Service limitations Many have advocated that in order for an auditor to remain strictly independent they should not be allowed to provide audit clients with any other advisory services. This idea was detailed in the EC's Eighth Directive and was designed to remove
conflicts of interest arising from audit companies having a high percentage of total revenue staked in the contract of one client. To date this has not been made a requirement. Both auditors and their clients have argued that the knowledge acquired during the audit process can allow other services to be provided less expensively.
Peer assessment Peer review of accounting firms is focused on helping maintain independence within a firm. A peer review is a recurring external assessment of a firm's quality control system, sometimes referred to as monitoring. This process helps members cultivate and increase audit quality to further advance the uniformity within the profession. For auditors of non issuers, peer review is required once every three years of the firms auditing practice and accounting department. During the peer review process for a nonissuer, members are required to be convinced that the employee's on the engagement have the ability to manage the assigned services. The firm being reviewed selects an approved CPA firm to conduct their peer review. Peer review is required once every three years for auditors of less than 100 publicly traded companies every year. The SEC portion is peer reviewed by the PCAOB and the non public portion is peer reviewed by an approved CPA firm, both every three years. For accelerated filers, firms who audit over 100 issuers every year, are required to have a peer review annually, performed by the PCAOB.
Audit committees The recommendation for companies to form an
audit committee was first made in the
Cadbury Report (1992). A group of three to five non-executive directors from within the company are chosen to provide what is supposed to be a truly objective view on all aspects of the audit: from evaluation of internal control systems to recommendations on audit fee. Since the
Cadbury Report, this practice has been implemented yet many still remain unconvinced of the neutrality of non-executive directors.
Rotating external auditors Proponents argue either mandatory
rotation of audit firm or mandatory
rotation of engagement partners could improve auditor independence. It is argued that an incumbent auditor has less incentive to collude with their client if the firm's contract expires in the foreseeable future or that auditors are less likely to forge conflicting relationships with client personnel. Further, because current auditors will know they are soon to be replaced, they will be inclined to produce audit reports which demonstrate high standards and are an exemplar of true independence, and avoid having any shortcomings exposed by the new audit team. However, empirical evidence is mixed. Most research suggests financial reporting quality is lower when auditor tenure is low. One possible explanation is that it is difficult and costly to obtain the client-specific knowledge required to produce a high quality audit. These costs need to be weighed against the threat of impaired independence, mentioned above. Proposals for a maximum client servicing period of five years have since been dismissed after lobbying by accounting firms and their clients, again stressing that it is vitally important that auditors familiarise themselves with client operations in order to conduct a successful audit. Recent research suggests the relation between partner tenure and audit quality might be more effective for small audit firms, but that five years might be too short a period. There is evidence that the relation between audit partner tenure and audit quality is hyperbolic, with perceived audit quality reduced at the time of rotation but then improving for several years, only to deteriorate again when the audit partner has been incumbent for a fairly long time. This is based on an Australian study, where mandatory audit partner rotation was introduced in 2004 by the
CLERP 9 legislation. The
International Federation of Accountants recommends partner rotation but not rotation of firms. The IFAC states in its
International Standard on Quality Control (ISQC1 of 15/12/09) that "The IESBA Code (
International Ethics Standards Board for Accountants) recognizes that the
familiarity threat is particularly relevant in the context of financial statement audits of
listed entities. For these audits, the IESBA Code requires the rotation of the key audit partner after a pre-defined period, normally no more than seven years, and provides related standards and guidance. National requirements may establish shorter rotation periods" In the area of
Government Auditing, in its
ISSAI 1000 standard (art.66) the
INTOSAI also recommends partner rotation: "ISQC 1 requires engagement partner rotation for listed entities after a predefined period. In the public sector, this requirement may be applied to significant public interest entities. However, legislation establishing the appointments and terms of office of the Auditor General may make rotation impractical.
Supreme Audit Institutions may establish policies and procedures to promote compliance with the spirit of this requirement". In the United States, audit partner rotation is recommended in Title II Section 203 Sarbanes Oxley 116 Stat 773 (Audit Partner Rotation) (Audit Partner Rotation) of the
Sarbanes–Oxley Act. The
European Commission has issued on 16/5/02 a recommendation: "
Statutory Auditors’ Independence in the EU, A Set of Fundamental Principles". The recommendation only requires partner rotation on listed clients after seven years. It differs in some respects from most national/international requirements, namely:• it allows a return after two years • it applies to ‘public interest clients’, not just listed clients • in a group context, extends to key audit partners other than the audit engagement partner. No countries within the EU, with the exception of Italy, currently have a system of mandatory audit firm rotation. In the United Kingdom, the
Auditing Practices Board (FRC) has issued a revised Ethical Standard 3: Long Association with the Audit Engagement (applies on 15 December 2009). It can be summarised as follows: Audit engagement partner - maximum rotation period remains at five years, with a minimum of five years not involved in the audit afterwards. However, flexibility of up to an additional two years is permitted. ==References==