Does the new leasing standard already apply?

The Exposure Draft of the proposed new lease accounting standard doesn't state the date that financial reporting will need to be prepared in accordance with the new standard. That date remains to be determined, and in the Basis for Conclusions, the boards say that they plan to consider the entire group of new standards for collective application (the FASB reports at least 14 active convergence projects with the IASB). In an online webinar, a staff member said that the boards recognize that a substantial amount of time will be needed for implementation. Discussion I've heard indicates that it wouldn't be before 2013.

The twist, however, is that paragraph 88 of the Exposure Draft states, "the date of initial application is the beginning of the first comparative period presented in the first financial statements in which the entity applies this guidance." All companies as far as I know report at least one prior year for comparison; some report multiple years. So if the standard applies to 2013 annual reports, and you report one prior year for comparison, your date of initial application (i.e., the date as of which you have to capitalize operating leases and renewal options) would be 1/1/2012. If you report three prior years for comparison, you may already be past the date of initial application of the new standard.