ACCT-470 · Lesson 3 of 12 · 26 min
Performance measures: MPMs and non-GAAP disclosures
Almost every listed company tells its story with numbers that are not defined in the accounting standards: adjusted earnings, adjusted EBITDA, organic growth, free cash flow, same-store sales. Management argues that these measures strip out items that do not reflect underlying performance and show the business as management runs it. Investors use them heavily, and many executive pay plans are built on them. Regulators accept that they can be useful but worry that they are often used to present a rosier picture, by excluding costs that are in fact normal and recurring. This lesson looks at how each framework and regulator handles these measures, and at the judgments a reporting team makes when it chooses and reconciles them.
Management-defined performance measures under IFRS 18
IFRS 18 brings some of these measures inside the audited financial statements for the first time. A management-defined performance measure (MPM) is a subtotal of income and expenses that the entity uses in public communications outside the financial statements, that it uses to communicate management's view of an aspect of the financial performance of the entity as a whole, and that is not a subtotal required by IFRS Accounting Standards or specifically listed in IFRS 18. Ratios are not MPMs, and neither are measures that are not subtotals of income and expenses, such as free cash flow or customer numbers. Subtotals that IFRS 18 lists as excluded, such as gross profit and operating profit before depreciation, amortization and impairments within the scope of IAS 36, are also not MPMs, so a plain EBITDA defined that way is exempt, while an adjusted EBITDA that removes restructuring costs is an MPM.
For each MPM, IFRS 18 requires disclosure in a single note: a description of the aspect of performance the measure communicates and why management believes it provides useful information; how the measure is calculated; a reconciliation to the most directly comparable subtotal specified by IFRS Accounting Standards; the income tax effect and the effect on non-controlling interests for each reconciling item, with a description of how the tax effect was determined; and, if the entity changes the calculation, an explanation. Because the note is part of the financial statements, the MPM disclosures are audited. Companies must label MPMs faithfully and present them in a way that is not misleading. Canadian securities law adds its own layer: National Instrument 52-112 Non-GAAP and Other Financial Measures Disclosure, in force since August 2021, applies to measures disclosed outside the financial statements, including in MD&A and news releases, and requires labelling, equal prominence for the most directly comparable financial statement measure, explanation and reconciliation.
| Requirement | IFRS 18 MPMs (in the notes) | NI 52-112 (outside the statements) |
|---|---|---|
| Scope | Subtotals of income and expenses used in public communications | Non-GAAP measures, ratios, segment and other measures in specified documents |
| Reconciliation | To the most comparable IFRS-specified subtotal, with tax and NCI effects per item | To the most directly comparable measure in the statements |
| Prominence | Faithful labels, not misleading | No more prominent than the comparable financial statement measure |
| Explanation | What aspect of performance and why useful | Composition and how it is useful |
| Audited? | Yes, part of the financial statements | No, but reviewed by regulators |
Tamarind Bay's adjusted measures
Tamarind Bay has reported two adjusted measures for years: adjusted operating profit, which adds back restructuring, impairment and acquisition-related costs, and adjusted EBITDA, which also adds back depreciation and amortization. Its credit agreement defines a covenant EBITDA that happens to equal adjusted EBITDA. In 2026 the business development team proposes a new adjustment: excluding 14.0 million of slotting fees paid to a national grocery chain to win shelf space for a new snack line, on the grounds that the fees are a one-off investment.
# IFRS 18 management-defined performance measure (MPM): adjusted operating profit.
# Each reconciling item must show its income tax effect and its effect on non-controlling
# interests (NCI). Tamarind Bay Foods, 2026, millions (invented). Harrow Creek is 80% owned.
op_profit = 129.2
items = [ # (name, pre-tax amount, deductible share, part arising in Harrow Creek)
("Restructuring", 18.6, 1.0, 1.5),
("Goodwill impairment, Frozen CGU", 46.0, 0.0, 0.0),
("Acquisition-related costs", 2.9, 0.4, 0.0),
]
rate, nci_share = 0.265, 0.20
print(f"{'':<40}{'Pre-tax':>9}{'Tax':>8}{'NCI':>8}")
print(f"{'Operating profit (IFRS 18)':<40}{op_profit:>9.1f}")
mpm, tax_tot, nci_tot = op_profit, 0, 0
for name, amt, ded, sub in items:
tax = amt * ded * rate
nci = sub * (1 - rate) * nci_share
mpm += amt; tax_tot += tax; nci_tot += nci
print(f"{'add: ' + name:<40}{amt:>9.1f}{0 - tax if tax else 0.0:>8.2f}{0 - nci if nci else 0.0:>8.2f}")
print(f"{'Adjusted operating profit (MPM)':<40}{mpm:>9.1f}{-tax_tot:>8.2f}{-nci_tot:>8.2f}")
print(f"\nDepreciation and amortization added for adjusted EBITDA: 71.7 -> {mpm + 71.7:.1f}")
proposed = ("Slotting fees paid to retailers", 14.0)
print(f"Rejected adjustment: {proposed[0]} ({proposed[1]}) - a normal, recurring cost of selling")Pre-tax Tax NCI Operating profit (IFRS 18) 129.2 add: Restructuring 18.6 -4.93 -0.22 add: Goodwill impairment, Frozen CGU 46.0 0.00 0.00 add: Acquisition-related costs 2.9 -0.31 0.00 Adjusted operating profit (MPM) 196.7 -5.24 -0.22 Depreciation and amortization added for adjusted EBITDA: 71.7 -> 268.4 Rejected adjustment: Slotting fees paid to retailers (14.0) - a normal, recurring cost of selling
Adjusted operating profit is an MPM: it is a subtotal of income and expenses, Tamarind Bay uses it in its MD&A, earnings releases and investor presentations, and it communicates management's view of performance. The reconciliation starts from the IFRS 18 operating profit of 129.2 million, the most directly comparable specified subtotal, and adds back the three items. The note must show the tax effect of each: restructuring is deductible, so its tax effect is 4.93 million at 26.5 per cent; the goodwill impairment has no tax effect, because goodwill amortization is not deductible for this acquisition; and only 40 per cent of the acquisition costs are deductible. The NCI column picks up the 1.5 million of restructuring incurred at the 80 per cent owned Harrow Creek. Adjusted EBITDA, as Tamarind Bay defines it, also removes restructuring and acquisition costs, so it too is an MPM; a plain EBITDA would not be.
The slotting fee proposal fails. Slotting fees are a normal, recurring cost of selling packaged food: Tamarind Bay pays them every time it launches a product or enters a retailer, and lesson 4 shows that they reduce revenue. Excluding them would overstate the profitability of the new line and make the measure misleading. Calling them a one-off investment does not change their nature; every launch is a one-off in isolation. The audit committee rejects the adjustment, and the minutes record why.
Recurring restructuring and other hard cases
Restructuring raises a harder question. Tamarind Bay has reported restructuring charges in each of the last four years: plant consolidation in 2023, a sales reorganization in 2024, warehouse automation in 2025 and the Frozen network review in 2026. Each programme is different, but a reader could fairly ask whether restructuring is part of how this company normally operates. The regulators' position is not that recurring charges cannot be excluded, but that they cannot be described as non-recurring, unusual or infrequent, and that the explanation must be honest about the pattern. Tamarind Bay's 2026 disclosure therefore lists the charges for the last four years and explains why management still finds a measure before restructuring useful for comparing the operating performance of the continuing business.
| Adjustment | Usually acceptable? | Comment |
|---|---|---|
| Goodwill impairment | Yes | Non-cash, unusual in size, explained |
| Acquisition-related transaction costs | Generally | Clearly linked to specific transactions |
| Restructuring | With care | Recurring programmes must not be called non-recurring |
| Share-based compensation | Common but debated | A real cost of employing people; explain why excluded |
| Slotting fees, ordinary marketing | No | Normal recurring cash operating expenses |
| Only losses, never gains | No | One-sided adjustments are misleading |
| Revenue on a different basis than GAAP | No | Individually tailored accounting principle |
Share-based compensation is a recurring debate. Many technology companies exclude it, arguing that it is non-cash and that its fair value depends on volatile share prices. Critics, including several large investors, reply that paying employees in shares is as much a cost as paying them in cash and that excluding it overstates profitability. Tamarind Bay does not exclude it, which makes its adjusted measures more conservative than some peers'. Whatever a company does, consistency matters: changing the definition of an adjusted measure from year to year to improve the trend is one of the patterns regulators look for, and IFRS 18 requires an explanation of any change in an MPM's calculation, with restated comparatives.
Key performance indicators and other measures
Not every measure is an MPM or a non-GAAP measure. Organic revenue growth, which removes acquisitions, disposals and currency effects, is a supplementary financial measure under NI 52-112 if it is calculated from amounts in the financial statements but is not itself presented there; it must be labelled and its composition explained. Operational metrics, such as tonnes produced or number of retail doors, are not financial measures at all, though the regulators expect them to be defined and consistently calculated. Ratios such as adjusted operating margin are non-GAAP ratios if a component is a non-GAAP measure. Free cash flow is a non-GAAP measure under NI 52-112 but not an MPM, because it is not a subtotal of income and expenses.
Using adjusted measures in pay and covenants
Adjusted measures matter beyond investor communication. Most of Tamarind Bay's annual bonus depends on adjusted operating profit, and its long-term incentive plan uses adjusted EPS. That creates a direct incentive for management to classify costs as adjustments. The compensation committee therefore approves the definition at the start of the year, specifies which kinds of items can be adjusted, and reviews every adjustment at year end, with internal audit testing the calculation. Lenders do the same in a different way: the credit agreement defines covenant EBITDA precisely, caps the add-backs for restructuring at a percentage of EBITDA, and requires a compliance certificate signed by the chief financial officer. When the definitions in pay plans, covenants and public reporting differ, the company must keep three sets of calculations, and analysts must be told which one they are reading.
Worked problem
Is it an MPM?
Which of these measures, each disclosed in Tamarind Bay's earnings release, is an MPM under IFRS 18, and which would be a non-GAAP measure under the SEC rules? (a) adjusted operating profit; (b) EBITDA defined as operating profit before depreciation and amortization; (c) free cash flow; (d) adjusted operating margin; (e) revenue growth at constant currency.
Show solution
- (a) A subtotal of income and expenses expressing management's view: an MPM; also a non-GAAP measure.
- (b) Operating profit before depreciation, amortization and IAS 36 impairments is a listed exempt subtotal under IFRS 18: not an MPM, though still subject to securities rules outside the statements; under US rules it is a non-GAAP measure with its own C&DI guidance.
- (c) Not a subtotal of income and expenses: not an MPM; a non-GAAP measure under both countries' securities rules.
- (d) A ratio: not an MPM, but the numerator is, so the ratio is a non-GAAP ratio and its components must be explained.
- (e) Not a subtotal of income and expenses: not an MPM; a non-GAAP or supplementary measure that must be defined and reconciled.
Answer: Only (a) is an MPM. All five are regulated as non-GAAP or other financial measures in public communications.
Common mistakes
MistakeExcluding normal recurring operating costs, such as slotting fees, from an adjusted measure.
InsteadAdjust only for items that do not reflect ongoing operations, and explain each.
MistakeCalling recurring restructuring non-recurring.
InsteadDescribe the pattern honestly and explain why the measure is still useful.
MistakeLeading an earnings release with adjusted results.
InsteadGive the comparable GAAP or IFRS measure equal or greater prominence.
MistakeChanging the definition of an adjusted measure to improve the trend.
InsteadKeep definitions consistent; explain and restate if a change is justified.
MistakeShowing the tax effect of all adjustments as one number.
InsteadDisclose the tax and NCI effect of each reconciling item for MPMs.
MistakeAssuming a measure is unregulated because it is not in the statements.
InsteadSecurities rules govern measures in news releases, presentations and websites as well.
Summary and key terms
- An MPM is a subtotal of income and expenses used in public communications to show management's view of performance, not required or listed by IFRS.
- MPM disclosures, including reconciliations with tax and NCI effects for each item, are part of the audited notes.
- NI 52-112 governs non-GAAP and other financial measures disclosed outside the statements.
- Excluding normal recurring costs such as slotting fees makes a measure misleading.
- Recurring restructuring may be excluded with care but must not be called non-recurring.
- Adjusted measures used in pay and covenants need strong governance over definitions and adjustments.
- Management-defined performance measure (MPM)
- A subtotal of income and expenses used in public communications to communicate management's view of performance, disclosed under IFRS 18.
- NI 52-112
- The Canadian securities rule on non-GAAP and other financial measures, in force since 2021.
- Supplementary financial measure
- Under NI 52-112, a measure not in the statements that is calculated from amounts in them, such as organic growth.
- Non-GAAP financial measure
- A numerical measure of performance, financial position or cash flow that adjusts a measure presented in the financial statements.
- Adjusted EBITDA
- Earnings before interest, taxes, depreciation and amortization, further adjusted for items management considers not representative of ongoing operations.
- Equal prominence
- The requirement that the comparable statement measure be shown at least as prominently as the non-GAAP measure.
- Covenant EBITDA
- EBITDA as defined in a credit agreement for testing financial covenants.
Practice problems
Work each problem on paper first, then reveal the answer to check.
Why does the slotting fee adjustment fail?
Show answer
Slotting fees are normal, recurring costs of selling packaged food; excluding them would make the measure misleading.
Rerun the MPM program treating 100 per cent of acquisition costs as deductible. What is the total tax effect?
Show answer
4.93 + 0.77 = 5.70 million.
Can restructuring be excluded from an adjusted measure if it occurs every year?
Show answer
It may be excluded if the measure is not misleading, but it cannot be called non-recurring, and the pattern should be disclosed.
Is free cash flow an MPM?
Show answer
No, it is not a subtotal of income and expenses; it is a non-GAAP measure under NI 52-112.
Why does consistency of definitions matter?
Show answer
Changing definitions to improve trends misleads investors; regulators look for this pattern.
Who should approve the definition of an adjusted measure used in a bonus plan?
Show answer
The compensation committee, at the start of the year, with year-end review of adjustments.
Name two prohibited or misleading practices.
Show answer
Excluding normal recurring cash operating expenses; presenting a full non-GAAP income statement; one-sided adjustments; tailored revenue recognition.
Why should gains be adjusted as well as losses?
Show answer
Adjusting only losses biases the measure upward.
Where in the financial statements are MPM disclosures located?
Show answer
In a single note.
How should a company treat share-based compensation in adjusted measures?
Show answer
Either way can be acceptable if explained, but excluding it is debated because it is a real cost; consistency matters.
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