AICPA VS Section 100 Subsequent Events Toolkit

The AICPA’s Statement on Standards for Valuation Services , Valuation of a Business, Business Ownership Interest, Security, or Intangible Asset (VS sec 100), establishes valuation standards that are mandatory for all AICPA members ‘who are engaged to, or, as part of another engagement, estimate the value of a business, business ownership interest, security, or intangible asset’.1

The purpose of this toolkit is to focus on paragraph 43 of VS sec 100 – Subsequent Events.   The content of this paragraph is straight forward; however, often the application of the guidance in real life situations can cause uncertainty. Practitioners often have the same or similar questions about subsequent events, especially in times of high uncertainty or rapidly changing economic, financial, and market conditions like those experienced during the Coronavirus (COVID-19) pandemic.  Presented below are ‘Frequently Asked Questions’ and sample disclosures that may help address some of these more common questions.

VS sec 100, paragraph 43 states:

The valuation date is the specific date at which the valuation analyst estimates the value of the subject interest and concludes on his or her estimation of value. Generally, the valuation analyst should consider only circumstances existing at the valuation date and events occurring up to the valuation date. An event that could affect the value may occur subsequent to the valuation date; such an occurrence is referred to as a subsequent event. Subsequent events are indicative of conditions that were not known or knowable at the valuation date, including conditions that arose subsequent to the valuation date. The valuation would not be updated to reflect those events or conditions. Moreover, the valuation report would typically not include a discussion of those events or conditions because a valuation is performed as of a point in time—the valuation date—and the events described in this subparagraph, occurring subsequent to that date, are not relevant to the value determined as of that date. In situations in which a valuation is meaningful to the intended user beyond the valuation date, the events may be of such nature and significance as to warrant disclosure (at the option of the valuation analyst) in a separate section of the report in order to keep users informed (see paragraphs 52p, 71r, and 74). Such disclosure should clearly indicate that information regarding the events if provided for informational purposes only and does not affect the determination of value as of the specified valuation date.

Frequently Asked Questions

Subsequent Event Disclosure Guidelines and Sample Disclosures

The purpose of this resource is to provide guidance for valuation analysts who exercise the option to include a subsequent event disclosure in a separate section of the valuation report.  This type of disclosure should:

  • State that VS sec 100 paragraph 43 provides guidance with regard to the disclosure of subsequent events
  • Explain that the valuation date is the specific date on which the valuation analyst estimates the value of the subject interest and concludes the estimate of value
  • Indicate that the valuation analyst generally considers only those circumstances existing as of the valuation date and only those events occurring up to the valuation date
  • State that an event that could affect the value may occur subsequent to the valuation date, and that occurrence is referred to as a subsequent event
  • Explain that the information regarding the subsequent event is provided for informational purposes only
  • Declare that the subsequent event does not affect the determination of value as of the specified valuation date

Note: These disclosures can be accomplished by quoting and citing VS sec 100 paragraph 43.

And, if the valuation analyst exercises the option to include a subsequent event disclosure in a separate section of the valuation report, that disclosure should not:

  • Present, or be construed as, an update valuation
  • Present, or be construed as, a value conclusion
  • Indicate a direction, a percent or a dollar adjustment, or an order of magnitude that may be used to calculate a value conclusion
  • Describe how the subsequent event will specifically affect the subject interest, other than to indicate that the subsequent event may affect the value of the subject at the later date

These FAQs and sample disclosures on subsequent events are meant to provide assistance about how and when to include subsequent events in a valuation report; however, these is not intended to cover all situations that valuation analysts will encounter on a particular engagement or throughout one’s career.  Each engagement is unique and presents its own set of challenges.  

The principal goal of this subsequent event toolkit is to help valuation analysts understand the concepts in VS sec 100 paragraph 43 - Subsequent Events so when the time comes to decide if a subsequent event disclosure is appropriate in a valuation report they will have the appropriate understanding of some of the important considerations that go into making this decision.


Published by the AICPA SSVS Task Force
Lead Authors: James Alerding, CPA/ABV, Edward Dupke, CPA, James Hitchner, CPA/ABV/CFF, ASA, Heather Tullar, ASA, CPA/ABV/CFF, William Strain, CPA/ABV, CVA and Mark Smith, JD, CPA

Special thanks to Susan E. Bradley, CPA/CITP/CFF, GSEC, Partner, TSHB, Fresno, CA for contributions to Sample Disclosure B and Timothy R. Lee, ASA, Managing Director, Mercer Capital, Memphis, TN for contributions to Sample Disclosure C.


1 American  Institute of Certified Public Accountants, Statement on Standards for Valuation Services, VS Section 100, Valuation of a Business, Business Ownership Interest, Security, or Intangible Asset, June 2007, paragraph 1.

2 American  Institute of Certified Public Accountants, Statement on Standards for Valuation Services, VS Section 100, Valuation of a Business, Business Ownership Interest, Security, or Intangible Asset, June 2007, paragraph 43.