Mid-tier Auditors and Audit Reform Proposals

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In an article in Accountancy Today , written by Harry Deacon, Chris Biggs, partner at Theta Global Advisors, discusses the FRC’s audit reform proposals, and why mid-tier auditors are intrinsically linked to any changes despite the Big Four gaining all of the headlines.

July saw the Financial Reporting Council (FRC) reveal that 29% of 103 FY21 public interest entity (PIE) audits reviewed from the seven largest UK audit firms required “improvement or significant improvement”. While this represented a marginal improvement from FY20’s 33%, Sir Jon Thompson, chief executive at the industry watchdog, stressed that “significant change still needs to happen to meaningfully improve audit quality”.

The FRC report merely reaffirmed the extent of the problem which has come to light time and again through major stories such as the Carillon, Silentnight, and Stagecoach failures. Chris Biggs, partner at the firm of chartered accountants Theta Global Advisors, recognises that he was used to “spotting a story every month, but now it’s almost weekly if not becoming daily”.

Yet, for Biggs, the issue of underperforming auditors leading to audit failures goes beyond just the Big Four and largest mid-tier firms. “I think it’s happening across the board,” says Biggs. “The big firms are the ones that grab the headlines because they’re dealing with household names, but I get to read the various rulings that circulate via the FRC where people have messed up and there are lots of smaller firms there as well, we just don’t know the names of their clients.

Despite this reality of audit failures across all sized firms confirming the need for reform for improvement, the impacts on these mid-sized FTSE 100 and 350 firms is not wholly self-inflicted. “You can’t get away from the fact that the mid-tier firms are intrinsically connected to the profession, to the audit product and to how it all works,” says Biggs.

He adds: “At the end of the day, it’s all about the consensus of public and investor confidence in the audit as a product. As much as I’m sure the mid-tier firms would like to separate themselves from the problems the Big Four have, it’s still a problem with the perception of what an audit actually is.”

So, what can be done to turn around this negative trend of poor-quality audits? One proposal set out by the FRC, and subsequently rejected by the Big Four, was that of shared audits. According to the Financial Times, those largest auditors have voiced their concerns that joint audits with smaller groups would fail to improve audit quality – an opinion also voiced by Biggs.

Biggs highlights that for a smaller accountancy firm to take on part of the audits of these larger PIEs, it doesn’t just centre around “technical audit” but a whole range of other requirements such as “derivative and trading expertise”. He adds: “For the smaller firms and mid-sized firms to get that experience in house, it’s incredibly expensive, particularly whilst it’s not just the Big Four that have those skills now. The top mid-tier are trying to get those people, so there’s a bit of a drain of specialists into those mid-tier firms.

“For the small firm trying to take on anything more than what they’re doing at the moment, the cards are somewhat stacked against them, both from a reputation experience, and also a resource cost and skillset.”

Biggs claims that as a matter of fact, for small to mid-sized firms, “there is a population of audit clients which they are perfectly suited for, and vice versa”. To take on anything more, and step out of their “comfort zone”, could in certain circumstances without significant investment in skills and resources by those firms, according to Biggs, break current legislation in the form of the “very clear policy that you only do the audit work that you are capable of doing and have the experience and skills to do so”.

If, then, shared audits isn’t the answer, what is? Biggs says that the FRC and other regulators need to have “bigger teeth” in order to “clamp down on those nonperforming” firms with tougher fines and individual bans. “I think directors need to be held far more responsible for what goes on,” he says. “When I first started training, my audit 101 was that the auditor is a watchdog, not a bloodhound. Yet, that seems to be what the auditors are getting criticised for now.

“A lot of it comes down to the fact that directors have done things they shouldn’t have done, and the auditors are complying with legislation, but because they don’t pick it up when doing what they are meant to do, then legally they’re still in the firing line. So, if you want the auditors to be more of a deterrent and a bloodhound and to really seek these things, then legislation has to change as well.”

Secondly, Biggs highlights the question of pricing. He suggests that the rotation of auditors then depressing audit costs is causing issues for audit quality across the board. Biggs says:  “The fees going down means that the amount of time the auditors can spend on doing what they need to do is really limited. There has to be an acceptance, particularly with a large set of FTSE 100 companies, that at the end of the day companies need to pay a decent amount for what they get.”

Evidently, the fate of the Big Four, large, and mid-sized auditors are intertwined. Biggs claims that proposals of shared audits could be ditched for a tougher set of regulations against company directors and a re-evaluation of audit fees to ensure auditors of all sizes have the available resources, and correct set of rules, to avoid being thrown under the bus.

For a situation that is encompassing companies of all relevant sizes that audit FTSE 100 and even FTSE 350 firms, it is thus only fair that all of these groups be consulted on audit reforms. Biggs adds: “Hearing more from the mid-tier firms will be positive because that will hopefully then start to come out with some thematic issues, as opposed to just those limited by the Big Four.”

For Biggs, audit reform is a necessity. Yet, it is key to remember the impact and importance of mid-tier firms when promoting change. A further realisation of what audits actually are, in terms of costing, legislation, and relationships between companies and their auditors, is needed to improve outcomes for both auditors and clients.

Change is needed, but industry watchdogs must consider those outside of the largest auditors if a compromise and real improvement is ever to be made.

Should I be working from home or going back to the office?

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What’s the advice in England and how might it change is covered in article by the BBC. Since Covid restrictions lifted on 19 July, people are no longer asked to work from home. PM Boris Johnson recommended a “gradual return” for staff who’d been at home since the start of the pandemic.

But although social distancing limits no longer apply, businesses still have a legal duty to manage risks to staff and customers.

Employers must follow official safety guidance and carry out Covid risk assessments. They may decide to keep some previous measures in place, such as minimising unnecessary visitors, frequent cleaning and one-way systems.

Regular lateral flow testing remains widespread and there is more detailed guidance for some industries – including construction, hospitality and manufacturing. Read the specific advice for EnglandScotlandWales and Northern Ireland.

Plan A and Plan B

The government has now published its Covid-19 Autumn and Winter Plan – which includes a Plan A and Plan B.

Much of Plan A focuses on the vaccine rollout:

  • booster jabs for over 50s, the most vulnerable and health workers
  • single jabs for 12-15 year olds
  • encouraging others who have not yet been vaccinated to come forward

But if despite this, the NHS struggles and there is “concerning data”, Plan B (or parts of it) may be introduced – including advice to work from home once again for “a limited period”.

Plan B could also see face coverings become mandatory again in certain settings and the introduction of so-called Covid passports.

Plan A or Plan B – what could happen this winter?

Does working from home help stop Covid spreading?

Working from home is one of the most effective ways to reduce social contacts, according to the government’s Scientific Advisory Group for Emergencies (Sage).

It has a “strong impact” against virus transmission and the R number, which is a way of rating a disease’s ability to spread.

Keeping people at home greatly limits face-to-face contact – both at work and when commuting on public transport.

Chief scientific adviser Sir Patrick Vallance says if Covid cases start rising fast, there could be a case to bring back some restrictions.

“If you look across the Channel, at countries where you have similar levels of immunity and some higher degrees of restriction, you can see cases are going down.”

What are the work-from-home rules in the rest of the UK?

In Scotland, most Covid restrictions have been lifted, but people are still advised to work from home where possible. The government is encouraging employers to consider long-term hybrid models of home and office working.

In Wales, again, most Covid restrictions have been lifted, but employers are still encouraged to let people work from home where possible. Guidance says that staff should not be “required or placed under pressure to return” to a workplace unless there is a clear business need for them to do so.

Northern Ireland’s guidance to work from home where possible also remains in place.

Can I ask to keep working from home?

You can ask, but employers don’t have to agree. However, the Chartered Institute for Personnel and Development (CIPD) – which represents HR professionals – says there could be much greater freedom and flexibility in how, when and where people work in future. “People generally want a mix of workplace and home working, and the possibility of more choice in their working routines, meaning hybrid working can provide an effective balance for many workers.”

The CIPD adds that the lifting of Covid restrictions “shouldn’t signal a mass return to workplaces,” and “it should be down to individual organisations, consulting with their people, to agree working arrangements”.

How safe is public transport?

Much of the risk depends on how crowded it is and your distance from other people. Wearing a mask helps, as does keeping windows open, and avoiding peak journey times where possible.

What are my rights if I am in a vulnerable group?

Previous advice that millions of “clinically extremely vulnerable” people should shield, has now ended. Many continue to work from home, but if your job cannot be done remotely, your employer can ask you to return to the workplace. However, they still have a responsibility to keep you safe, so you should raise any specific concerns you have about going back. In addition, if you are disabled, your employer has an extra responsibility to make and pay for “reasonable adjustments”.

Job vacancies surge past one million in new record!

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Job vacancies have hit a record high as the economic recovery continues, according to official figures and a recent article by the BBC.

The number of vacancies in the three months to August rose above one million for the first time since records began in 2001.

Figures also showed employee numbers were back at pre-Covid levels in August, the Office for National Statistics (ONS) said.

August payrolls showed another monthly increase of 241,000 to 29.1 million.

Business groups said, however, despite the return of staffing levels to pre-pandemic rates there remained high demand for more staff, and there was a risk labour shortages would dampen growth.

What’s happening to those people on furlough?

The ONS deputy statistician, Jonathan Athow, said: “Early estimates from payroll data suggest that in August the total number of employees is around the same level as before the pandemic, though our surveys show well over a million are still on furlough.”

But Mr Athow pointed out that the recovery was not even, with areas such as London and sectors like hospitality and the arts still down.

The ONS also cautioned that young people had been badly affected by job losses.

“The overall employment rate continues to recover, particularly among groups such as young workers who were hard hit at the outset of the pandemic, while unemployment has fallen,” he said.

Overall, the unemployment rate fell from 4.7% to 4.6% in the three months to July.

‘Acute hiring crisis’

Siren Thiru, head of economics at the British Chambers of Commerce said, however, that firms were currently facing an “acute hiring crisis”.

“With Brexit and Covid-19 driving a more deep-seated decline in labour supply, the end of furlough is unlikely to be a silver bullet to the ongoing shortages,” he said.

“These recruitment difficulties are likely to dampen the recovery by limiting firms’ ability to fulfil orders and meet customer demand.”

The food and accommodation sectors saw the biggest jump in the number of jobs available in August, increasing by 57,600.

Some companies in the food industry, which has already seen a shortage of fruit pickers and lorry drivers, have been unable to provide normal service recently.

Supermarket bosses have also warned that it is vital to fix the labour shortage problems before key trading over the Christmas period.

Dairy giant Arla, meanwhile, has also had to cut back on milk deliveries to supermarkets because of the driver shortages.

And Yael Selfin, chief economist at KPMG, warned that there could be more pain to come.

“While the pressure should ease as more people look to return to work and the furlough scheme ends, the UK labour market is set to remain choppy with vacancies taking time to fill due to skills shortages and reduced availability of overseas workers,” she said.

Plans for a new professional body for corporate auditors questioned by the IACEW and ACCA

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Sam Alberti  in an article in Accountancy Age writes that Government proposals to establish a new professional body for corporate auditors have been dismissed as “a costly distraction” and “career limiting” by the Institute for Chartered Accountants in England and Wales (ICAEW) and the Association for Chartered Certified Accountants (ACCA).

As part of the government’s wider crackdown on audit in the UK, the plans were outlined in a whitepaper published by the Department for Business, Energy and Industrial Strategy (BEIS) earlier this year. A four-month consultation period followed, concluding on July 8.

According to the whitepaper, a new professional body could help to raise the status of corporate auditors and reinforce their public interest obligations.

“The existing recognised qualifying bodies and supervisory bodies already deliver a profession that clearly and distinctly supports auditors, drives high audit quality and is inclusive for wider corporate auditors,” said the ICAEW in its official response to the whitepaper.

“Establishing a separate professional body for corporate audit risks reducing the attractiveness of entering the profession and obtaining a high-quality qualification which is a source of UK global competitive advantage.”

The response also notes that the ICAEW is prepared to develop its qualifications and training infrastructure in line with the government’s reform objectives. This, it argues, would further nullify the creation of a new professional body.

ACCA’s response to the consultation offers further criticism, asserting that, while the idea of expanding audit aligns with its own research findings, funding a new professional body dedicated to audit would “not be in the public interest”.

“It is not in the public interest to publicly fund a specialised professional body, either through the UK government or the new profession when the demand for corporate auditor services has not been tested.

“Whilst there is likely to be a wider demand for accountants and auditors in this space, ACCA does not believe that a new, distinct professional body is required to facilitate this.”

The response goes on to highlight the training, qualification and personal development infrastructure that ACCA already provides, arguing that the duplication of this would be unnecessary.

Perhaps most importantly, the ACCA response condemns the “separation” of corporate audit from accountancy, which it argues would be the consequence of establishing a new professional body for audit.

“We do not consider that the case has been made to separate auditing as a profession from its existing roots in the accountancy profession.”

Among other things, ACCA argued that this new commitment to a separate profession could be “career limiting” and “less attractive to young talent”.

Comments published by the Chartered Institute of Internal Auditors (CIIA) also reject the proposal. It argues that the establishment of a new corporate auditing body could have “unintended consequences” for internal audit by duplicating its remit and responsibilities.

“We do not see it as being necessary or desirable to set up a completely new corporate auditing profession with a new dedicated professional body,” it said.

“If it were deemed there was value in establishing a ‘corporate auditor’ qualification, a far more effective and better mechanism for delivering this would be for the existing relevant professional bodies to provide this.”

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