Togo

Member Organizations

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  Ordre National des Experts-Comptables et des Comptables Agréés du Togo

Legal and Regulatory Environment

  • Overview of Statuatory Framework for Accounting and Auditing

    The corporate financial framework of Togo is determined by legislation issued by two regional bodies: the West African Economic and Monetary Union (WAEMU) and the Organization for the Harmonization of Business Law in Africa (OHADA). Legislation issued at the regional level by WAEMU and OHADA has a significant impact on the legal and regulatory framework for commercial entities, banks, financial institutions, and insurance companies in Togo as well as on the accountancy profession. Togo, as a member of the two regional groups, harmonizes national laws with directives issued at the regional level.

    WAEMU’s eight member states share the CFA franc as a common currency, a common securities regulator, and a stock exchange. In addition, since its creation, WAEMU has also progressively developed activities to assist with accounting and auditing standard-setting and to support the development of the accountancy profession. OHADA sets common business regulations, including accounting standards, and adopts unified commercial laws and other legislative norms that, once adopted, become domestic law in its 17 member states. Member States are required to establish a Conseil National de la Comptabilité (CNC) with responsibility for implementation of accounting and auditing directives at the national level. The Togolese CNC was established in 2014 and became operational in 2015.

    OHADA and WAEMU are responsible for the development of member countries’ accounting standards. The WAEMU Treaty gives responsibility to the WAEMU Council to set the accounting standards to be applied by the member states. In accordance with the WAEMU Regulation No. 3/97/CM/UEMOA, the WAEMU delegated its accounting standard-setting activities to the Conseil Comptable Ouest Africain, which in turn now adopts the OHADA standards for application in the WAEMU member states.

    In January 2017, the Commission de Normalisation Comptable de l’OHADA (CNC)-OHADA, established in 2009 through an OHADA Uniform Act, adopted the OHADA Uniform Act on Accounting and Financial Information (AUDCIF) to update the previous OHADA Uniform Act on Organizing and Harmonizing Company Accounting Systems 2/2000. The previous Act had outlined the OHADA Accounting System and applicable standards—known has SYSCOHADA.

    The OHADA AUDCIF revised the SYSCOHADA, namely the OHADA general accounting plan as well as the consolidated and combined accounting rules in order to serve as a single accounting reference in all OHADA member states. The OHADA AUDCIF will come into effect on January 1, 2018 for individual accounts and on January 1, 2019 for consolidated accounts, combined accounts, and financial statements prepared in accordance with IFRS. The SYSCOHADA continue to differ from IFRS; however, the AUDCIF now requires public interest entities, which include listed companies, banks, insurance, and pension companies as well as any other companies determined by national Ministries of Finance, to prepare financial statements in accordance with IFRS in addition to SYSCOHADA.

    The OHADA Uniform Act Relating to Commercial Companies and Economic Interest Groups 4/1997 (revised January 2014) stipulates that statutory audits are mandatory for all public companies and limited liability companies that exceed one of these three thresholds: (i) share capital in excess of CFA franc 10 million; (ii) sales volume greater than CFA franc 250 million; or (iii) have more than 50 permanent employees. Banking and insurance legislations also require mandatory audits of banks, financial institutions, and insurance companies.

    Auditing standard-setting at the regional level is determined by WAEMU Regulation No. 01/2009/CM/UEMOA of 2009, which established the Council of the Chartered Accountants Profession (le Conseil Permanent de la Profession Comptable, CPPC). The CPPC is responsible for defining auditing, ethics, and quality control standards for the WAEMU member states. The CPPC was the recipient of funding from the World Bank in 2010 to develop ISA-based auditing guidelines; however, it is not clear if the project is continuing given the adoption of auditing standards by OHADA.

    In June 2017, the OHADA issued Regulation No. 01/2017/CM/OHADA Pratiques Professionelles de la Comptabilité et de l’Audit dans les pays membres de l’OHADA to harmonize regional auditing standards with international best practice. The regulation, effective from January 1st, 2018, states that all audits must be conducted in accordance with ISA as issued by the IAASB.

    Prior to June 2017, ONECCA-Togo had adopted the French version of ISA in May 2014 as a self-regulatory requirement for its members in efforts to apply the international standards within the country in the absence of regionally and nationally specified auditing standards.

    Banking and insurance regulatory bodies—Banque Centrale des États de l’Afrique de l’Ouest (the Central Bank of West African States), WAEMU Banking Commission, and the Commission Régionale de Contrôle des Assurances (Regional Insurance Control Commission)—stipulate additional requirement for entities under their supervision. Banks are required to appoint two auditors, who are subject to prior approval by the Banking Commission. Additionally, listed entities must comply with regulations issued by the regional stock exchange, Bourse Régionale des Valeurs Mobilières.

  • Regulation of Accountancy Profession

    Entry requirements for the accountancy profession are set at the regional level by the West African Economic and Monetary Union (WAEMU) Regulation No. 12/2000/CM/UEMOA, which introduced the Higher Degree in Accounting and Finance (DECOFI) and the Degree in Accounting and Financial Management (DESCOGEF) as pre-requisites to practice the profession in WAEMU countries. ONECCA-Togo states the regional qualification requirements meet the International Education Standards requirements. The DESCOGEF qualification is for Certified Accountants and the DECOFI qualification is for Chartered Accountants. Only Chartered Accountants registered by a professional institute in WAEMU countries are permitted to practice auditing. Furthermore, candidates for entry to the profession must complete three years of verified practical experience and pass final examinations with the Regional Commission for the Formation of the Accounting and Financial Experts, an external body recognized by WAEMU.

    Additionally, WAEMU Regulation No. 01/2009/CM/UEMOA of 2009 grants the Conseil Permanent de la Profession Comptable responsibility for defining auditing, ethics, and quality control standards. However, throughout 2017, the Organization for the Harmonization of Business Law in Africa (OHADA)—a separate regional economic union—issued two new regulations that outline the applicable accounting, auditing, and ethical standards as well as the mandate the establishment of quality assurance review systems by professional accountancy organizations in OHADA member states, which includes Togo.

    At the national level, Law No. 2001-001 of January 2001 establishes the Ordre National des Experts Comptables et des Comptables Agréés du Togo (ONECCA-Togo) and sets the supervision of its activities under the authority of the Ministry of Finance. Membership in the institute is mandatory for all professional accountants in the country.

    According to Law 2001-001, ONECCA-Togo is required to (i) register all accounting professionals (individuals and firms); (ii) improve the quality of accounting and financial information; (iii) set ethical requirements for members; (iv) promote fair accounting practices and compliance with international standards; (v) establish an investigation and discipline framework for members; (vi) establish a quality assurance review system; and (vii) enforce initial professional development requirements (IPD) and establish continuing professional development (CPD) requirements for members. The law also states the rights and responsibilities of members.

    Law No. 2001-001 states IPD and CPD requirements for the profession which are supplementary to those of WAEMU. In Togo, the Ministry of Secondary Technical and Professional Training and the Ministry of High Level Education and Scientific Research are responsible for the development of the accountancy education programs.

    In order to register as a Chartered Accountant with ONECCA-Togo, candidates must have a certified public accounting DECOFI degree, which is obtained after completing a five year professional accountancy program culminating in written and oral tests, and three years of practical experience. In line with WAEMU requirements, only Chartered Accountants may conduct audits in Togo.

    Certified Accountants are required to hold the DESCOGEF qualification or the equivalent diploma recognized by the Ministry of High Level Education and Scientific Research and complete a three year internship which is formally recognized by a certificate issued by a registered professional of ONECCA-Togo.

    Individuals holding a DEC from France or Tunisia and the equivalent qualification from the United States or Canada may also register with the institute as Chartered Accountants after the Ministry of High Level Education and Scientific Research confers equivalency. ONECCA-Togo is considering allowing Certified Accountants to qualify as Chartered Accountants provided that they have ten years of experience, participate in training sessions related to audit work, and pass an oral exam to demonstrate knowledge of local business law and audit work.

    Finally, there are additional requirements for auditors of banks set by the Banque Centrale des États de l’Afrique de l’Ouest (the Central Bank of West African States) and the WAEMU Banking Commission. Banks are required to appoint two auditors, who are subject to prior approval by the Banking Commission.

  • Audit Oversight Arrangements

    There is no independent audit oversight body at the regional or national level.

    Auditors are regulated at the regional level by the West African Economic and Monetary Union (WAEMU) Regulation No.12/2000/CM/UEMOA, which introduced the Degree in Accounting and Finance as a mandatory qualification for Chartered Accountants, who are the only individuals permitted to publicly practice auditing in WAEMU countries. The WAEMU Conseil Permanent de la Profession Comptable (CPPC) is responsible for defining auditing, ethics, and quality control standards based on WAEMU Regulation No. 01/2009/CM/UEMOA.

    The CPPC was the recipient of funding from the World Bank in 2010 to develop ISA-based auditing guidelines; however, throughout 2017, the Organization for the Harmonization of Business Law in Africa (OHADA)—a separate regional economic union—issued two new regulations that outline the applicable auditing, and ethical standards as well as the mandate the establishment of quality assurance (QA) review systems by professional accountancy organizations in OHADA member states, which includes Togo. These requirements become effective in January 2018.

    Auditors are regulated at the national level by the Ordre National des Experts Comptables et des Comptables Agréés du Togo (ONECCA-Togo) as established by Law No. 2001-001. Only registered Chartered Accountants of ONECCA-Togo are permitted to conduct audits in Togo.

    Under Law No. 2001-01, ONECCA-Togo’s responsibilities related to auditing include to: (i) register all accounting professionals (individuals and firms); (ii) set ethical requirements for members; (iii) promote compliance with international standards; (iv) establish an investigation and discipline framework for members; (v) establish a QA review system; and (vi) enforce initial professional development requirements and establish continuing professional development requirements for members. Furthermore, Law No. 2001-001 authorizes the Ministry of Finance to supervise ONECCA-Togo’s activities.

  • Professional Accountancy Organizations

    The Ordre National des Experts Comptables et des Comptables Agréés du Togo (ONECCA-Togo)

    ONECCA-Togo was established following the adoption of the Act of Parliament 2001-001 on January 23, 2001, which implemented the West African Economic and Monetary Union Directive N.04/97/CM/UEMOA of November 2, 1997. ONECCA-Togo’s membership is comprised of Chartered Accountants and Certified Accountants and membership is mandatory for all professional accountants in the country.

    According to the law, ONECCA-Togo is required to (i) register all accounting professionals (individuals and firms); (ii) improve the quality of accounting and financial information; (iii) set ethical requirements for members; (iv) promote fair accounting practices and compliance with international standards; (v) establish an investigation and discipline framework for members; (vi) establish a quality assurance review system; and (vii) enforce initial professional development requirements and establish continuing professional development requirements for members. The law also states the rights and responsibilities of members. Furthermore, it authorizes the Ministry of Finance to supervise ONECCA-Togo’s activities.

    In addition to being an Associate of IFAC, ONECCA-Togo is a member of the Pan-African Federation of Accountants, the Association of Accountancy Bodies in West Africa, and the Fédération Internationale Des Experts-Comptables Francophones.

  • Projects or Other Information

    Throughout 2017, the Organization for the Harmonization of Business Law in Africa (OHADA) issued two new regulations that outline the applicable accounting, auditing, and ethical standards as well as mandate the establishment of quality assurance review systems by professional accountancy organizations in OHADA member states.

    The regulations require the application of IFRS by all public interest entities in OHADA member states, require all audits to be conducted in accordance with ISA as issued by the IAASB, and stipulate that professional accountants within OHADA member states must adhere to the OHADA Code of Ethics, which will be based on the IESBA Code of Ethics, as well as the relevant parts of the 2017 OHADA Uniform Act on Accounting and Financial Information. These requirements become effective in January 2018.

    Additionally, the World Bank has also been assisting the OHADA Secretariat in the development of a regional professional qualification curriculum and continuing professional development. The World Bank reports that the implementation of this component has been delayed and a mid-term review is underway to accelerate the implementation of this activity.

Adoption of International Standards

  • Quality Assurance

    At the regional level, West African Economic and Monetary Union (WAEMU) Regulation No. 01/2009/CM/UEMOA authorizes le Conseil Permanent de la Profession Comptable (CPPC) to establish a quality assurance (QA) review system. Draft regulation establishing this requirement was finalized by the Council of Ministers of the WAEMU in 2014. However, due to delays the CPPC has recommended that professional accountancy organizations (PAOs) within member states pursue the adoption and implementation of QA systems and quality control standards at a national level.

    Furthermore, in June 2017, the Organization for the Harmonization of Business Law in Africa (OHADA) issued Regulation No. 01/2017/CM/OHADA Pratiques Professionelles de la Comptabilité et de l’Audit dans les pays membresde l’OHADA mandating PAOs within OHADA member states, which includes Togo, to develop and implement QA review systems.

    The Ordre National des Experts Comptables et des Comptables Agréés du Togo (ONECCA-Togo) has been working to establish a QA review system since 2009 by introducing quality control standards, setting up a mentoring program for audit firms, and conducting voluntary pilot reviews. In 2014, ONECCA-Togo’s General Assembly approved the establishment of a QA review system and adopted ISQC 1 and ISA 220.

    By 2020, the institute expects to assist each member firm to undergo a mandatory QA review and by 2021, the institute intends to establish a permanent QA review team and procedures that are aligned with the SMO 1 requirements.

    Current Status: Partially Adopted

  • International Education Standards

    Entry into the accountancy profession is governed at a regional level by West African Economic and Monetary Union (WAEMU) Regulation No. 12/2000/CM/UEMOA. The regulation introduced the Higher Degree in Accounting and Finance and Degree in Accounting and Financial Management, for Chartered Accountants and Certified Accountants, respectively, as mandatory requirements to practice accountancy within WAEMU countries. To practice the profession, candidates are also required to complete three years of verified practical experience and must pass final examinations with the Regional Commission for the Formation of the Accounting and Financial Experts, an external body recognized by WAEMU. The Ordre National des Experts Comptables et des Comptables Agréés du Togo (ONECCA-Togo) states that this programming meets the IES requirements.

    At the national level, the Togolese Law No. 2001-001 stipulates initial professional development and continuing professional development (CPD) requirements for the profession. In Togo, the ONECCA-Togo regulations supplement those of WAEMU. In addition, the Ministry of Secondary Technical and Professional Training and the Ministry of High Level Education and Scientific Research are responsible for the development of educational programs.

    With World Bank assistance, ONECCA-Togo, the Ministry of Secondary Technical and Professional Training, and the Ministry of High Level Education and Scientific Research developed and launched a national accountancy education program in August 2013 related to the traditional entry level, which the institute reports partially aligns with the IES.

    The institute also reports that Law No. 2001-01 establishes CPD requirements which are in line with the IES—ONECCA-Togo members must complete 120 hours of CPD over three years.

    Current Status: Partially Adopted

  • International Standards on Auditing

    The Organization for the Harmonization of Business Law in Africa (OHADA) Uniform Act Relating to Commercial Companies and Economic Interest Groups 4/1997 (revised January 2014) stipulates that statutory audits are mandatory for all public companies and limited liability companies that exceed determined thresholds. Banking and insurance legislations also require mandatory audits of banks, financial institutions, and insurance companies.

    The Conseil Permanent de la Profession Comptable (CPPC) is the regional auditing standard-setter based on the West African Economic and Monetary Union Regulation No. 01/2009/CM/UEMOA of 2009. The CPPC was the recipient of funding from the World Bank in 2010 to develop ISA-based auditing guidelines; however, it is not clear if the project is continuing given the adoption of auditing standards by OHADA.

    In June 2017, the OHADA issued Regulation No. 01/2017/CM/OHADA Pratiques Professionelles de la Comptabilité et de l’Audit dans les pays membresde l’OHADA to harmonize regional auditing standards with international best practice. The regulation states that effective from January 1, 2018, all audits in member states must be conducted in accordance with ISA as issued by the IAASB.

    Prior to June 2017, in May 2014, the Ordre National des Experts Comptables et des Comptables Agréés du Togo had adopted the ISA as issued by the IAASB as a requirement for its members in efforts to apply the international standards within the country in the absence of regionally and nationally specified auditing standards.

    Current Status: Adopted

  • Code of Ethics for Professional Accountants

    At the regional level, West African Economic and Monetary Union Regulation No. 01/2009/CM/UEMOA grants authority to the Conseil Permanent de la Profession Comptable (CPPC) to determine ethical requirements for member states. The CPPC has not yet adopted a Code of Ethics and it is not clear if it will do so given the adoption of ethical standards by the Organization for the Harmonization of Business Law in Africa (OHADA).

    In June 2017, the OHADA issued Regulation No. 01/2017/CM/OHADA Pratiques Professionelles de la Comptabilité et de l’Audit dans les pays membresde l’OHADA to harmonize regional ethical requirements with international best practice. The regulation states that effective from January 1, 2018, professional accountants in OHADA member states must adhere to the OHADA Code of Ethics, which will be based on the IESBA Code of Ethics, as well as the relevant parts of the OHADA Uniform Act on Accounting Law and Financial Information (AUDCIF). As of the time of the assessment, the OHADA Code of Ethics had not been issued. It is unclear what version of the IESBA Code of Ethics the OHADA Code will be based on and what the relevant requirements of the OHADA AUDCIF state.

    Prior to June 2017, as empowered by Law No. 2001-01, the Ordre National des Experts Comptables et des Comptables Agréés du Togo (ONECCA-Togo) revised its Code of Ethics in order to fully comply with the requirements of the 2012 IESBA Code of Ethics. All professional accountants in Togo must adhere to ONECCA-Togo’s Code of Ethics. As of the date of the assessment, there are no stated plans to adopt the 2016 IESBA Code of Ethics and for this reason, the jurisdiction has been assessed as having partially adopted the IESBA Code.

    Current Status: Partially Adopted

  • International Public Sector Accounting Standards

    At the regional level, West African Economic and Monetary Union (WAEMU) Regulation No.09/2009/CM/UEMOA requires that WAEMU member states adopt public sector accounting standards that are based on IPSAS by January 2017.

    In Togo, the Ministry of Finance is responsible for the adoption of IPSAS and implementation of the WAEMU regulation. As of 2017, IPSAS have not been adopted in Togo; however, the authorities have undertaken reforms in the area of public financial management to work towards the adoption of accrual accounting in the public sector with the support of different institutions, including the World Bank and the International Monetary Fund.

    Nonetheless, at the time of the assessment, it is unclear what the applicable public sector accounting standards are in Togo.

    Current Status: Partially Adopted

  • Investigation and Discipline

    At the regional level, the World Bank is supporting the Organization for the Harmonization of Business Law in Africa in the development of an investigative and disciplinary (I&D) system for its member states. There is no further information available as of the date of the assessment regarding the status of a regional I&D system.

    Law No. 2001-001 grants authority to the Ordre National des Experts Comptables et des Comptables Agréés du Togo (ONECCA-Togo) to investigate and discipline its members in order to promote compliance with applicable standards. While ONECCA-Togo is responsible for professional breaches and infractions, the Judiciary handles civil and criminal acts. ONECCA-Togo’s Council is responsible for making disciplinary decisions. In 2016, ONECCA-Togo self-assessed its I&D system against the SMO 6 requirements and noted several areas that require improvements, such as the separation of investigative and disciplinary procedures, the implementation of its planned appeals mechanism (the National Discipline Commission), as well as public interest communications and considerations.

    In cases of civil and criminal decisions, individuals may appeal a decision of the Commission to the Administrative Chamber of the Supreme Court.

    Current Status: Partially Adopted

  • International Financial Reporting Standards

    As a member state of West African Economic and Monetary Union (WAEMU) and the Organization for the Harmonization of Business Law in Africa (OHADA), Togo’s accounting standards are defined in WAEMU Regulation No. 04/96/CM/UEMOA, WAEMU Regulation No. 05/CM/UEMOA, OHADA Uniform Act Relating to Commercial Companies and Economic Interest Groups 4/1997 (revised January 2014), and the OHADA Uniform Act on Accounting and Financial Information (AUDCIF).The Conseil Comptable Ouest Africain is authorized by WAEMU Regulation No. 3/97/CM/UEMOA to set accounting standards for member states and has decided to adopt the standards set by OHADA.

    In January 2017, the OHADA AUDCIF was signed by the OHADA Council to update the previous OHADA Uniform Act on Organizing and Harmonizing Company Accounting Systems 2/2000 which had outlined the OHADA Accounting System and applicable standards—known has SYSCOHADA.

    The OHADA AUDCIF revised the SYSCOHADA, namely the OHADA general accounting plan as well as the consolidated and combined accounting rules in order to serve as a single accounting reference in all OHADA member states. The OHADA AUDCIF will come into effect on January 1, 2018 for individual accounts and on January 1, 2019 for consolidated accounts, combined accounts, and financial statements prepared in accordance with IFRS. The SYSCOHADA continue to differ from IFRS; however, the AUDCIF also requires that public interest entities, which include listed companies, banks, insurance, and pension companies as well as any other companies determined by national Ministries of Finance, prepare financial statements in accordance with IFRS as well as SYSCOHADA.

    Current Status: Adopted

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Methodology

Methodology
Last updated: 11/2017
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