Contents11 sections
Ask a technology leader for their AI budget and you usually get one number. Ask what is inside it and you get four categories, two of which nobody is forecasting and one of which is quietly eating gross margin.
The most useful thing I have done on this subject is refuse to let AI be one line. It is three lines. They behave differently from each other, and the accounting, the forecasting and the governance are distinct for each.
The three budgets
| Tooling | Building | Serving | |
|---|---|---|---|
| What it is | Seats, subscriptions, developer assistants | Implementation, integration, re-architecture | Inference on behalf of customers, and GPU capacity |
| Cost behaviour | Per seat, semi-fixed | A one-time project | Variable, scaling with usage |
| Where it lands | Operating expense, research or administration | Expensed or capitalized | Cost of revenue |
| Book treatment | Expensed as incurred | Potentially capitalizable under ASC 350-40 | Expensed as consumed |
| Tax treatment | Deductible | Domestic work deductible now under Section 174A | Deductible, and owned GPUs take bonus depreciation |
| Forecasting | Easy, it tracks headcount | Medium, it is a scoped project | Hard, it tracks behaviour |
| Who owns it | Engineering leadership | The project sponsor | Product and finance together |
| Touches gross margin? | No | No | Yes, directly |
One line of that table carries the argument. Serving is the budget that moves gross margin. It is usually the one with no owner.
Budget 1, tooling
Coding assistants, chat subscriptions and meeting tools sit here. The spend is per seat, predictable, easy to approve and easy to sprawl, and the mistakes are small individually.
Seat sprawl is the first one. Licences get assigned at onboarding and never reclaimed, which is the same problem as any subscription software and takes the same fix: quarterly reclamation against actual sign-in data.
Overlapping tools are the second. Three assistants do one job because three teams each chose one, and consolidation buys back real money plus more context-switching time than the money is worth.
The third is API keys bought on personal cards and reimbursed through expenses, which is the shadow IT of this cycle: unbudgeted, ungoverned, and frequently the route by which company data reaches a service nobody approved.
None of this is strategically interesting. It is hygiene, the numbers are small against the third budget, and the risk is that it absorbs the governance attention the third budget needs.
Budget 2, building
This one deserves to be run as a capital project and usually gets run as a science experiment.
| Component | Share of effort | Capitalizable? |
|---|---|---|
| Data pipeline and preparation | Large | Often, once the approach is settled |
| Retrieval and indexing infrastructure | Medium | Often |
| Evaluation harness and test sets | Medium | Often |
| Agent orchestration and tool integration | Medium | Often |
| Guardrails, safety and policy enforcement | Medium | Often |
| Model selection experiments and spikes | Small | No, this is where the uncertainty lives |
| Prompt iteration after launch | Ongoing | No, this is maintenance |
ASU 2025-06 removed the project-stage model and replaced it with an authorization-plus-probability test carrying an explicit brake for significant development uncertainty, and that line happens to fall in a place that suits AI work. The exploratory stretch — where you are still finding out whether a model can reach the accuracy the product needs — is genuinely uncertain, so it gets expensed. Once feasibility is proven, funding is committed and the remaining question is execution, the build can be capitalized from that date forward.
That maps onto how a good AI project already runs: a bounded evaluation phase ending in a kill decision, then a build. A kill decision buys two things at once: project governance, and a capitalization story. An organization without one is missing both, and the gap has a single cause.
The artifact that carries both is one page. "We evaluated three approaches, approach B reached 91 percent on our evaluation set, we are committing $1.4 million to build it, the sponsor is X and the target is the third quarter." That document is the project charter and the capitalization evidence at the same time, and writing it takes an afternoon.
Budget 3, serving, and the gross margin problem
Here is the part that changed the economics of software and that most organizations are still catching up with.
In classic software, the marginal cost of serving one more user of one more feature rounds to zero. That rounding is why the category carries gross margins of 75 to 85 percent; the whole valuation model rests on it.
Inference refuses to round. Every invocation costs money, and the cost scales three ways at once: with usage, with context length, and with how capable a model somebody chose. That produces a failure mode the industry has not had before: a feature customers love can dilute gross margin at the exact moment it succeeds.
The questions that follow are pricing questions, and engineering has to supply the numbers behind them. What does the median customer cost to serve, per month, in inference? What does the customer at the ninety-fifth percentile cost? At what level of usage does a customer stop being profitable? Does this feature belong in the base tier or in a paid add-on?
Most companies cannot answer the first two, because inference spend is not attributed per customer. That instrumentation has become mandatory. It is the same discipline as tagging cloud resources so cost of revenue can be split from research spend, which Part 2 covers, applied to a cost that varies far more.
| Lever | Effect | The trade |
|---|---|---|
| Model tiering, small models for simple tasks | Large | Routing logic, and an evaluation per tier |
| Caching common responses | Large where it applies | Staleness and invalidation |
| Prompt and context compression | Moderate | Quality risk if trimmed too far |
| Batching non-interactive work | Moderate | Latency, so it suits asynchronous cases only |
| Fine-tuning a smaller model | Large at volume | Upfront cost and ongoing maintenance |
| Usage-linked pricing | Solves it commercially | Sales friction, and harder forecasting for the customer |
| Rate limits and quotas by tier | Direct | A cost paid in customer experience |
The first lever returns the most and gets used the least. Routing a simple request to a smaller model is unglamorous engineering with a direct and measurable effect on gross margin. It competes for attention against work that demos better, and it loses.
Owning GPUs
For most companies the answer is rent. Sustained utilization is the number that changes it.
| Sustained utilization | Usually best |
|---|---|
| Under 30 percent | On-demand cloud |
| 30 to 60 percent | Reserved or committed cloud capacity |
| Over 60 to 70 percent, stable, with 18 months of visibility | Owning, in colocation |
Cross that line and you are back in Part 4 territory: useful-life estimates, bonus depreciation, power and cooling as a fixed cost per rack unit, and the real risk that a chip's economics degrade before the chip does. The tax side is favourable right now, with 100 percent bonus depreciation permanent for qualified property acquired and placed in service after 19 January 2025, so a GPU purchase can be deducted in full in year one for tax while depreciating over five years for book.
One thing stays off the table: buying accelerators against a demand forecast built on a feature that launched last quarter. Utilization has to be demonstrated.
Why AI made cloud forecasting worse
Flexera's 2026 State of the Cloud Report put self-estimated wasted infrastructure and platform spend at 29 percent — the first increase in five years — and attributed the reversal specifically to AI workloads making rightsizing and forecasting harder. In the same survey 81 percent reported using generative AI, up from 72 percent the year before and 47 percent the year before that, and 53 percent named security and compliance as their top challenge for cloud AI work.
That is a signal worth sitting with. Cloud cost discipline had improved for five straight years, and one workload category reversed it. If your FinOps numbers got worse this year, the practice is probably fine. The problem got harder faster than the practice got better.
What I actually do
- Split the budget into three named lines with three different owners. Nothing else in this article works until that exists.
- Instrument inference cost per customer and per feature before the second AI feature ships, because retrofitting attribution across a live estate is painful and nobody volunteers for it.
- Put an evaluation gate with a real kill decision in front of every AI build. Good governance and clean capitalization turn out to be the same artifact.
- Write the authorization document: date, sponsor, scope, amount, expected completion. That page is the capitalization trigger under the new standard.
- Review model routing every quarter. The cheapest adequate model changes every few months and almost nobody goes back to check.
- Treat gross margin impact as a launch criterion, alongside latency and error rate. A feature that moves margin past an agreed threshold brings pricing into the launch.
- Buy GPUs on demonstrated utilization (demonstrated meaning measured, over months, on the workload that will actually run there). A forecast is a forecast, whatever the slide calls it.
- Assume the forecast will be wrong, and commit to the confident floor, which is Part 7's rule applied to the least predictable workload anyone runs.
Glossary
| Term | Definition |
|---|---|
| Agentic workload | A system where models take multi-step actions using tools |
| Context window | How much text a model considers at once, where more costs more |
| Cost of revenue | What it costs to deliver what customers bought |
| Evaluation set | A test suite measuring model output against known-good answers |
| Fine-tuning | Adapting a smaller model to your task to cut serving cost |
| Gross margin | Revenue minus cost of revenue, as a percentage |
| Guardrails | Controls on what a model may accept or produce |
| Inference | Running a trained model to produce output, which is the per-use cost |
| Model routing, or tiering | Sending simpler requests to cheaper models |
| Retrieval | Fetching relevant data to give a model context at query time |
| Significant development uncertainty | The ASU 2025-06 concept that blocks capitalization while feasibility is still in doubt |
| Token | The unit models are billed in, roughly a word fragment |
References
- Flexera, 2026 State of the Cloud Report, on waste, generative AI adoption and AI governance
- FASB, ASU 2025-06, Subtopic 350-40, issued 18 September 2025
- IRC Section 174A and Section 168(k), as amended by the One Big Beautiful Bill Act, 2025
- theCUBE Research, "Resetting GPU Depreciation", on utilization and the value cascade
- DORA, 2025 State of AI-assisted Software Development, for adoption context
Best next read
Part 9, AI and Headcount. The spend is budgeted. Part 9 takes the harder question: whether the productivity evidence supports planning a smaller team, and what it actually shows.
The full series
| Part | Title |
|---|---|
| 1 | CapEx, OpEx, and EBITDA: The Same Dollar, Two Different Stories |
| 2 | Reading the Financials: The Primer for Everyone Who Never Had To Care |
| 3 | Capitalize or Expense: Your Jira Board Is Now Audit Evidence |
| 4 | Depreciation and Useful Life: The Chip Outlives Its Economics |
| 5 | Placement Economics: The Right Answer, Applied Everywhere |
| 6 | Lift-and-Shift or Re-Architect: The Two That Modernized Later |
| 7 | Vendor Economics: The Email in November |
| 8 | AI Spend: Three Budgets Pretending to Be One, which is this one |
| 9 | AI and Headcount |
| 10 | Outsourcing After Section 174A |
This series is an introduction for technology leaders. It is accounting and tax context rather than accounting or tax advice. Treatment is fact-specific. Model it with your CFO and auditor before you commit.
Part 8 of 10 · The Money Language Series
The rest of the set
Ten pieces for technology leaders on capital versus operating cost and the decisions that sit on top of it: placement, migration, vendor commitments, AI spend, staffing and sourcing. Each stands on its own, and together they read in order.
- CapEx, OpEx, and EBITDA: The Same Dollar, Two Different StoriesPart 1 of 10 · Start here
- Reading the Financials: The Primer for Everyone Who Never Had To CarePart 2 of 10
- Capitalize or Expense: Your Jira Board Is Now Audit EvidencePart 3 of 10
- Depreciation and Useful Life: The Chip Outlives Its EconomicsPart 4 of 10
- Placement Economics: The Right Answer, Applied EverywherePart 5 of 10
- Lift-and-Shift or Re-Architect: The Two That Modernized LaterPart 6 of 10
- Vendor Economics: The Email in NovemberPart 7 of 10 · Previous
- AI and Headcount: Somebody on the Board Did the ArithmeticPart 9 of 10 · Next
- Outsourcing After Section 174A: Eleven Months to Relearn ItPart 10 of 10
Keep reading
More field notes
This piece is part of the MAX Research Collective library. Browse the rest, or connect on LinkedIn.