Togo

The corporate financial reporting framework of Togo is determined by legislation issued by two regional organizations: the West African Economic and Monetary Union (WAEMU) and the Organisation for the Harmonization of Business Law in Africa (OHADA). Legislation issued at the regional level by WAEMU and OHADA has a significant impact on the legal and regulatory framework for commercial entities, banks, financial institutions, and insurance companies in Togo, as well as on the accountancy profession. As a member of both organizations, Togo harmonizes national legislation with directives and regulations issued at the regional level.

OHADA and WAEMU are responsible for the development of accounting standards applicable in member countries, while national authorities are responsible for implementing the regional framework within their jurisdictions. The WAEMU Treaty assigns responsibility for accounting standard setting to the WAEMU Council of Ministers. In accordance with WAEMU Regulation No. 3/97/CM/UEMOA, responsibility for accounting standard-setting activities was delegated to the Conseil Comptable Ouest Africain (CCOA), which subsequently adopts the accounting standards issued under the OHADA framework for application within WAEMU member states.

Accounting Framework

In January 2017, the Commission de Normalisation Comptable de l’OHADA (CNC-OHADA) adopted the OHADA Uniform Act on Accounting and Financial Information (Acte Uniforme relatif au Droit Comptable et à l’Information Financière (AUDCIF)), which replaced the previous OHADA Uniform Act on Organizing and Harmonizing Company Accounting Systems adopted in 2000. The earlier act had established the OHADA accounting framework known as the Système Comptable OHADA (SYSCOHADA).

The 2017 Uniform Act revised SYSCOHADA, including the OHADA general accounting plan and rules governing consolidated and combined financial statements, creating a single accounting reference framework applicable across OHADA member states. The revised standards became effective on January 1, 2018 for individual financial statements and January 1, 2019 for consolidated financial statements.

Under the revised framework, SYSCOHADA continues to differ from International Financial Reporting Standards (IFRS) and is generally applied by small and medium-sized entities. However, the AUDCIF requires that listed companies and companies seeking financing from public capital markets prepare consolidated financial statements in accordance with IFRS. Other entities are permitted, but not required, to use IFRS.

Auditing Framework

Statutory audit requirements are established through the OHADA Uniform Act Relating to Commercial Companies and Economic Interest Groups (1997, revised in 2014). The Act requires statutory audits for public companies, limited liability companies, and partnerships that exceed defined thresholds relating to balance sheet size, turnover, or number of employees. Banking and insurance legislation also require mandatory audits of banks, financial institutions, and insurance companies.

At the regional level, WAEMU Regulation No. 01/2009/CM/UEMOA established the Conseil Permanent de la Profession Comptable (CPPC), which is responsible for defining auditing, ethical, and quality control standards applicable within WAEMU member states.

In June 2017, OHADA issued Regulation No. 01/2017/CM/OHADA on professional practices of accounting and auditing in OHADA member states, which harmonizes auditing practices with international standards and best practice. The regulation requires that all statutory audits be conducted in accordance with the International Standards on Auditing (ISA) issued by the International Auditing and Assurance Standards Board (IAASB). The regulation became effective on January 1, 2018, and ISA as issued by the IAASB are therefore applicable in Togo.

Chartered Accountants and Certified Accountants in Togo are regulated through a combination of regional and national requirements. At the regional level, the West African Economic and Monetary Union (WAEMU) establishes the framework for the organization of the profession across member states, including the creation of national professional bodies and the rules governing free movement and establishment of professionals within the Union. At the national level, Togo implemented this framework through Law No. 2001-001 of January 23, 2001, which created the Ordre National des Experts-Comptables et des Comptables Agréés du Togo (ONECCA-Togo).

Law No. 2001-001 establishes ONECCA-Togo as the national professional accountancy organization responsible for bringing together professionals authorized to practice as Chartered Accountants and Certified Accountants in Togo. Membership in ONECCA-Togo is mandatory for individuals wishing to practice these professions in the jurisdiction. ONECCA-Togo operates as the national order within the WAEMU framework and maintains the professional register for the jurisdiction.

Entry requirements for the profession are established at the regional level through WAEMU Regulation No. 03/2020/CM/UEMOA, which replaced the earlier Regulation No. 12/2000/CM/UEMOA. The current regional framework provides for a coordinated professional education and training pathway leading to the Diplôme d’Expertise Comptable et Financière (DECOFI). The qualification pathway comprises the Diplôme d’Études de Comptabilité et Gestion Financière (DECOGEF), the Diplôme d’Études Supérieures de Comptabilité et Gestion Financière (DESCOGEF), a three-year professional internship, and a final examination. The regional system is administered through the Commission Régionale pour la Formation des Experts Comptables et Financiers (CREFECF).

Under the WAEMU framework, the DECOFI is the professional qualification leading to the Chartered Accountant designation. The regional rules also recognize the DESCOGEF as part of the pathway to the profession and require completion of the practical training period and final examination before award of the DECOFI. Only individuals registered with a national professional body within the WAEMU system are authorized to practice as Chartered Accountants.

In Togo, ONECCA-Togo is responsible for administering access to the national register, processing applications for inscription, and supervising the exercise of the profession in accordance with the national legal framework. The institute’s public materials indicate that it oversees access to the profession, ethical compliance, continuing training, and quality-related matters, and it publishes application procedures for Chartered Accountants, Certified Accountants, firms, and trainee Chartered Accountants.

The regional framework also provides for the mobility of Chartered Accountants and Certified Accountants within the WAEMU area. Under WAEMU Regulation No. 05/2006/CM/UEMOA, a professional registered with a national order in one member state may circulate freely or establish in another member state, subject to the requirements of the host jurisdiction and the procedures of the host national order.

With respect to professional standards, WAEMU Regulation No. 01/2009/CM/UEMOA established the Conseil Permanent de la Profession Comptable (CPPC) as the consultative body responsible for professional regulation and the harmonization of conditions of practice across the Union. In addition, OHADA Regulation No. 01/2017/CM/OHADA on the professional practices of accounting and auditing in OHADA member states provides the regional framework for auditing and ethics requirements applicable in Togo.

Only Chartered Accountants are authorized to conduct statutory audits in Togo. For entities in the banking sector, additional regional requirements apply. BCEAO Instruction No. 002-04-2010 sets conditions for the designation of two statutory auditors for certain banking financial institutions, and the Banking Commission approval process applies within the WAEMU framework, including in Togo.

There is no independent public audit oversight authority in Togo.

Auditors are regulated at the regional level through the regulatory framework established by the West African Economic and Monetary Union (WAEMU) and the Organisation for the Harmonization of Business Law in Africa (OHADA). OHADA Regulation No. 01/2017/CM/OHADA on the professional practices of accounting and auditing in OHADA member states establishes the professional standards, ethical requirements, and quality assurance framework applicable to statutory audits across member states, including Togo.

At the national level, oversight of the accountancy profession is exercised through the Ordre National des Experts-Comptables et des Comptables Agréés du Togo (ONECCA-Togo) in accordance with Law No. 2001-001 of January 23, 2001. The institute is responsible for maintaining the register of professional accountants and firms, monitoring compliance with applicable professional and ethical standards, supporting quality control and quality assurance mechanisms, and administering disciplinary processes for members.

Only Chartered Accountants registered with ONECCA-Togo are authorized to conduct statutory audits in Togo. The institute’s public information confirms that access to the profession, professional standards, ethics, continuing training, and quality-related matters are overseen by the Order.

Government authorities maintain an oversight role through the Ministry of Economy and Finance, which supervises the activities of ONECCA-Togo under the national legal framework. However, there is no separate public oversight body that operates independently of the profession with responsibility for supervising audit activities.

The Ordre National des Experts Comptables et des Comptables Agréés du Togo (ONECCA-Togo)

ONECCA-Togo is the national professional accountancy organization responsible for regulating the accountancy profession in Togo. The institute was established by Law No. 2001-001 of January 23, 2001, which created the Order and defined its legal basis, organization, and scope of authority.

Membership of ONECCA-Togo comprises Chartered Accountants, Certified Accountants, and professional firms operating in the jurisdiction. Membership in the institute is mandatory for individuals wishing to practice public accountancy and auditing in Togo. Only Chartered Accountants registered with ONECCA-Togo are authorized to conduct statutory audits.

In accordance with its legal mandate, ONECCA-Togo is responsible for maintaining the register of professional accountants and firms; regulating access to the profession; promoting compliance with applicable professional, auditing, and ethical standards; establishing and operating an investigative and disciplinary system; supporting quality assurance review mechanisms; and implementing continuing professional development requirements for its members. The institute is also responsible for safeguarding the honor, independence, and ethical conduct of the profession.

At the national level, ONECCA-Togo operates under the supervision of the Ministry of Economy and Finance in accordance with Law No. 2001-001. At the regional level, the institute operates within the West African Economic and Monetary Union (WAEMU) and Organisation for the Harmonization of Business Law in Africa (OHADA) framework applicable to professional accountants in member states.

In addition to being an Associate of IFAC, ONECCA-Togo participates in regional and international professional accountancy networks to support the development of the profession and the implementation of international standards.

At the regional level, the West African Economic and Monetary Union (WAEMU) Regulation No. 01/2009/CM/UEMOA established the Conseil Permanent de la Profession Comptable (CPPC), which provides the legal basis for a quality assurance review system across member states. In addition, the Organisation for the Harmonization of Business Law in Africa (OHADA) Regulation No. 01/2017/CM/OHADA on the professional practices of accounting and auditing in OHADA member states includes provisions relating to professional standards, ethical requirements, practical guidance, and the quality assurance system. The regulation provides that professionals in OHADA member states are to implement the quality assurance system in accordance with the applicable quality assurance manual.

At the national level, the Ordre National des Experts-Comptables et des Comptables Agréés du Togo (ONECCA-Togo) is responsible for implementing the quality assurance review system for its members. Publicly available information indicates that the institute incorporated quality assurance review requirements and International Standard on Quality Control 1 (ISQC 1) into its bylaws in 2014–2015 and initially carried out voluntary pilot reviews. Between 2017 and 2020, ONECCA-Togo reports that member firms underwent mandatory quality control reviews conducted by qualified reviewers. In 2021, the review cycle was postponed due to operational circumstances, and the institute has indicated its intention to establish a permanent review team and procedures aligned with Statement of Membership Obligations 1 (SMO 1).

ONECCA-Togo also reports that it has provided training on International Standard on Quality Management 1 (ISQM 1), International Standard on Quality Management 2 (ISQM 2), and International Standard on Auditing 220 (Revised) (ISA 220 (Revised)), and continues to advocate for the adoption of the quality management standards at the regional level. However, based on the currently available evidence, ISQM 1 and ISQM 2 cannot yet be assessed as formally adopted and effective in the jurisdiction.

While a system has been established and implemented in practice, the available information does not demonstrate that it is fully operational on a continuing basis or fully aligned with all SMO 1 requirements, including a regular inspection cycle, permanent operational review arrangements, documented linkage with disciplinary processes, and evidence of ongoing monitoring of effectiveness.

Current Status: Partially Adopted

At the regional level, the West African Economic and Monetary Union (WAEMU) establishes the initial professional development framework for professional accountants in member states through Regulation No. 03/2020/CM/UEMOA, which replaced the earlier Regulation No. 12/2000/CM/UEMOA. The current framework establishes a coordinated professional qualification pathway leading to the Diplôme d’Expertise Comptable et Financière (DECOFI), consisting of the Diplôme d’Études de Comptabilité et Gestion Financière (DECOGEF), the Diplôme d’Études Supérieures de Comptabilité et de Gestion Financière (DESCOGEF), a three-year professional internship, and a final examination. The regulation also establishes the Commission Régionale pour la Formation des Experts Comptables et Financiers (CREFECF) to oversee the regional education and examination system. The regulation states that this framework was reformed to align with international training standards and the Licence-Master-Doctorat higher education model in the Union.

Under this regional framework, aspiring professional accountants complete a structured education and training pathway that includes academic study, practical experience, and final assessment. The DECOGEF is awarded after a six-semester program following the baccalaureate or equivalent, the DESCOGEF is awarded after a further four-semester advanced cycle, and the DECOFI is awarded only after successful completion of the three-year internship and final examination. These elements correspond to key components of the International Education Standards (IES), including professional education, practical experience, and assessment.

At the national level, Law No. 2001-001 establishes the profession in Togo and authorizes the Ordre National des Experts-Comptables et des Comptables Agréés du Togo (ONECCA-Togo) to regulate the profession within the national framework. Publicly available information indicates that ONECCA-Togo supplements the regional requirements through its own rules on initial professional development and continuing professional development. ONECCA-Togo also reports that its members are required to complete 120 hours of continuing professional development over a three-year period.

The regional qualification system includes an education program, practical experience requirements, final assessment, and continuing professional development obligations that are broadly consistent with the structure of the IES. However, the available evidence does not demonstrate full alignment with all current IES requirements in effect at the time of the assessment, particularly the learning-outcomes approach embedded in the revised 2019 IES.

Current Status: Partially Adopted

The Organisation for the Harmonization of Business Law in Africa (OHADA) Uniform Act Relating to Commercial Companies and Economic Interest Groups 4/1997 (revised January 2014) stipulates that statutory audits are mandatory for all public companies and limited liability companies (LLCs) that exceed determined thresholds. Banking and insurance legislation also require mandatory audits of banks, financial institutions, and insurance companies.

In June 2017, OHADA issued Regulation No. 01/2017/CM/OHADA Pratiques Professionnelles 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 January 1, 2018, all audits in member states, including Togo, must be conducted in accordance with the International Standards on Auditing (ISA) as issued by the International Auditing and Assurance Standards Board (IAASB).

The Ordre National des Experts-Comptables et des Comptables Agréés du Togo (ONECCA-Togo) indicates that the regional requirement is in force in the jurisdiction and that ISA are effective as issued by the IAASB.

Current Status: Adopted

At the regional level, the West African Economic and Monetary Union (WAEMU) Regulation No. 01/2009/CM/UEMOA authorizes the Conseil Permanent de la Profession Comptable (CPPC) to determine ethical requirements for member states. Since the CPPC has not separately established a regional code, the Organisation for the Harmonization of Business Law in Africa (OHADA) issued Regulation No. 01/2017/CM/OHADA Pratiques Professionnelles de la Comptabilité et de l’Audit dans les pays membres de l’OHADA to harmonize regional ethical requirements with international best practice.

The regulation states that, effective January 1, 2018, professional accountants in OHADA member states must adhere to the OHADA Code of Ethics, which is based on the 2015 International Ethics Standards Board for Accountants Code of Ethics for Professional Accountants and complemented by the ethical requirements related to statutory auditors contained in the OHADA accounting and company law framework.

At the national level, Law No. 2001-001 requires the Ordre National des Experts-Comptables et des Comptables Agréés du Togo (ONECCA-Togo) to establish ethical requirements for its members. All professional accountants in Togo are required to comply with the ethical requirements established under the OHADA regional framework and the institute’s professional rules.

Based on the available evidence, the ethical requirements currently in force are aligned with a pre-2018 version of the IESBA Code. Accordingly, the adoption status remains Not Adopted under the current methodology, since the 2025 edition of the International Code of Ethics for Professional Accountants (including International Independence Standards) as issued by the International Ethics Standards Board for Accountants (IESBA) has not been demonstrated to be adopted in the jurisdiction.

Current Status: Not Adopted

At the regional level, the West African Economic and Monetary Union (WAEMU) Directive No. 09/2009/CM/UEMOA establishes the public sector accounting framework applicable to member states, including Togo. The directive forms part of the broader WAEMU public financial management reform package and introduced the Plan Comptable de l’Etat for member states. Publicly available sources indicate that this framework was designed with reference to the International Public Sector Accounting Standards (IPSAS), but not as a direct adoption of IPSAS as issued.

At the national level, the Ministry of Economy and Finance is responsible for implementing the WAEMU public sector accounting framework in Togo. Available public sources indicate that IPSAS have not been adopted in Togo and that the applicable framework remains based on regional and national public sector accounting standards rather than accrual-basis IPSAS applied by all public sector entities. Togo has, however, been pursuing broader public financial management reforms with support from development partners, including the World Bank and the International Monetary Fund.

Accordingly, the adoption status of IPSAS in Togo is assessed as Not Adopted. Although the WAEMU framework is informed by IPSAS and supports modernization of public sector financial reporting, the available evidence does not demonstrate that accrual-basis IPSAS, with or without local modifications, have been adopted for application by all public sector entities in the jurisdiction.

Current Status: Not Adopted

At the regional level, the Organisation for the Harmonization of Business Law in Africa (OHADA) Regulation No. 01/2017/CM/OHADA on the professional practices of accounting and auditing in OHADA member states covers professional standards, practical guides, the code of ethics, and the quality assurance system. However, the regulation does not establish a complete regional investigation and discipline (I&D) system for professional accountants. Publicly available sources reviewed do not provide evidence that a comprehensive OHADA-level I&D system is operational for member states, including Togo.

At the national level, Law No. 2001-001 of January 23, 2001 grants the Ordre National des Experts-Comptables et des Comptables Agréés du Togo (ONECCA-Togo) responsibility to establish an I&D framework for its members. The law creating ONECCA-Togo provides the institute with authority over professional regulation and discipline within the jurisdiction.

Publicly available information indicates that ONECCA-Togo has established disciplinary arrangements, but the system is not yet fully aligned with Statement of Membership Obligations 6 (SMO 6). According to ONECCA-Togo’s publicly available compliance materials, the institute identified several areas still requiring improvement, including the separation of investigative and disciplinary processes, implementation of a distinct appeals mechanism through a National Discipline Commission, and stronger public interest communication and consideration.

While a system exists and the national professional accountancy organization has legal authority to investigate and discipline members, the available evidence does not demonstrate that the jurisdiction-level system is fully operational and aligned with all SMO 6 requirements, particularly with respect to separate investigative and disciplinary stages, an independent appeals process, and broader public interest features.

Current Status: Partially Adopted

The corporate financial reporting framework of Togo is determined by legislation issued by two regional organizations: the West African Economic and Monetary Union (WAEMU) and the Organisation for the Harmonization of Business Law in Africa (OHADA). As a member of both regional bodies, Togo harmonizes its national legal and financial reporting framework with the directives and regulations issued at the regional level.

In January 2017, the Commission de Normalisation Comptable de l’OHADA (CNC-OHADA) adopted the OHADA Uniform Act on Accounting and Financial Information (Acte Uniforme relatif au Droit Comptable et à l’Information Financière (AUDCIF)), replacing the previous 2000 accounting framework and revising the Système Comptable OHADA (SYSCOHADA). The revised framework became effective on January 1, 2018 for individual financial statements and on January 1, 2019 for consolidated and combined financial statements.

The AUDCIF requires that listed companies and companies seeking financing in a public capital market prepare consolidated financial statements in accordance with International Financial Reporting Standards Accounting Standards (IFRS Accounting Standards). According to the IFRS Foundation jurisdiction profile for Togo, IFRS Accounting Standards in effect are required for all domestic publicly accountable entities in consolidated general purpose financial statements. Accordingly, the adoption status of IFRS in Togo is assessed as Adopted under the current methodology.

For all other entities, including small and medium-sized entities, SYSCOHADA remains the applicable accounting framework. The IFRS for Small and Medium-sized Entities Accounting Standard (IFRS for SMEs) has not been separately adopted in Togo. Instead, non-publicly accountable entities generally apply SYSCOHADA.

Current Status: Adopted

Relevant Organizations

Commission de Normalisation Comptable de l’OHADA (CNC-OHADA)

Ministry of Economy and Finance, Togo

Ordre National des Experts-Comptables et des Comptables Agréés du Togo (ONECCA-Togo)

Organisation for the Harmonization of Business Law in Africa (OHADA)

Pan African Federation of Accountants (PAFA)

West African Economic and Monetary Union (WAEMU / UEMOA)

Relevant Legislation

Law No. 2001-001 of January 23, 2001 establishing ONECCA-Togo

OHADA Regulation No. 01/2017/CM/OHADA – Pratiques Professionnelles de la Comptabilité et de l’Audit dans les pays membres de l’OHADA

OHADA Uniform Act on Accounting and Financial Information (AUDCIF), 2017

OHADA Uniform Act Relating to Commercial Companies and Economic Interest Groups (revised 2014)

WAEMU Directive No. 09/2009/CM/UEMOA on public financial management reform

WAEMU Regulation No. 01/2009/CM/UEMOA establishing the Conseil Permanent de la Profession Comptable

WAEMU Regulation No. 03/2020/CM/UEMOA establishing the regional professional qualification framework

Relevant Publications

IFRS Foundation, “Use of IFRS Accounting Standards by Jurisdiction: Togo”

PAFA, “4th Public Financial Management Reforms Conference Report,” 2024

World Bank, Implementation Status Reports and public financial management reform support documentation (Togo)