Comments from ACCA to the International Accounting Education Standards Board.
17 April 2014
ACCA supports the revision of this IES 8. The proposed revisions are preferable to the previous standard.
1. Is the Objective statement (see paragraph 9) of the proposed IES 8 Exposure Draft (December 2013) appropriate and clear?
2. Is the Requirement (see paragraph 10) of the proposed IES 8 Exposure Draft (December 2013) appropriate and clear?
3. Do you agree with the proposed learning outcomes provided in Table A?
Yes, however the personal characteristics are a little light, primarily in j and k of Table A. While there is a base line on technical knowledge that is well captured, to ACCA the audit partner role is all about how this is applied. This is primarily in the CPD camp from an educational perspective, and unlikely to be met by formal courses.
4. Do you agree that levels of proficiency for the competence areas should not be included in Table A?
Yes, including levels of proficiency would cause unnecessary complication.
5. Are there any additional explanatory paragraphs needed to better explain the requirement of the proposed IES 8 Exposure Draft (December 2013)?
6. Does figure 1 of Explanatory Material section for the proposed IES 8 Exposure Draft (December 2013) assist in understanding which stakeholders have responsibilities that impact the professional competence of engagement partners?
The inclusion of Initial Professional Development should be reflected as the engagement partner would be building on initial audit skills.
Question 7. Are there any terms within the proposed IES 8 Exposure Draft (December 2013) which require further clarification? If so, please explain the nature of the deficiencies?
Question 8. Do you anticipate any impact or implications for your organization, or organizations with which you are familiar, in implementing the requirement included in this proposed IES 8 Exposure Draft (December 2013)?
There are significant implications for ACCA in implementing the requirements included in this proposed IES 8 Exposure Draft (December 2013). ACCA will need to identify individuals on our database, verify compliance with the standard at monitoring visits and capture information on annual CPD returns. ACCA will develop our licensing and CPD requirements for engagement partners.
Question 9. What topics or subject areas should Implementation guidance cover?
Does the standard reflect that if a firm holds an auditing certificate but conducts no audits the engagement partner is still required to maintain competence? With regards to the implementation date, will organisations have to be ready to implement on the date the standard is approved?