The IFAC Small and Medium Practices (SMP) Committee submitted this comment letter to the International Ethics Standards Board for Accountants (IESBA) in response to its Exposure Draft, Improving the Structure of the Code of Ethics for Professional Accountants—Phase 2.

The IFAC Professional Accountants in Business Committee agrees with the International Ethics Standards Board for Accountants that there is a need to strengthen the concept of professional skepticism in the Code of Ethics for Professional Accountants based on clarifying how the fundamental principles support the exercise of professional skepticism in the audit and assurance context.

The IFAC Small and Medium Practices (SMP) Committee submitted this comment letter to the International Ethics Standards Board for Accountants in response to its Exposure Draft, Proposed Revisions Pertaining to Safeguards—Phase 2 and Related Conforming Amendments.

The IFAC Small and Medium Practices (SMP) Committee submitted this comment letter to the International Ethics Standards Board for Accountants in response to its Exposure Draft, Proposed Revisions to Clarify the Applicability of Provisions in Part C of the Extant Code to Professional Accountants in Public Practice.

The IFAC Small and Medium Practices Committee welcomes the International Auditing and Assurance Standards Board's agreed-upon procedures Discussion Paper. It strongly believes that the revision of International Standard on Related Services 4400, Engagements to Perform Agreed-Upon Procedures Regarding Financial Information, should be a high priority for the board.

The SMP Committee welcomes and supports the IAASB Data Analytics Working Group’s work to explore the effective and appropriate use of technology, with a focus on data analytics, in the audit of financial statements. In its view, an objectives- and principles-based approach to standard setting is now more necessary than ever, especially to prevent the ISAs from being out of date as soon as they are updated.

To remain relevant in the future, IFAC and its Professional Accountants in Business (PAIB) Committee believe that the accountancy profession in all its forms needs to embrace integrated reporting by reporting on the business in its entirety, and building trust and confidence in this reporting.

The IFAC SMP Committee agrees that emerging forms of external reporting (EER) are still evolving and supports the initiative to better understand the developments and challenges being encountered. At this stage, it does not believe there is a need for the IAASB’s international standards to cover a broader range of engagements than what are currently addressed.

IFAC is pleased to respond to Independent Regulatory Board for Auditors (IRBA)’s Consultation Paper, Mandatory Audit Rotation.

IFAC recognizes the crucial role that audit plays in the financial reporting ecology. However, while vital, it is just one element of the supply chain for high-quality financial reporting. Others in the financial reporting supply chain include financial report preparers, organizational management, boards of directors, audit committees, regulators, standard setters, investors, and financial statement users.