May 3, 2018
IFAC (International Federation of Accountants) commissioned Gibson Dunn, a leading global law firm, to perform an independent qualitative and quantitative analysis of the public responses to the Consultation Paper published by the Monitoring Group: Strengthening the Governance and Oversight of the International Audit-related Standard-setting Boards in the Public Interest.
A large number of responses were received from stakeholders from around the world.
· The 179 responses included investors, standard setters, government auditors, regulators, researchers, individuals, accounting firms and professional organizations from a wide range of geographies.
· In any consultation, the input from all respondents must be considered. It should be noted that 74 professional accountancy organizations, or 41 percent of all respondents, felt strongly enough to provide comments. Notably, the overall, main conclusions from the report remained intact even when responses from these accountancy organizations were removed from the analysis.
The Gibson Dunn analysis highlighted marked differences of opinion across geographies and stakeholder groups on key proposals, but included several overall, main conclusions:
· Respondents generally criticized the premise of the Consultation Paper, namely that there are major concerns with the current standard-setting process. Respondents also expressed concern that a Public Interest Framework to evaluate change has not yet been issued and agreed.
· Respondents generally expressed skepticism regarding the broader governance changes proposed by the Consultation Paper.
· Respondents provided significant support for some operational changes proposed in the Consultation Paper.
After carefully reviewing the report IFAC has the following observations:
Broad support and agreement for any Public Interest Framework is necessary before any of the broader governance changes proposed can be properly assessed.
· While there was virtually universal agreement that any changes must be in the public interest, there was significant criticism that the proposed Public Interest Framework has not been released for consultation.
· The Public Interest Framework, agreed by stakeholders, should include multi stakeholder composition of both the standards boards and their oversight bodies, and should provide the umbrella within which all significant proposals can be evaluated and agreed as an integrated package by key stakeholders.
Seeking consensus on proposals which could have a significant global impact depends not only on the merits of the proposals but also on the way the process is conducted; a new multi stakeholder approach is needed.
· The way forward should be under the direction of a multi stakeholder group that will engage all key stakeholders in a broad, open and collaborative dialogue.
· The need for this multi stakeholder group is reinforced not only by the multi stakeholder elements that should undoubtedly form part of the Public Interest Framework but also by the differences of opinion that currently exist across geographies and stakeholder groups.
· Without this approach global agreement and international acceptance is unlikely.
Change and transition can bring significant disruption and risk that must be mitigated.
· Any steps taken must not jeopardize the existing widespread adoption of the International Auditing and Assurance Standards Board (IAASB) and International Ethics Standards Board for Accountants (IESBA) standards, their acknowledged high quality, or the standard boards’ current work plans.
· This concern is particularly relevant at a time when the standard-setting process must deal in a timely way with the impact of changes to complex accounting standards, as well as a rapidly changing technology and audit environment.
· Any changes proposed must be justified on a cost/benefit basis and have widespread international support, particularly as there is general agreement among respondents on the absence of significant problems with the current standard-setting processes.
· Forming a multi stakeholder group to take the process forward should assist in mitigating disruption and risk.
Steps to improve operational processes can and should be taken quickly.
· There is strong support for some operational changes.
· IFAC takes its responsibility to support the operations of the independent standard-setting boards very seriously.
· IFAC is reviewing identified operational areas with IAASB and IESBA leadership and other stakeholders to determine the actions they would agree can be taken now to improve the efficiency and effectiveness of the operations of the two boards in the public interest.
IFAC intends to actively engage with all stakeholders to seek a revised approach to improve the standard-setting process, that responds constructively to the feedback received, and that is:
· Grounded in a Public Interest Framework that needs to be agreed as a first step in the process.
· Under the direction of a multi stakeholder group.
· Designed to minimize disruption and risk.
· Focused on making agreed operational improvements.
IFAC welcomes stakeholders’ reactions to these observations.
Please send any comments to email@example.com.