ICAS response to proposed amendments to IAASB's International Standards
ICAS broadly supports IAASB proposals but questions timing.
ICAS has now submitted its response to the International Auditing and Assurance Standards Board's (IAASB) Exposure Draft on proposed amendments to International Standards on Responding to Non-Compliance or Suspected Non-Compliance with Laws and Regulations.
Read ICAS' response in full
The IAASB proposals were issued whilst the International Ethics Standards Board for Accountants (IESBA) consultation on proposed revisions to this Code of Ethics was still underway.
Whilst we acknowledge and welcome this approach to align the two projects, we believe that it would have been prudent and more efficient for IAASB to wait until IESBA had finalised the revision of its Code of Ethics before embarking on this project.
Nonetheless, we support the overall approach to only undertake a limited review of International Standard on Auditing (ISA) 250 at this stage. However, a further cautionary comment, based on feedback received from other EU member states, is to highlight that frequent limited changes to the ISAs, which require retranslation in some jurisdictions, create a time-consuming and costly administrative burden. We would therefore suggest that a cost benefit approach should be applied to any future limited changes to ISAs.
As far as some of the more detailed comments in the ICAS response are concerned, these generally focus on the following issues:
- We question whether replacing the word 'responsibilities' with the term 'legal or ethical duty or right' is appropriate. The absence of a clear definition of a 'legal or ethical duty or right' risks creating some uncertainty or ambiguity in the application of the standard and as such we would prefer to retain the more commonly understood term 'responsibilities'.
- We believe that IAASB, as has IESBA, understated the importance of highlighting the need for auditors to be aware of the legal requirements placed on them in relation to the potential offence of "tipping off" in certain jurisdictions. We would suggest that there should be some guidance that refers the auditor to consider the legal and regulatory framework that applies and which serves as a reminder of possible 'tipping off' provisions.
- We believe that the 'tipping off' material should be given greater prominence and therefore should be placed in the requirements section in the main body of the various standards as opposed to the explanatory material.