQ text.

Deloitte DISE Guide (DART Accounting Spotlight, 2026): The Best Implementation Roadmap

Deloitte's 2026 Accounting Spotlight is the strongest resource for teams that already understand what DISE requires and need to know how to implement it. It is structured around four implementation phases:

1. Understanding, education, and planning
2. Assessment (scope and gap analysis)
3. Implementation (system and process changes)
4. Adoption and post-adoption

Deloitte's guide is the only Big-4 resource with a dedicated section on internal control over financial reporting (ICFR). This matters because DISE creates new data flows, new manual inputs, and new judgment calls (particularly around the selling-expenses definition) that will need to be covered by controls documentation. External auditors will test these controls, and SEC staff will scrutinise the outputs in comment letters.

Deloitte's "dos and don'ts" section is practically useful. Key recommendations include:

• Identify a cross-functional team (accounting, finance, operations, IT, IR, internal audit) before agreeing on an implementation plan.
• Engage external auditors early to align on policies and interpretations.
• Create an implementation roadmap with key milestones.
• Monitor FASB and SEC developments, including the FASB's May 2026 public roundtable on DISE implementation.

Deloitte also flags a point that most teams miss: multinational or decentralised entities may need to identify key contacts in each region or business unit, especially where business models or IT systems differ. If your entity consolidates across three ERPs in five countries, the data extraction problem is not just an accounting question.

Where Deloitte's guide falls short: The scope edge cases (Reg S-X 3-05/3-09 entities, OTC-traded non-SEC-registrants) are less thoroughly addressed than in PwC's guide. The worked examples are also less detailed than KPMG's.

KPMG DISE Guide (Issues in Depth, November 2025): The Best Worked Examples

KPMG's November 2025 Issues in Depth is the most useful resource for preparers who need to see what the new tabular disclosure actually looks like before they design their own. KPMG provides its own illustrative disclosures rather than simply reproducing the ASU's appendix example, which makes the guidance more adaptable to common income statement structures.

KPMG also contextualises DISE within the FASB's recent disclosure enhancement trilogy:

• ASU 2023-07: Improvements to Reportable Segment Disclosures
• ASU 2023-09: Improvements to Income Tax Disclosures
• ASU 2024-03: Disaggregation of Income Statement Expenses (DISE)

This framing is useful for audit committees and boards who want to understand why DISE is happening now. It is not an isolated standard; it is the third installment in a deliberate FASB effort to give investors more granular data behind functional line items.

KPMG's guide covers the selling-expenses disclosure in a dedicated section, which is rare. Most secondary coverage of DISE barely mentions it. The requirement has two components: (1) disclose the total amount of selling expenses at every interim and annual period, and (2) in annual periods, disclose your definition of selling expenses. That second requirement is where audit risk concentrates. There is no prescribed definition in the standard, so entities must develop and document their own, apply it consistently, and be prepared to defend it to auditors and SEC staff.

Where KPMG's guide falls short: The implementation roadmap is less structured than Deloitte's. The scope edge cases are addressed but not as thoroughly as PwC's FAQ format allows.

EY DISE Guide: The Most Concise Summary

EY's DISE coverage is the most concise of the four, which makes it a useful first read for executives who need a quick orientation before diving into the more detailed guides. It covers the core requirements accurately but does not go deep on scope edge cases, worked examples, or implementation sequencing.

For a practitioner who needs to brief a CFO or audit committee in 15 minutes, EY's summary is a reasonable starting point. For anyone who needs to make implementation decisions, it is not sufficient on its own.

The Scope Question: Who Must Apply DISE?

All four guides agree on the basic scope: DISE applies to all public business entities (PBEs) as defined in the ASC Master Glossary. But the definition of PBE is broader than most finance teams assume.

You are a PBE subject to DISE if you are:

• An SEC registrant (including emerging growth companies and small reporting companies)
• An entity whose financial statements must be included in another SEC registrant's filing under Regulation S-X Rule 3-05 or Rule 3-09
• An entity with securities traded on an over-the-counter market

You are not currently subject to DISE if you are:

• A private company
• A not-for-profit entity
• An employee benefit plan

But private companies need to pay attention if:

• You are preparing for an IPO. When you file your Form S-1 registration statement, you must apply DISE for the periods presented. For a practical walkthrough of what that means for the S-1 process, see our Form S-1 guide for CFOs and finance teams.
• You are an acquisition target and your financial statements will be required under Regulation S-X Rule 3-05 or 3-09 as part of a public company's SEC filing.

PwC's guide is the most explicit on these edge cases, particularly the Reg S-X 3-05/3-09 scenario. Deloitte's deals-focused content also addresses this clearly. If you are a private company in a sale process, DISE readiness is now a transaction execution issue, not just a future compliance item.

Prospective vs. Retrospective Transition: The Decision the Guides Underplay

All four guides note that DISE requires prospective application by default, with an option for retrospective. None of them adequately stress the operational consequence of choosing retrospective.

If you adopt retrospectively, you need comparative-year data starting as early as 2025. For a calendar-year company that adopts DISE in its 2027 annual report (the first required period), retrospective application means restating 2026 and potentially 2025 comparatives. That data must be collected now, while the transactions are occurring, not reconstructed after the fact from aggregated ledger balances.

As PwC states directly: "Entities considering adopting the new standard on a retrospective basis will need to collect data for the comparative years beginning as early as 2025."

This is a 2025-2026 data infrastructure problem, not a 2027 accounting problem. The transition decision should be made now, not when you begin drafting your first DISE footnote.

Effective Dates: The Calendar Every CFO Needs

For a detailed compliance calendar mapped to SEC filing deadlines, see our ASU 2024-03 effective date guide.

The Selling-Expenses Disclosure: The Requirement Nobody Talks About

Every Big-4 guide mentions the selling-expenses disclosure. None of them give it the attention it deserves.

The requirement has two distinct parts:

1. Quantitative: Disclose the total amount of selling expenses at each interim and annual period.
2. Qualitative (annual only): Disclose your definition of selling expenses.

The second part is where the audit risk sits. The standard does not define "selling expenses" for you. Your entity must develop a definition, apply it consistently across periods and segments, and document it in a way that is auditable. SEC staff reviewing your first DISE footnote will look at whether your definition is internally consistent, whether it aligns with how you discuss selling costs in MD&A, and whether it is comparable to peers.

Entities that have historically blended selling costs into a single SG&A line without further disaggregation will face the most work here. The definition you choose will also affect how you present selling expenses in MD&A discussions of operating leverage, so the accounting team and the IR team need to be aligned before the definition is finalised.

Which Guide Should Your Team Use?

The honest answer is that no single guide is sufficient. Here is a practical allocation:

• Start with KPMG's Issues in Depth to understand what the tabular disclosure actually looks like in practice. The illustrative examples are the clearest available in open access.
• Use PwC's In-Depth guide (id202406) as your interpretive reference for specific fact patterns, particularly around purchases of inventory (post-November 2025 update) and scope questions for Reg S-X entities.
• Use Deloitte's 2026 Accounting Spotlight to build your implementation roadmap and ICFR documentation plan.
• Use EY's summary to brief executives and board members who need orientation without detail.

For the industry-specific application of DISE across manufacturing, SaaS, and financial services cost structures, see our ASU 2024-03 industry application walkthrough. For how DISE interacts with segment reporting under ASC 280, see our DISE vs. segment reporting guide.

FAQ

Is the PwC DISE guide free to access? No. PwC's Viewpoint platform requires a login to access the full In-Depth guide (id202406) and Section 3.11 of the Financial Statement Presentation guide. PwC's podcast episode on DISE is publicly accessible on Spotify and PwC's website.

What did PwC update in November 2025? PwC clarified Questions 2-5, 2-6, and 2-11 regarding the purchases-of-inventory natural expense category, and added Question 5-2 addressing interim reporting requirements. These updates reflect that inventory classification has been the most contested interpretive issue since the ASU's issuance.

When do calendar-year companies first have to apply DISE? Annual periods beginning after December 15, 2026, meaning the first required DISE disclosure appears in the 2027 Form 10-K. Interim periods follow one year later, first appearing in Q1 2028 Form 10-Q filings.

Do private companies need to worry about DISE? Not for their own standalone financial statements. But a private company filing a Form S-1 for an IPO must apply DISE in its registration statement. A private company acquired by a public company may also become subject to DISE if its financials are required under Regulation S-X Rule 3-05 or 3-09.

What is a "relevant expense caption" under DISE? Any expense caption on the face of the income statement within continuing operations that contains at least one of the five mandated natural expense categories. Only relevant expense captions trigger the tabular disclosure requirement.

How is the selling-expenses definition audited? External auditors will test whether the definition is applied consistently across periods and segments, whether it is documented in accounting policy, and whether it aligns with how selling costs are discussed elsewhere in the filing, particularly in MD&A. There is no prescribed definition in the standard, so the entity's documented policy is the audit anchor.