Change to the ICAS code of ethics: NOCLAR

Ethics: sunlight on boardwalk
By Ann Buttery, Head of Ethics, Policy Leadership, ICAS

3 October 2017

Ann Buttery reports on one of the main changes to the ICAS Code of Ethics, which takes effect from 1 November 2017.

ICAS is revising its Code of Ethics. The revised Code will apply from 1 November 2017. Read more here

One of the main changes to the ICAS Code is the introduction of the International Ethics Standards Board for Accountants (IESBA) content on what a professional accountant should do if they encounter actual or suspected “Non-Compliance with laws and Regulations (NOCLAR)” at their client or employer (new Sections 225 and 360 of the Code respectively).

Laws and Regulations

The laws and regulations which are relevant to the professional accountant for the purposes of the NOCLAR guidance are those which have a direct impact on material items in the financial statements, or are fundamental to the organisation’s operations.

The NOCLAR provisions in the Code do not take precedence over local laws and regulations regarding the reporting of actual or suspected non-compliance with laws and regulations.  If there is a conflict between local legislation and the provisions of the Code, the professional accountant must adhere to local legislation. Therefore, CAs must always be aware of the disclosures that could amount to “tipping-off” under the UK Anti-Money Laundering laws and regulations.

NOCLAR framework

The underlying principle of NOCLAR is the same for all professional accountants i.e. they should respond to an issue and not turn a blind eye.  However, NOCLAR has different requirements depending on the particular role and level of seniority of the professional accountant.  Four categories of professional accountant are distinguished and specific steps are identified for each.  The classifications are:

  • Auditors.
  • Other Professional Accountants in Public Practice (PAPP).
  • Senior-level Professional Accountants In Business (PAIB).
  • Other Professional Accountants In Business.

Greater responsibility is placed on auditors and senior-level professional accountants in business.

Further guidance on implementing NOCLAR is available via the IESBA website


  • Ethics and integrity research

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