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Comments from ACCA
ACCA welcomes the opportunity to comment on the above. ACCA is the largest and fastest-growing global body for professional accountants with over 147,000 members and 424,000 students in 170 countries.
We aim to offer the first choice qualifications to people of application, ability and ambition around the world who seek a rewarding career in accountancy, finance and management. ACCA works to achieve and promote the highest professional, ethical and governance standards and advance the public interest.
ACCA agrees that the principles of assessment methodology should apply to both IPD and CPD. As such the assessment scope and approaches must be more flexible to take into account the differing needs of initial learners and those validating or updating their knowledge in continuous professional development as members. An example of this would be the need to have more reflective learning at the CPD stage.
We felt that the extant version was too detailed in its content and effectively involved a lot of repetition with content within IES 2, IES 4 and IES 7. The fact that this is recognised in the revised document is therefore to be welcomed.
Question 1: Is the change in the scope of IES 6 to assessment across Initial Professional Development (IPD) and Continuing Professional Development (CPD) appropriate?
Yes, this is a sensible logical approach, simplifies matters considerably and is consistent with the lifelong learning ethos.
Question 2: Does this change accommodate the different approaches taken by professional accounting organizations?
As mentioned above, consistent with amending the IES to cover lifelong learning, the standard must take a less prescriptive approach than contained within the extant standard. It is also appropriate to recognise within the standard that there are many different assessment approaches which can achieve the same objective of assessing the attainment of professional competence of aspiring professional accountants.
To be consistent with the content of the IES 4 Exposure Draft we suggest that A4 includes reference to assessment of the reflective activities listed in paragraph A17 of IES 4 e.g. record of learning, reflective record, personal development portfolio or critical incident diary. This would also better accommodate CPD assessment, which may well have more emphasis on reflection than IPD.
Question 3: Are the principles of assessment sufficient?
Yes, the principles of assessment are sufficient and explain the differences between reliability and validity clearly.
Question 4: Is the objective to be achieved by a member body, stated in the proposed revised IES 6, appropriate?
Yes, but the final sentence on 'Applying the principle…' appears superfluous. It could be re-written as 'Applying the principles of assessment in the standard contributes to public confidence in the competence of professional accountants' or deleted.
Question 5: Have the criteria identified by the IAESB for determining whether a requirement should be specified been applied appropriately and consistently, such that the resulting requirements promote consistency in implementation by member bodies?
Yes, we feel that the requirements have been applied appropriately and consistently.
Question 6: Are there any terms within the proposed IES 6 which require further clarification? If so, please explain the nature of the deficiencies.
No, the terms are explained clearly.
Comments on Other Matters
Translations - no comments.
Effective Date - We consider an effective date of 12 - 15 months after approval of the final revised standard to be appropriate.
Detailed drafting points
A3 - Change 'and' in the second bullet point to 'or' to indicate that each of these assessment strategies is valid in its own right.
A6 - Is this necessary given that paragraph 4 has already explained that specific aspects of assessment are dealt with in other standards? If this paragraph is necessary, it should not single out IES 7.
A14 - These examples read rather strangely. Suggest redrafting as follows:
There are many ways assessment can be designed to increase its equity, including, for example:
Last updated: 21 May 2013