Ordre National des Experts-Comptables et des Comptables Agréés du Togo
Associate | Established: 2001 | Associate since 2012
The ONECCA-Togo was established by law in 2001 and its membership is comprised of Chartered Accountants and Certified Accountants. Membership of ONECCA-Togo is mandatory in order to practice in Togo and the institute strives to ensure that its members are properly trained and educated in order to comply with professional and ethical rules and fulfill their civic responsibilities.
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
As of 2017, regional regulation set by the Organization for the Harmonization of Business Law in Africa stipulates that national professional accountancy organizations should establish and implement quality assurance (QA) review systems to ensure compliance with adopted standards. However, ONECCA-Togo, under the supervision of the Ministry of Finance, has played a leading role in promoting the establishment of a national QA review system since 2011. To spearhead this initiative, ONECCA-Togo established Committee 1 which is in charge of ensuring fulfillment of SMO 1 and developing and implementing a QA review system.
In 2013, two ONECCA-Togo members received training and guidance from a World Bank consultant on how to conduct QA reviews of firms.
In 2014–2015, ONECCA-Togo reports that it incorporated QA review system requirements and ISQC 1 into its by-laws but the full implementation of the QA system is still in progress. During this period, volunteer firms were selected to go through a voluntary QA review process and training tools and information sessions were offered to members.
As of 2017, the institute plans to assist all member firms to undergo a mandatory QA review—carried out by its two qualified reviewers—within the next three years. Member firms may choose when their procedures will be reviewed within this first cycle of QA reviews.
By 2021, the institute plans to establish a larger, permanent QA review team that will carry out reviews in compliance with SMO 1 requirements and as suitable for the Togolese context. ONECCA-Togo notes that financing the QA review system is a challenge that its leadership is trying to address as it schedules QA reviews for 2018.
During the next three years, the institute notes that it will continue to offer training sessions on quality control standards and the QA mechanism to supports its members.
In its next Action Plan submission, ONECCA-Togo is encouraged to provide an update on the execution of its progress to implement its QA review system. The institute should continue to review the SMO 1 requirements to ensure that the implemented system is aligned with best practices. ONECCA-Togo is also encouraged to include developments, if any, regarding the establishment a QA review system at the regional level on an ongoing basis in the Background Note of its Action Plan.
SMO 2: International Education Standards
With initial professional development requirements established at the regional level by the West African Economic and Monetary Union (WAEMU), ONECCA-Togo is responsible for setting continuing professional development (CPD) requirements for its members and closely collaborates with other organizations in Togo that are involved in education and training to better align national educational programs with the IES requirements.
For example, in 2013, the institute received a grant from the World Bank to finance and support the revision of national accounting and finance programs. Throughout 2014 and 2015, the Ministry of Secondary Technical and Professional Training and the Ministry of High Level Education and Scientific Research trained approximately 500 teachers in order to operationalize the program. The revised education program was able to commence during the academic year of 2015–2016; however, the institute indicates that the program does not yet fully align with IES requirements. ONECCA-Togo is therefore working with universities to align their curriculum and syllabi with IES and reports that it regularly goes to universities to explain the Degree in Accounting and Finance (DECOFI) qualification—a regional prerequisite to offer auditing services in any WAEMU country that is in line with the IES.
To assist students seeking the DECOFI the institute organizes trainings sessions to prepare for the exam. ONECCA-Togo also supports members’ continuing education and has therefore established CPD requirements that are in line with the IES and publishes a calendar of annual training events. The institute emphasizes that it will be providing trainings for members and education providers on the new the Organization for the Harmonization of Business Law in Africa regulations that were adopted in 2017 and come into effect in January 2018 given that the regulations will affect the applicable accounting, auditing, and ethical standards within the country.
Finally, ONECCA-Togo also notes that it offers training for members on other specific sectors and topics such as tax law, microfinance, public sector standards, and labor law.
ONECCA-Togo is encouraged to consider working with the Ministry of Secondary Technical and Professional Training and the Ministry of High Level Education and Scientific Research to further enhance the national accountancy education to align with the IES requirements and indicate related activities in its Action Plan. As part of this consideration, the institute could share the revised 2015 IES with the Ministries with the objective of collaborating on a joint review of the standards as the revised IES are significantly more principles-based and competencies-focused. The institute could also consider including some specific examples of CPD activities it carries out within its Action Plan to illustrate how it supports its members in this area.
SMO 3: International Standards on Auditing
In June 2017, 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 membres de l’OHADA to harmonize regional auditing standards with international best practice. The regulation states that effective from January 1, 2018, all audits in member states must be conducted in accordance with ISA as issued by the IAASB. However, ONECCA-Togo had been committed to the adoption of ISA at the national level prior to OHADA’s recent regulatory decision.
The institute indicated that it began collaborating with CPA Canada in 2013 to provide its members with translated versions of IAASB pronouncements, Exposure Drafts, and technical guidance and in 2014, ONECCA-Togo adopted ISA as issued by the IAASB as a requirement for its members. However, the institute was only able to refer members to CPA Canada’s 2012 French translations of ISA for implementation support. After adopting the ISA for application by its members, the institute had proposed legislation to the government to officially adopt the ISA as the auditing standards for Togo; however, this has been pending the government’s approval since 2014. In light of the new OHADA directive, it is unclear if this legislation will still move forward for the Ministry’s approval.
The institute reports that it plans to raise awareness amongst its members of the new OHADA regulation along with the 2016 ISA, which include the new auditor’s report, and will update its continuing professional development programming accordingly. ONECCA-Togo notes that its Committee on Standards will support its information dissemination efforts in this area.
ONECCA-Togo is encouraged to clarify if the Ministry of Finance has approved ISA as national auditing standards or if new legislation will need to be proposed and approved in regards to the transposition of the OHADA regulations. The institute should also confirm if the 2016 ISA, which includes the new auditor’s report, is available in French for its members to begin applying the new standard in the jurisdiction. Within its Action Plan, ONECCA-Togo is also encouraged to demonstrate how it plans to undertake to raise awareness amongst its members and relevant stakeholders of the new OHADA regulation and how it will support its members’ implementation of the applicable standards. This is especially important if the 2016 ISA is the newly adopted standard.
SMO 4: Code of Ethics for Professional Accountants
The Organization for the Harmonization of Business Law in Africa (OHADA) Regulation No. 01/2017/CM/OHADA Pratiques Professionelles de la Comptabilité et de l’Audit dans les pays membres de l’OHADA, issued in June 2017, intends to harmonize regional ethical requirements with international best practice. The regulation states that effective from January 1st, 2018, professional accountants in OHADA member states must adhere to the OHADA Code of Ethics, which will be based on the IESBA Code of Ethics, as well as the relevant parts of the OHADA Uniform Act on Accounting Law and Financial Information (AUDCIF). As of the time of the assessment, the OHADA Code of Ethics had not been issued. It is unclear what version of the IESBA Code of Ethics the OHADA Code will be based on and what the relevant requirements of the OHADA AUDCIF state.
While the regional economic union, of which Togo is a member state, has taken steps to adopt a Code of Ethics that is aligned with the IESBA Code, the ONECCA-Togo has been leading ethical standard-setting initiatives at the national level. The institute indicates it revised its Code of Ethics in 2014 to incorporate the 2012 IESBA Code of Ethics requirements, and the Code has reportedly been pending the Ministry of Finance’s approval since then. In light of the new OHADA directive, it is unclear if this legislation will still move forward for the Ministry’s approval.
As part of its self-regulatory process and best practice, the institute reports it established an SMO 4 Committee to review its by-laws, Code of Ethics, and Constitution to ensure that ethical requirements comply with the IESBA Code. In 2014, ONECCA-Togo reports that it disseminated the French translation of the Code to its members, accountants in business, trainee accountants, public and private sector bodies as well as other relevant stakeholders in order to support the implementation of the Code and delivered trainings on the Code to its members. Given the adoption of the new OHADA regulation, institute reports that it plans to raise awareness amongst its members and will update its continuing professional development programming accordingly.
ONECCA-Togo is encouraged to clarify if the Ministry of Finance has approved the 2012 French translations of the IESBA Code that the institute adopted as national ethical requirements or if new legislation will need to be proposed and approved in regards to the transposition of the OHADA regulations. The institute should also confirm if the 2016 IESBA Code of Ethics, which includes the new NOCLAR standard, is now to be applied in the jurisdiction and if not, how the ethical requirements stated in the OHADA Code of Ethics and the AUDCIF align with the IESBA Code. Within its Action Plan, ONECCA-Togo is also encouraged to demonstrate learning and capacity building activities it is incorporating into its educational and training programs to raise awareness of the OHADA regulation and to support members’ implementation of the new ethical requirements. This is especially important if the 2016 IESBA Code is the newly adopted standard.
SMO 5: International Public Sector Accounting Standards
ONECCA-Togo has no direct responsibility for the adoption of public sector accounting standards, which are set at the regional level by the West African Economic and Monetary Union (WAEMU) Regulation No.09/2009/CM/UEMOA, and transposed at the national level by the Ministry of Finance. The WAEMU regulation requires all WAEMU member states to adopt public sector accounting standards that are based on IPSAS by January 2017.
As of 2017, the institute states IPSAS have not been adopted in Togo but that it uses its best efforts to promote the adoption and implementation of IPSAS at the national level. In 2013, the institute began collaborating with the State Comptroller General, the World Bank representation in Togo, and the National Accounting Council to promote the adoption of IPSAS and it states it will continue to work with these entities once the WAEMU directive is transposed into national law. The SMO 5 Committee of ONECCA-Togo is responsible for promoting the adoption of ISPAS in Togo and in 2013, the institute distributed the 2005 version of IPSAS in French to the Committee’s members.
ONECCA-Togo reports that it will continue to provide education and training sessions on IPSAS to support its members, although details of these activities are not included in its Action Plan.
ONECCA-Togo is encouraged to indicate in its Action Plan if there is a timeline in place for the adoption and implementation of IPSAS at the national level and consider, if feasible, the role ONECCA-Togo may have in this process. The institute may consider providing relevant stakeholders with a more recent translation of the IPSAS. If the institute is involved in meetings and taskforces with the Ministry of Finance, this information should be included within its Action Plan. The institute is also encouraged to include further details of trainings it is holding for members to support their implementation of currently applicable standards.
SMO 6: Investigation and Discipline
ONECCA-Togo is responsible for establishing an investigative and disciplinary (I&D) system for its members and its Discipline Commission, which is comprised of Council members, has been operational since 2013. In 2016, ONECCA-Togo self-assessed its I&D system against the SMO 6 requirements and noted several areas that require improvements: the separation of investigative and disciplinary procedures, the inclusion of non-professional accountants in the disciplinary process, the implementation of its planned appeals mechanism (the National Discipline Commission) and investigative committee, as well as public interest communications and considerations.
The institute indicates that its Council is proposing a number of activities to enhance alignment with the SMO 6 requirements, most notably the creation of a separate investigative committee and implementation of the appeals mechanism. ONECCA-Togo states that its founding legislation makes no reference to an investigation committee and therefore, its Council is exploring how it can address this matter. In regards to its appeals mechanism, the institute explained that the appeals committee is comprised of seven members from six different institutions who no longer convene. Similarly, its Council is also considering how to move forward in reestablishing this mechanism. The institute is also planning to increase the public’s awareness of types of professional misconduct through more communications, and intends to link its I&D system with its quality assurance (QA) review results by 2023—two years after the anticipated implementation of mandatory QA reviews for all members.
While ONECCA-Togo has taken a notable first step in identifying areas in its I&D procedures that require improvements, the institute is now encouraged to outline the actions it will take to execute and implement the proposed and necessary changes within its Action Plan. The actions should include concrete timelines for their execution to enable the institute to track its progress against its plans and make strategic adjustments as needed.
SMO 7: International Financial Reporting Standards
As a member state of West African Economic and Monetary Union and the Organization for the Harmonization of Business Law in Africa (OHADA), Togo’s accounting standards are defined in regional directives. In January 2017, the OHADA Uniform Act on Accounting Law 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. Although the SYSCOHADA continue to differ from IFRS, the AUDCIF now requires that public interest entities, which include listed companies, banks, insurance, and pension companies as well as any other companies determined by national Ministries of Finance, prepare financial statements in accordance with IFRS as well as SYSCOHADA. This will come into force in all member states in January 2019.
The institute played a key role in promoting the adoption of IFRS at the regional level by assisting the Conseil National de la Comptabilité of Togo—the national body which reports to the OHADA—and the Togolese Ministry of Finance to review, compare, and analyze the SYSCOHADA and IFRS
In addition, ONECCA-Togo has been raising awareness of IFRS amongst its members since 2015 while also providing trainings on the implementation of SYSCOHADA. However, with the passage of the AUDCIF, the institute reports that it will hold trainings on the new law and work to support members with the implementation of IFRS.
ONECCA-Togo is encouraged to update its Action Plan to include specific activities it will undertake to support members’ understanding and implementation of the IFRS given the new OHADA directive. As part of this, it would be beneficial for ONECCA-Togo to consider how it can monitor and provide updates on IFRS on a regular basis to members. Additionally, it is encouraged to include trainings it offers to support its members’ implementation of the SYSCOHADA, which is still applicable in the jurisdiction for some financial statements.
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