We welcome the development of a framework for educational standards. However we do recognise that ‘policing' a framework is not possible in that IFAC member bodies can only implement standards. A set of principles underpinning specific standards will ensure a level of consistency and coherence in the approach taken in individual standards and will act as a fixed grid of reference points for standard setters in the future.
Clarity and readability
The goal of the Framework revision project was to improve clarity and readability
Question 1 : Is the revised Framework document likely to be understandable to the first time readers of the IESs?
The Framework document was felt to be clear, readable and self-explanatory. A few suggestions were made to improve clarity further:
Paragraph 5 (page 11): The Framework is intended to assist IFAC member bodies as they have direct or indirect responsibility for the learning and development of their members and students.
Paragraph 19 could be split, following the style used in Paragraphs 13 and 15, with a new paragraph for the example given.
We agree with the sentiment expressed in the Framework document about the comprehensibility of the terms used and feel that an accompanying Glossary as proposed in the IFAC: Explanatory memo on IAESB Drafting Conventions (March 2009) will be useful.
Initial Professional Development and Continuing Professional Development as markers of career stage
The assumption is often made that ‘pre-qualification' and ‘post- qualification' are universal terms to describe career stages across all international accounting education programs. IAESB have adopted Initial Professional Development (IPD) and Continuing Professional Development (CPD) as alternative markers.
Question 2 : Is the IPD – CPD terminology understandable? Does it have any significant drawbacks?
The adoption of IPD – CPD terminology was felt to be useful.
Clarification of terms
Question 3: Are there any other terms within the Framework document which require further clarification?
No other terms were identified as requiring clarification. However the term ‘University' does not reflect that other institutions can be degree-awarding.
Reflecting the viewpoints from the online survey and focus groups
Question 4: Does the revised Framework document adequately reflect those viewpoints? If not, what are the significant deficiencies?
The Framework document adequately reflects the viewpoints from the online survey and focus groups. It would, however, have been helpful to see a summary of the on-line survey and focus groups viewpoints, together with commentary on how you had responded to these views.
Priority areas for revision and/or additional guidance
IAESB is waiting to be informed by this Framework project before targeting specific standards for revision.
Question 5 : Which, if any, IESs do you believe should be high-priority for revision in light of the revised Framework document?
All IESs would need to be revised to incorporate IPD and CDP definitions.
In priority order:
- IES8 - remove current difficulty with the given definition of ‘audit professional' as a professional accountant who has responsibility, or delegated responsibility, for significant judgements in an audit of historical financial information. Recognise that audit work is generally carried out by teams not individuals.
- IESs 3 & 5 & 7 – as these link most directly to the development and ongoing maintenance of competence.
- IES2 – as this deals with content and it is content that very quickly goes out of date.
Suggested effective date: December 31 2010
IAESB feels this date allows member bodies time to make arrangements for adoption of the Framework.
Question 6: Do you agree with the suggested effective date of December 31 2010? If you do not agree, please provide an explanation of how you would revise the effective date or transitional provisions to achieve that balance.
Yes, we agree with the suggested effective date of December 31 2010. However, we would not want to see the work to review and revise standards in light of the revised Framework delayed until this date.
Comments on Other Matters
No translation issues were noted.