Under the Environment Protection (End-of-Life Vehicles) Rules, 2025, companies are required to recognise provisions for Extended Producer Responsibility (EPR) obligations arising from historical vehicle sales. Since these obligations exist independently of future operations, they satisfy the criteria for present obligations under Ind AS 37. The authorities discussed below clarify that failure to recognise this cumulative provision when the rules became effective constitutes a prior period error under Ind AS 8, and not a change in accounting policy or accounting estimate. Consequently, entities are required to correct such omission through retrospective restatement, unless a reliable estimate could not initially be made due to the absence of available pricing mechanisms.
INTRODUCTION
Ind AS 8, Accounting Policies, Changes in Accounting Estimates and Errors, prescribes the accounting treatment and disclosure requirements relating to changes in accounting policies, changes in accounting estimates and the correction of prior period errors. While these concepts are often interlinked in practice, the accounting consequences arising from each are significantly different.
A change in accounting estimate is recognised prospectively, whereas a prior period error requires retrospective restatement. Accordingly, determining the correct characterisation of an accounting adjustment assumes considerable importance.
This issue becomes particularly relevant in the context of statutory obligations, where management may initially conclude that no present obligation exists and subsequently revisit such conclusion after a more detailed technical evaluation of the applicable legal and accounting framework.
This article examines the distinction between a change in accounting policy, a change in accounting estimate and a prior period error in the context of accounting for Extended Producer Responsibility (“EPR”) obligations arising under the Environment Protection (End-of-Life Vehicles) Rules, 2025 (“ELV Rules”).
This article proceeds on the assumption that management was able to estimate the required provision when the ELV Rules became effective. However, many companies have taken the position that the provision was not capable of reliable estimation at that stage. In such cases, the conclusions may differ, and that aspect has been addressed in the concluding paragraph.
QUERY
ABC Limited is engaged in the manufacture and sale of automotive vehicles and prepares its financial statements in accordance with Indian Accounting Standards (“Ind AS”).
The Environment Protection (End-of-Life Vehicles) Rules, 2025 (“ELV Rules”) became effective from April 1, 2025. The Rules require automobile manufacturers to fulfil Extended Producer Responsibility (“EPR”) obligations in respect of vehicles introduced into the market. The annual EPR targets are linked to vehicles sold during the preceding 15 years in the case of transport vehicles and the preceding 20 years in the case of non-transport vehicles.
Further, the ELV Rules specifically provide that the obligation to fulfil EPR requirements continues in respect of vehicles already introduced into the market even if the producer ceases operations.
During the financial year 2025–26, the Company did not recognise any provision in respect of the cumulative EPR obligation relating to vehicles introduced into the market during the preceding 15 years in the case of transport vehicles, and the preceding 20 years, in the case of non-transport vehicles. Management concluded that no present obligation existed as at the reporting date in respect of such past vehicle sales, on the basis that the obligation was dependent upon future operations and future compliance activities. Accordingly, the Company recognised a provision only in respect of vehicles completing the 15th year or the 20th year, as the case may be, during financial year 2025–26, instead of recognising a provision for the entire cumulative obligation arising from vehicles introduced into the market during the preceding 15 or 20 years, as applicable.

Subsequently, during the financial year 2026–27, management reassessing the accounting position, sought an opinion on the following issues:
- What is the correct accounting treatment for EPR obligations under Ind AS 37 in the aforesaid fact pattern; and
- If the accounting treatment adopted in financial year 2025–26 is to be changed, whether recognition of the cumulative provision in the financial year 2026–27 should be treated as:
- a change in accounting estimate; or
- correction of a prior period error under Ind AS 8.
RELEVANT ACCOUNTING STANDARD REFERENCES
Ind AS 37 – Recognition of Provision
Paragraph 14 of Ind AS 37 states:
“A provision shall be recognised when:
a) an entity has a present obligation (legal or constructive) as a result of a past event;
b) it is probable that an outflow of resources embodying economic benefits will be required to settle the obligation; and
c) a reliable estimate can be made of the amount of the obligation.”
Paragraph 17 of Ind AS 37 states:
“A past event that leads to a present obligation is called an obligating event.”
Paragraph 18 further provides:
“Financial statements deal with the financial position of an entity at the end of its reporting period and not its possible position in the future. Therefore, no provision is recognised for costs that need to be incurred to operate in the future.”
Paragraph 19 states:
“It is only those obligations arising from past events existing independently of an entity’s future actions (i.e. the future conduct of its business) that are recognised as provisions.”
Ind AS 8 – Prior Period Errors
Paragraph 5 of Ind AS 8 defines prior period errors as follows:
“Prior period errors are omissions from, and misstatements in, the entity’s financial statements for one or more prior periods arising from a failure to use, or misuse of, reliable information that:
a) was available when financial statements for those periods were approved for issue; and
b) could reasonably be expected to have been obtained and taken into account in the preparation and presentation of those financial statements.”
Paragraph 41 states:
“Errors can arise in respect of the recognition, measurement, presentation or disclosure of elements of financial statements.”
Paragraph 42 states:
“Subject to paragraph 43, an entity shall correct material prior period errors retrospectively in the first set of financial statements authorised for issue after their discovery by:
a) restating the comparative amounts for the prior period(s) presented in which the error occurred; or
b) if the error occurred before the earliest prior period presented, restating the opening balances of assets, liabilities and equity for the earliest prior period presented.”
Ind AS 8 – Change in Accounting Estimate
Paragraph 32 of Ind AS 8 states:
“As a result of the uncertainties inherent in business activities, many items in financial statements cannot be measured with precision but can only be estimated.”
Paragraph 34 states:
“An estimate may need revision if changes occur in the circumstances on which the estimate was based or as a result of new information or more experience.”
Paragraph 36 states:
“The effect of a change in an accounting estimate… shall be recognised prospectively…”
Ind AS 8 – Accounting Policies
Paragraph 5 states:
Accounting policies are the specific principles, bases, conventions, rules and practices applied by an entity in preparing and presenting financial statements.
Paragraph 7 states:
When an Ind AS specifically applies to a transaction, other event or condition, the accounting policy or policies applied to that item shall be determined by applying the Ind AS.
DISCUSSION
Under the ELV Rules, effective from April 1, 2025, the obligation to fulfil EPR requirements exists in respect of vehicles already introduced into the market and continues even if the producer ceases operations. Therefore, the obligation is not contingent upon future production, future sales or continuation of business operations, as contemplated in paragraphs 18 and 19 of Ind AS 37.
The obligating event in the present case is the historical introduction/sale of vehicles in the market during the preceding 15 years, in the case of transport vehicles, and the preceding 20 years, in the case of non-transport vehicles. Accordingly, the past event contemplated under paragraph 17 of Ind AS 37 has already occurred.
The obligation exists independent of the entity’s future conduct of business, including in circumstances where the company may cease operations or be wound up. This aspect assumes significance in light of paragraph 19 of Ind AS 37, which specifically states that provisions are recognised only for obligations “existing independently of an entity’s future actions”.
Accordingly, the conditions prescribed under paragraph 14 of Ind AS 37 appear to be satisfied:
- a present legal obligation exists pursuant to the ELV Rules as a result of past event;
- settlement of the obligation can be enforced by law and there is no realistic alternative but to comply;
- an outflow of economic resources would be required for purchase of EPR certificates or equivalent compliance mechanisms; and
- the obligation is capable of reliable estimation.
In financial year 2025–26, management concluded that no present obligation existed because it viewed the obligation as dependent upon future operations. However, this conclusion arose from an incorrect interpretation of the legal and accounting framework rather than from absence of information or estimation uncertainty.
The ELV Rules and the relevant facts were already available when the financial statements for financial year 2025–26 were approved. Therefore, the matter does not involve the emergence of new information in financial year 2026–27.
Similarly, the issue does not involve refinement of estimation techniques, reassessment of assumptions, or revision of measurement inputs. Accordingly, the matter cannot be characterised as a change in accounting estimate within the meaning of paragraphs 32–36 of Ind AS 8.
Further, there is no change in accounting policy. Paragraph 5 clearly describes what constitutes an accounting policy, and paragraph 7 requires the selection of accounting policy in compliance with the relevant Ind AS. The accounting framework under Ind AS 37 requiring recognition of provision for present obligations remained unchanged. The error lies in the incorrect application of that framework to the facts existing in financial year 2025–26.
Paragraph 5 of Ind AS 8 specifically states that prior period errors arise from the failure to use, or misuse of, reliable information available when the financial statements were approved. Further, paragraph 41 clarifies that errors may arise in respect of the recognition and measurement of various items in the financial statements.
Accordingly, where management incorrectly concluded that no present obligation existed despite the legal obligation arising from past events and existing independently of future operations, the non-recognition of the provision constitutes a prior period error.
Therefore, recognition of the EPR provision in the financial year 2026–27 would represent correction of a prior period error and not a change in accounting estimate.
CONCLUSION
In the aforesaid fact pattern, the ELV Rules effective from April 1, 2025 create a present legal obligation in respect of vehicles introduced into the market in earlier years. Since the obligation survives even cessation of operations, the liability exists independently of the Company’s future conduct of business.
Accordingly, the recognition criteria prescribed under paragraph 14 of Ind AS 37 stands satisfied, and a provision ought to have been recognised in the financial year 2025–26 itself.
The subsequent recognition of such provision in the financial year 2026–27 does not constitute:
- a change in accounting estimate, since there is no revision arising from new information, updated assumptions, or improved estimation techniques; nor
- a change in accounting policy, since there is no alteration in accounting principles or recognition basis.
Rather, the matter constitutes correction of a prior period error under Ind AS 8 because the earlier non-recognition resulted from the incorrect application of the existing accounting and legal framework despite all relevant information being available at the time of approval of the financial statements for financial year 2025–26.
Accordingly, the correction in the financial year 2026-27 should be carried out retrospectively in accordance with paragraphs 42 of Ind AS 8, including restatement of comparative information and appropriate disclosures, wherever material.
Several companies have claimed in the financial year 2025-26 results that obligations required to be settled by obtaining EPR certificates could not be provided for because the pricing mechanism had not yet been notified and, consequently, a reliable estimate could not be made. This aspect would require careful evaluation by the statutory auditors of the company in determining the appropriate audit response.
If the above assertion by management is considered reasonable, some auditors though not required to do so, may prefer to draw attention to the matter and provide a matter of emphasis in addition to disclosure under key audit matters. However, if such assertion is found to be incorrect, an audit qualification may become necessary.
If, in subsequent years, the pricing mechanism for EPR certificates is notified and the necessary systems and processes are established for the EPR market to become operational, the provision should then be recognised. In such circumstances, the recognition of the provision would not constitute a prior period error but rather a revision of an accounting estimate.











