top stories

IFAC Exposure Draft
Comments from ACCA
February 2007

GENERAL Comments

ACCA welcomes the publication of this Strategic and Operational Plan, 2007-2009 for public comment. The exposure draft gives a concise and accessible description of IAESB's plans for the future. ACCA commends the IAESB for giving its stakeholders the opportunity to input into its planning process.

The exposure draft is useful in that it gives an insight into both the overall strategic plans of the IAESB and also the operational detail of how that strategy will be realised. However, ACCA believes that the proposed plan is rather ambitious and would suggest that additional in-house technical resource or an active strategy of collaboration with appropriate third party bodies to deliver the range of projects is considered as part of the overall three year plan.

The IAESB indicated that it was particularly interested in comments on the matters set out below:

ACCA will therefore provide specific comments on the following four questions.

1. Do you agree that the three proposed projects (a review of the Framework for International Education Statements, developing a benchmarking methodology and a review of existing IESs) should be considered high priority? If not, which projects should be considered high priority?
2. Are the priorities given to the IAESB's further potential projects and activities for the period 2007-2009 appropriate? Which potential projects and activities should, in respondents' views, be addressed first? Please explain.
3. What if any, additional or alternative projects and activities should the IAESB consider undertaking in the period 2007-2009? Please explain.
4. What are the respondents' views on the pace of development of the IAESB's projects and activities?

Specific Comments

QUESTION 1

Do you agree that the three proposed projects (a review of the Framework for International Education Statements, developing a benchmarking methodology and a review of existing IESs) should be considered high priority? If not, which projects should be considered high priority?

ACCA supports the prioritisation of these three areas. However, ACCA would caution against any substantial rewrites of the extant standards given that they are relatively new, many professional bodies are still working towards full implementation. Hasty revision of the relatively new standards could undermine the credibility of these standards. Many professional bodies are experiencing ‘standards fatigue' and the IAESB should, wherever possible, avoid adding unnecessarily to the burden of adoption, implementation and change which is required by new standards.

Although the plan refers to the review being carried out only to determine areas where the clarity of standards could be improved and/or additional guidance most usefully developed ACCA sees a potential danger here if the scope of the exercise is not carefully defined and controlled.

Benchmarking against the existing standards is in its infancy and until a workable methodology has been established it would appear to be premature to change the standards substantially. However, if significant improvements to the framework document can be made this would be welcome. Our priorities therefore are:

• Develop a workable benchmarking methodology
• Revise the framework document
• On the basis of the above revise the standards as necessary.

QUESTION 2

Are the priorities given to the IAESB's further potential projects and activities for the period 2007-2009 appropriate? Which potential projects and activities should, in respondents' views, be addressed first? Please explain.

ACCA strongly endorses the IAESB plans to undertake work in 2007 to develop an IAESB search engine to facilitate access to educational materials. ACCA regards this area of the IAESB's work as essential to be developed alongside a benchmarking methodology in order to provide professional bodies with the tools and support needed to develop their educational provision.

Although an important area worthy of inclusion in the overall plan, ACCA would attach low rather than medium priority to developing guidance to support education and development of accountants training in business. ACCA does not support the development of a separate standard on accountants in business as it believes that the existing standards 1-7 are relevant to accountants generally. ACCA would, however, welcome guidance in this area as to how the standards can be applied to training in business.

ACCA would attach a medium priority to guidance for member bodies in producing and using competency frameworks, linked to learning outcomes.

ACCA agrees on the prioritisation of an IEPS to support IES8 but would not want to see the IEPS restricted to only covering guidance on ‘advanced level' knowledge.

Given IAESB's restriction to three new projects, ACCA would prioritise identifying educational materials, support for IES 8 and guidance for competency frameworks.

QUESTION 3

What if any, additional or alternative projects and activities should the IAESB consider undertaking in the period 2007-2009? Please explain.

The IAESB's role in fostering international debate on emerging issues relating to the education and development of professional accountants is an important one. ACCA strongly supports part b) of the IAESB's focus on ‘undertaking activities to improve the communication of IESs and other IAESB pronouncements, and of the work of the IAESB in general'. This is a critical area and one which could suffer if the IAESB is too ambitious or too hasty in the more tangible projects and activities listed in Appendix 1 and 2, particularly with the current level of resource available to the Board.

ACCA would therefore support additional work on the communications aspects of the IAESB's role as outlined in the strategic plan section on Reporting and Communication, rather than any additional projects and activities.

QUESTION 4 

What are the respondents' views on the pace of development of the IAESB's projects and activities?

For many professional bodies the IESs are still unfamiliar and changes to systems are complex, expensive and slow to implement. ACCA believes that the IAESB is right to focus at this point on promoting convergence to and implementation of the existing IES and communication activities around this, rather than developing further standards or suggesting substantial rewrites to the current ones.

The time of 33 months to deliver an IEPS is obviously restricting the pace of development, although it is accepted that a large element of this time is essential to ensure sufficient time for public consideration and comment. As noted in the General Comments section above, ACCA believes that the proposed overall plan is over ambitious and would suggest that additional in-house technical resource or an active strategy of collaboration with appropriate third party bodies to deliver the range of projects is considered as part of the overall three year plan.

Back to top