ACCA responds to consultations

Feedback and insights shape ACCA’s responses to various consultations

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In August and September, ACCA responded to the following consultations:

  • FRC: Firm-level audit quality indicators – the FRC proposed a number of quality indicators to be reported by audit firms auditing a FTSE 350 client or with 20+ Public Interest Entity audits. We broadly supported the proposals, and suggested specific enhancements
  •  HMRC: Raising standards in tax advice – protecting customers claiming tax repayments – HMRC proposed measures to improve transparency for customers, reduce the volume of speculative claims and prevent abuse of assignments. ACCA supported these measures, but highlighted the need for improved taxpayer education about the distinction and benefits of relevant professional qualifications for advisors
  • Ofqual: Regulating alternative academic and alternative technical qualifications at level 3 – the consultation set out proposed conditions, requirements and statutory guidance. We broadly supported approaches to simplification across grading and scales while highlighting the risk of reducing innovation across the examination landscape
  • Charity Commission: Annual Return 2023 – the Commission proposed new questions to the annual return; while we supported the rationale for proposing new questions, we expressed our concern that the Commission has not yet struck the right balance, and raised serious concerns on the lack of guidance on some of the questions.
  • Public Audit Forum: Consultation on Practice Note 10 in public sector auditing – the Public Audit Forum proposed specific updates to PN10 to align with recent updates to UK ISAs issued by the FRC. These proposals expanded the guidance on auditing in a public sector environment, with particular focus on the audit of regularity. ACCA highlighted the need for further guidance and examples in relation to compliance with laws and regulations, and the auditing of non-routine transactions.

ACCA will shortly be submitting responses to HMRC on its ‘digitalising business rates’ proposals, under which ratepayers would be required to provide their tax reference numbers to their local authority (or their business rates reference numbers to HMRC). We will also submit a response to HMRC on its ‘Improving the data HMRC collects from its customers’ proposals, which would require:

  • Self-employed businesses to provide a SIC code for their business in their self-assessment tax return
  • Employers (via RTI reporting) to specify the occupational ‘SOC’ code of each employee, the work address of each employee, and the hours worked by each employee
  • Taxpayers in receipt of dividend income to disclose the amount of dividends received from a close company and the percentage of their shareholding, separate from their dividend income from other sources

If you have any particular case studies highlighting particular challenges with HMRC’s proposals, particularly in relation to self-employed businesses, RTI reporting and dividend income for close companies, please contact Tim Dee on