Regulation of Third Country Auditors - Giving Effect in the UK to the Requirements of The Statutory Audit Directive
Comments from ACCA
June 2008
ACCA welcomes this opportunity to comment on the Professional Oversight Board (POB) consultation: Regulation of Third Country Auditors - Giving Effect to the Requirements of the Statutory Audit Directive .
Our comments are limited to the timing of the introduction of the arrangements for registration of third country auditors. We shall let you have our comments concerning other issues raised in the consultation paper by 25 July 2008.
Timing of introduction of arrangements for registration
We do not believe it is absolutely necessary for POB to have arrangements in place to accept and process applications from third country auditors as soon as the Commission Decision on transitional provisions is published (expected to be July).
Article 1 of the draft Commission Decision requires Member States to operate these transitional arrangements with respect to audit reports on accounts for years starting at any time during the period 29 June 2008 to 1 July 2010. In our view, it is the date of the audit report, rather than the date of appointment or the date for implementing the transitional period procedures, which is relevant, thus making immediate application of the new requirements (after the publication of the Commission Decision in July) unnecessary.
Recital 5 of the draft Commission Decision allows third country auditors to 'continue' their audit appointments during the transitional period if they provide the required information to EU Member States. Additionally, recital 6 provides that third country auditors, so long as they provide the required information to Member States, can continue their activities in relation to audit reports concerning accounts for the period starting during the transition period. Third country auditors are, therefore, able to continue with their current terms of office and compliance with the new arrangements will only be necessary in respect of terms of office covering financial years starting on or after 29 June. Accordingly, we believe POB should allow more time to try to use common format application forms with other Member States from the outset.