Álit: tímarit löggiltra endurskoðenda - 01.01.1993, Blaðsíða 22

individuals or firms who are specially licensed to
carry out statutory audits. The 8th directive
specifies the minimum requirements for
qualification as a statutory auditor. Under the 4th
and 7th directives national law may - but need not -
exempt small and medium-sized enterprises (SME)
from the statutory audit obligation. The definition
of an SME is very wide, and it has been widened
further in the course of the E.C. legislation
procedure. I assume that in Iceland like in Sweden
the vast majority of domestic companies qualify for
exemption. The practical consequence is that the
legislation can be left very much the way it is,
unless there is a national desire to change.
Obviously, the qualification requirements of the 8th
directive have to be studied carefully by all the non-
E.C. Nordic countries. They concem theoretical
education, practical training, professional
examination, independence and the disciplinary
system.
It is important to notice, however, that the 8th
directive does not cover work in non-regulated
areas performed by professional accountants. It
does not demand that states regulate non-audit
services, such as tax and management advisory
services, accounting services etc. In fact, the EEA
agreement may even restrict the possibilities to
regulate certain aspects of those activities, based on
the rather strict mles in the E.C. directives that
protect free competition. Let ine say a few words
about the requirements of the 8th directive. I shall
have to limit my remarks to a very general
description. In order to qualify under the 8th
directive, an accountant first of all needs a specified
level of theoretical education, as required by article
4. He or she must first obtain the qualifications
necessary to enter into university studies -
qualifications which may obviously vary between
different countries but which generally include
some twelve years in school, often leading to a
certificate referred to as the “baccalaureate” or
some similar designation. The student should then
be given a theoretical education in certain
professional subjects that are specified in article 6
of the directive, and finally pass an examination at
university level, covering those subjects. The
directive is very vague on the education procedure -
no doubt intentionally - but it is a common
interpretation that the theoretical education should
be equivalent to at least three years of university
studies. The education could be given by the
national university system, as in the Nordic
countries, or by the professional bodies, as is
generally the case in the United Kingdom and
Ireland, and elsewhere. Article 8 of the directive
further requires that the student be given no less
than three years of practical training. At least two
years of the practical training must take place under
the supervision of persons who have already
qualified as statutory auditors. The directive is
equally vague on the procedure, but is does say that
it is the responsibility of the member state to make
certain that the accountants in charge of the
supervision provide a satisfactory guarantee for the
quality of the practical training. I like to think that
this means an obligation to provide the student with
active guidance and not only let him or her
participate in audit work without having the idea of
the audit explained. It is worth remembering that in
some countries, notably in the British Isles, not all
practitioners are allowed to take on students for
practical training. As I mentioned, the 8th directive
requires a professional examination, article 5. I
cannot think of any other country than my own,
Sweden, where this means a change. It is a slightly
embarrassing fact that up till now, although an
academic degree has been compulsory for
qualification since 1912, our legislation has
demanded no other test of a student’s practical
skills that a written opinion from the employer of
the training period. My institute has advocated a
compulsory comprehensive professional
examination for a long time, and a little more than a
year ago we demonstrated our dissatisfaction by
making a privately organised examination
mandatory for membership of the institute. The
demand in the 8th directive for auditors’
independence has a very general format. Actually,
the only specific rule concems the ownership of
accounting firms, where it is stated that licensed
auditors should have the majority. In the proposed
5th directive there is more on independence.
However it is very unclear when the 5th directive
can be launched and how it is going to look at that
time. In the working plan for 1993/94 of the E.C.
Commission there are no provisions for resources to
5th directive work. There have been suggestions to
cut out the audit parts from the draft and put them
into a new directive, referred to in the discussions
as “directive 8 bis.” It does not seem likely that this
will take place in the near future. The 8th directive
finally demands that member states ascertain that
auditors are exposed to a system of professional
discipline. As long as the govemment is satisfied
that the system works there is wide freedom to
tailor the system to national needs. In most cases a
country with a working disciplinary scheme can go
on operation in the traditional manner. Another
thing is that I have understood from Icelandic
colleagues that this may be the right time to do the
changes that FLE has wanted to see for some time.
It is perhaps relevant to point out that the four other