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Tariffs, Federal Cuts, and Disclosures: GASB Chair Says the Rulebook Already Covers It

Denise Lugo, Checkpoint News  Senior Editor

· 10 minute read

Denise Lugo, Checkpoint News  Senior Editor

· 10 minute read

State and local finance officials are running scenarios they didn’t expect to revisit this soon: tariff shocks that hit trade and sales tax, tax changes that scramble forecasts, and federal dollars that arrive late—or not at all. The politics move fast. The budget math follows.

Governmental Accounting Standards Board (GASB) Chair Joel Black’s message: governments don’t need a brand-new accounting rule to explain what this volatility could do. In a January 15, 2026, interview with Thomson Reuters, Black said stakeholders are talking “a lot” about emerging issues, but he doesn’t see a need—at least so far—for GASB to launch a new standards project aimed specifically at tariff and federal-funding uncertainty.

“We always listen,” he said. But he keeps coming back to the same point: the reporting model already includes tools governments can use to tell a clearer story—if they’re willing to be direct about their weak spots.

Black’s remarks were in response to a question about whether today’s policy churn—including tariff talk, tax changes, and potential federal spending cuts—is volatile enough to require new GASB standards—or whether the existing rulebook already covers the disclosure job. For many governments, the uncertainty shows up in three disclosure pressure points: the reliability and timing of federal funding, Medicaid exposure, and tariff-driven cost increases.

A Standard Built for This Moment

He pointed to GASB Statement No. 102, the risk-disclosure standard that took effect for the first time in 2025. It isn’t a requirement to list every risk under the sun. It’s a push to name the exposures that could actually disrupt a government’s normal operations.

Statement 102 homes in on two things: concentrations—dependence on a narrow source of money or support, including federal funding—and constraints, the legal or contractual limits that shrink flexibility when conditions tighten.

The trigger isn’t simply having a concentration. Governments have to decide whether the risk is heightened and whether the impact could be substantial—a higher bar than “material,” Black said. Material means financially significant. Substantial means big enough to disrupt normal functioning. That’s why tariffs and federal-funding volatility fit cleanly: the hit may come later, but the warning may belong now.

Take a port city heavily dependent on import duties, or a state that draws significant Medicaid funding from Washington. If federal cuts or new tariffs create heightened risk of a substantial impact, Statement 102 would require disclosure—even in 2025 financial statements, before the budget damage fully lands.

“That standard that we issued before any of this was kind of in the environment, it is fortuitous that it is now effective in 2025,” Black said.

A Board Racing Its Calendar

While Black argues the standards already in place can surface many emerging risks, he’s also managing a different constraint: the board’s timeline.

His term ends June 30, 2027—and another board member’s (Kristopher Knight) term ends the same day. A new board member, Lisa Washburn, starts July 1, 2026. That means three of seven seats will turn over within roughly a year—tight timing for an organization that often works in multi-year cycles.

Black said GASB’s near-term goal is to finish what’s close to completion, so it doesn’t become unfinished business for the next “version of the board.” He singled out the infrastructure assets project as on track for completion by June 30, 2027.

Beyond that, he described a mix of standards-setting, implementation support, and research—some aimed at publication soon, others designed to give the next board options rather than a backlog.

One Rulebook or Two?

Among those research items is a structural question that’s geeky, but consequential for how practitioners find and apply GASB guidance.

Right now, GASB maintains authoritative guidance in two parallel forms: the original pronouncements (Statements 101, 102, 103, and so on) and the GASB Codification, which reorganizes all that guidance by topic rather than chronologically. Both are authoritative. FASB used to do the same thing but eventually moved to a single codification structure.

GASB is researching whether it still makes sense to maintain both, or whether it should follow FASB’s lead. Black said the research is scheduled to conclude by the end of 2026, giving the next board a clearer basis to decide whether to pursue a formal project or keep the current dual approach.

For practitioners, the stakes are practical: how you search for guidance, which source controls if there’s ambiguity, and how updates get tracked.

Implementation Help and Infrastructure Assets Next

Black said GASB’s near-term output includes two practical “next-stage” deliverables: an implementation guide to help governments apply Statement No. 103 (effective in 2026) and continued due-process movement on the infrastructure assets project, which he highlighted as a priority the board is aiming to complete by June 30, 2027.

On Statement 103, he said GASB will “get out” implementation Q&As aimed at the issues preparers will trip over in practice—especially how to define and apply the new “subsidy” concept introduced in the standard. That kind of guidance often determines whether adoption stays consistent or fragments into competing interpretations across jurisdictions.

The Big Rewrite

GASB’s largest technical agenda item, Black said, is its revenue and expense recognition project. He described it as fast-moving, complex, and intentionally designed to be as uncomplicated as possible while still capturing real transaction complexity.

He also revealed a key strategic possibility: the board is considering splitting its exposure draft into two sections to separate refinements from more novel guidance.

The first part would tackle classification—how governments decide whether a transaction is a nonexchange transaction (like taxes and grants) or an exchange transaction (like utility fees). It would also cover all the recognition and measurement principles for nonexchange items, an area where GASB already has detailed guidance it’s refining.

The second part would focus on exchange transactions—an area where GASB currently has relatively little guidance. This section would bring in concepts similar to FASB’s Topic 606, including performance obligations. That’s new territory for governments, and Black said it involves “a lot of new guidance.”

If GASB follows its current schedule, the first section would be exposed for comment before Black’s term ends, with the second following within a year.

Black also flagged the going concern/severe financial stress project as another major item that may not conclude under his chairmanship. He said he once hoped it would be completed by June 30, 2027, but “trying to get it right” may extend the timeline. His current expectation is that GASB could reach an exposure draft stage before his term ends, with the next board left to evaluate feedback and finalize the work.

For stakeholders, that’s more than scheduling. It signals where influence concentrates: the comment period, when preparers, auditors, users, and other parties respond to GASB’s proposed tradeoffs.

Cutting Disclosure Clutter Without Cutting Transparency

Another notable topic isn’t a new measurement model. It’s about volume: whether pension and OPEB note disclosures have grown so large that some items no longer meet GASB’s own threshold for what belongs in the notes.

Black said GASB has completed a post-implementation review of its pension standards and expects to complete the Other Post-Employment Benefits (OPEB) review by the end of 2026. Broadly, he said, the accounting appears to be working. The recurring complaint is the length of the disclosures.

He pointed to Concept Statement No. 7, issued in June 2022, which says note disclosures should be “essential”—information that meaningfully affects the decisions of a breadth or depth of financial statement users. Those users include investors, taxpayers, legislative oversight bodies, and analysts who assess government creditworthiness and accountability.

Because that concept statement came after the pension and OPEB standards, Black said GASB is now researching a blunt question: which disclosure items do users actually use, and which ones add burden without changing decisions?

He was careful to draw a boundary. This effort wouldn’t reduce transparency around the underlying liabilities or change recognition. If a disclosure matters—such as a commonly used funding measure—he suggested it likely stays. The goal is practical: reduce workload by trimming what doesn’t drive decisions, without weakening accountability.

“Anything that is important or essential for users to know to assess the government’s accountability should remain,” Black said.

Voluntary Digital Reporting

Black also emphasized a project he considers strategically important even though it won’t become a required GASB statement: voluntary digital financial reporting.

He argued that users increasingly consume government financial information by pulling numbers out of PDFs into models, dashboards, and other tools. The risk is that context disappears—the “why” and “what it means” embedded in a traditional report.

GASB’s goal is to build a framework that preserves context and reliability as information moves outside static documents. Black said GASB expects to issue a discussion memorandum in 2026 for public comment. It won’t be a full taxonomy, he said, but it will lay out key architectural decisions and parts of a taxonomy, with more work to follow.

FDTA and the SEC: Still There, Not Final Yet

Asked about the Financial Data Transparency Act (FDTA)—federal legislation aimed at standardizing financial data reporting across agencies, including potentially municipal bond disclosures—Black said it remains on regulators’ agenda, but hasn’t advanced recently.

Proposed joint rules were issued, he said, but final joint rules have not been released, and the effort appears to have slowed amid competing priorities and timing around the election and comment period.

Black said the next meaningful milestone is the issuance of joint rules, because that starts the two-year clock for individual agency rulemaking—when municipal bond information and the SEC’s implementation choices would come into sharper focus. He added that it’s still unclear whether the annual financial report will be part of FDTA’s scope.

But he noted GASB’s taxonomy work for voluntary digital reporting could, in theory, be used by the SEC if it chose to apply it to annual financial reports. Either way, Black said GASB is pushing forward because digital consumption of government reporting is the direction of travel regardless of FDTA’s pace.

The Throughline: Listen, Finish, and Use What’s Already on the Books

Asked what advice he’d give the next chair, Black returned to stakeholder focus. The chair role is “unique,” he said, and the approach that works is steady outreach: listen broadly and follow priorities communicated by GASB’s advisory council and other stakeholders.

And with board turnover approaching, the bigger challenge may not be writing the next rule at all. The harder part may be cultural: getting governments to use the tools already on the books to say, plainly, where the pressure points really are.

 

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