Non-assurance Services Roundtable briefing
EXPLORING ISSUES TO DETERMINE A WAY FORWARD I. Background The term non-assurance services is used throughout the Code when referring to engagements that do not meet the definition of an assurance engagement. An assurance engagement is an engagement in which a professional accountant in public practice (PAPP) expresses a conclusion designed to enhance the degree of confidence of the intended users other than the responsible party about the outcome of the evaluation or measurement of a subject matter against criteria. An audit engagement is a reasonable assurance engagement in which a PAPP expresses an opinion on whether financial statements are prepared, in all material respects (or give a true and fair view or are presented fairly, in all material respects), in accordance with an applicable financial reporting framework. This includes statutory audits, which is an audit required by legislation or other regulation. Auditor independence is critical to public trust in audited financial statements, and contributes to audit quality. In recent years, there have been a number of legal and regulatory developments aimed at responding to issues affecting auditor independence, including audit firms’ provision of non-assurance services (NAS)[1] to audit clients.[2] Some stakeholders and the Public Interest Oversight Board have called for IESBA to review its International Independence Standards relating to the provision of NAS to audit clients. Having completed a number of projects which culminated in the April 2018 release of a completely rewritten and substantively revised International Code of Ethics for Professional Accountants (including International Independence Standards) (the Code[3]), the IESBA has established a Working Group to further understand and respond to those calls. Global Roundtables In deciding to hold three global roundtables in North America (Washington, DC, USA), Europe (Paris, France), and Asia Pacific (Tokyo, Japan), the IESBA is seeking to further understand stakeholders’ views about specific issues that might arise when firms and network firms provide NAS to their audit clients and whether changes are needed to the Code to address them. Purpose of Briefing Note This briefing note summarizes the NAS issues that the IESBA has identified to-date, in particular, in relation to audit clients that are public interest entities (PIEs). Some of the issues were raised by [1] Except where otherwise noted, NAS in this paper is used to refer to the term “non-assurance services” as used in the IESBA Code. In some jurisdictions the term “non-audit” services is used in describing similar issues. For example, the term “non-audit services” is used in the UK to cover any service that does not form part of the audit engagement (i.e., both “non-assurance” and “assurance services” other than an audit).The terms “non-audit services” and “non-assurance services” are not defined terms in the IESBA Code. [2] The main focus of this paper and the roundtable discussions is on firms’ provision of NAS to audit clients in the context of independence. Some of the issues may be relevant also to circumstances where firms provide NAS to assurance clients in the context of independence. [3] The references to “the Code” in this paper are to the revised and restructured Code which was released on April 9, 2018, and which will become effective in June 2019. respondents to Exposure Drafts (EDs) relating to the IESBA’s recently completed Safeguards and Structure of the Code (Structure) projects, and respondents to the IESBA’s November 2017 Fees Questionnaire. The paper is intended to facilitate a multi-stakeholder dialogue to explore possible solutions to the public interest issues that have been raised in relation to the provision of NAS by audit firms. The paper is organized as follows: Overview of NAS provisions in the Code; General policy objective; Summary of specific issues identified by stakeholders; and Questions for roundtable participants. II. Overview of NAS Provisions in the Code In addition to the requirement to apply the enhanced conceptual framework[1] to identify, evaluate and address threats when providing NAS to audit clients, Section 600[2] of the Code contains general and specific requirements and application material that apply to firms and network firms when providing NAS to audit clients. The general provisions set out in paragraphs 600.1 to R600.10 apply in all situations when a NAS is provided to an audit client. Additional and more specific provisions are set out in subsections 601-610 and apply when providing certain types of NAS to audit clients. A list of the types of NAS that are dealt with in the Code is included in Appendix 1 of this document. As part of the general provisions in paragraphs 600.1 to R600.10, the Code includes: An overarching requirement that prohibits the assumption of management responsibilities when providing any NAS to audit clients.[3] Management responsibilities involve controlling, leading and directing an entity, including making decisions regarding the acquisition, deployment and control of human, financial, technological, physical and intangible resources. The conceptual framework specifies the approach that all professional accountants, including auditors, are required to use to identify, evaluate and address threats to compliance with the fundamental principles and, where applicable, independence. Clarifications and improvements to assist firms and network firms to better apply the conceptual framework in relation to identifying, evaluating and addressing threats created by providing a NAS to an audit client. For example, the Code now states in a more explicit manner that there are some situations in which safeguards might not be available, or capable of reducing threats created by providing a NAS to an acceptable level and that in such situations, the firm or network is required to decline or end the NAS or the audit engagement. Highlights of the clarifications and improvements to the conceptual framework is included in Appendix 2 of this document. [1] The conceptual framework is set out in Part 1 – Complying with the Code, Fundamental Principles and Conceptual Framework, Section 120, The Conceptual Framework. [2] International Independence Standards, Part 4A – Independence for Audits and Reviews, Section 600, Provision of Nonassurance Services to an Audit Client [3] See Part 4, Section 600, paragraph R600.7 and related provisions in paragraphs 600.7 A1
Non-assurance Services Roundtable briefing Read Post »