Transparency reporting by auditors of public interest entities: The statutory auditors (transparency) instrument 2008
Comments from ACCA
March 2008
ACCA welcomes the opportunity to comment on the above. We commented on the earlier consultation document Transparency Reporting by Auditors of Public Interest Entities and in general welcomed the preliminary conclusions set out in the ' Next Steps' document.
We are concerned that the proposed Instrument has to some extent gone against the preliminary conclusion that there should be no imposition of requirements additional to those specifically required by the Directive . This may be, in part, as a result of making changes to the Directive wording where the requirement was felt to be unclear.
As an overall comment, we would prefer to see the Instrument use the Directive wording. Although some requirements lack clarity, this is not a sufficient reason to vary the wording of the requirements from the way they are set out in the Directive . The 'Next Steps' document referred to the development of non-statutory guidance. Were this to be taken forward (in addition to The Audit Quality Framework) it could provide interpretation to resolve any lack of clarity in the wording of the Directive.
The Appendix to this letter is a comparison of the wording of the Directive and of the proposed Instrument , with comment on individual disclosure provisions.
The consultation calls for views on the definition of 'network' in Regulation 1: whether 'through the sharing of significant common professional resources' should be added to the definition in Regulation 34(7) of the Statutory Auditors and Third Country Auditors Regulations 2007. We see no reason why that should not be done as it is included in the definition in the Statutory Audit Directive. However, as that would create differences between the two UK statutory provisions, and as Amendment Regulations have recently been issued (SI 2008 No. 499) we suggest that the Professional Oversight Board and the Department for Business, Enterprise and Regulatory Reform reach agreement over the definition.
