Statutory audit requirements for smaller companies
The DTI’s consultation paper on the future of the audit threshold
Comments from The Association of Chartered Certified AccountantsIntroduction and Executive Summary
The Introduction to the consultation paper published by the DTI states that “the key question is not whether an audit is desirable and/or valuable for companies, and smaller companies in particular, but whether the balance of costs and benefits supports a mandatory requirement for an external audit for companies of a certain size”. The central section of this response comments, therefore, on the “burdens” and “possible benefits” of the statutory audit as set out in sections 4 and 5 of the consultation paper.
The issues cannot be discussed in purely financial, quantitative terms, however. There are qualitative considerations which must be given due weight, and these provide the context in which costs and benefits must be assessed. These are considered under the heading ‘The Statutory Audit’.
The key points in this response are set out below.
- ACCA believes that the statutory audit for small companies brings benefits which exceed its cost.
- Mandatory external audit helps to
enforce the obligations which are placed on companies and their
directors in return for limited liability.
- Mandatory external audit also helps to
ensure the reliability of published financial information.
- External audit reinforces sound
financial management and corporate governance - which are both
essential to a company’s health. Many companies will
choose to take advantage of audit exemption on the grounds of
cost alone, and will not replace the audit with other services
from professionally qualified practitioners. They will,
therefore, lose the advantages which audit brings, and it is
widely accepted that inadequate financial management is a major
element in small company failure.
- The cost of audit is small compared to
that of other statutory regulations bearing on small companies.
In contrast to external audit, few of these regulatory burdens
bring direct or indirect benefits to the companies themselves.
- The argument in the consultation paper that the key issue is one of costs versus benefits is flawed. Whereas the costs of the external audit are comparatively easy to identify, and are not very great, most of the benefits cannot be quantified. If the parts of the proposed “mathematical model” are examined properly, the scales are not weighted so heavily against audit, if indeed at all. The benefits flowing from audit include the facts that:
- published accounts are more reliable
- fraud within and on companies is deterred
and - alternative checking procedures may
be more costly to the company or third parties which seek
reassurance, or both.
- The issue of audit exemption should not
be considered in isolation from the wider issue of company law
reform. Raising the audit exemption threshold as a ‘quick
fix’ risks giving rise to inconsistencies when the legal
framework is revised. It would also restrict the freedom of
manoeuvre of the Company Law Review to re-evaluate the nature of
the small company audit and its relevance to companies and their
stakeholders.
- Turnover should not be the only
criterion for exemption. Other factors, such as the existence of
minority shareholders or significant unsecured creditors, should
also be taken into account. Consideration should be given to
requiring shareholders to approve opt-out by the company or to
requiring all minority shareholders to subscribe to a waiver of
their right to receive audited accounts.
- There is an observed lack of financial
management awareness across the SME sector - particularly at the
lower end of the size scale. Exempting still more companies from
the external audit requirement raises the question of how the
residual responsibility of directors to file accounts showing a
true and fair view can be applied and monitored.
- The UK operates a far more liberal
company formation and capital regime than most other countries
referred to in Table 2 of Annex B in the consultation paper. We
do not consider that it is appropriate to consider audit
exemption in terms of simple accounting criteria and in
isolation from the other regulations affecting the operation of
small companies in those countries.
- Many small, local practices which have hitherto provided the bulk of accountancy services to small businesses may, over time, cease to carry out audit work. This will reduce choice severely for those small entities which retain the audit on a voluntary basis.
This response does not set out to suggest any new audit exemption limits, and, indeed, we cannot find any logic to support audit exemption purely on the grounds of turnover. Rather, our response argues for the continued application of the mandatory audit requirement to the widest possible range of companies, subject to certain changes to company law such as reduced filing periods and the introduction of minimum capital requirements. If, however, an increase in the threshold is seen as necessary, we urge the Government to delay the increase for some considerable period until the impact of audit exemption on all sections of business and society can be assessed.
1. The Statutory Audit
1.1 We believe that external audit brings important benefits for companies themselves, as well as for regulators, shareholders and other stakeholders. The statutory requirement for an audit is a major contributor to efficient management of companies, a significant disincentive to fraud, a stimulus to openness and transparency and a highly effective driver for the promotion of good corporate governance.
Limited liability issues1.2 The owners of limited liability companies of all sizes enjoy a series of advantages which arise solely from their limited liability status. The original purposes of the statutory audit remain valid. As the SME sector has developed, however, and as the limited liability company has been adopted as a tax-efficient and popular business vehicle, the statutory audit for small companies where the owners and managers are the same has come to fulfil an additional public interest role. The fact that this was not anticipated by the legislators does not make it invalid. External scrutiny of the financial statements helps to encourage company directors, who may also be the shareholders, to fulfil their obligations under the Companies Acts and other legislation.
1.3 The consultation paper accepts that audit increases the reliability of accounts and thus their value to users. We consider that, as long as there is a requirement for companies to publish their annual accounts, there should be a regulatory control to ensure the reliability of the information placed on the public record. We see the protection of the wider public interest as being one of the core functions of company law. As far as disclosure is concerned, a company makes public prescribed financial and narrative information on its activities as a consequence of its acceptance of the privileges of limited liability status.
Financial management issues
1.4 Paragraphs 48 and 49 of the consultation paper touch on what are termed the general benefits of the audit, namely the inculcation of honesty and integrity in company management and the assurance of the quality of the accounting information which is placed on the public record.
1.5 These arguments could and should be extended to encompass the value of the external audit in terms of promoting high standards of financial management in smaller companies. According to the Society of Practitioners in Insolvency (SPI), the biggest single cause of company failure remains the lack of financial and managerial skills on the part of the directors and managers of smaller companies. SPI reports that, in 1998, 40,000 jobs were lost directly because of financial mismanagement, which includes failure to keep proper control of cashflow and working capital. These figures do not take account of jobs which may be lost through the knock-on effects of failure on other businesses. Clearly, therefore, the lack of financial expertise among smaller companies is a problem which has tangible economic and social consequences.
1.6 While the audit process does not of itself provide companies with professional help in organising and planning their finances, Auditing Standards require auditors to report to client management any significant defects in the financial and accounting structures which have come to their attention during the course of the audit. An exempt company does not have the benefit of regular professional input of this kind. In our experience, too, the audit relationship routinely leads to further consultation between the client and auditor on additional matters. While there is nothing to prevent exempt companies from securing specific professional advice, we believe that this is less likely to happen where there is not a trusted, on-going professional relationship.
1.7 In its other recent initiatives, the Government has acknowledged that lack of in-house financial and managerial skills is a serious problem which is holding back many UK businesses. The recent consultation paper from the Insolvency Service on company rescue mechanisms accepts that the failure of management to respond to financial threats is often an important contributory factor in the eventual insolvency of the business. The document adds that owner-managers in smaller companies may lack the range of skills needed (to take appropriate remedial action) and that, anyway, since they are usually heavily involved in the production or supply of the company’s goods and services, they may not have the time, energy or inclination (our italics) to attend to the detail of the company’s finances. This is the extreme - though arguably inevitable - consequence of a business declining to obtain proper financial advice.
1.8 It is not reasonable to expect all small companies to have in-house financial and accounting expertise. This is not to say that, on behalf of all the company’s stakeholders, the law should not expect such companies to conduct their financial affairs in accordance with high standards. We believe that a statutory requirement for a company to be audited fills this gap not only by exposing companies to the discipline of the independent audit but also by establishing a professional relationship which can be exploited to the on-going advantage of the business.
1.9 It seems inconsistent to us that the DTI is, on the one hand, arguing for better management of businesses, especially SMEs, while, on the other, it is contemplating the removal of the single most effective method of promoting corporate financial dicipline.
Supply side issues
1.10 In practical terms, a substantial increase in the audit threshold is likely to result in a much more restricted choice of auditors in some areas, if not a near monopoly. If the majority of smaller companies entitled to do so then elect not to commission an audit, many smaller High Street audit practitioners will cease to carry out audit work and will be ineligible to train audit staff. Ultimately, only a comparatively small number of larger firms will be able to offer audit services. The creation of an oligopoly of audit service providers, which could develop into a cartel, cannot be in the public interest. Well-managed businesses, which operate good systems of corporate governance including the retention of external audit on a voluntary basis, may in the future be denied their traditional choice of auditor from among local, small practices. Less competent enterprises, on the other hand, will be allowed the benefits of limited liability while being subjected to none of the necessary regulation.
1.11 Although small firms of accountants may continue to offer a wide range of business services after withdrawing from audit work, their range of activity will be restricted. There are many laws and regulations which currently require some form of assurance to be provided by persons who are qualified as registered auditors (see Appendix 2 to this submission). Quite apart from the fact that many accountants will cease to be so qualified, they could lose the ‘audit’ skills which render their reports valuable to users. Government and grant providers, to name just two interest groups, need reassurance that small businesses are properly accountable. The audit probably remains the most cost-efficient alternative to increasing red tape.
De-regulatory issues
1.12 We believe that it is disingenuous to promote audit exemption as a deregulatory measure which will relieve small companies of an unnecessary cost. At the same time as the Government is consulting on the need for statutory audit, we note that the costs to small companies of acting as tax collectors for the Government in relation to PAYE, VAT, student loans, and the Working Family Tax Credit, for example, are considerably greater than those imposed by audit.
1.13 There is a broad consensus that the regulatory burden on small businesses has increased significantly since 1997. In September, the Small Business Research Trust produced a survey showing that 15% of SMEs now highlight red tape as their most serious problem (the second biggest problem after inadequate turnover). Ten years ago this issue ranked a poor sixth or seventh in similar polls. Accountants Chantry Vellacott estimate that the compliance burden has increased by 15-20% over a two and a half year period. ICAEW suggests that a business with a turnover of £1,000,000 per annum faces an additional £5,000 compliance bill.
1.14 Some individual measures, such as the improved employment and parental rights and the Working Families Tax Credit, are positive and fair. Collectively, however, the range of new burdens introduced has imposed a substantial cost burden, which weighs disproportionately heavily on the smallest businesses and will continue to do so.
1.15 The weight of bureaucracy created by the taxation and NI/PAYE systems also imposes considerable burdens on SMEs. We believe that they far exceed the cost of audit but have generally still to be tackled.
1.16 In the early 1990s, the Global Entrepreneurship Monitor (GEM) identified the UK as the only significant economy where business believed that regulation had a neutral impact on business growth. The most recent GEM survey has signalled a shift in opinion. There are increasing concerns that regulation from Whitehall and Brussels is a drag on the economy. Many of these concerns have been shared by the Government’s own Better Regulation Task Force. On the scale of concerns considered by these two authorities, the small company audit ranks very low as an impediment to growth.
2. Cost Burdens and Financial Benefits
2.1 The consultation paper indicates that “the Secretary of State’s initial view is that there is a good case for a significant increase in the [audit exemption] threshold” on the grounds that the statutory audit is an unnecessary burden for smaller companies. ACCA does not concur with this view.
2.2 The consultation paper suggests that the audit exemption question can be reduced to a mathematical exercise, of weighing costs on the one hand against benefits on the other. A simplistic approach has taken a figure which is said to be the average cost of an individual audit and multiplied this by the number of companies which would be exempt from audit were the threshold raised to, say, £4.2 million; this is suggested to be the annual saving to small businesses. And because the benefits of audit are less easily identified and measured, they appear to have been given a zero value in the equation. We readily understand how an erroneous initial view could have been formed on the basis of such partial arithmetic.
2.3 To provide a balanced view, the equation needs to be refined into the following parts:
- direct cost of the audit, defined as
the amount charged for audit work by the auditor
- indirect cost of the audit, defined as
the time and money spent by the audited entity in dealing with
audit requirements
- direct benefits of the audit, defined as
quantifiable inflows to the audited entity resulting from the
audit process
and
- indirect benefits of the audit, defined as access to long-term and working capital, savings resulting from better financial discipline and other values attributed to the audit.
2.4 Even this equation, however, is incomplete if it fails to take into account the question ‘cost/benefit to whom?’ It is widely recognised that even the smallest companies have some stakeholders beyond the people who own and manage them. These other stakeholders may be grouped under the single heading ‘the public interest’, and any consideration as to the merits of retaining the statutory audit requirement must include an assessment of the cost/benefit to the public interest. Here, the balance of the simple equation is the opposite of that for the audited entity: there are no obvious direct or indirect costs attributable to the audit, but there are substantial benefits, including the cost saving of not having to pay for an alternative form of assurance and avoidance of the risks which exist when there is no external check on an entity’s activities. This submission considers each of the components of the equation in turn.
Direct cost of audit to the audited company
2.5 A short questionnaire on costs and audit adjustments was sent to a sample of ACCA members practising as registered auditors. The survey results suggest that the average marginal cost of audit to companies with turnover between £350,000 and £750,000 is £1,141, compared to £1,590 for accountancy work. For companies with turnover between £750,000 and £1 million, the average fees for audit and accountancy services rise to £1,519 and £1,926 respectively. Even for companies with turnover between £2 million and £4.2 million, the average marginal cost of an audit is £3,079. A summary of the survey results is contained in Appendix 1 to this submission from which it can be seen that the cost of audit to small companies is much lower than the figure of £5,000 quoted in paragraph 34 of the consultation paper.
Indirect costs to the audited company
2.6 We accept that the audit imposes some indirect costs in addition to direct costs, such as:
- the cost of the bank letter and other
‘certificates’ required by auditor from third
parties - depending on the number of banks with which the
company deals, this is usually between £20 and £50
- the time cost of staff dealing with
audit queries and explaining accounting and related systems to
audit staff; a similar amount of time is likely to be spent if
the annual accounts are prepared by an independent accountant
- the time spent by staff preparing schedules specifically for auditors; this would not include schedules such as aged debtor analyses, which should be available from a good financial management system, while most so-called ‘audit schedules’, which are largely accounting and tax schedules needed to support the annual accounts, would still be necessary.
Direct benefits of the audit
2.7 Some inflows of economic benefits to the company may be directly attributable to the audit process, for example:
- a detected fraud or loss which results
in a full or partial recovery
- an audit recommendation regarding the
methods utilised for disposing of scrap/ waste materials or
retired fixed assets
- a recommended change in payment times
or contract terms to achieve more favourable discounts
- a review of taxation payments and liabilities which uncovers Revenue errors.
2.8 This list is by no means exhaustive. The fact of the matter is that such direct benefits do occur on a regular basis but are seldom quantified or aggregated. It seems to us that these direct benefits are more likely to be enjoyed by those SMEs whose size militates against the employment of qualified accounting personnel.
Indirect benefits of the audit
2.9 As the consultation paper states, the statutory audit acts, indirectly, as an assurance for stakeholders generally that the company has complied with its reporting and disclosure obligations. Given their respective interests in the reliability of financial reports, Companies House and the Inland Revenue are clearly stakeholders. Due to the lack of any significant procedure for the monitoring of incoming accounts by Companies House, financial statements which are submitted by companies which have taken advantage of audit exemption, will have been given no expert and/or independent scrutiny before they are placed on the public record. This has obvious implications for the reliability of publicly available information. External audit reduces the risk of material errors and mis-statements in annual accounts.
2.10 A majority of members responding to the questionnaire referred to in paragraph 2.5 above estimated that they had to make adjustments to accounts prepared by more than 75% of their clients in respect of matters such as depreciation, accruals and prepayments, stock valuation, bad debts, and accounting errors. More than a third of those surveyed responded that the accounts for all their clients needed to be revised in respect of one or more of these items. A summary of the responses on accounting adjustments is included in Appendix 1. We recommend that, as a minimum to protect users of accounts, unaudited accounts filed on the public register should be identified as such by the addition of the word ‘unaudited’ printed in a prominent place on each page.
2.11 The consultation paper acknowledges at paragraph 31 that the statutory audit is a significant deterrent against fraud. Although the paper goes on to comment that it is not easy for auditors to detect fraud organised by management, this does not mean that auditors do not find management fraud. We suggest that the ability of company managers to commit fraud will be greatly increased if their companies are exempt from the audit requirement.
2.12 The audit also serves to protect employees in companies where managers might be tempted to misappropriate payroll deductions such as pension contributions to pay company or personal liabilities. Auditing Standards require auditors to consider the possibility that the financial statements may be affected by contraventions of applicable law and regulations. But companies which are most likely to be affected by financial mismanagement are those that will take advantage of audit exemption as a way of saving costs. Employees could suffer as a result of the increase in the audit threshold - the higher the threshold, the greater will be the number of employees.
2.13 Possible detection of employee fraud is a further indirect benefit of audit: our members’ experience contradicts the view further expressed in the consultation paper, that “detecting fraud by employees will usually not be material to the accounts”.
2.14 The 1998 MORI research commissioned by ACCA (the MORI study) showed that, for the vast majority of lenders, the willingness to allow independent professional scrutiny of a business was a pre-requisite for financial support. Other stakeholders, such as suppliers, creditors and prospective partners, appeared from the MORI survey to derive greater confidence from the knowledge that a business has been audited. The 1998 MORI survey confirms soundings which have been taken separately by ACCA.
2.15 The statutory audit brings a direct cost saving to third parties if they would otherwise have to commission and pay for their own ‘audit’ or other form of external review of the company’s accounts. A specially commissioned audit may be more costly, as the auditor will need to consider the purpose for which the work has been commissioned and possibly carry out more detailed, or additional, procedures to meet specific objectives. Such an audit is also likely to be more expensive for the company if its accounts have not been audited in recent years.
2.16 There will be cost savings for companies which have their accounts audited under the Companies Act and which have dealings with third parties with the muscle to require some form of ‘certification’ of the figures reported, for example:
- the Inland Revenue, vis a vis tax
credits and energy saving incentives
- central or local government as grant
provider, to give assurance that the applicant is eligible for
funding and that money is being properly spent
and
- creditors such as major finance providers and trading partners.
2.17 We accept the argument presented in the consultation paper that the credibility of the audit report to non-member readers suffers to some extent because of the long delay between the accounting year-end of a small company and the time of its filing. The long, ten-month filing period which currently applies is, however, a separate issue and must not be used as an argument against the value of the audit report to readers. The issue of filing deadlines is being specifically addressed by the Government’s Company Law Review project and it is possible that the Steering Group will put forward recommendations in due course on whether reporting deadlines generally should be brought forward in the interests of making company reports more relevant to readers. ACCA itself has responded to the Company Law Review consultation paper by favouring a reduction in the filing period to a maximum of six months.
3. Other Issues
The Company Law Review
3.1 The audit threshold proposals cannot be taken in isolation. They must be seen in terms of the wider reform of company law. This is a longer-term fundamental review and, quite obviously, does not fit in with the timetable of the audit thresholds initiative. Some correlation should, however, be made, since a discrete decision on this single proposal is incompatible with the Government’s broader objectives. The question of the mandatory audit for smaller companies is not as clear cut, nor is the alleged burden so great, as to justify an immediate, or even a short-term, response.
3.2 In our response to the consultation paper issued by the Company Law Review Steering Group, we argued that the statutory audit should be seen as a standard quid pro quo for the award of limited liability. A logical extension of our argument is that the purpose of, and therefore the legal requirements for, the statutory audit should be reviewed and changed if necessary to bring them more into line with current expectations and circumstances. We consider that it would be wholly unacceptable to raise the threshold to any great extent in the short term, only to have to re-impose the requirement on at least some small companies in the longer term because a modified form of audit had been devised in the public interest.
Criteria for exemption
3.3 ACCA does not accept that entitlement to audit exemption should depend only on a company’s reported turnover. Turnover is not the only criterion - indeed, other criteria, such as the existence of shareholders not involved in management or indebtedness to third parties, may be more appropriate. We recommend that, as well as not exceeding any turnover threshold, an audit should be required if unsecured creditors exceed a stated maximum, which should be set fairly low. The criteria for audit exemption should include either a specified gearing ratio, or a stated minimum solvency, as well as a minimum paid up capital. Such criteria would be consistent with those applied to companies in other European countries.
3.4 The paper asks for views on a reduction from 10% to 5% of the percentage of share capital needed to require an audit . We support such a reduction. We should, in addition, prefer there to be a requirement for a positive vote by the resulting 95% of members of any newly exempt company to opt out of audit. Under the current procedure, inertia or ignorance may mean that members not involved in management do not exercise an informed choice as to whether to have an audit or not. An alternative to a formal vote would be a requirement for every minority shareholder to sign a declaration waiving the right to receive audited accounts.
The role of audit in other EU countries
3.5 In Annex B, the consultation paper presents details of the audit exemption criteria in other EU countries. It also touches on the fact that countries which have more generous audit exemption regimes may have requirements for corporate bodies to have a minimum retained capital.
3.6 The minimum capital rule is, in fact, standard for limited companies in all but two EU member states. In Germany, the minimum share capital for the equivalent of a UK private company is DM 50,000, of which 50% must be paid up on incorporation. In France, the equivalent minimum capital is FF250,000 all of which must be paid up within five years of incorporation. It is also the case that, in most other EU countries, there is a wider range of business format from which to choose.
3.7 These capital requirements may be said to serve two purposes. First, by demonstrating that a company has a strong financial base, they give reassurance to customers and clients and provide a potential source of funds should the company have difficulty in meeting its liabilities as they fall due. Secondly, they serve to concentrate the minds of their proprietors at the incorporation stage. It seems very possible to us that, if incorporators are required to invest substantial sums as start up capital, they will approach their duties and responsibilities very seriously. Neither of these considerations can be said to apply in the UK. Since it is possible to start a company here with unpaid share capital of just £1, there is less inherent financial credibility in the average UK company than is the case in other EU countries.
3.8 Given, therefore, that the UK operates a far more liberal company formation and capital regime than most other partner countries, we feel that it is not appropriate to consider audit exemption criteria in terms of simple accounting criteria and in isolation from these factors. ACCA itself advocates the introduction of a minimum capital requirement.
Appendix 1 - The cost and benefits of audit for smaller companies
Results of the questionnaire survey
Introduction
1. Paragraph 34 of the consultation paper issued by the DTI contains the sentence “One estimate puts the typical cost of an audit for a £1M turnover company at around £5,000 or 0.5% of turnover”. The paper then extrapolates this figure to a potential saving of £500 million a year to the small business sector if the exemption threshold were raised to £1M. The DTI has made cost issues central to its consultative document, so ACCA has set out to establish what the marginal cost of audit really is to small companies.
2. A short questionnaire was sent to a sample of ACCA members who are listed as having registered auditor clients. The sample group were telephoned before the questionnaires were sent out, to check that they had audit clients (a number of members are registered auditors but do not carry out any audits), and that they were willing to help ACCA on this matter. This ensured a maximum response rate.
3. The questionnaire focused on two main issues: the identifiable cost of audit, and the frequency of accounting adjustments arising as a result of the audit process. The responses to the survey are set out in the two tables on the following pages.
The cost of audit
4. The questionnaire asked practitioners to estimate the breakdown of the annual statutory audit fee into audit and non-audit elements. The table on the next page summarises the responses.
Average audit fee for auditing statutory accounts
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Most small company engagements include some accounting work and some audit work. Nevertheless, the two types of work are often combined for billing purposes and for practical purposes the aggregate amount is often called the audit fee.
The results indicate that initial estimates of cost savings of £5,000 per company were greatly exaggerated. The average cost of audit was shown to be much lower than the £5,000 quoted when the question of raising the audit threshold was first mooted. Whilst it must be borne in mind that - in reality - there is no such thing as an “average audit fee”, since the work on an individual assignment will vary according to factors such as the sector in which the company operates and the nature of the company’s management, the cost to companies even in the £2 to £4 million bracket is little more than £3,000.
Audit adjustments
5. The questionnaire also asked how often practitioners needed to correct figures prepared by their clients. The objective was to establish the likely reliability of unaudited accounts filed on the public record.
Percentage of auditors reporting on accounts (prepared by the clients themselves) which needed to be adjusted for accounting errors
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Some respondents pointed out that they would make the adjustments whether they were carrying out an audit or simply preparing accounts. Whilst our members should be expected to prepare accounts to the highest standard, however, there is no guarantee that companies which are exempt from audit will continue to employ firms of qualified accountants to prepare their annual accounts. They may decide they can manage on their own, or appoint cheaper, unqualified firms.
Appendix 2 – Legislation requiring reports to be given by persons eligible for appointment as company auditor
Statutory Instrument No. 1997 of 1991 contains a schedule of enactments which were amended following the implementation of the 1989 Companies Act. The effect of the amendments was to substitute the words “[a person] eligible for appointment as a company auditor under section 25 of the Companies Act 1989” for the previous requirement for accounts to be reported on by a member of one of the accountancy bodies named in the legislation. The legislation includes:
- Friendly and Industrial and Provident Societies Act 1968 (as amended)
- Friendly Societies Act 1974 (as amended)
- Industry Act 1975 (as amended)
- Theatres Trust Act 1976
- Estate Agents Act 1979 (as amended)
- Education (Scotland Act 1980) (as amended)
- Housing Acts 1985 and 1988
- Housing Associations Act 1985
- Landlord and Tenant Act 1985 - amended by section 41 of and Schedule 2 to the Landlord and Tenant Act 1987
- Income and Corporation Taxes Act 1988
Legislation made after 1991 includes the Charities Act 1993 and the Pensions Act 1995, and related Regulations.
In addition, there are non-statutory requirements for reports by persons eligible for appointment as company auditors under the Companies Act 1989, for example the Solicitors’ Accounts Rules 1998, issued by the Law Society (England and Wales).