ACCA welcomes the revisiting of the format, structure and content of the education standards, particularly to allow member bodies to develop better understanding of how to comply with these standards and apply these requirements in their qualifying programmes. The main benefit for member bodies is to see more consistency and logic in the structural content and in the explanatory materials made available. The suggested use of standard instructional verbs is welcomed.
QUESTION 1: Do you agree with the proposed structure for the Standards (Introduction, Objectives, Requirements and Explanatory Materials)?
If you do not agree, what changes would you suggest and why?
The structure works well. It is clear, simple and follows a logical sequence.
It is clearly more logical and sensible to begin with an introduction and to include the scope of the standard and the effective date within that section, before moving to purpose and the detailed content.
Having an objectives section following the introduction is also more logical before going on to the detailed requirements.
It is an improvement to have a separate section entitled ‘requirements’ as this makes it clear that member bodies have an obligation to incorporate these, which gives a clear compliance obligation.
The inclusion of explanatory materials is an excellent idea as this is the best way for member bodies to get an understanding of how the requirements “shall” or “should” be applied or implemented. However, this section needs to be of consistent detail in all standards, so that standards are properly balanced.
Using a ‘taxonomy’ of a few verbs to determine emphasis and compliance is welcomed and will add more force to these standards, but the IFAC Compliance Program may need to allow a “comply or explain’ clause within the Statement of Membership Obligations to allow member bodies to establish why they do not meet certain requirements because of their special or mitigating circumstances.
Paragraph 8: Introduction
We are pleased to see that definitions will appear in a glossary as this makes the standards themselves shorter, particularly when a proportion of the intended audience may already be familiar with these terms.
ACCA welcomes IAESB’s recognition that there are member bodies that do not have direct responsibility for the learning and development of students so some requirements in respect of tuition support and learning development will be beyond the control of those member bodies.
This section clearly reinforces that while IAESB recognises the different structure, jurisdiction and arrangements of member bodies in respect to the delivery of qualifying programmes, there is still an obligation for member bodies to meet the requirements or prepare appropriate action plans to map out how these can be met at some future date.
The IFAC Compliance Program should consider the possibility of introducing some ‘comply or explain’ clauses to permit member bodies in particular circumstances to explain their inability to comply with certain requirements where it may be impractical or inappropriate to do so, so that IFAC can determine whether this is justified or not.
Paragraph 16: Explanatory Materials
It is to be welcomed that this now becomes a separate section of each standard. However, there needs to be clear guidance given to authors around the format, structure, the level of detail and length of these.
QUESTION 2: Do you agree with the proposed categories of requirements and presumptive requirements, and the related obligations they would impose on member bodies?
Please state the reasons that support your response.
The term ‘presumptive requirement’ may not be easily understood by those who have English as a second language. As language has been an obstacle, perhaps there could be a clearer phrase used as presumptive is not considered to be an everyday or common word. Could this term be explained in an easier way? Would conditional requirement work better?
QUESTION 3: The following terms have been proposed in this explanatory memorandum:
- “evaluate” and
Do you agree that these terms (as explained) are understandable?
If you disagree, please indicate what alternatives would you propose and why?
ACCA agrees that these terms are understandable.
Paragraph 20: Discontinue use of present tense
This section did not seem clear. We do not understand the specific connection between students needing to reflect on their work and the use of the present tense within requirements in general. It is not obvious that using the present tense is inappropriate, any more that using the past or future tense. Surely this depends on context.
QUESTION 4: Do you agree with the proposed implementation approach? If you disagree, please indicate what changes you would make and why?
ACCA agrees with the proposed implementation approach.
QUESTION 5: Do you agree that these proposals will help the IAESB to achieve its objective of improving clarity in its pronouncements?
If you disagree, please indicate what changes you would make and why?
We believe that these proposals will help to standardise the language used and will therefore definitely help in improving consistency in application of IESs.
QUESTION 6: Are there any additional steps or actions that the IAESB could take to make their pronouncements easier to (i) translate into other languages, (ii) understand, or (iii) implement?
The term presumptive requirement could be more easily explained which would aid translation to other languages.
Overall, the proposal is clear and it will clarify future requirements and drafts.