Colegio de Contadores de Chile
Member | Established: 1958 | Member since 1981
The CCCH, created by the Law 13.011 of 1958, is a voluntary professional accountancy organization with responsibilities such as: (i) setting accounting and auditing standards for non-regulated companies; (ii) issuing professional and ethical standards for its members; (iii) establishing membership requirements; (iv) investigating and disciplining its members; (v) providing training programs; and (vi) representing and promoting the accounting profession.
In addition to being an IFAC Member, the CCCH is a member of the Inter-American Accounting Association and the Integration Committee Europe—Latin America, and a member of the Group of Latin-American Accounting Standard Setters.
Statements of Membership Obligation (SMO)
The Statements of Membership Obligations form the basis of the IFAC Member Compliance Program. They serve as a framework for credible and high-quality professional accountancy organizations focused on serving the public interest by adopting, or otherwise incorporating, and supporting implementation of international standards and maintaining adequate enforcement mechanisms to ensure the professional behavior of their individual members.
SMO 1: Quality Assurance
There is no legal requirement to establish a quality assurance (QA) review system for all audits of financial statements in Chile. While the Law No. 18.045 does set the legal foundation for the establishment of QA for auditors providing services to listed companies, as of 2021, no mandatory QA review system has been implemented. Only the Financial Market Commission (CMF) requires audit firms listed in the Registry of External Auditors (RAE) to establish quality control mechanisms. However, audit reviews are only carried out when a suspicion or risk is identified.
The CCCH states that it regularly promotes the need to adopt a mandatory QA system at the jurisdiction level to the CMF through the Chairman of its Auditing Standards Committee. Furthermore, the CCCH indicates it plans to support members’ understanding of QA reviews when the regulators eventually adopt a QA system.
The CCCH has adopted and translated audit and quality control standards as issued by the Audit Standards Board of the American Institute of Certified Public Accountants (AICPA) for application by its members, which, in turn, are based on ISA and ISQC1. The CCCH has reported plans to translate the proposed AICPA quality management standards, which are aligned with the IAASB, as reported by AICPA, once the standards are approved. To support the implementation of the requirements, the CCCH reports that it offers training and courses on effective quality control and supports audit firms with the implementation of the standards.
As the CMF is the authority responsible for developing and operating a QA review system, and the CMF carries out reviews under suspicion or risk is identified, the CCCH should continue using its best efforts to collaborate with CMF and relevant stakeholders to promote compliance with the revised SMO 1 requirements.
Importantly, the new suite of IAASB Quality Management standards that will become effective in 2021–2022 will require significant change management for regulators and firms. The CCCH is encouraged to prepare members and raise awareness of the changes from quality control standards to quality management standards and update its training programming to ensure that its members are sufficiently prepared to apply the standards once they become effective.
SMO 2: International Education Standards
Universities, the National Accreditation Commission, the Ministry of Education, and the Superintendency of Higher Education have a role in implementing initial professional development (IPD) requirements for all professional fields, including professional accountants. CCCH reports that the universities providing accounting education programs have partially adopted the 2019 IES requirements. However, according to the CCCH, there are no minimum requirements to practice accountancy in Chile.
To implement some educational requirements, the CCCH reports that it requires candidates to hold a bachelor’s degree in accounting in order to be considered for membership.
The CCCH indicates that its primary activities in this area are centered on promoting the need to implement IES requirements to regulators. In line with this, the CCCH has established a Higher Education Committee (CES), which consists of members from several Chilean universities. In addition, the CCCH established mechanisms, such as its magazine, to distribute information to members regarding recent developments on educational matters.
The CCCH is encouraged to continue collaborating with regulators and universities, specifically the Financial Market Commission (CMF) that has additional registration requirements for external auditors, to promote and support the adoption and implementation of the IES requirements. A voluntary certification aligned with the IES could be one option, adopt mandatory CPD requirements for its members, as well as a university accreditation scheme, and CCCH can refer to examples in the region for best practices and learnings. The CCCH is also encouraged to adopt specific CPD requirements for its members.
Revised requirements of the IES 2, 3, 4 and 8 are effective as of 2021. The revisions to these standards reflect the need for competency-based approaches as well as the increasing demand for accountants skilled in information and communications technologies and place further emphasis on professional skepticism skills and behaviors. These apply to both aspiring and professional accountants. The Accountancy Education E-Tool and the IES Checklist developed by IFAC may be useful to identify implementation support materials and the CCCH’s Higher Education Committee should review these available tools as part of its work plan.
SMO 3: International Standards on Auditing
The CCCH and the Financial Market Commission (CMF) are responsible for setting auditing standards in Chile. The Auditing Standards Committee (CNA) of the CCCH adopts the Chilean Generally Accepted Auditing Standards (NAGA), which, as reported by the CCCH, are the translation of the standards issued by the Audit Standards Board of the American Institute of Certified Public Accountants (AICPA), which, in turn, are based on ISA. The financial sector regulator require the application of standards issued by the CCCH.
The CCCH has been translating the AICPA’s audit standards since 1972 and therefore has an established mechanism in place to monitor, translate, and issue new and revised standards in a timely manner. The institute reports that it continues translating and issuing the AICPA’s audit standards due to the large number of U.S. companies operating in Chile and the large number of Chilean companies participating in the U.S. stock market.
To facilitate members’ implementation of the NAGA, the CCCH offers continuing professional development programming and disseminates information on updates and revisions of NAGA. The CNA reports plans to disseminate information on ISA and promote the inclusion of ISA as part of CCCH’s training.
Additionally, the CCCH reports that the CNA maintains communications with the CMF around firms’ compliance with the auditing standards.
Despite the fact that the CCCH translates and adopts the AICPA’s audit standards on an ongoing basis, the CCCH is encouraged to include specific plans, to adopt ISA and other IAASB pronouncements as part of its commitment to support international standard-setting. In addition, the CCCH is encouraged to raise awareness on ISA by communicating with the regulators on new IAASB initiatives and including ISA in accountancy curricula.
If deemed feasible, it may be beneficial for the CCCH to participate in the international standard-setting process by providing comments on exposure drafts and other IAASB pronouncements to share its experiences and perspective.
SMO 4: Code of Ethics for Professional Accountants
The CCCH is responsible for setting ethical requirements for its members and has developed its own Code of Ethics, and indicates it utilizes the International Code of Ethics for Professional Accountants as a supplement to its own Code. In addition, while the Financial Market Commission (CMF) has not issued a specific regulation related to ethical requirements, in practice, audit firms listed on its registry apply the CCCH Code of Ethics.
The CCCH reports that it has ongoing processes in place to monitor changes to the IESBA Code of Ethics — most recently the 2018 and 2020 versions — and subsequently issue new sections of its Code of Ethics or amend existing parts when necessary.
To support effective implementation of the Code, the CCCH: (i) raises awareness of the Code among the financial sector regulators, universities, judiciary and legislative powers, and government; (ii) disseminates information to relevant stakeholders about the changes to its Code and new, proposed, and revised provisions of the IESBA Code of Ethics; and (iii) includes ethical requirements in its training programs.
The CCCH is encouraged to promote the adoption and implementation of its Code or the International Code of Ethics for Professional Accountants for application by all professional accountants in Chile. The CCCH is encouraged to consider entering into mutual agreements with the CMF to officially adopt the IESBA Code of Ethics or require the application of ethical requirements issued by the CCCH.
If deemed feasible, the CCCH is encouraged to consider plans to participate in the international standard-setting process by providing comments on exposure drafts and other IESBA pronouncements to share its experiences and perspective.
SMO 5: International Public Sector Accounting Standards
The CCCH is not responsible for the adoption of public sector accounting standards in Chile, which are adopted by the Controller General of the Republic of Chile. The Controller General developed accrual - IPSAS modified for local context (2013 version) as the applicable public sector accounting standards. The CCCH notes that it was active in the convergence process with IPSAS by participating in meetings and providing advice to the Controller General.
The CCCH indicates that it has established mechanisms to distribute information regarding recent developments and revisions issued by the IPSASB. Additionally, the CCCH’s Higher Education Committee has incorporated IPSAS into educational programming.
The CCCH reports that it has held meetings periodically to coordinate and support the application of the standards.
The CCCH is encouraged to promote the adoption and implementation of the 2021 IPSAS Handbook to the Controller General of the Republic of Chile.
The IFAC’s Train the Trainers: Introduction to IPSAS resource might be helpful to CCCH to continue providing support to public sector accountants in the jurisdiction. It would also be beneficial to demonstrate how the CCCH engaged with universities to incorporate the standards into the accounting education curriculum.
SMO 6: Investigation and Discipline
The CCCH is responsible for establishing and operating an investigative and disciplinary (I&D) system for its members and has established and implemented I&D procedures accordingly. In addition, the Financial Market Commission (CMF) has responsibility for the I&D of audit firms registered in the Registry of External Auditors (RAE) and individual professionals registered in the register of auditors and account inspectors (RICAE).
The CCCH and its regional councils carry out I&D processes on an ongoing basis. The CCCH reports it has issued procedures and guidance for I&D systems at regional councils that are incorporated under the umbrella of the CCCH. As part of its efforts to align its system with the international best practices, in 2019 and 2021, the assessed its I&D policies and processes against the requirements of SMO 6 and identified gaps. These include the composition of members of the I&D committee (i.e. no non-accountants); public interest considerations (results of the proceedings are not publicly available) and the CCCH is prohibited by the Chilean Constitution to impose penalties such as loss of professional designation or exclusion from membership, among others.
I&D procedures that meet the SMO 6 benchmark are foundational to maintaining public trust and confidence in the profession. CCCH's system continues to have gaps since its last Action Plan update in 2019. It is strongly recommended that it invest time and resources in strengthening its procedures. CCCH is encouraged to connect with other PAOs in the region that have overcome similar obstacles to learn from them. At a minimum, the CCCH should communicate if and how it is planning to address the needed improvements in this area where it is legally capable. Secondly, IFAC has previously urged CCCH to consider its role regarding SMO 6 at the jurisdictional level and provide more details and information about its plans either to recommend and support the implementation of I&D processes in line with the SMO 6 requirements to CMF; or to promote a unified national system that can investigate and discipline all professional accountants while being in line with SMO 6.
SMO 7: International Financial Reporting Standards
The CCCH is mandated by law to adopt corporate accounting standards for non–regulated companies and has accordingly adopted IFRS and IFRS for Small- and Medium-sized Entities (SMEs) by reference. The Financial Market Commission (CMF) is empowered to set accounting and financial reporting requirements for companies under its supervision when the Superintendent of Banks and Financial Institutions (SBIF) became part of the CMF, despite the unification, regulated entities are subject to different requirements. The CMF requires accounting standards that differ from IFRS.
To support the adoption of the standards, the CCCH reports that it has a permanent Accounting Principles and Standards Committee that reviews and approves accounting standards on an ongoing basis. The committee also develops presentations for the financial sector regulators on IFRS, reviews the translations of the standards to detect errors that may cause confusion in the application of the standards, sends the analysis to the IASB, and participates remotely in the IASB meetings.
The CCCH states that it holds regular meetings with regulators to participate in technical discussions regarding analysis of issues or rules that affect the application of the regulations, and does the same with educational institutions to communicate changes to the IFRS and to ensure that universities have included this subject into their accounting curriculum. Additionally, the institute indicates that it supports members’ implementation and compliance with IFRS by disseminating information on new and modified IASB pronouncements, making the translated standards available on its website, and providing training courses.
The Accounting Principles and Standards Committee developed a training program on IFRS for Small- and Medium-sized Entities (SMEs) to support the implementation of the standards in different Chilean regions.
Furthermore, the CCCH is a member of the Latin American Accounting Standard Setters Group and participates in the international standard-setting process by providing comments to exposure drafts on a regional level.
If deemed feasible, the CCCH is encouraged to consider how it might promote the need for the full adoption of IFRS for banks and other financial institutions in the jurisdiction to the CMF.
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