Ordre National des Experts Comptables et Comptables Agréés du Sénégal
Member | Established: 1996 | Member since 2013
ONECCA-Senegal was established by Senegalese Law 2000-05 in January 2000, pursuant to a Community Directive issued in September 1997. Its membership comprises Certified Accountants and Chartered Accountants. Membership in the institute is mandatory and only Chartered Accountants registered with ONECCA-Senegal are permitted to offering audit services.
ONECCA-Senegal is responsible for: (i) maintaining a register of Chartered Accountants and Certified Accountants; (ii) licensing qualified members to practice auditing; (iii) monitoring compliance with technical standards; (iv) setting ethical requirements for its members; (v) establishing an investigative and disciplinary system; (vi) implementing initial professional development requirements; (vii) setting continuing professional development requirements; and (viii) monitoring conduct and performance of members, including quality assurance reviews of all audits and services carried out by members. Law 2000-05 stipulates that the institute’s activities are subject to the oversight and supervision of the Ministry of Finance.
In addition to being a member of IFAC, ONECCA-Senegal is a member of the Pan African Federation of Accountants, the International Federation of Francophone Accountants, and the Association of Accountancy Bodies in West Africa.
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
At the regional level, 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 Senegal, to develop and implement QA review systems.
In 2013, under the oversight of the Ministry of Finance, ONECCA-Senegal established a Quality Assurance Review System (QARS) for its members and adopted ISQC 1 and ISA 220 as quality control standards. QA reviews are to be conducted every three years for public interest entity (PIE) audit firms and every six years for all other audits. The QARS was performed on a voluntary basis for PIE statutory audits in 2013. In 2014, the QAR extended to all ONECCA-Senegal members on a voluntary basis. This was done with the assistance of the French professional accountancy organizations. Subsequently, in 2015, the institute’s Quality Assurance Commission took over the reviews but were unable to carry out reviews due to resource constraints related to compensating QA reviewers. The institute states that its QA Commission will convene to determine the first cycle of reviews to begin on a mandatory basis beginning in Q4 2019 and is considering approaching donor organizations to support a pool of funds for reviewers as well as having firms pay for the reviews.
The institute conducted a review of its QARS against the SMO 1 requirements and it indicates that with QA reviews soon to be performed on a mandatory basis, the results will be linked to its investigative and disciplinary system and therefore meets all SMO 1 best practices. At as of the date of the assessment, confirmation that QA reviews have resumed is still pending.
The ONECCA-Senegal QA Commission has shared an OHADA-issued QA manual and provides access to standards and related handbooks in French. Prior to resuming QA reviews, the institute states it provided its members with questionnaires to prepare for a review and is organizing workshops and training for members to on how to use available tools. Furthermore, once the QA reviews are complete, ONECCA-Senegal notes it will publish a report on the main issues found during reviews and conducts trainings for members on the most significant and frequent issues found to enhance improvements.
Despite the pandemic, ONECCA-Senegal is taking the necessary steps to re-operationalize its QA review system, this time on a mandatory basis. As it continues to advance in this initiative, it is encouraged to report on progress in its SMO Action Plan and specific actions to support its members, report on results, and address any deficiencies. The institute may consider regional engagements and collaboration to learn how other PAOs in the African region built up the capacity to execute their QA review systems considering the need for additional resources.
Lastly, ONECCA-Senegal is encouraged to continue monitoring and preparing members for the changes from quality control standards to quality management standards that being adopted by the IAASB effective December 2022.
SMO 2: International Education Standards
With initial professional development (IPD) requirements established at the regional level by the West African Economic and Monetary Union (WAEMU), the role of the ONECCA-Senegal is to enforce the IPD requirements and establish continuing professional development (CPD) requirements for its members.
Presently, the regional IPD requirements include obtaining the Higher Education Degree in Accounting and Financial Management (DESCOGEF—for Certified Accountants) and the Degree in Accounting and Finance Expertise (DECOFI—for Chartered Accountants) in order to pass the qualifications’ exam and practice within any of the West African Economic and Monetary Union (WAEMU) member states.
ONECCA-Senegal has worked to strengthen IPD requirements by requiring that candidates’ three-year internship must be with a Chartered Accountant licensed by ONECCA-Senegal and demonstrate appropriate knowledge of Senegal’s business and legal environment. The institute has established a Training Committee which is responsible for identifying the areas that candidates for ONECCA-Senegal membership must demonstrate sufficient knowledge of.
ONECCA-Senegal states that among OHADA member states, and separately within the WAEMU, there are curriculum reforms under consideration that would enable accountancy education to better align with the revised IES requirements. Currently, it is still in the consultation phase, but the institute is committed to participating in regional discussions and working with the regional unions to enhance accountancy education.
The institute’s Training Committee is also in charge of developing and maintaining the institute’s CPD system. ONECCA-Senegal members must fulfill 40 hours of CPD per year and submit proof as part of renewing their membership. Beginning in 2020, the institute reports it will begin to monitor CPD fulfillment throughout the year. The institute indicates that the CPD catalogue is updated regularly and available for members to view on its website. ONECCA-Senegal will offer at least 40 hours of training to its members and is working to have these trainings take an output-based approach rather than input-based. It also encourages members to attend trainings outside of the institute.
A review of regional IPD requirements and curriculum is an opportunity for ONECCA-Senegal to encourage both the WAEMU and the OHADA to consider the 2019 IES requirements which emphasize learning-outcome and competencies-based approaches to accountancy education rather than just theoretical training. It is unclear if the current IPD requirements (e.g. DECOFI curriculum; final assessment) are aligned with the 2019 IES requirements.
Further, in 2019, newly revised IES address learning and development for information and communications technologies (ICT) and professional skepticism. These revised standards become effective January 2021. The requirements likely require both regional and national changes to accountancy education programming, which presently seems focused on theoretical training. The institute should take a lead role in raising awareness of, advocating for, and planning for the incorporation of IES requirements to OHADA and WAEMU as it considers reforming its accountancy curriculum and is encouraged to include actions around how it may support a regional review of IPD requirements. The IES Checklist and the Accountancy Education E-Tool developed by IFAC may be used to conduct an assessment and to consider available implementation support materials.
SMO 3: International Standards on Auditing
The Organization for the Harmonization of Business Law in Africa (OHADA) has been revising regional regulation in order to harmonize auditing standards with international best practice. In June 2017, OHADA issued regulation stating that all member states, which includes Senegal, must adopt ISA as issued by the IAASB beginning in January 2018. In accordance with the regional requirements, ONECCA-Senegal indicates that at the jurisdiction level, the ISA are effective as issued by the IAASB.
ONECCA-Senegal has been committed to the adoption of ISA at the national level prior to 2017. In 2010, ONECCA-Senegal had drafted and adopted the Senegal Auditing Standards (SAS) based on the 2009 ISA without any modifications. The SAS were approved by the Ministry of Finance in 2016 along with procedures to update the standards on an ongoing basis.
With adoption now effective at the regional level, ONECCA-Senegal indicates that its role is to provide implementation support by disseminating information and providing training on the applicable standards. The institute notes that it offers regular trainings for its members, shares tools and guidance issued by the OHADA, and notifies members of any developments.
With the new OHADA regulations now effective, the ONECCA-Senegal is encouraged to ensure that it specifies current implementation support (such as trainings and guides) activities for its members within its SMO Action Plan. The 2018 Handbook is now effective and available in French, which includes revised standards ISA 250 and 540. If it is not already doing, ONECCA-Senegal should disseminate French translations of the standards to support proper application. The institute is also encouraged to continue monitoring and preparing members for the changes from quality control standards to quality management standards that are being proposed and reviewed by the IAASB. ONECCA Senegal is encouraged to comment on the Proposed International Standard on Auditing for Audits of Financial Statements of Less Complex Entities (ISA for LCE) Exposure Draft (due January 31, 2022)
SMO 4: Code of Ethics for Professional Accountants
The Organization for the Harmonization of Business Law in Africa (OHADA) has been revising regional regulation in order to harmonize ethical standards with international best practice. In June 2017, OHADA issued regulations stating that its member states, which includes Senegal, must adhere to the OHADA Code of Ethics— which is note and guidance on ethical requirements.
The new OHADA regulations only incorporate up to the 2015 IESBA Code of Ethics. The ONECCA-Senegal is encouraged to leverage its advisory and advocacy role and share the 2018 International Code of Ethics—which is significantly revised, contains the NOCLAR standard issued in 2016, and now available in French—with the OHADA so that it might update its regulations accordingly to align with international benchmarks. ONECCA-Senegal is to review IESBA’s revisions to Part B of the Code (effective June 2021) and revisions to Sections 100, 110, 120, and 220 (effective December 2021) to form plans to support members with implementation. Lastly, since OHADA regulations incorporate only up to the 2015 version of the IESBA Code, the institute is encouraged to continue its advisory and advocacy role by sharing the 2018 International Code (along with the 2020 revisions) with the OHADA so that it might update its regulations accordingly
SMO 5: International Public Sector Accounting Standards
At the regional level, West African Economic and Monetary Union (WAEMU) Regulation No.09/2009/CM/UEMOA establishes public sector accounting standards for member states of the WAEMU, which includes Senegal. Article 6 of that directive indicates that the government’s general accounting should be based on international accounting standards. IFAC member organizations in the WAEMU member states indicate that the regulation has undergone revisions to integrate a significant number of IPSAS. The revised standards were finalized in November 2018 by the West African Accounting Council and will be subject to the review of the WAEMU in 2020.
At the national level, the Ministry of Finance is responsible for adopting public sector accounting standards. The current standards used in Senegal are cash-basis with the intention to transition to accrual. IPSAS are not adopted (IFAC, CIPFA 2018).
ONECCA-Senegal has no standard-setting authority in this area, nor do its members work in the public sector, however, the institute indicates that it has a collaborative relationship with the government and advocates for the adoption of accrual-basis IPSAS. For example, it has shared a 2005 version of the IPSAS translated into French and in 2015, ONECCA-Senegal, in collaboration with IFAC, the Pan African Federation of Accountants, and the International Federation of Francophone Accountants, organized a two-day event on public financial management in order to promote accrual IPSAS. The institute reports this event is now an annual occurrence for the Francophone African professional accountant community.
ONECCA-Senegal indicates that it has a partnership agreement with both the Accountant and Auditor General and the Court of Auditors. It has been working closely with the Court of Auditors to support its technical capacity. The institute also states that it is part of a Steering Committee established by the Ministry of Finance on adoption and implementation of accrual-based standards.
ONECCA-Senegal’s advocacy efforts around IPSAS adoption are noteworthy. In the next SMO Action Plan update, additional and more up-to-date information is requested from the institute. Pending approval of the revised standards by WAEMU, the ONECCA-Senegal is encouraged to indicate a timeline for the adoption of the standards within Senegal and how it might support the Ministry of Finance in its adoption and implementation plan.
For example, a 2015 version of IPSAS is available in French that the institute may consider sharing with the Ministry of Finance as part of its advocacy efforts. Other activities for consideration include organizing roundtables to meet key stakeholders and users of financial information; and offering to provide trainings and technical expertise for government staff.
SMO 6: Investigation and Discipline
Within Senegal, Law No. 2000-05, as approved by the Ministry of Finance, authorizes ONECCA-Senegal to establish an investigative and disciplinary (I&D) system for its members. The institute’s bylaws stipulate the establishment of a Disciplinary Committee to hear cases of misconduct, investigate, and sanction members. The Disciplinary Committee is chaired by a judge appointed by Dakar’s Court of Appeals.
In practice, to date, ONECCA-Senegal has implemented an arbitration and mediation process in the event of any complaints received. The complaints are received through a Council committee known as an Instructional Committee and go through a mediation process between the client and member to distinguish between professional misconduct complaints and commercial disagreements. If non-compliance or misconduct is found, or if a member does not address the recommendations of the Instructional Committee, the case would go to the Disciplinary Committee. ONECCA-Senegal indicates that this has only occurred twice.
However, with quality assurance reviews scheduled to commence on a mandatory basis in Q4 2019 and the institute considering conducting due diligence reviews of other services, more cases may arise that are referred to the Disciplinary Committee. Furthermore, a review conducted in 2019 of its procedures against the SMO 6 best practices indicates that there is room for improvement by strengthening the following areas: having a separate investigative and disciplinary committee, making results publicly available, and liaising with appropriate external entities in the case of serious offences.
ONECCA-Senegal states it communicates frequently on the importance of ethical behavior and consequences of non-compliance.
As ONECCA-Senegal begins increasing the frequency of due diligence reviews, it should continue to refer to the SMO 6 best practices to ensure its procedures align to the extent permitted in law. The institute should update the Action Plan with a timeline for this process. I&D procedures are foundational to maintaining public trust and confidence in the profession. The institute is therefore encouraged to indicate clear examples of outreach and awareness raising to the public, business, private, and public sector stakeholders on the I&D processes, how to submit any complaints, and that disciplinary actions will be taken when necessary. Any disciplinary actions should be made public for this reason as well.
SMO 7: 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), Senegal’s corporate accounting standards are defined in regional directives. In January 2017, the OHADA Uniform Act on Accounting and Financial Information (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 to serve as a single accounting reference in all OHADA member states. The SYSCOHADA continue to differ from IFRS and are generally applied by small and medium-sized entities (SMEs); however, the AUDCIF now requires that listed companies and companies seeking financing in a public capital market to apply IFRS in consolidated statements. All other companies are permitted but not required to use IFRS.
ONECCA-Senegal participated in the OHADA’s convergence process between 2010 through 2017 by proposing recommendations and contributed to several consultations. As of the date of the assessment, ONECCA-Senegal reports to be active in supporting the transition to IFRS as part of the SYSCOHADA by disseminating information on the standards and offering trainings to its members. Between 2017-2019, the institute notes that it has undertaken several activities to raise awareness among members of the revised standards, including continuing professional development, the update of the qualification curricula, and provision of application guides.
With the recent adoption of IFRS for listed companies in OHADA member states, ONECCA-Senegal is encouraged to demonstrate examples of implementation support in its Action Plan, such as training and sharing resources, which it might provide for its members in cases where they need to apply the standards. The IFRS Foundation has French translations of the IFRS readily available that the institute may consider sharing amongst its members and other stakeholders to support understanding and implementation. The institute could also consider advocating for the regional adoption of IFRS for SMEs as a permissible framework to bring SME reporting in line with international best practices.
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