Institute of Certified Public Accountants of Bulgaria

ICPAB shares the responsibility for the QA review system in Bulgaria with the Commission for Public Oversight of Statutory Auditors (CPOSA) and is responsible under the Independent Financial Audit Act of 2016 for audits of non-public interest entities.

ICPAB was very supportive of the adoption of a QA system and has been active in supporting implementation since 2008. For example, each year training is offered to CPOSA inspectors and ICPAB controllers on quality control standards and other areas of quality assurance reviews prior to inspections. ICPAB collaborates with CPOSA to ensure a robust QA review system that continues to meet the SMO 1 requirements and on occasion will carry out reviews jointly. ICPAB will also provide their QA review annual report to CPOSA.

ICPAB is active in supporting its members’ understanding of quality control standards and their ability to carry out high-quality audits within its continuing professional development program. Each year, ICPAB distributes the planned QA review program and offers training (also in conjunction with the Institute of Chartered Accountants in England and Wales (ICAEW)) on ISQC 1 and other areas of quality assurance reviews prior to inspections. It also provides members with implementation guidelines and has translated IFAC’s Guide to Quality Control for Small- and Medium-Sized Practices to ensure consistent and effective implementation.

ICPAB signed an agreement with the ICAEW to translate and publish ICAEW QA review guidance to further assist individual audit firms and sole practitioners in implementing policies and procedures that comply with ISQC 1. All translated guidance materials are available to ICPAB members on the website.

Beginning in 2021, ICPAB has translated the new quality management standards and organized training on auditors’ responsibilities under the new standards. The Quality Review Committee is also introducing a new component to the controller training which will emphasize how QA reviewers must inspect a system of quality management.

ICPAB is encouraged to continue to monitor and support the implementation of QM standards among members. Resources on the QM standards are available on the IAASB website.

Current Status: Sustain

ICPAB reports that it strives to ensure that the national standards and requirements comply with all IES, EU Directives, and national legislation. The Independent Financial Audit Act of 2016 outlines the requirements for initial professional development (IPD) and continuing professional education (CPD) for certified public accountants and registered auditors.

Responsibility for conducting IPD is shared between Bulgarian universities (IES 1), as stipulated in the Higher Education Act, and the ICPAB (IES 2–6) under the oversight of the CPOSA. IPD requirements consistent of a university degree, professional experience, completing a program of accountancy education, and passing exams organized by ICPAB. ICPAB’s Education and Methodological Committee – which comprises university professors and ICPAB members – develops the educational programming for candidates. ICPAB has also signed MoUs with ICAEW and ACCA and with the ICAEW is planning to launch a joint accreditation program with the University of National and World Economy (UNWE) with the objective of integrating professional competency development in addition to technical skills.

Practical experience by candidates is monitored in the following ways: (a) requiring a self-declaration from the candidate that they have completed adequate experience; (b) record of the practical experience is kept and submitted to ICPAB when applying for membership; (c) an assessment is made by the mentor or employee of the candidate; and (d) through a mentoring system.

CPOSA oversees ICPAB in organizing and conducting CPD for certified public accountant candidates and registered auditors. ICPAB has set CPD requirements of 40 hours of CPD per year and has CPD Rules and Procedures that are in accordance with IES 7 as effective 2015. ICPAB indicates that it offers 60 – 70 CPD courses per year for members. It also cooperates with various training providers to offer a wider variety training programs. ICPAB monitors compliance with CPD by maintaining personal electronic files for each member and through the information provided by members in their annual report to ICPAB. In cases of non-compliance, ICPAB implements sanctions whereby it can fine its members and/or deny them the right to practice for up to two years. Repeat offenders lose their licenses and are removed from the registry of registered auditors.

ICPAB also translates the IES and the 2017 Handbook is available in Bulgarian.

Alignment with the IES requirements is an important foundation for a strong accountancy profession at all levels. ICPAB is encouraged to review and complete the IES Checklist developed by IFAC which may be useful in progressing with the adoption of the revised requirements of the IES, especially IES 2, 3, 4 and 8 that are effective as of January 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, which ICPAB is working to integrate into IPD. ICPAB may also consider utilizing the IFAC Accountancy Education E-Tool to review the current version of IESs and share these requirements with its members and stakeholders. The 2019 Handbook may also be translated into Bulgarian.

Current Status: Review & Improve

According to Article 9 of the Independent Financial Audit Act of 2016, audits must be conducted in accordance with ISA and other pronouncements as issued by the IAASB. ICPAB proactively translates and disseminates the standards and other pronouncements of the IAASB. ICPAB has a formal procedure for the translation process and as of 2023, ICPAB reports that the 2021 version of the standards has been translated.

ICPAB reports that it offers approximately 17–20 courses for continuing professional development training on ISA-related topics each year. It delivers courses and seminars alongside implementation support for its members on a variety of audit-related topics with a focus on new and/or revised standards.

ICPAB maintains a timely translation and implementation support process to fulfill obligations under SMO 3.

Current Status: Sustain

Article 10 of the Independent Financial Audit Act of 2016 requires application of the IESBA Code of Ethics for registered auditors as issued by IESBA and adopted by the Institute of Certified Public Accountants in Bulgaria (ICPAB) under the oversight of the Commission for Public Oversight of Statutory Auditors (CPOSA). Furthermore, ICPAB requires its members, both registered auditors and certified public accountants, to comply with the IESBA Code of Ethics. ICPAB’s Ethics Council has established an ongoing process for reviewing and translating new and revised pronouncements of the IESBA. As of 2023, the 2022 version of the International Code of Ethics for Professional Accountants has been adopted for all professional accountants in the jurisdiction.

ICPAB states that it monitors the issuance of new and/or revised IESBA Code of Ethics and strives to ensure timely translations for its members. ICPAB also obtains comments from members on the new and/or revised IESBA Code of Ethics to assess their impact on implementation.

To assist members with implementation, ICPAB hosts continuing professional development events and training programs on ethics. For example, it developed and established an educational and training program on the IESBA Code of Ethics and incorporated a separate one-day session on professional ethics and independence for candidates seeking the registered auditor qualification. ICPAB also offers implementation guidance to members via its Intranet.

ICPAB maintains a timely translation and implementation support process to fulfill obligations under SMO 4.

Current Status: Sustain

The Ministry of Finance is responsible for establishing public sector accounting standards and has adopted partial accrual, national accounting standards for application in the public sector. According to the CIPFA/IFAC 2020 International Public Sector Financial Accountability Index, there are plans to utilize partial-accrual IPSAS by 2025.

ICPAB has no responsibility for the adoption of public sector accounting standards and uses its best efforts to advocate for IPSAS adoption when opportunities arise by liaising with the MoF on IPSAS and related matters and through public consultations with representatives from the MoF. Previously, it participated in a task force with the MoF and the National Audit Office to conduct a survey on the current accounting framework and accrual approach at the EU level.

At the end of 2020, ICPAB indicates it established a working group on its Education and Methodology Committee with the objective of translating the IPSAS and in 2021, it translated the Conceptual Framework for General Purpose Financial Reporting by Public Sector Entities into Bulgarian. The working group consists of members from the profession, academia, and government.

ICPAB is using its best endeavors to fulfill its obligations under SMO 5, and it is encouraged to continue its advocacy and support toward accrual-basis IPSAS. Adoption and implementation of accrual IPSAS as issued by the IPSASB would ensure application of global best practice. ICPAB may consider if it can translate the 2021 IPSASB Handbook which was effective as of January 2021. It may also find IFAC’s Train the Trainers: Introduction to IPSAS resource helpful for any advocacy and/or educational activities it offers.

Current Status: Sustain

ICPAB shares responsibility for investigation and discipline (I&D) of the profession with the Commission for Public Oversight of Statutory Auditors (CPOSA). In accordance with the Independent Financial Audit Act of 2016, and with the support and cooperation of ICPAB, CPOSA established an I&D system to address infractions made by registered auditors in the conduct of statutory audits. ICPAB cooperates with CPOSA regarding any disciplinary actions of its members.

With respect to ICPAB’s direct responsibilities, it has established an I&D system for its members. Any violations found by the Ethics Council, the Quality Control Committee or the Supervisory Board, the relevant files are submitted to the Disciplinary Council, notifying accordingly ICPAB’s Board. Disciplinary sanctions are outlined in Article 41 of the Independent Financial Audit Act of 2016, and chapter seven of ICPAB’s By-laws. ICPAB’s I&D system incorporates most of the requirements of the revised SMO 6. As of the date of the assessment, the only gap pertains to the composition of the disciplinary committee since it only includes professional accountants.

ICPAB periodically reviews I&D mechanisms and informs members about the processes and procedures that are in place.

If feasible, ICPAB is encouraged to consider the inclusion non-professional accountants in its disciplinary council as part of strengthening public interest representation and perceptions of independence, which are important to public confidence in the enforcement procedures.

Current Status: Review & Improve

The Accountancy Act of 2015 stipulates the accounting standards that are applicable in Bulgaria and prescribes application of IFRS as endorsed in the European Union (EU) and published in the EU Official Journal. As of January 1, 2017, all public interest entities are required to apply the IFRS as adopted by the EU. All other entities (primarily MSMEs) are required to apply the National Accounting Standards set by the Ministry of Finance.

ICPAB has no authority over the adoption of IFRS in Bulgaria. It focuses on supporting implementation among members and candidates (students) by keeping them informed of new and/or revised IFRS through professional development courses, ICPAB newsletters, and the ICPAB website. ICPAB states it organizes and delivers approximately 20–22 annual training courses and/or seminars for its members on IFRS amendments and additions. It has also signed an agreement with the IFRS Foundation for the translation of standards in Bulgarian.

Lastly, ICPAB reports to be in the process of establishing a system to monitor its members’ application of IFRS through the QA review system.

If appropriate, ICPAB may consider plans and dialogue with the MoF to adopt IFRS for SMEs which might support and strengthen the financial reporting regime for MSMEs in the jurisdiction.

Current Status: Sustain