Q2 2026 Quarter-End Reporting Checklist for Controllers

This quarter is different. Controllers closing the books on June 30, 2026 face five converging pressure fronts that no generic close checklist addresses: IEEPA tariff refund accounting with a model-consistency trap, a wave of open SEC rulemaking proposals, FASB DISE data-readiness work that can't wait until 2027, iXBRL tagging obligations including new cybersecurity tags, and goodwill impairment triggering events driven by tariff-induced margin compression. Large accelerated filers have until August 11, 2026 to file. That window is shorter than it feels.

Use this checklist to manage your Q2 2026 close and brief your CFO and audit committee on what is genuinely new this quarter.

Key takeaway: The single most consequential accounting judgment most controllers face in Q2 2026 is not a new one. It is the requirement to apply the same IEEPA tariff refund accounting model selected in Q1 consistently in Q2. Switching models is not permitted simply because the CAPE portal has opened. Every other checklist on the SERP misses this entirely.

Why Q2 2026 Is Different From Any Prior Quarter

Five issues converge simultaneously this quarter:

1. Tariff accounting execution -- IEEPA refund claims via the CBP CAPE portal, model-consistency requirements, and a separate Section 122 tariff analysis
2. SEC rulemaking flux -- at least six open comment windows affecting current disclosure strategy
3. FASB DISE readiness -- ASU 2024-03 is a 2027 mandate, but the data-readiness work must start now
4. iXBRL/inline XBRL -- cybersecurity incident tagging obligations now in effect for large accelerated filers
5. Impairment triggering events -- tariff-driven margin compression and equity-market volatility may have created ASC 350 and ASC 360 triggers as of June 30

PwC's Q2 2026 Closing Statements, published June 19, 2026, is the most current authoritative practitioner synthesis and the primary source for the tariff and DISE sections below.

Deadlines at a Glance

What Changed Since Q1 2026

New since March 31, 2026 -- update your analysis on each of these:

• CBP CAPE portal opened in April 2026 for IEEPA tariff refund claims (Phase 1 live; Phase 2 details pending)
• U.S. government filed intent to appeal the IEEPA tariff ruling in May 2026
• Section 122 tariffs imposed by the Trump Administration following the SCOTUS IEEPA decision -- separate legal and accounting analysis required
• FASB issued proposed ASU on hedge accounting June 17, 2026 (HTM securities, SOFR tenors, float-to-float cross-currency swaps)
• European Commission published revised ESRS in July 2026 -- multinationals with EU operations must assess impact
• AICPA opened two exposure drafts: Sustainability Information and amendments to SSAEs 18-19, 21
• ISSB opened exposure draft on amendments to SASB Standards and IFRS S2 industry-based guidance

Workstream 1: Tariff Accounting (IEEPA and Section 122)

Can you change your IEEPA accounting model from Q1?

No. This is the most important accounting governance point of the quarter. PwC's National Office is explicit: "Once a company selects an accounting model, it should apply that model consistently. A company should not change models simply because the refund process has advanced."

Three models were observed in Q1 2026:

Only a limited number of companies recognized IEEPA receivables in Q1. Those that did used the legal framework or loss recovery model. Many applied the gain contingency model and recorded nothing.

Q2 tariff accounting checklist:

• Confirm which model was applied in Q1 and document the basis
• Update the accounting analysis to reflect facts and evidence as of June 30, 2026 -- including the government's May 2026 appeal and CAPE Phase 1 status
• Assess whether the government's appeal affects your probability threshold (loss recovery model) or "realized or realizable" determination (gain contingency model)
• Review timing and liquidation status of affected import entries
• Determine whether protests or other legal remedies are needed to preserve refund rights before entries are finally liquidated
• Coordinate with trade compliance on CAPE filing status -- Phase 1 covers unliquidated and recently liquidated entries still within the protest period; Phase 2 details for more complex situations are still pending
• Treat CAPE as a formal customs filing, not a mechanical upload. PwC notes: "A company needs to be comfortable with both its eligibility analysis and the underlying support for its refund claims, and it should be prepared to respond to questions or validation issues."
• Confirm cross-functional alignment: finance, tax, trade compliance, legal, treasury, and supply chain must all be on the same accounting conclusion. As of early June 2026, approximately half of the $166 billion of IEEPA tariffs are being processed in Phase 1.
• Disclose tariff refund status in MD&A and notes regardless of whether a receivable has been recorded -- PwC is explicit that disclosure obligations exist independent of recognition. See Finrep's tariff disclosure guide for the full Item 303 framework.

Section 122 tariffs: a separate analysis is required

Section 122 tariffs, imposed by the Trump Administration following the SCOTUS IEEPA decision, are not covered by the CAPE refund process and are subject to distinct litigation. Controllers who treat "tariffs" as a single accounting issue will miss this.

• Perform a standalone accounting analysis for Section 122 tariff impacts -- do not fold into the IEEPA analysis
• Monitor Section 122 litigation status separately from the IEEPA appeal
• Assess whether Section 122 tariff costs require separate MD&A disclosure or note disclosure under ASC 450

Workstream 2: Financial Statements and Close Mechanics

Standard quarter-end close items -- confirm each is complete before the 10-Q is filed:

• Condensed financial statements prepared in accordance with Regulation S-X Article 10 (interim financial statements)
• All period-end adjusting entries reviewed with appropriate sign-off -- the SEC's MagnaChip enforcement action (2015) cited the absence of a detailed period-end checklist as a control weakness
• Intercompany eliminations reconciled
• Earnings per share (basic and diluted) computed and tied to the income statement
• Segment information updated per ASC 280 and ASC 2023-07 (significant segment expense disclosures now required)
• Income tax provision updated for the interim period; ASU 2023-09 rate reconciliation and cash taxes paid disclosures applied
• Debt covenant compliance confirmed and any waiver or amendment disclosed
• Subsequent events evaluated through the date the 10-Q is filed (ASC 855) -- include post-June 30 tariff developments (CAPE Phase 2 announcements, appeal rulings, new tariff actions)

Goodwill and long-lived asset impairment triggering events

Tariff-driven margin compression and equity-market volatility may have created triggering events as of June 30, 2026 under ASC 350-20-35-3C (goodwill) and ASC 360 (long-lived assets). A triggering event requires at least a qualitative assessment -- and may require a quantitative test.

• Evaluate each reporting unit for ASC 350 triggering events: sustained stock price decline, tariff-driven cost increases reducing expected cash flows, loss of a significant customer or contract
• Document the triggering event analysis in writing -- "no triggering event" conclusions are as important to document as positive findings
• If a quantitative test is required, ensure the valuation team is engaged early enough to complete before the filing deadline
• See Finrep's ASC 350 triggering event guide for the full checklist and headroom analysis framework

Workstream 3: SEC Reporting and MD&A Disclosures

Form 10-Q Part I -- Financial Information

• Item 1 financial statements: condensed balance sheet, income statement, statement of comprehensive income, cash flow statement, and statement of changes in equity
• Item 1 notes: confirm all required interim disclosures under ASC 270 are included -- significant changes since year-end, not a full repeat of annual notes
• Item 2 MD&A (Regulation S-K Item 303): discuss material changes in results of operations, liquidity, and capital resources. Tariff impacts on cost of goods sold, gross margin, and forward guidance must be addressed quantitatively where material
• Item 3 quantitative and qualitative disclosures about market risk (Regulation S-K Item 305): update for tariff-driven currency and commodity exposures
• Item 4 controls and procedures: disclosure controls and procedures evaluation by principal executive and financial officers

Open SEC rulemaking proposals -- track and assess disclosure strategy

At least six SEC proposals have open comment windows as of the Q2 2026 close. None requires action in the 10-Q itself, but each affects how you frame current disclosures:

• Decide whether to submit comment letters on proposals material to your business
• Do not present proposed rules as final rules in risk factors or MD&A

Workstream 4: FASB Standards Pipeline

DISE (ASU 2024-03) -- data readiness work starts now

ASU 2024-03 (Disaggregation of Income Statement Expenses) is mandatory for public business entities for annual periods beginning after December 15, 2026 -- meaning calendar-year 2027 annual reports. That is closer than it feels, and PwC warns that "implementation may be more complex than expected."

DISE will require disaggregation of key income statement expense captions (employee compensation, depreciation, cost of goods sold, and others) in the notes. Most companies do not currently capture this data at the required level of granularity.

• Complete a data mapping exercise: identify which systems hold the data needed for each required expense caption
• Assess whether your ERP or consolidation tool can produce the required disaggregation without manual workarounds
• Identify judgment calls (e.g., allocation of shared costs) and begin documenting accounting policy positions
• Assign ownership for DISE implementation -- this is a cross-functional project (accounting, FP&A, IT, HR for compensation data)
• Consider whether early adoption in 2026 is feasible or desirable

FASB proposed hedge accounting ASU (June 17, 2026)

The FASB issued a proposed ASU on hedge accounting on June 17, 2026, with comments due August 17, 2026. Three proposed changes are relevant to Q2 2026 planning:

1. HTM securities hedging -- the proposal would permit hedging of interest rate risk for held-to-maturity debt securities, which is currently prohibited under GAAP. Companies that have classified debt securities as HTM and face interest rate risk should assess the potential impact.
2. SOFR tenor flexibility -- the proposed amendment would permit any tenor of SOFR as a benchmark interest rate, not just the current GAAP-defined SOFR OIS rate. Relevant for companies with SOFR-based hedges.
3. Float-to-float cross-currency swaps -- expanded eligibility for net investment hedging instruments.

• Assess whether your hedging program would benefit from any of the three proposed changes
• Consider submitting a comment letter by August 17, 2026 if the proposals affect your hedge accounting strategy
• Monitor for finalization -- early adoption may be available

Other FASB items to confirm

• ASU 2025-05 (credit losses): confirm updated credit loss measurement and disclosures are applied for calendar-year 2026 interim periods
• ASU 2025-07 (derivatives and hedging / revenue): confirm scope clarifications are reflected in note disclosures
• ASU 2024-01 (stock compensation -- scope of ASC 718): confirm correct application for any new awards

Workstream 5: iXBRL / EDGAR Tagging

Cybersecurity incident tagging -- now in effect

Cybersecurity incident disclosures in Form 10-Q Part II must be tagged in iXBRL using the CYD 2024 taxonomy. This requirement is now in effect for large accelerated filers. EDGAR validation does not catch all taxonomy errors, so manual review is essential.

• Confirm any Item 1.05 (material cybersecurity incident) disclosures in Part II are tagged with the correct CYD 2024 taxonomy elements
• Validate block text tags vs. detail tags -- the distinction matters for AI engine extraction and SEC review
• Run EDGAR pre-validation tool before submission; also run an independent taxonomy validator
• See Finrep's cybersecurity iXBRL tagging guide for the full taxonomy mapping

Standard iXBRL checklist

• All financial statement line items tagged with correct US-GAAP taxonomy elements
• Custom (extension) elements minimized and documented
• Decimal attribute values correct for each tagged element
• Context references (period, entity, unit) consistent throughout the instance document
• EDGAR Filer Manual (current version) requirements confirmed

Workstream 6: ICFR and SOX 302/906 Certifications

SOX 302 certifications under tariff uncertainty

The principal executive and financial officers must certify, under Rules 13a-14 and 15d-14, that the 10-Q does not contain material misstatements and that disclosure controls and procedures are effective. Tariff accounting judgments -- particularly the IEEPA model-consistency requirement and the CAPE filing status -- are exactly the kind of complex, evolving estimates that heighten certification risk.

• Brief the certifying officers on the three IEEPA accounting models and which model the company applied in Q1 and Q2
• Confirm the certifying officers understand the government's May 2026 appeal and its effect on the accounting conclusion
• Document the disclosure controls and procedures evaluation to include tariff-related processes (CAPE coordination, cross-functional sign-off, accounting conclusion approval)
• Confirm ICFR has not changed materially since the last annual assessment -- if tariff processes are new, assess whether they constitute a material change
• See Finrep's SOX 404 AI controls checklist for the broader ICFR framework

PCAOB AS 4105 interim review

PCAOB AS 4105 governs the auditor's procedures on the 10-Q. The standard's objective is to give the auditor a basis for communicating whether any material modifications should be made to the interim financial information for it to conform with GAAP. It is not an audit opinion -- it consists principally of analytical procedures and inquiries.

Amendments to AS 4105 paragraph .08 are approved and effective December 15, 2026. The current standard governs Q2 2026.

• Confirm the auditor's AS 4105 review is scheduled and scoped before the filing deadline
• Prepare for auditor inquiries on unusual or complex situations (AS 4105 Appendix B) -- tariff accounting judgments, impairment analyses, and new financing structures are all likely to fall into this category this quarter
• Ensure written management representations are prepared and signed before the review is complete
• Confirm audit committee communications required under AS 4105 are planned
• If the 10-Q states that interim financial information has been reviewed by an independent accountant, the accountant's review report must be filed

Workstream 7: Sustainability and ESG Disclosures

What is required in the Q2 2026 10-Q

The SEC's 2024 climate disclosure rules are subject to a rescission proposal with an open comment period. Do not present them as currently effective requirements. Voluntary climate disclosures remain permissible but require careful framing. See Finrep's climate rescission guide for the full SAB 74 and materiality analysis.

• Assess whether California SB 253 (climate disclosure) or SB 261 (climate-related financial risk) obligations apply and whether any Q2 disclosures are required
• For companies subject to CSRD: the European Commission published revised ESRS in July 2026. Assess the impact on your sustainability reporting obligations for EU-in-scope entities. See Finrep's CSRD guide for US companies for the post-Omnibus scope analysis.
• For IFRS S1/S2 reporters: the ISSB has an open exposure draft on amendments to SASB Standards and IFRS S2 industry-based guidance. Monitor for finalization. See Finrep's IFRS S1/S2 checklist.
• For companies providing or planning third-party assurance on ESG data: the AICPA has two open exposure drafts (Sustainability Information; amendments to SSAEs 18-19, 21). Assess the impact on your assurance engagement scope.
• For IFRS reporters with hedge accounting: the IASB has an open exposure draft on Risk Mitigation Accounting (proposed amendments to IFRS 9 and IFRS 7).

Workstream 8: Subsequent Events and Audit Committee Briefing

Subsequent events evaluation window

ASC 855 requires evaluation of events through the date the financial statements are issued (i.e., the 10-Q filing date, not June 30). For a large accelerated filer filing August 11, that is a six-week window. Tariff-related developments are the most likely source of material subsequent events this quarter.

• Monitor CAPE Phase 2 announcements between June 30 and the filing date
• Monitor IEEPA appeal court rulings or procedural developments
• Monitor any new tariff actions or executive orders affecting import costs
• Assess whether any post-June 30 tariff development is a recognized subsequent event (adjusts Q2 financials) or a non-recognized subsequent event (disclosed but not adjusted)
• Confirm no material debt covenant violations, litigation settlements, or business combinations occurred after June 30

Audit committee briefing agenda

Controllers who have worked through the above checklist are well-positioned to brief the audit committee concisely. Suggested agenda items:

1. IEEPA tariff accounting model applied in Q1 and Q2, and the consistency rationale
2. CAPE portal status and cross-functional coordination model
3. Section 122 tariff separate analysis and current status
4. Goodwill/long-lived asset impairment triggering event conclusion
5. DISE implementation timeline and resource requirements
6. Open SEC rulemaking proposals and their disclosure strategy implications
7. SOX 302 certification process and any heightened risk areas
8. Revised ESRS (July 2026) impact for EU-in-scope entities

FAQ

What are the Q2 2026 Form 10-Q filing deadlines?

Large accelerated filers and accelerated filers both have 40 days from the end of the fiscal quarter under SEC Rule 13a-13. For a June 30, 2026 quarter-end, that is August 11, 2026. Non-accelerated filers have 45 days, making their deadline August 14, 2026.

Can we switch our IEEPA tariff accounting model from Q1 to Q2?

No. PwC's National Office states that once a company selects an accounting model for IEEPA tariff refunds, it must apply that model consistently. Switching models simply because the CAPE portal has opened or the refund process has advanced is not permissible. The accounting conclusion must reflect facts and evidence as of June 30, 2026, applied consistently with the Q1 model.

Do we need to disclose tariff refunds even if we haven't recorded a receivable?

Yes. PwC is explicit: "Disclosure also remains important, whether or not a receivable has been recorded." MD&A and note disclosure obligations exist independently of the recognition question.

What is the difference between IEEPA tariffs and Section 122 tariffs for accounting purposes?

IEEPA tariffs are the only tariffs addressed by the SCOTUS decision and the only tariffs covered by the CAPE refund process. Section 122 tariffs, imposed following the SCOTUS decision, are subject to separate litigation and require a completely independent accounting analysis. They are not interchangeable.

What should we be doing on DISE (ASU 2024-03) in Q2 2026?

ASU 2024-03 is mandatory for calendar-year public business entities starting with 2027 annual reports, but the data-readiness work must begin now. Map which systems hold the data for each required expense caption, assess ERP capabilities, document judgment calls on cost allocation, and assign cross-functional ownership. PwC warns implementation will be more complex than most companies expect.

What does the FASB's June 17, 2026 proposed hedge accounting ASU mean for us?

The proposed ASU would permit hedging of interest rate risk on held-to-maturity debt securities (currently prohibited), expand eligible SOFR tenors as benchmark rates, and broaden net investment hedging instruments to include certain float-to-float cross-currency swaps. Comments are due August 17, 2026. Any entity that uses or is considering hedge accounting should assess the impact and consider whether to comment.