Ordem dos Contabilistas e Auditores de Moçambique
Associate | Established: 2012 | Associate since 2019
The OCAM is empowered by Law No. 8/2012 to regulate the accountancy profession. OCAM’s membership is comprised of certified accountants (CCs) and certified auditors (CAs). All individuals who wish to be professional accountants must have the designation of certified accountant (CC) or certified auditor (CA). The designations of CC and CA are protected by Law No. 8/2012 such that only members of OCAM may use them upon registration.
Under Section 6 of the Law, OCAM’s responsibilities include: (i) promoting the interests of the accountancy profession; (ii) issuing practicing certificates for certified accountants (CC) and certified auditors (CA); (iii) maintaining a registry of its members; (iv) establishing initial and continuing professional development (IPD and CPD) requirements; (iv) setting ethical requirements; (v) establishing and implementing an investigative and disciplinary (I&D) system; (vi) defining technical standards taking into consideration international best practices; (vii) proposing legislative measures, regulations or any decree of similar nature relating to the Accounting System for the Business Sector (SCE) according to international standards; and (viii) establishing and implementing a quality assurance (QA) review system.
In addition to being an Associate member of IFAC, OCAM is a member of the Pan African Federation of Accountants (PAFA).
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
The OCAM is responsible for conducting quality assurance (QA) reviews in Mozambique and in 2014, passed regulations that adopted quality control standards (ISQC 1), established QA review procedures incorporating the SMO 1 requirements, and a Quality Assurance Committee (QAC).
Recognizing a lack of internal capacity, in 2017, OCAM signed a Memorandum of Understanding (MoU) with the Public Accountants and Auditors Board—Zimbabwe (PAAB) to support the implementation of a QA review system. The MoU commenced in August 2017. Since then, a QA questionnaire and user guide have been prepared and approved and the PAAB has conducted trainings for firms that will be subject to QA reviews. The PAAB began conducting QA reviews in July 2018 with OCAM’s QA review team participating in the reviews to build its capacity. Two pilot QA reviews have been completed and OCAM’s objective to visit 10 firms in 2019 was completed. It has begun to collect annual returns from members that audit public interest entities to create a database that will be utilized to determine risk and future QA review cycles. OCAM reports that its QA review team is being led by a consultant with extensive QA review experience in South Africa, Botswana, Zimbabwe, and Namibia.
As part of its efforts to support its members, OCAM indicates that at the end of the review period, OCAM and the PAAB will produce a report highlighting the common findings and deficiencies. OCAM then intends to organize a workshop with practitioners and firms to discuss these topics and include them within continuing professional development (CPD) courses to improve practitioners’ capabilities. The association also states it has published QA guidelines and disseminates information on the value of QA reviews via its website. Considering that many of its member firms are small- and medium-sized, the association has also shared IFAC’s SMP resources on this topic as well.
As QA reviews are underway with the partnership of the PAAB, OCAM is encouraged to continue ensuring that the review process meets the SMO 1 best practices and that local reviewers are enhancing their capacity to conduct QA reviews in the future. The new suite of Quality Management standards will become effective in 2021-22 and will require significant change management for regulators and firms. To prepare auditors in the jurisdiction for the implementation of the standards, OCAM is encouraged to closely follow the developments and publication of implementation support materials, raise awareness of its members about the forthcoming change, and update its educational programming to ensure that its members are sufficiently prepared for the application of the standards once they become effective.
SMO 2: International Education Standards
Law No. 8/2012 outlines some general entry and educational requirements and states that the OCAM may set more specific initial professional development and continuing professional development (CPD) of professional accountants. OCAM states it has adopted the requirements of the 2019 IES and has taken several steps to enhance the implementation of national education requirements leading to the designation of certified auditor and accountant.
In September 2016, OCAM reports that its General Council approved a new Admission, Exams, and Practical Experience Regulation which aligns OCAM’s entry requirements with the IES. OCAM noted that it can be challenging to ensure that university programming is aligned with IES requirements. To address this, OCAM is working with the national Council of Higher Studies (CNAQ) within the Ministry of Education to design the accounting curriculum and ensure it meets IES benchmarks. A team of OCAM and CNAQ representatives will visit universities for accreditation purposes and provide recommendations to enhance training materials. If universities do not take steps to comply with the standards set out by CNAQ, the accreditation can be revoked. Presently, OCAM is encouraging students to study at universities that are accredited and in the long-term will only permit students that graduated from accredited universities to proceed with OCAM’s examinations.
As mentioned above, there is also a practical experience requirement of three years for each designation which OCAM will evaluate after candidates successfully complete oral and written final examinations of the College. 2018 was the first year where admissions to OCAM factored in practical experience and examinations. There is a low number of practical experience providers in the country currently. OCAM is working with OCC to utilize a virtual software that simulates running a business from start to finish which would help candidates have a foundational understanding of workplace demands.
OCAM reports that as of the date of the assessment, over 100 individuals have completed OCAM–OROC’s programming for auditors. The institutes have prepared study packs and made previous examination questions available to students as part of the program. Through the partnership, OROC is running all related training and examinations and OCAM conducts the local tax and business law exam. For its College of Accountants, the OCAM has partnered with universities to offer online training and online study materials as a cost-effective way for individuals to pursue the accounting qualification. After resolving logistical challenges and strengthening its certification regime throughout 2017, OCAM ran its first set of examinations from its College of Accountants in November 2018 with support from OCC to select questions, and continues to conduct accountancy examinations on an annual basis.
Furthermore, OCAM has revised its compulsory CPD requirements for its members to comply with the IES. All members are now required to record 120 CPD hours (60 credits) every three years with an annual CPD calendar provided. OCAM has created an online registry for members to record their CPD attendance and has notified members via email and newsletter articles of consequences of non-compliance with CPD requirements. Beginning in 2018, OCAM monitored and analyzed cases of non-compliance and sent disciplinary warnings to members as needed.
To facilitate greater accessibility to CPD courses, OCAM offers free training for members and has permitted its members to obtain CPD credits through e-learning platforms provided by other IFAC members.
OCAM’s partnerships with other Portuguese-speaking PAOs are highly beneficial to supporting its educational initiatives. As it progresses with these initiatives, it is encouraged to continue building up its own local, technical capacity to offer trainings and support the variety of educational and practical experience providers in the jurisdiction to address the IES requirements.
SMO 3: International Standards on Auditing
OCAM is authorized by Law No. 8/2012 to define audit standards taking into consideration international best practices. OCAM states it has adopted the ISA as issued by the IAASB.
OCAM does note that implementation can be a challenge due to ongoing translation needs. To support the application of more recently issued ISA, the association is partnering with Instituto dos Auditores Independentes do Brasil (IBRACON) to utilize its online platform for continuous professional education. The platform contains individual ISA and related resources that the IBRACON has been able to translate into Portuguese.The 2018 Handbook of International Quality Control, Auditing, Review, Other Assurance, and Related Services Pronouncements is the latest version available in Portuguese, which OCAM has republished in line with IFAC’s Permission Policy.
OCAM reports that ISA are included in its IPD and CPD courses and that it makes standard-related material available via its newsletter. As part of its CPD programming, OCAM has invited experts from IAASB and the Independent Regulatory Board for Auditors (IRBA) to give seminars on the standards.
Finally, OCAM states that it joined in PAFA’s Technical Forum to provide comments on international standard exposure drafts.
OCAM is encouraged to continue its collaborations with the Portuguese-speaking PAOs grouping to establish ongoing processes that would ensure timely access to translated standards. The IAASB has issued an exposure draft of the proposed separate standard for audits of Less Complex Entities. OCAM is encouraged to participate in the public consultation process for this landmark new draft standard.
SMO 4: Code of Ethics for Professional Accountants
As the entity responsible for setting ethical requirements, OCAM issued internal Resolution 5/GB/2014 which adopted the International Code of Ethics as issued by IESBA in its entirety as OCAM’s Code of Ethics.
OCAM is considering how to collaborate with other Portuguese-speaking countries to facilitate translations of standards and resources into Portuguese. OCAM indicates that it has internally translated the 2018 International Code of Ethics due to demand and is seeking IFAC permission to disseminate it among members. OCAM states that it will continue to monitor IESBA activities and changes to the Code and work to disseminate IESBA pronouncements to members through its newsletter.
Additionally, OCAM has taken steps to improve its staff’s expertise in this area by sending one of its staff to participate in a course offered by the South African Institute of Ethics. Through this course, the staff was trained and certified as a Certified Ethics Practitioner and has returned to OCAM to support the work of its Ethics Committee.
OCAM indicates that it has included the IESBA Code of Ethics into the topics on the examinations. The association has also provided CPD trainings on the Code to members as well as board members and OCAM delegates throughout the country. Within its newsletter OCAM also includes current ethical challenges being faced by members.
Finally, OCAM states that it partakes in the Pan African Federation of Accountants (PAFA)’s Technical Forum to provide comments on international standard exposure drafts.
OCAM is encouraged to continue its collaborations with the Portuguese-speaking PAOs grouping to establish ongoing processes that would ensure timely access to translated standards. There have been several significant changes to the IESBA Code, notably since 2018. The 2020 Handbook of the International Code of Ethics for Professional Accountants is now available and includes the following changes: revisions to Part 4B of the Code?to reflect terms and concepts used in the IAASB's International Standard on Assurance Engagements (ISAE) 3000 (Revised), which are effective June 2021 and revisions to promote the role and mindset expected of all professional accountants which are effective in December 2021. with these latest changes and educate its members of these obligations.
SMO 5: International Public Sector Accounting Standards
In Mozambique, the government is responsible for adopting public sector accounting standards and is currently implementing cash-basis accounting standards (IFAC, CIPFA 2020). OCAM has held meetings with the Prime Minister of Mozambique and other senior government officials to further promote the adoption and implementation of IPSAS. A new taskforce with public sector representatives and OCAM has been created to pursue the adoption of IPSAS by 2026 along with developing a public sector curriculum and qualification.
The 2012 IPSAS are available in Portuguese and OCAM has shared the translations with the government with IFAC permissions as part of its advocacy efforts. OCAM has also been an active participant in events related to the IPSAS, such as attending the 2016 IPSASB Standard-setting Forum and the 2018 IPSASB Roundtable in Ethiopia, and referring to the successful Tanzanian case of IPSAS adoption as part its knowledge gathering and sharing.
In 2020, despite the ongoing global COVID-19 pandemic, OCAM and Ministry of Finance visited Tanzania regarding IPSAS adoption and implementation as a best practice case study and met with Tanzanian PAO (NBAA) and MoF. As a result, OCAM signed an MoU with NBAA to evaluate the current state of Mozambique standards and create a roadmap toward IPSAS adoption. OCAM will support the Mozambican MoF with staff to work full-time on this initiative to achieve IPSAS adoption by 2026.
Additionally, the association states it has included topics on IPSAS into its examinations for Accountants’ and Auditors’ College and as mentioned earlier is considering the creation of a third College, dedicated to a public sector qualification / specialization. The challenge facing the association is that there is no existing public sector qualification available in Portuguese that OCAM could build upon. While the timeline for operating such a College is tenuous given the need to collaborate closely with the government, OCAM is already collecting data on the number of public sector accountants that are either professionally qualified; only have an accounting degree; or have no accounting education to help determine an action plan for the initiative.
OCAM has sought assistance from PAFA and the Organisation of English-speaking African Supreme Audit Institutions (AFROSAI-E) on how to enhance its involvement in the public sector sphere. IPSAS were also apparently incorporated into its CPD activities and trainings as of 2016. OCAM indicates it will disseminate information on IPSAS updates to its members via its newsletter
Lastly, OCAM states that it participates in PAFA’s Technical Forum to provide comments on international standard exposure drafts.
OCAM’s recent engagements with the MoF to strengthen public financial management and accounting are commendable. It is encouraged to continue these actions and advocacy efforts with the government to progress its roadmap of IPSAS adoption. Adoption and implementation of accrual IPSAS as issued by the IPSASB would ensure application of global best practice. Several revisions to IPSAS have been issued since 2012 and OCAM may consider if it can translate the 2021 IPSASB Handbook which was effective as of January 2021. It also may find IFAC’s Train the Trainers: Introduction to IPSAS resource helpful for any advocacy and/or educational activities it offers.
SMO 6: Investigation and Discipline
OCAM is empowered by Law No. 8/2012 to establish an investigative and disciplinary (I&D) system for professional accountants. OCAM’s internal Resolution No 8/GB/2014 establishes the procedures for the I&D system which is overseen by the Judicial Council of the association. The Judicial Council has four separate divisions: investigation, discipline, rights’ representative, and a tribunal. All committee members are independent, and committees are comprised of members and non-members, such as retired practitioners and lawyers. There is also an administrative court for members to appeal.
OCAM reports that its system is operational and with the commencement of quality assurance reviews in Q4 2018 and QA review cycles having punitive consequences, its procedures incorporate all the SMO 6 best practices. It conducts annual reviews of the I&D system to ensure effectiveness of the system.
To enhance its recordkeeping and tracking of cases, OCAM notes that an online platform is operational as of the date of the assessment. Since 2020, the institute is revising its bylaws and constitution to align with its internal regulations which meet SMO 6. The constitution must be approved by Parliament—the matter is pending due to COVID-19 delays.
In 2017, OCAM reports that its Council considered 16 cases and in 2018, 13 cases. Of these, three did not move forward due to lack of information, two individuals were sanctioned, six were settled by mediation, and one case has been postponed. Subsequently in 2019, two cases were settled by mediation. In the first quarter of 2021, the Council considered 9 cases which are ongoing as of the date of the assessment.
Complaints may be initiated members, clients, and employers as well as publicly available information such as newspapers. OCAM publishes a list of suspended members on its website.
Additionally, OCAM states that it shares quarterly articles about the most common I&D cases and the outcomes of disciplinary proceedings in its newsletter. It will also make results of all I&D cases publicly available in its Annual Report.
Finally, OCAM indicates that it works closely with the Attorney General’s office and the Central Office of Anti-Corruption in the case of more serious offences.
OCAM is encouraged to continue its regular review of effectiveness of the I&D system to ensure ongoing alignment with SMO 6 requirements.
SMO 7: International Financial Reporting Standards
Accounting requirements are established by Decree 70/2009 and as of the time of the assessment, the accounting system is based on IFRS as published in November 2008. The decree explicitly states that institutions and companies in the banking and insurance sectors are subject to separate requirements of the Bank of Mozambique (BM) and the Ministry of Finance. Both entities adopted IFRS as published in 2008 but in practice, OCAM indicates that these regulators require entities to apply IFRS as it is issued by the IASB.
The Decree 70/2009 also stipulates that a Regulatory Board of the Accounting Standards, which should be created by the Ministry of Finance, would be responsible for reviewing, adjusting, interpreting, and updating the SCE in Mozambique. Such a standard-setting board has not yet been created. Meanwhile, OCAM has authority under its founding legislation to define technical standards considering international standards. The association, with assistance from PAFA, has drafted a proposal to present to the Ministry of Finance outlining how an independent standard-setting committee would function and be financed with the support of OCAM. The association circulated the proposal to all members, relevant stakeholders, and held two public consultations to receive input. OCAM has also signed agreements with the Mozambican Chamber of Commerce, the Securities Exchange Commission, the BM, and Ministry of Finance to be part of the standard-setting committee. The abovementioned proposal is pending approval by the Ministry as of the time of the assessment.
OCAM is committed to the establishment of the standard-setting committee and in April 2019, it secured financial support from a local non-government organization—Fundação para a Melhoria do Ambiente de Negócios (FAN)—to bring in consultants to train up the committee on the technical standard-setting processes. With funding secured, OCAM began working with the Ministry of Finance to work on the legal matters regarding the establishment of the standard-setting body. OCAM reports that it will be engaging with the Zambia Institute of Chartered Accountants (ZiCA) to learn more on the institute’s standard-setting processes as the PAO is both the regulator and standard-setter in the jurisdiction like OCAM.
OCAM also seems to have taken notable steps to progress with the dissemination and accessibility of IFRS translations in Portuguese for its members and relevant stakeholders. OCAM states that it consulted with the IFRS Foundation in 2016 to obtain an annual subscription with access to all IFRS and pronouncements in Portuguese. The most recent version of the IFRS are taught by lecturers in pre-qualification courses as well as in CPD activities and included in examinations. The 2020 version of the standards are available in Portuguese as of the date of the assessment.
In efforts to further promote the usage of up to date IFRS amongst companies, OCAM has plans to launch its own Transparency Index to recognize companies that are champions in accountability, apply IFRS, employ qualified professional accountants in their organizations, and are transparent in their financial statements.
Finally, OCAM also participates in standard-setting activities through its participation in PAFA’s Technical Forum to provide comments on international standard exposure drafts. OCAM also states it shares standard-related information with its members through its newsletter and website.
OCAM has undertaken several positive initiatives to drive the adoption of the most recent IFRS. The association is encouraged to continue providing updates on the progress and timeline to establish the accounting standard-setting board that would maintain a continuous process for IFRS adoption.
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