IESBA staff have developed a new publication, Ethical Considerations Relating to Audit Fee Setting in the Context of Downward Fee Pressure, in response to stakeholder concerns about downward pressure on fees and its potential to adversely impact audit quality. The publication highlights important considerations in the Code of Ethics for Professional Accountants (the Code) for auditors in relation to the setting of audit fees.

Among other matters, the publication outlines some of the reasons for downward pressure on audit fees and focuses on the key fundamental principles in the Code to which auditors must pay particular attention in these circumstances. It also highlights the different, but important, roles that those charged with governance, entity management, regulators, and other stakeholders can play in ensuring that financial considerations related to audit fees do not drive actions and decisions that undermine audit quality.

The publication will be relevant to auditors when considering tendering for a new audit engagement, or when proposing or agreeing fees for recurring audit engagements. It may also be of interest to those charged with governance, preparers, regulators and audit oversight bodies, investors, and others with an interest or role in auditors’ work and their independence.

Log in to the IESBA site to access the publication now: Ethical Considerations Relating to Audit Fee Setting in the Context of Downward Fee Pressure.

As a response to stakeholder concerns about downward pressure on fees being a factor potentially adversely impacting audit quality, this publication highlights important considerations in the Code of Ethics for Professional Accountants (the Code) for auditors in relation to the setting of audit fees.

Denise Canavan is Managing Director of Global Independence for Deloitte Touche Tohmatsu Limited. In her role, she oversees the development of Deloitte’s independence policies and advises the member firms throughout the network in the application of the independence rules and professional standards.

Ms. Canavan is a Certified Public Accountant in the state of New York and is a member of the American Institute of Certified Public Accountants. She holds an MBA in finance and international business from New York University and a BS in accounting from Boston College. 

Mike Ashley, is the Task Force Chair of the Definitions of Listed Entity and Public Interest Task Force and is a former member of the IESBA.

Mr. Ashley is a Non-Executive Director and Chair of the Audit Committee of Barclays Plc. Prior to joining the Barclays Board in September 2013, he was the Head of Quality and Risk Management for KPMG Europe LLP and the Ethics Partner for KPMG in the UK. He spent most of his full-time career as an Audit Partner with KPMG or its predecessor firm, Peat Marwick, mainly engaged in the audits of major banking institutions.

Mr. Ashley is a Board member and Chair of the Policy and Guidance Committee of the Charity Commission of England and Wales, a Board member and Chair of the Audit and Risk Committee of the UK Cabinet Office and, since 2006, a member of the Ethics Standards Committee of the Institute of Chartered Accountants in England and Wales (ICAEW). He was a member of the Technical Expert Group of the European Financial Reporting Advisory Group (EFRAG) from 2005 to 2016 and Vice Chair from 2010 to 2016. He was also Chair of the UK Government Internal Audit Agency from 2014 to September 2018, a member of the Audit Committee of the UK Treasury from 2009 to 2015 and a member of the UK Accounting Standards Board from 2004 to 2010. Mr. Ashley has an MA in mathematics from Trinity College, Cambridge, and is a Fellow of ICAEW and Honorary Fellow of the Chartered Institute of Internal Auditors.

Ian McPhee, AO PSM, FCPA, FCA became a member of the International Ethics Standards Board for Accountants in January 2016. Mr. McPhee was formerly a member of the International Auditing and Assurance Standards Board between 2003 and 2008.

Mr. McPhee holds the position of Distinguished Honorary Professor at the Australian National University. He is also a Council member of Central Queensland University, chair of the Audit Quality Advisory Board for PwC Australia, a non-executive company director, a chair and member of a number of audit and risk committees, and (part-time) Australian Capital Territory Public Sector Standards Commissioner. Previously, he was Auditor-General for Australia between 2005 and 2015, and prior to that appointment held senior positions with the Department of Finance and the National Audit Office in Australia.

Mr. McPhee has been Deputy Chair of the Australian Accounting Standards Board, a member of the Australian Auditing and Assurance Standards Board, and Chair of the former Public Sector Accounting Standards Board in Australia. He was made an Officer of the Order of Australia in 2015, awarded a Public Service Medal in 2002, awarded a First Class Medal of Honour by the Government of Indonesia in 2009, and received several other prestigious awards for his contribution to the public sector, including an honorary doctorate, and federal government leader of the year award. Mr. McPhee is also a life member of CPA Australia.

Mr. McPhee has a bachelor's degree in business (accountancy) from the University of Central Queensland and a bachelor of arts (computing studies) from the University of Canberra.

Saadiya Adam became a member of the International Ethics Standards Board for Accountants in January 2021. She was nominated by the independent audit regulator and standard setter in South Africa, the Independent Regulatory Board for Auditors (IRBA).

Ms. Adam is the Senior Professional Manager for Standards at the Independent Regulatory Board for Auditors (IRBA) in South Africa. She is also the Secretariat to the Committee for Auditor Ethics (CFAE) and the Committee for Auditing Standards (CFAS), standards- setting statutory committees established by South Africa's Auditing Profession Act. The CFAE is responsible for determining what constitutes improper conduct by registered auditors, including developing the IRBA Code of Professional Conduct. The CFAS is responsible for developing, maintaining and adoption of auditing standards and other pronouncements.

Ms. Adam is a chartered accountant in South Africa—CA (SA)— a member of the South African Institute of Chartered Accountants, and a Certified Ethics Officer with The Ethics Institute of Southern Africa.

The International Ethics Standards Board for Accountants^® (IESBA^®, the Ethics Board) today released for public comment two Exposure Drafts (EDs) proposing key enhancements to fundamental aspects of the Code of Ethics for Professional Accountants (the Code).

The first ED, Improving the Structure of the Code of Ethics for Professional Accountants—Phase 1 (Structure ED) represents the first application of proposed new structure and drafting conventions for the Code, covering both a number of the provisions of the Code dealing with its general application and selected sections addressing professional accountants in public practice. In addition to the use of clearer language, key features in the Structure ED include:

• Requirements clearly distinguished from application material;
• Increased clarity of responsibility for compliance with the Code’s requirements;
• A reorganization of the content of the Code; and
• A new Guide to the Code.

“The Board has undertaken to restructure the Code as a high priority. This is a major infrastructural undertaking, three years in the making already, and responds to a public interest need for the Code to be more understandable and usable,” said IESBA Chairman Dr. Stavros Thomadakis.

The second ED, Proposed Revisions Pertaining to Safeguards in the Code—Phase 1 (Safeguards ED) includes enhanced requirements and application material pertaining to the application of the Code’s conceptual framework, including safeguards.

“Safeguards are a linchpin of the ‘threats and safeguards’ approach that is fundamental to the proper application of the Code. The proposals respond to a public interest need to clarify the meaning of safeguards and to make sure that they directly relate to identified threats to compliance with the fundamental principles of the Code,” explained Dr. Thomadakis.

Key enhancements proposed in the Safeguards ED, which is presented in accordance with the new structure and drafting conventions, include:

• More robust and prominent requirements related to the application of the conceptual framework, including a required overall assessment of the judgments made and conclusions reached;
• A clearer and more robust description of the concept of safeguards, and clarified and streamlined examples of safeguards; and
• New guidance regarding the application of the concept of a “reasonable and informed third party” that is essential to properly applying the conceptual framework.

“Pending stakeholder feedback on the EDs, the IESBA will continue with work on the next phases of the projects, which will include restructuring other sections of the Code and a review of safeguards pertaining to the provision of non-assurance services to audit and other assurance clients,” added IESBA Technical Director Ken Siong.

Details about the second phases of the projects, including information about the Ethics Board’s plans for coordination of the restructuring effort with other work streams in progress, can be found in the IESBA Update, Restructuring the Code of Ethics for Professional Accountants.

How to Comment
The Ethics Board invites all stakeholders to comment on the EDs. To access the EDs and submit a comment, please visit the Ethics Board’s website at www.ethicsboard.org.

Comments on the Safeguards ED are requested by March 21, 2016. Comments on the Structure ED are requested by April 18, 2016.

About the IESBA
The International Ethics Standards Board for Accountants is an independent standard-setting board that develops and issues, in the public interest, high-quality ethical standards and other pronouncements for professional accountants worldwide. Through its activities, the IESBA develops the Code of Ethics for Professional Accountants, which establishes ethical requirements for professional accountants. The structures and processes that support the operations of the IESBA are facilitated by IFAC. Please visit www.ethicsboard.org for more information, and follow us on Twitter @Ethics_Board.

About IFAC^®
IFAC is the global organization for the accountancy profession dedicated to serving the public interest by strengthening the profession and contributing to the development of strong international economies. IFAC is comprised of more than 175 members and associates in more than 130 countries and jurisdictions, representing approximately 2.8 million accountants in public practice, education, government service, industry, and commerce.