EBA欧洲银行-2009-10-05-28CEBS-CL-EC-Consultation-on-the-Adoption-of-ISAs29_4页_150kb

European Commission DG Internal Market and Services - EC Consultation on the Adoption of ISAs Summary

Core Content

The Committee of European Banking Supervisors (CEBS) has provided comments on the European Commission's consultation regarding the adoption of International Standards on Auditing (ISAs) at the European level. The CEBS emphasizes the importance of aligning European audit standards with globally accepted ISAs to enhance financial stability, banking supervision, and audit quality across the EU.

Main Views and Key Information

1. Support for ISA Adoption

• CEBS supports the adoption of ISAs at European level, believing that they contribute to a sound banking system and financial stability.
• They advocate for adopting ISAs without amendment, as the standards are already internationally accepted, globally convergent, and well-established.
• The adoption should follow the criteria outlined in Article 26.2 of Directive 2006/43/EC, which include international acceptance, high credibility, and alignment with the European public good.

2. Application Material

• CEBS supports including Application Material in the adoption process, as it is essential for auditors to fully understand and apply the ISAs.
• They propose that the EC should use the same terminology as ISA 200 and refer to the application material as "application and other explanatory material".
• A legally binding adoption of the Application Material is recommended to ensure consistency and clarity.

3. ISQC1 and Internal Quality Controls

• CEBS supports the adoption of ISQC1 (Internal Quality Control Standards) as it is interrelated with the ISAs and enhances audit quality.
• The inclusion of ISQC1 in the adoption process would increase the benefits of ISA implementation across the EU.

4. Audit Reports Harmonisation

• A common reference to "ISAs as adopted in the EU" in all auditors' reports is considered sufficient.
• CEBS does not support further harmonisation of audit reports at this stage, as it should not delay the adoption of ISAs.
• They suggest that the EC could evaluate further harmonisation after some time has passed since the adoption.

5. Member States' Add-ons and Carve-outs

• CEBS accepts add-ons that arise from specific national legal requirements related to the scope of statutory audits.
• However, they advocate against carve-outs, as these may impair the coherence of the audit standards or create level playing field issues.
• Carve-outs should only be considered in rare circumstances where an ISA is not conducive to the European public good.

6. Cost/Benefit Analysis

• CEBS does not have any comments on the cost/benefit analysis presented in the University of Duisburg/Essen study.

7. Adoption Timing

• CEBS supports an early and practical adoption of ISAs within the EU.
• They consider that the transition period should include management, training, education, and software adaptations.

Conclusion

CEBS is in favor of a unified and globally aligned audit standard across the EU. They believe that the adoption of ISAs is necessary to ensure audit quality, consistency, and international recognition. The endorsement process should involve consultation with all relevant stakeholders, including banking supervisors, and should be transparent and based on the standard comitology process.

CEBS supports option 3 in the consultation, which calls for the adoption of ISAs for the statutory audit of all companies, including small ones. They argue that having multiple sets of audit standards at the national level is not cost-effective or practical.

Appendix Summary

The CEBS has provided detailed responses to all ten questions in the consultation document, with the focus on maintaining coherence, consistency, and international alignment of audit standards. Their comments were coordinated by the Expert Group on Financial Information (EGFI), chaired by Mr. Didier Elbaum from the Commission Bancaire, France, and supported by the Subgroup on Auditing under Marc Pickeur from the CBFA, Belgium.