Comments from ACCA to the Financial Reporting Council (FRC), July 2009.
ACCA welcomes the opportunity to respond to the Consultation Paper Proposed Clarified International Standards on Auditing (UK and Ireland) issued by the Auditing Practices Board (APB) of the Financial Reporting Council.
We express our appreciation for the very detailed information provided in the consultation, which facilitates responses and enhances the UK and Ireland due process for setting auditing standards.
We welcome the proposed substantial reduction in UK and Ireland-specific requirements and guidance from the level in the extant APB standards. This reflects both the success that the APB has had in arguing internationally for a strengthening of auditing standards and also its commitment to convergence towards International Standards of Auditing (ISAs).
We also welcome the announcement that the APB is updating its Practice Note providing guidance on documenting the audit of the smaller entity. This will assist in achieving proportionate and efficient use of the new standards by all types of audit firm.
Our response provides general comments, answers to the specific questions asked in the Consultation Paper and detailed comments on the UK and Ireland supplementary material that remains in the proposed ISAs (UK and Ireland).
We examine the criteria proposed by the APB for inclusion of supplementary requirements (of which there are few) and supplementary guidance. We propose a tightening of the inclusion criteria and explain in detail how that should, in our view, affect the clarified standards. We also comment on the titles of the documents, the way material relating to UK and Ireland companies has been included and the treatment of supplementary guidance on management and those charged with governance.