Third Country Auditor Deregistration Procedures

ACCA has responded to a public consultation issued by the Financial Reporting Council (FRC) on Third Country Auditor Deregistration Procedures.

ACCA welcomes the opportunity to comment on the proposed procedures.  The FRC has the power to remove a third country auditor (TCA) from the register of third country auditors in the circumstances set out in section 1246 and Regulation 12, including where the TCA’s application statement to the FRC made pursuant to Regulation 8 is no longer correct or where the FRC considers that the TCA has failed to comply with certain statutory duties. We note that there is no statutory requirement to have procedures in place for the de-registration of TCAs, and that the procedures in Appendix A to the public consultation (which are non-binding) have been developed with the objectives of consistency, efficiency and transparency.  Our response to this public consultation has been prepared with the same objectives in mind.

Although we note that ‘[t]he Procedures have not been prepared in response to the outcome of the UK EU referendum’, the UK’s exit from the European Union (‘Brexit’) would be expected to have an impact on the outcomes of this public consultation. After Brexit, there may be no difference between TCAs and European auditors from a UK perspective. We must assume that audit regulation in the UK will align as closely as possible to that of Europe. If this is not the case, the requirements of the UK in respect of TCAs could become extremely onerous.

Our detailed comments in respect of specific questions to which we responded within the consultation are set out in the attached document.