Conseil Supérieur de l'Ordre des Experts-Comptables
Member | Established: 1945 | Member
The CSOEC is an independent organization, under the purview of the Ministry of Economy, Finance and Budget, created by Ordinance No. 45-2138 of 1945. Individuals and legal entities are required to be members of CSOEC in order to offer accountancy services other than auditing. In accordance with the law, the CSOEC responsibilities include the following: (i) maintaining the registry of chartered accountants and accounting firms; (ii) establishing CPD and professional conduct requirements; (iii) establishing and operating a quality control system; (iv) preparing and drafting professional conduct standards; (v) drafting auditing standards for contractual audits and reviews of historical financial information, and other assurance and related services engagements; (vi) providing input into the accountancy curricula and IPD requirements for chartered accountants; and (vii) representing, promoting, defending, and developing the profession of chartered accountant, both in France and abroad.
In addition to being an IFAC Member, CSOEC is also a member of Accountancy Europe, the Federation Internationale des Experts-Comptables Francophone, and the Fédération des Experts-Comptables Mediterranéens. In addition, CSOEC participates in the European “Common Content Project.”
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
In France, the High Council for Statutory Audits (H3C), is responsible for the establishment and implementation of a quality assurance (QA) review system for all statutory audits of financial statements. The H3C has established a QA system for all public interest entities (PIEs) and has delegated the QA reviews for non-PIEs to the CNCC. It appears that the QA reviews for statutory auditors being carried out by the H3C and CNCC are largely aligned with the SMO 1; however; ISQC 1 and ISA 220, which are key components of the SMO 1 best practices, are not adopted.
The CSOEC reports that it has developed and implemented a system of quality control for the work activities—i.e. contractual audits and other engagements—of its members since 2012. Accounting firms are reviewed approximately once every eight years. The CSOEC indicates that its system is mostly aligned with the best practices of SMO 1, having only one difference: in the cycle for reviews (once every eight years). However, the institute reports it aims to increase the frequency of the reviews. In addition, the CSOEC specifies that it has adopted the ISQC 1 for its members with slight modifications given the nature of its members’ engagements.
To support its members with the review process, the CSOEC has translated the ISQC 1 into French and incorporated the standard into its Handbook of professional standards. Furthermore, the CSOEC states that it: (i) disseminates information on quality control standards through printed materials and its website; (ii) includes quality control standards in its continuing professional development; and (iii) liaises with regional bodies to ensure implementation of the relevant standards.
The CSOEC is encouraged to provide a timeline regarding its initiative to further align its review system with the SMO 1 best practices.
SMO 2: International Education Standards
Initial professional development (IPD) requirements for professional accountants are established in the Commercial Code (“Commissaires aux comptes”) and Decree 2012-432 of 2012 (Experts-comptables), and are implemented by the French universities, the Ministries of Higher Education, Justice and Economy, Finance and Budget. The CNCC and CSOEC report that the education requirements in place for all professional accountants meet the revised 2019 IES requirements.
To be eligible to practice as a chartered accountant, individuals must: have a university degree; three years’ work experience; pass a final assessment, and obtain the French higher accountancy degree: “Diplôme d’Expertise Comptable” (DEC). Subsequently, candidates must be registered with the CSOEC.
Once a member of the CSOEC, individuals are required to complete 120 hours of continuing professional development (CPD) over a 3-year rolling period.
To support adoption and implementation of the IES requirements into national accountancy programming, the CSOEC, in collaboration with the CNCC, reports a number of advocacy activities with the regulators. For example, the institutes provided input into the accounting syllabus delivered by universities and influenced regulators in the establishment of work experience requirements. Furthermore, as a fellow founder of the “EU Common Content Project”, which aims to harmonize the accountancy education programs participating in the project, the CSOEC worked on the content of the education programs to better harmonize with other countries.
At the international level, the CSOEC through the “EU Common Content Project” participates in the international standard-setting process by providing comments on exposure drafts and other IAESB pronouncements.
SMO 3: International Standards on Auditing
Applicable auditing standards in France are prepared and drafted by a joint commission of the Compagnie Nationale des Commissaires aux Comptes (CNCC) and the High Council for Statutory Audits (H3C), the audit oversight authority. After receiving an opinion on the standards from the CNCC, the H3C will subsequently adopt the standards as professional practice. The Ministry of Justice is ultimately responsible for endorsing the standards at the end of the process. The standards are based on the ISA; however, it is unclear the version used as reference.
In this context, the CSOEC assumes responsibility for adopting standards related to its members’ areas of work, which does not include statutory audits. CSOEC drafts auditing standards for contractual audits and reviews of historical financial information, and other assurance and related services engagements, and submits them to the Ministry of Economy, Finance and Budget for approval. The CSOEC indicates that the standards for contractual and for other services the standards are based on the 2009 ISA. The CSOEC continues to review recently issued ISA as part of its convergence process and is now awaiting the Ministry of Economy’s agreement to apply the 2016 ISA version.
To facilitate an ongoing adoption and implementation process, the CSOEC indicates that it: (i) monitors new and amended standards issued by the IAASB, (ii) regularly incorporates and updates the relevant standards into its Handbook of professional standards; (iii) completes timely translations of the ISA, in collaboration of the CNCC and Belgian Institut des Réviseurs d’Entreprises (IRE); (iv) develops implementation guidelines for its members; (v) disseminates information on updates to the standards and international developments in the area through printed materials and its website; and (vi) provides professional development activities.
SMO 4: Code of Ethics for Professional Accountants
The CSOEC is responsible for drafting ethical requirements for its members, which are chartered accountants, and the Ministry of Economy, Finance and Budget then approves the requirements. The Code of Ethics for chartered accountants was approved and published in the Decree 2012-432 of 2012.
The CSOEC states that its ethical code cannot be directly compared to the IESBA Code as its Code does not include Part B of the IESBA Code and does not aggregate all the texts dealing with ethical issues that can be encountered by professional accountants. As reported by the CSOEC, the Code of Ethics does not incorporate all the requirements of the IESBA Code of Ethics.
While its CSOEC does not adopt the IESBA Code, it supported the translation of the 2009 IESBA Code into French in collaboration with the Compagnie Nationale des Commissaires aux Comptes (CNCC), the Belgian Institut des Réviseurs d’ Entreprises (IBR-IRE), CPA Canada, and the Institute of Chartered Accountants of Cameroon.
The CSOEC is encouraged to provide more details and information about any plan to work on eliminating differences between its Code of Ethics and the IESBA Code of Ethics and/or consider the full adoption of the IESBA Code of Ethics for its members. Importantly, in light of the 2018 IESBA Code of Ethics, which is a completely restructured and rewritten Code, the CSOEC should consider reviewing and developing a comparison exercise of the requirements. Subsequently, the CSOEC is encouraged activities to collaborate with the Ministry of Economy, Finance and Budget and demonstrate how it supports its members with the implementation of ethical requirements.
SMO 5: International Public Sector Accounting Standards
The CSOEC is not responsible for the adoption of public sector accounting standards, which are adopted by the Public Sector Accounting Standards Council (CNOCP)—an advisory body under the authority of the Ministry of Public Accounts. As reported by CSOEC and the Compagnie Nationale des Commissaires aux Comptes (CNCC), IPSAS have not been adopted in France but they are considered as one of the references for establishing standards.
The CSOEC states it is proactive in this area and that it collaborates with the CNCC in the following activities: (i) participation in the CNOCP’s working group to provide comments to the IPSASB’s exposure drafts and other pronouncements; (ii) advocate for IPSAS adoption through the professional accountants on the CNOCP’s Board; and (iii) development of specialized training in the public sector as part of the CPD programs; and (iv) assist the CNOCP in the translation of the 2015 IPSAS Handbook.
The CSOEC is encouraged to clarify the extent on the alignment of the national public sector accounting standards with IPSAS.
SMO 6: Investigation and Discipline
The investigative and disciplinary system for professional accountants (Experts-Comptables) is set by the Ordinance No. 45-2138 of 1945 and complemented by Decree 2012-432 of 2012. The system is based on Regional Disciplinary Chambers which are fully integrated into the French judicial system and are composed of professional accountants together with a judge and a representative of the government. The CSOEC reports that the I&D mechanism for chartered accountants fulfills the requirements of the SMO 6.
The appeal takes place with the National Disciplinary Chamber which is composed of professional accountants together with a judge, a representative of the government, a representative of the Court of Auditors (Cour des Comptes) and a representative of the Ministry of Finance. The appeal to the decisions of the National Disciplinary chamber takes place before the Supreme Court (Conseil d’Etat). Sanctions are published once they are made anonymous or they can be fully consulted at the regional disciplinary chamber. The list of the possible sanctions is limited and defined by the legal framework.
The CSOEC is encouraged to consider elaborating the SMO 6 section in its Action Plan by providing information on its involvement in regards to the I&D systems: e.g. activities to disseminate information on the I&D systems to the public; implementation of training activities based on the outcomes and results of the I&D systems. These are examples of best practices that can be shared and highlighted through the Action Plan.
SMO 7: International Financial Reporting Standards
French accounting standards are developed and adopted by the Accounting Standards Authority (ANC), which is the legal body responsible for accounting standard-setting. The EU statutory framework has been transposed into national legislation by the ANC, such that listed entities are required to apply EU-endorsed IFRS Standards for consolidated financial statements. In addition, all other companies are permitted to apply IFRS for their consolidated financial statements. However, entities are not permitted to apply IFRS for the preparation of their individual financial statements, which are required to use French accounting standards (French GAAP). The ANC has concluded that there is no demand for the IFRS for SMEs in France as French GAAP is considered fit for purpose.
The CSOEC reports that, in collaboration with the Compagnie Nationale des Commissaires aux Comptes (CNCC), it has promoted the adoption of IFRS to the ANC by participating in different working groups set up by the national accounting standard setter. In addition, while the CSOEC itself is no longer a direct member of the ANC, professional members of both institutes are members of the ANC Board, its committees, and working groups which help support the ANC’s standard-setting work.
Among its members, the CSOEC, in association with the CNCC, supports IFRS implementation through the development and maintenance of a website dedicated to IFRS; the issuance a French version of the Guide to IFRS for SMEs; the provision of training activities, including biennial technical conferences on IFRS and inclusion of comprehensive IFRS related issues into CPD courses; distribution of information on the standards through various means, such as its website, quarterly newsletter on IFRS application and,, professional magazine; and lastly responding to technical questions from its members on IFRS.
The CSOEC indicates that it aids the ANC and Accountancy Europe in developing responses to the public consultations issued by the IASB and/or the European Financial Advisory Group (EFRAG) on IFRS and related matters.
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