Polish Chamber of Statutory Auditors
Member | Established: 1991 | Member since 2001
The PIBR was established by the Act on Statutory Auditors, Audit Firms and Public Oversight of 1991 as a mandatory membership organization uniting all statutory auditors and audit firms in Poland. Its mission is to ensure the reliability of financial information and the security of business transactions. The main legal responsibilities of PIBR are: (i) certification and registration of auditors; (ii) adopting auditing standards and standards on quality control, (iii) establishing and enforcing ethical requirements as well as continuous professional development (CPD) requirements; (iv) establishing investigation and discipline mechanisms and conducting disciplinary proceedings for certain violations. The PIBR’s activities are overseen by the Polish Audit Oversight Agency (PANA).
In addition to being a member of IFAC, PIBR is a Member of the Visegrad Group composed of Chambers of Auditors from the Czech Republic, Hungary, Slovakia and Poland (V4), an Associate Member of the Professional Accountancy Education Europe (PAEE) (previously the Common Content Project) and of the Fédération Internationale des Experts-Comptables Francophones (FIDEF).
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 PIBR was previously responsible for the establishment and implementation of a quality assurance review system under the audit oversight entity. It implemented and maintained a QA review system for all non-PIE audits and reported that it was working to ensure that the system met all SMO 1 requirements. Following amendments to the Act on Statutory Auditors, Audit Firms and Public Oversight, and the consequent establishment of the PANA as the new supervisory authority for auditors, PIBR retains no further responsibility for conducting quality assurance reviews.
PIBR reports that they have developed a guide to support their members in implementing systems of quality control as required by amended legislation. These amendments included the application of such systems to assurance services other than audit and related services. PIBR will also provide support to statutory auditors and audit firms when concerns or questions arise regarding specific situations.
The PIBR also assists its members with the implementation of the quality control standards by including QA-related topics in its continuing professional development courses and publishing technical guidance on this topic. In addition, prior the establishment of PANA, PIBR trained inspectors responsible for conducting QA reviews.
PIBR has a dedicated page on its website on the new suite of quality management standards issued by the IAASB. The page includes a timeline for adoption of the standards in Poland, Polish translations of the standards (translated by PIBR), and implementation support materials.
The PIBR has demonstrated an ongoing process to maintain its level of fulfillment with the SMO 1 obligations and is committed to continuous review & improvement. In its Action Plan, the PIBR may consider including examples of training it is providing to members and/or other key stakeholders on the QM standards.
SMO 2: International Education Standards
Broad initial professional development requirements (IPD) are established by law and are reported by PIBR as being in line with the IES issued in 2019. Implementation of these legislated requirements, including issues such as qualification proceedings and thematic scope of examinations, are determined by PIBR and approved by the Polish Audit Oversight Authority (PANA).
In 2021, the PIBR signed an agreement with the University of Economics in Krakow to ensure that the curricula provide the technical competence and professional skills necessary to pass the PIBR examinations, which consist of a written and oral portion to assess practical application and theoretical knowledge. The scope of expected knowledge & learning outcomes for candidates are specified in legal resolutions. The PIBR provides sample exam questions for candidates to prepare.
According to the World Bank’s 2016 report, Chamber of Auditors of Poland: Institutional Analysis, practical experience requirements align with IES 5 and the PIBR has developed principles and templates for documenting experience and competencies gained.
Similarly, PIBR develops CPD requirements in line with IES 7 which are subject to annual approval by the PANA. It publishes these requirements on its website to inform members of their obligations. It has also detailed in its SMO Action Plan the training topics for CPD in 2021 and 2022.
In addition, PIBR reports that is has aligned its regulations on the education requirements for statutory auditors to IES 8, Competence Requirements for Audit Professionals. It has also conducted various activities in support of the implementation of the IES 8 requirements.
PIBR has demonstrated its reviewing & improving actions as related to the SMO 2 obligations. PIBR may considering completing the IES Self-Assessment developed by IFAC as part of its continued progress and ensuring that the recent revisions to IES 2, 3, 4, and 8 (specifically on ICT & professional skepticism and effective in 2021) are incorporated into national requirements.
SMO 3: International Standards on Auditing
The PIBR is responsible for drafting auditing standards for application in Poland and proposing them to the audit oversight entity (PANA) for their approval. In April 2015, the PIBR proposed and received approval for the adoption of Clarified ISA with modification and effective for the audits of PIEs on December 31, 2016, and to audits of non-PIEs on December 31, 2017. Since then, PIBR has developed a methodical and timely process (outlined in its SMO Action Plan) to translate the international standards in line with the IFAC Translation Policy and has worked closely with PANA to complete the adoption of the ISA and other IAASB Pronouncements. As of 2022, PIBR reports that all effective IAASB pronouncements (i.e., the 2020 IAASB Handbook) have been adopted in Poland by reference in the National Auditing Standards (NAS). The quality management standards are expected to be adopted in Poland with an effective date of January 1, 2023.
In addition to its standard-setting role, PIBR has carried out a range of activities to assist its members with the implementation of the auditing standards. These include: translating a number of technical guides on the implementation of ISA such as the Guide to Using International Standards on Auditing in the Audits of Small- and Medium-Sized Entities and Guide to Quality Control for Small- and Medium-Sized Practices; publishing resources and regulatory updates & resolutions on the PIBR website; providing technical support to frequently asked questions; and including ISA in its calendar of continuing professional development courses each year.
The PIBR has demonstrated an ongoing process to maintain its level of fulfillment with the SMO 3 obligations and is committed to continuous review & improvement and the sustained adoption process of IAASB pronouncements. As feasible, IAASB pronouncements that are adopted in Poland should have the same effective date as that provided by the IAASB.
SMO 4: Code of Ethics for Professional Accountants
In accordance with the Act on Statutory Auditors, Audit Firms and Public Oversight of 2017 as amended, the Polish Chamber of Statutory Auditors (PIBR) has responsibility for adopting ethical requirements for auditors subject to approval of the Polish Audit Oversight Agency (PANA).
Since 2011, the IESBA Code has been required for application by Polish auditors as translated by the PIBR and approved by the public oversight authority. The 2018 International Code of Ethics issued by IESBA was translated and adopted for application for auditors in Poland effective January 1, 2020. Revisions to Part 4B of the Code to Reflect Terms and Concepts Used in International Standard on Assurance Engagements 3000 (Revised) and revisions to Parts 1 and 2 to promote the role and mindset expected of professional accountants effective within the 2021 International Code of Ethics have been translated to Polish; however, only Revisions to Part 4B are effective as of September 2022. The full 2021 International Code of Ethics, with revisions effective December 2022, is in the process of being translated into Polish and the PIBR is planning to propose an adoption resolution by end of 2022. The PIBR continuously monitors pronouncements and alerts issued by the IESBA.
The PIBR has developed activities to raise awareness of the IESBA Code of Ethics and to assist its members with the implementation of the standards. Examples of such activities include the organization of seminars on ethical issues, the delivery of continuing professional development courses on the IESBA Code of Ethics, organizing a conference on ethics, collating a bank of ethical dilemmas and responses from the Ethics Committee for publication on its website, translating additional implementation materials from IESBA and IFAC, and providing responses to members’ specific inquires and concerns regarding ethical problems and/or situations.
The PIBR has demonstrated an ongoing process to maintain its level of fulfillment with the SMO 4 obligations and is committed to continuous review & improvement and the sustained adoption process of IESBA pronouncements. As feasible, the PIBR should continue to advocate for the adoption of the revisions to role & mindset of professional accountants which had an effective date of December 2021. Similarly, it is encouraged to advocate for the early adoption of revisions in the 2021 Code that become effective December 2022.
SMO 5: International Public Sector Accounting Standards
The Ministry of Finance (MoF) is responsible for the adoption of public sector accounting standards in Poland. IPSASs have not been adopted and the MoF does not appear to have set the adoption of IPSAS as an objective.
PIBR notes that at this time its efforts are focused on promoting the adoption of IPSAS to the Ministry of Finance. PIBR reports that it raises awareness of the international standards through conferences and training courses. It also states that it provides input on legal drafts of regulations that affect public sector accounting in Poland.
SMO 6: Investigation and Discipline
In accordance with the Act on Statutory Auditors, Audit Firms and Public Oversight of 2017 as amended, the Polish Chamber of Statutory Auditors (PIBR) and the Polish Audit Oversight Agency (PANA) are responsible for the I&D mechanisms for auditors.
The PIBR conducts disciplinary proceedings for statutory auditors who do not adhere to CPD requirements and for other offenses that are not related to the performance of assurance engagements or in violation of national professional standards. Meanwhile, the PANA conducts disciplinary proceedings against statutory auditors for violations and offenses related to the performance of the audit profession other than those which are subject to the PIBR responsibility. The PIBR reports that its I&D procedures are based on SMO 6 requirements; however, only statutory auditors may sit on the Disciplinary Tribunal.
The nomination procedure for both the National Disciplinary Prosecutor (NDP) and the National Disciplinary Court (NDC) is regulated by the Act of May 11, 2017 on Statutory Auditors, Audit Firms and Public Oversight, independently from the self-government of statutory auditors. Pursuant to the Act, it is currently not possible for non-accountants to nominated to the PIBR disciplinary tribunal. But the act does allow the accused to appoint advocates or legal advisers to their defense team.
PIBR indicates that it publishes information on its I&D regulations, proceedings, and results on its website to promote understanding amongst members and the public and in the interest of transparency.
If feasible during any future legislative amendments, PIBR 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.
SMO 7: International Financial Reporting Standards
As a member of the European Union, Poland is subject to relevant EU regulations regarding the area of corporate financial reporting and subsequently, the EU requirements are transposed into Poland’s national legislation. In line with the EU requirements, Poland requires application of IFRS as endorsed by the European Commission for the preparation of consolidated financial statements of listed entities, credit institutions, insurance undertakings, and other entities designated as PIE by the Ministry of Finance.
The PIBR has no responsibility for setting accounting standards although it does have representatives that serve on the Accounting Standards Committee (ASC) of the Ministry of Finance. PIBR is primarily focused on familiarizing its members (who are statutory auditors) with the IFRS by providing trainings and CPD courses on the IFRS.
If appropriate, PIBR may consider plans and dialogue with the MoF to adopt IFRS for SMEs which might support and strengthen the financial reporting regime for SMEs in the jurisdiction.
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