IAASB Internatinal Federatin f Accuntants (IFAC) Attentin Prf. Dr. A. Schilder 529 5 th Avenue, 6 th Flr 10017 NEW YORK USA Date RE Reference Attachment(s) Direct Dial 8 April 2014 IAASB Strategy and KvH - +31 20 3010399 Wrkplan 2015-2019 Dear prf. Schilder The NBA appreciates the pprtunity t cmment n the IAASB Cnsultatin Paper The IAASB s Prpsed Strategy fr 2015-2019 and The IAASB s Prpsed Wrk Prgram fr 2015-2016 (hereafter respectively IAASB Strategy and Wrk Prgram). The prfessin is rapidly changing as a result f changing stake hlders demands and therefre it is essential that the IAASB, as a facilitatr fr gd practice, respnses t this changing landscape. General cmments We welcme the IAASB Strategy and Wrk Prgram. First f all, we wuld like t respnd t the mandate, the cmmitment and the fcus areas f the IAASB. Mandate As described in the cnsultatin paper, high quality standard setting in the public interest is the essence f the mandate f the IAASB. We feel that timeliness is a key aspect t setting standards in the public interest. Based n its current resurce cnstraints, the IAASB has decided t pstpne imprtant prjects n ISA 315 and ISA 600 until 2017. Pstpning these prjects des nt seem t be in the public interest. Thse standards need revisin t imprve the audit quality and therefre the IAASB shuld cmmence prjects regarding thse imprtant standards as sn as pssible. We are cnvinced that the current rapidly changing envirnment in which the IAASB sets its standards will cntinue in the next decades as well as the need t imprve audit quality. That is why we expect the resurce cnstraints will cntinue in the near future. Hence, the IAASB needs t extend its resurces r it shuld wrk with thers in rder t fulfill is mandate. Since Natinal Standards Setters (NSS) have the same mandate within their wn jurisdictin we expect that they are willing t wrk with the IAASB t reslve the budget r resurce cnstraints. This wuld nt impair the due prcess f the IAASB and des nt
jepardize the mandate f the IAASB t set high-quality internatinal standards independently and under its wn authrity t serve the public interest. We are aware that the IAASB is evaluating the efficiency f its wn prcesses and is investigating pprtunities t apply its available resurces satisfactrily. We acknwledge the IAASB fr taking this initiative. Nevertheless, we are cnvinced that this will nt reslve the resurce cnstraints f the IAASB. Cmmitment In general we agree t the cmmitment f the IAASB as described in the cnsultatin paper. It is als imprtant fr the IAASB t cntribute t enhanced quality and cnsistency f cmpilatin engagements r agreed-upn prcedures. We encurage the IAASB t make it clear t stakehlders and prfessinals that the IAASB recgnizes the imprtance f this wrk t the public interest. Mandate The financial crisis in Eurpe has nt nly prven that the financial system was vulnerable t disruptin caused by financial institutins but als by disruptin caused by cuntries. In bth cases financial reprting did nt prvide early warnings t the prblems encuntered in the financial crisis. In bth cases financial audits might have been instrumental in prviding transparency cncerning the vulnerabilities. We wuld encurage the IAASB t cnsider t categrize fcus areas n markets instead f the current categrizatin based n the activities f the IAASB. Fr instance: Listed entities and ther public interest entities in the private sectr; Small and medium entities; and Public sectr. Respnse t the questins Prpsed Strategy fr 2015-2019 In the cnsultatin paper the IAASB asks the fllwing questins: The IAASB is particularly interested in respndents views n: (a) (b) Whether the strategic bjectives identified are cnsidered apprpriate fr the perid 2015 2019. If nt, please explain. Whether the factrs included in Appendix 2 n page 19 represent a reasnable basis fr the IAASB t use in develping its Wrk Prgrams beynd the Wrk Prgram fr 2015 2016. Ad. a Whether the strategic bjectives identified are cnsidered apprpriate fr the perid 2015 2019. If nt, please explain. Firstly, it seems that all the bjectives set by the IAASB verlap. Withut cllabratin and cperatin with cntributrs t the Financial Reprting supply chain it is almst impssible t develp and maintain high quality ISAs. Als, in rder t ensure the relevance f the ISAs it is necessary t develp and maintain high quality ISAs. Secndly, it seems that the IAASB s fcus lies primarily n the ISAs. Althugh we fully appreciate that the ISAs are the flagship f the prfessin, ther standards are equally imprtant, especially in this rapidly changing envirnment.
Regarding the bjectives we have the fllwing bservatins and suggestins t make the bjectives mre ambitius and cncrete: Develp and Maintain High-Quality ISAs that Are Accepted as the Basis fr High-Quality Financial Statement Audits: We are cnvinced that High-Quality Financial Statements Audits are nt a gal in itself. Stakehlders are interested in the cntributin f Audits t transparent, relevant and reliable Financial Statements. Therefre we feel that it is imprtant that: The IAASB perfrms activities t restre the cnfidence in audits by shwing the value f an audit in transparent reprting. The IAASB des nt nly issue standards, facilitate r mnitr the implementatin. The IAASB investigates if new IT develpments are reflected in the ISAs. High quality audits shuld be effective and efficient and thus effectively embrace pprtunities fr new audit prcedures that result frm new develpments. The maxim f an audit is an audit shuld nt prevent discussins n the scpe f the audit. The nature f the financial statements has changed in the last decades. It started as a retrspective dcument and is far mre frward lking nwadays. In rder fr audits t be high quality and relevant, thse audits might need t change their scpe t respnd t the public interest. At the same time it shuld be clear what the bundaries fr an audit cntain. (Inherent limitatins, such as nt being able t detect all frauds r t evaluate strategic risks.) Ensure the IAASB s Suite f Standards Cntinues t Be Relevant in a Changing Wrld by Respnding t Stakehlder s Needs We feel that the secnd bjective culd be written mre cncretely by taking the fllwing int accunt: IAASB needs t assess varius develpments, such as IT (scial media, big data, clud) and the impact they have n the audit prfessin. IAASB des nt nly t respnd t (infrmed) stakehlder s needs but als influences these. Cllabrate and Cperate with Cntributrs t the Financial Reprting Supply Chain t Fster Audit Quality and Stay Infrmed We feel that the third strategic bjective culd be described as mre practive. Cperatin with and between all actrs in the (financial) reprting chain is imprtant. Hwever, in ur pinin, audit quality shuld be imprved mre actively. Mrever, we cnsider integrated reprting an imprtant develpment, smething IAASB shuld take int accunt. Ad b. In ur pinin, the factrs seem reasnable. We think we culd have a mre detailed descriptin n hw the (ptential) stakehlder s needs are cnsidered and balanced. Hw are they priritised, e.g. when they are in cnflict. It is impssible t respnd t all stakehlder s needs which may be cntrary as well. T be able t respnd t future develpments, we suggest IAASB cnducts, r spnsrs, further research int the effects that future develpments can have n the prfessin. Prpsed Wrk Prgram fr 2015 2016 The IAASB is particularly interested in respndents views n:
(a) The apprach t the develpment f the Wrk Prgram fr 2015 2016, in particular the IAASB s decisin t fcus n fewer key prjects twards the gal f their cmpletin by 2017. As explained in the intrductin, we feel that the IAASB is incrrect in pstpning prject that in ur pinin are essential t high quality audits in the public interest. We agree that the IAASB has been very successful fcusing n auditr reprting. At the same time we feel that this cncept is nt acceptable in the lng run since prjects that need t start as sn as pssible will be pstpned. (b) The apprpriateness f the tpics chsen as the fcus fr the Wrk Prgram fr 2015 2016 (see paragraph 4 f the Wrk Prgram and Table A n pages 26 29) in light f the strategic bjectives set ut in the IAASB s Strategy fr 2015 2019. We d nt believe that the issue f lack f prfessinal scepticism can be slved by prviding mre rules. Auditrs that are sceptical d nt need further guidance. Auditrs that are nt sceptical enugh prbably need training rather than reinfrcing the cncept in the standards. We wnder whether it is useful t prvide special audit cnsideratins relevant t financial institutins in 2015/2016. We have the impressin that there already is a lt f lcal guidance available fr audits f financial institutins. NSS might wrk tgether t share this infrmatin with their prfessinals and regulatrs verseeing lcal financial institutins t decide what is needed in certain jurisdictins. (c) Whether there is ne r mre actins r prjects that are included in the Wrk Prgram fr 2015 2016 which yu believe the IAASB shuld address during that perid. Fr example, shuld any f the tpics in Appendix 1 (n pages 39 41) be priritized? If s, which initiative(s) identified in Table A (n pages 26 29) d yu believe shuld be replaced by these actins r prjects. Please prvide an explanatin f yur views. Befre prviding backgrund n specific prjects, we feel that there is a mre urgent issue fr the IAASB t slve. We have experienced the struggle frm the IAASB regarding the differences between limited assurance and reasnable assurance in a few prjects. Slving these issues and slving the issue f direct reprting versus assertin based reprting is rather imprtant t new prjects. Generally, the changing envirnment that we are living in will ask different questins frm auditrs. In rder t be able t answer these questins we need t make sure that the fundaments f ur prfessin are sund. Therefre we encurage the IAASB t revisit the Internatinal Framewrk fr Assurance Engagements and make sure that the fundatin f ur prfessin is sund. As explained befre, we are f the pinin that imprtant prjects such as revising ISA 600 and ISA 315 shuld start befre 2017. These are ISAs relevant t high quality audits and it is in the public interest t start with these prjects as sn as pssible. Fr instance, regarding ISA 600 we believe that it is imprtant t prvide further guidance with respect t material equity investments and letterbx audits as mentined by the IAASB. We think that nly mnitring the develpment f integrated reprting is insufficient. Mre activities shuld be perfrmed t prmte integrated reprting and t develp guidance fr the assurance f integrated reprting. In the wrk prgram f 2012-2014 the revisin f ISRS 4400 was scheduled t be cmpleted in 2013. In the current prpsal the prject will cmmence in 2017. This is an huge delay. As ther NSS have already dne we will start a prject urselves. This might result in divergence in the glbal market. In ur view the fllwing tpics/prjects are wrth investigating:
1. Assurance n risk reprting. In ur pinin, this is the mst urgent prject that is missing as there is a grwing need fr assurance n risk reprting. 2. Impact f IT n audits. The rapidly changing IT develpments has an impact n the audit prcess. Hw shuld we respnd t the IT develpments such as the clud, scial media, cntinuus mnitring and hw can audit sftware/caas be used? Hw can big data be applied fr analytical review and ther audit prcedures? 3. The gatekeeper s rle f the auditr. The signalling auditr. Accrding t sharehlders assciatins in the Netherlands, the auditr shuld speak up if he is aware f is a relevant issue at a cmpany. that is nt cmmunicated by the cmpany. 4. Bradening the scpe f the audit : Prviding assurance n narrative infrmatin in the annual reprt. 5. Hybrid assurance. In a hybrid engagement, varius types f assurance, such as reasnable assurance and limited assurance, as well as agreed-upn prcedures, may be cmbined in ne reprt. (d) Whether there are alternative appraches fr the IAASB t cnsider in rder t enhance the IAASB s ability t address calls frm stakehlders fr IAASB effrts n a variety f imprtant tpics, in light f the cnstraints f available resurces and the need fr due prcess t be applied in the develpment r revisin f standards. In the utreach and ther activities the fllwing culd als be cnsidered: analysis f develpments f the rle and respnsibilities f the auditr (public pinin), fr example by studying (academic) research and articles; rganizing discussin meetings; surveys; and dialgue with (assciatins f) stakehlders and ptential stakehlders. IAASB culd als cnsider t issue ther publicatins than Standards. In this respect, brchures r research papers culd als be relevant t meet IAASB s bjectives. Clsing remarks We trust t have infrmed yu sufficiently. If yu have any questins, please d nt hesitate t cntact Karin van Hulsen: k.vanhulsen@nba.nl. Yurs sincerely, NBA, the Netherlands Institute f Chartered Accuntants Huub Wieleman, President Peter Eimers, Chairman f the Dutch Ethics & Assurance Standards Bard