The audit of local authorities in England
In 2010 the Secretary of State for Communities and Local Government announced plans to disband the Audit Commission. This was enacted in The local Audit and Accountability Act 2014, which provided for the abolition of the Audit Commission and established a new framework for the regulation of auditors of local public bodies that reflects the current framework for the regulation of company auditors. Under this new framework, councils and local health bodies procure and appoint their own auditors.
ICAS has been approved by the FRC (Financial Reporting Council) as a Recognised Supervisory Bodies (RSB) for Local Audit, to license, register and monitor audit firms conducting such work.
What are the roles of different bodies, including ICAS?
The responsibilities of the Audit Commission have transferred to other bodies:
- The FRC (Financial Reporting Council) is now responsible for:
- inspecting the quality of the audits of the largest local public bodies;
- overseeing the regulation of auditors of local public bodies by Recognised Supervisory Bodies (RSBs) the FRC recognises for this purpose; and
- setting specific statutory requirements on auditors.
- The National Audit Office is responsible for the codes of audit practice and guidance; and
- The Recognised Supervisory Bodies (RSBs) are responsible for the registration of audit firms and auditors.
When will the new framework become effective?
The first audits to be carried out under the new framework will be the accounts of local bodies for the financial year 2017/18, and likely for year-ends 31 March 2018. As such, firms wishing to bid for these audits will require to be registered under the new arrangements by 2016.
How does my firm become a Local Auditor?
Once ICAS becomes a Recognised Supervisory Body for Local Audit, you will be able to apply to become a Local Audit firm with ICAS.
If you want your firm to become registered for Local Audit, you will need to:
- Nominate an Audit Compliance Principal who is responsible for audit compliance for Local Audits.
- Ensure that at least 50% of the voting rights in your firm and any Management Board are held by holders of an 'Appropriate Qualification'; Registered Auditors; European Economic Area auditors or EEA audit firms (For more information please refer to the Local Audit Regulations. The audit qualification is explained in the 'Key Audit Partner' section below).
- Ensure that all the Principals in the Firm meet the eligibility requirements set out in Regulation 3.4 and that Affiliate applications are submitted for any Principals requiring to become Affiliates.
- Submit an application form for Audit Registration to ICAS (see download below).
- Submit applications for each Key Audit Partner in your firm (see Key Audit Partner Section below).
- Submit applications for each Affiliate in your firm (see above).
- An audit registration fee is payable on application (please contact ICAS for the fee scale).
- Have appropriate Professional Indemnity Insurance in place.
- If your firm is incorporated, please provide a copy of your Articles of Association and ensure that the Articles have the ICAS model wording.
This application covers all firms applying for:
- Local Audit registration with ICAS;
- Local Audit AND Company Audit registration with ICAS.
If you are only applying for Company Audit Registration you can complete the Registered Auditor Application Form: Company Audit which is included on the 'audit registration' page of this website. Search on 'audit registration'.
For information about our Local Audit registration fees please contact email@example.com or 0131 347 0286.
How do Local Audit engagement leads become Key Audit Partners?
Each individual who is responsible for Local Audit work and who signs audit reports, must be designated as a 'Key Audit Partner' ('KAP') for audit work by the Recognised Supervisory Body (RSB) who registers your firm for Local Audit work.
Despite the term 'Key Audit Partner' ('KAP') you do not need to be a principal in your audit firm to become a KAP. Similar to company audit, where an employee can be an Employee Responsible Individual, employees can also be Employee KAPs.
The firm will require to ensure that for each KAP applicant:
- The individual must be an employee or Principal of the Firm and must be nominated by the Audit Compliance Principal responsible for Local Audit;
- The individual must hold an appropriate qualification (i.e. an audit qualification allowed by the Local Audit Regulations - for more information see below) or be an EEA Auditor AND have passed an aptitude test;
- If the applicant is a member of a Recognised Qualifying Body (RQB), the individual must hold a Practicing Certificate, or equivalent, with their RQB;
- The individual must meet all the experience and competence requirements (for more explanation see 'What are the Minimum Experience & Competence Requirements?' below).
- A 'Responsible Individual & Key Audit Partner Application Form' is submitted (see below).
- A 'Local Audit Experience Form' is submitted.
- Responsible Individual & Key Audit Partner Application Form DOCX [146 KB]
- Responsible Individual & Key Audit Partner Application Form (Print version) PDF [361 KB]
- – this form is required for each engagement lead who is going to be:
- a KAP for Local Audit; or
- a KAP for Local Audit And a Responsible Individual for company audit.
- – this form is required for each engagement lead who is going to be:
- Local Audit Experience Form DOC [165 KB]
- Local Audit Experience Form (Print version) PDF [186 KB]
- – this form is required for each individual applying as a Local Audit KAP
- Audit Experience form – this form is only needed if you are also applying to become a Responsible Individual for company audit – please refer to the 'audit registration' page for more information.
What is an ‘Appropriate Qualification’?
It is a recognised audit qualification which, in accordance with the Act, is awarded by a Recognised Qualifying Body or is recognised by the Secretary of State. This includes:
- The audit qualification granted by the Recognised Qualifying Bodies (RQBs) for company audit work. The RQBs are:
- ICAEW (Institute of Chartered Accounts of England & Wales);
- CAI (Chartered Accountants Ireland);
- ACCA (Association of Chartered Certified Accountants);
- AIA (Association of International Accountants); AND
- The audit qualification granted by RQBs for Local Audit work, being; CIPFA (Chartered Institute of Public Finance & Accountancy (CIPFA));
- Any other qualification recognised by the Secretary of State.
If you are in doubt please contact us for advice.
What are the minimum experience and competence requirements which an individual applying to be a Key Audit Partner must demonstrate?
An individual who applies for this role must have:
- Completed, in an Authorised Training Office, a minimum of three years supervised practical training in audit of accountancy, of which not less than six months shall be in local audit, and at least one year in local audit and/or similar audit work;
- Obtained an appropriate qualification;
- Be an employee or principal of a registered firm;
- Within the six years prior to the date of the application, have at least two years post-qualification experience of local audit work and/or similar audit work in a supervisory role; and
- During the two years preceding the date of the application, the individual must have undertaken adequate CPD appropriate to maintaining and developing competence.
Is the integrated audit qualification provided by ICAS and CIPFA required to be approved as a Key Audit Partner?
ICAS is working with the Chartered Institute of Public Finance and Accountancy (CIPFA) to provide an integrated audit qualification which provides a dual designation of CA and CPFA, as well as a dual audit qualification for company audit and local audit. Whilst this qualification is not a requirement for approval as a Key Audit Partner, we believe that this is a significant development for the audit profession and ICAS and CIPFA will deliver excellent education, training, helpsheets and support to local audit firms.
Can current Responsible Individuals for company audit become a Key Audit Partner for local audit?
Yes – subject to the minimum competence and experience requirements detailed above.
Will an individual who previously acted as a Key Audit Partner meet the experience and competence requirements?
Yes – the FRC has indicated that anyone previously acting as an audit engagement lead under arrangements in place prior to The Local Audit & Accountability Act 2014 (such as Audit Commission engagement leads or engagement leads working in audit firms) can be 'grandfathered' in to the new regulatory framework, if their experience and competence is sufficient, without having to have met the practical training requirements. Individuals who could be grandfathered in will still need to provide evidence of their experience for assessment even though the practical training requirements do not have to be met.
What is involved in applying to become an affiliate?
We need to ensure that all principals who are not members of a Recognised Supervisory Body (and are not UK or RoI Registered Audit firms) are regulated by ICAS by becoming Affiliates.
To apply for Affiliate status the firm needs to submit an Affiliate Application Form for each applicant.
What happens after we submit our application?
The ICAS team will aim to process your application within two weeks of receiving it, unless your firm is large or there are any complexities in your application. If we think that it will take longer, we will keep you informed.
Please note that each application requires to undergo a detailed checking process including consideration of fit and proper status and, for Key audit partners, competence and experience. There is no automatic approval, given the public interest element nature of audit applications. You will be notified when a decision has been made. However, you should note that the following circumstances could delay the application:
- If you have not provided all of the information required we will contact you to request this information. This could delay your application being processed. We will let you know how this affects your application timescales.
- For less straightforward applications, the Authorisation Committee (AC) may need to consider the application (for example concerns over eligibility, potential fit and proper matters or concerns over audit experience). This may take a bit longer as the AC meets six times a year. We will let you know how this affects your application timescales.
- We are here to help. If you would like to know the status of your application at any time please contact Regulatory Authorisations on 0131 347 0286 or via email at firstname.lastname@example.org.
What happens once my firms is registered?
Once you are registered there are a number of obligations that you will need to fulfill. We are here to help, so please contact us if you would like advice or support. Your firm will need to:
Are you changing the legal status of your firm?
If your firm is changing legal status (for example incorporating or becoming an LLP) you will need to submit a new application form for Local Audit Registration. You will not need to submit 'Key Audit Partner' ('KAP') applications or Affiliate application for any existing KAPs and Affiliates transferring over from the old firm to the new firm. Any new KAPs or Affiliates would need to complete an application form.
What happens if my application is denied?
If your application is denied:
- You will be notified of the reason for this decision.
- If you are unhappy with this decision, concerns should be notified in writing to the Director of Regulatory Monitoring in the first instance and this will be considered by the Authorisation Committee (AC). (Please email email@example.com or phone 0131 347 0286).
- If you are dissatisfied with the ARCs decision, there is an Independent Review and Appeals process, which is explained in Section 5 of the Local Audit Regulations (see the Local Audit Regulations).
How to access the public audit register
The Register of Local Auditors contains information on Audit Firms and Key Audit Partners that are registered to conduct Local Audit work in the UK.
The following information is available on this Register:
- Contact details for all Recognised Supervisory Bodies (RSBs) and details of firms registered by them.
- Details of Local Audit Registered Firms, who registers them and the individuals linked to them.
- The full address of the registered firm, the RSBs and the individual details.
What are the Local Audit Regulations?
All Local Audit firms, 'Key Audit Partners' and audit staff involved in Local Audit work are required to comply with the Local Audit Regulations.
Help and support
ICAS will keep you informed of any Local Audit developments through our quarterly editions of Audit News.
We will provide more help and support as the Local Audit regime evolves, to meet any highlighted demands.
How do I complain?
If you are not happy with the service you have received from us in respect of your applications please contact the Director of Regulatory Monitoring in the first instance on 0131 347 0286 or email and they will revert back to you.
The EU Service Directive and The Provision of Services Regulations
In accordance with the requirements of the EU Services Directive, which was brought into UK law by The Provision of Services Regulations 2009, information is available about the rules, regulations and formalities that apply to service activities in other EU countries. This information can be found through Points of Single Contact (PSCs), which are online e-government portals. Guidance is available on the UK Government's website.
Any enquiries regarding Local Audit registration should be addressed to firstname.lastname@example.org or 0131 347 0286.