Chartered Accountants Ireland has been engaging with the Companies Registration Office, Revenue, the Central Bank and other key government agencies and stakeholders around the impact of COVID-19. The most up to date information available from regulators is as follows:
Companies Registration Office (CRO) – The CRO has confirmed that all annual returns due to be filed by companies between now and 30 June 2020 will be deemed to have been filed on time if all elements of the annual return are completed and filed by that date. The situation will be kept under review and the date of 30 June 2020 may be extended depending on the situation at the time. Please see the CRO twitter for more information. The CRO have also issued a FAQ document which clarifies some of the issues raised by users.
The Registrar of Friendly Societies also has an updated annual return date of 30 June 2020.
Courts Service – The Courts Service has published a comprehensive list of amendments to Court schedules and procedures which are available on their website. There are ongoing updates available on the Courts Service twitter account. A further note was issued on 24 March regarding the interim process in place for the delivery of judgments.
Law Society of Ireland (Law Society) – We have been in touch with the Law Society of Ireland regarding the filing of Reporting Accountants Reports. They noted that the obligation to furnish the accountants reports rests with the solicitor and the Law Society is continuing to pursue outstanding reporting accountants’ reports. Where solicitors are in difficulty in furnishing signed reports the Law Society is accepting unsigned reports by email at financialregulation@lawsociety.ie with an undertaking from the solicitor that the original signed report will be filed as soon as is practicable. Where solicitors are in genuine difficulty filing the reports, additional time is being afforded to solicitors to file the report. Solicitors should notify the Society at financialregulation@lawsociety.ie of the current difficulty. The Law Society is dealing with these on a case by case basis. It is worth noting that there has been no change in the law in relation to the requirements for execution, stamping and registration of deeds. The requirements for registration of deeds in the PRA means that wet signatures on deeds are still required.
Central Bank of Ireland – The focus of the Central Bank is ensuring that the financial system can continue to provide services to households and business in this difficult time. They have worked constructively with all of the sectors that they regulate and have published the measures that have been taken to date here. The Central Bank of Ireland relies on the various regulatory filings in order to monitor the financial system. Should firms believe that they will not meet their regulatory reporting obligations, they should speak to their supervisors or their usual Central Bank contact in the first instance, as they usually would, providing specific information on difficulties faced. Their usual Central Bank contact will be best placed to advise on their individual situation.
Property Services Regulatory Authority (PSRA) – The PSRA has issued details of the measures it has put in place around license renewal applications, audits, investigations and general queries to continue the smooth running of its day to day activities.
Central Statistics Office (CSO) – The CSO acknowledges that collecting data will be difficult in the COVID-19 period and has issued a press release outlining their priorities and the processes in place during this period. Insofar as possible, they are continuing to collect survey information, so that they can provide statistics that show the changing situation from March 2020 onwards.
Data Protection Commissioner (DPC) – The DPC has issued a note which serves as a reminder on data protection obligations when processing personal data relating to COVID-19. They have also published tips to keep personal data safe when working remotely which are included here.
Charities Regulator – The Charities Regulator is currently open and working on ways to continue our regulatory work and provide supports to Irish charities. It understands that one of the impacts of this crisis may be a delay in the filing of annual reports by charities who are due to file over the next few weeks. The Charities Regulator is conscious that all organisations are facing challenges at this time and would ask that charities endeavour to file annual reports on time using the Charities Regulator’s online portal, which all charities will be familiar with. Please be aware that automated reminders to file your annual report will continue to issue. The Charities Regulator will be considerate and proportionate in how we deal with such issues where they arise. While it does not propose to formally extend filing deadlines at this time, we will keep this under review.
Charity Commission for Northern Ireland – Some changes have been made to the way the Charity Commission for Northern Ireland delivers its services. Details are available on their website. In terms of annual reporting, they note that, in the current circumstances, “until otherwise advised, no charity will be penalised for missing its annual reporting deadline, which includes that no charity will be marked as in default on the register of charities if they fail to meet this deadline. We would ask that if charities find themselves in this position that they contact us via email to admin@charitycommissionni.org.uk where possible, to keep us apprised of their situation.”
Law Society of Northern Ireland – The timeframe in which independent statutory Reporting Accountants’ Reports must be delivered to the Society will be extended by three (3) months from the date on which the report should otherwise be delivered. See full notice here.
Companies House – The Companies House is now granting those who apply, a two-month extension to file company accounts. Companies House advise that companies should act before the filing deadline. If accounts will be late because your company is affected by COVID-19, and your filing deadline has not yet passed, you can apply for an automatic and immediate 3 month extension to file your accounts but you must apply for the extension before the filing deadline.
Other
We have also collated specific information for both auditing and financial reporting. The auditing updates includes FAQ’s which consider some of the audit challenges faced in this period and updates from regulatory bodies and professional bodies. The Financial Reporting update includes some updates from accounting standard setters/regulators, professional bodies and material from member firms.
IAASA has published news articles noting the issuing of: the ESMA public statement (27 March 2020) promoting co-ordinated action by National Competent Authorities regarding issuers’ obligations to publish periodic information for reporting periods ending on or after 31 December 2019 in the context of the COVID-19 outbreak (see below); the ESMA public statement (25 March 2020) on the financial reporting implications of the COVID-19 outbreak on the calculation of expected credit losses in accordance with IFRS 9 Financial Instruments (see below); and an earlier ESMA public statement addressing actions that market participants have to take in relation to the COVID-19 outbreak in order to preserve investor protection, the integrity of markets and financial stability (12 March 2020).
The FRC has published guidance for companies preparing financial statements and a bulletin for auditors covering factors to be taken into account when carrying out audits during the current Covid-19 crisis. Previously they issued guidance for auditors arising from the coronavirus pandemic. It has also published advice for companies and auditors on disclosure of risks and other reporting consequences arising from the emergence and spread of COVID-19. Updates from the FRC are available here.
The FCA, FRC and PRA announced a series of actions (26 March 2020) to ensure that information continues to flow to investors and to support the continued functioning of the UK’s capital markets.
The European Central Bank (ECB) has announced a number of measures to ensure that its directly supervised banks can continue to fulfil their role in funding the real economy as the economic effects of the coronavirus (COVID-19) become apparent.
The Department of Business, Enterprise and Innovation (DBEI) have published a list identifying the current supports which are available for impacted businesses. There is also a comprehensive checklist of issues for businesses to consider. which can be found here. This includes the recently published Business Continuity Planning: Checklist of preparatory actions in responding to COVID-19. This checklist includes planning activities, business issues to address, measures to underpin continuity and responding to workplace risks due to COVID-19, as well as some useful links.
Accountancy Europe has collated resources for European accountants including updates from Accountancy Europe member bodies, public authorities and firms.
Institute of Chartered Accountants of England and Wales (ICAEW) – ICAEW has a useful COVID-19 hub available on their website to support individuals, businesses and their advisors. Members may find the articles on The financial reporting implications of coronavirus and Considerations for group auditors of interest.
Competition and Consumer Protection Commission (CCPC) – The CCPC has set out some steps on its website that businesses can take to assist the CCPC in carrying out its merger review.
ESMA, the EU’s securities markets regulator, has issued a Public Statement (27 March 2020) on the implications of the COVID-19 pandemic on the deadlines for publishing financial reports which apply to listed issuers under the Transparency Directive.
ESMA has issued a public statement (25 March 2020) on the financial reporting implications of the COVID-19 outbreak on the calculation of expected credit losses in accordance with IFRS 9 Financial Instruments.
In other instances, we advise members to make contact with the relevant stakeholder body for specific advice.
Member firms
Several of the Institute’s member firms have produced material to help businesses respond to and manage the impact of COVID-19.
To date, we have come across the following updates:
PwC Ireland recently published an update which includes information for organisations on crisis planning with information PwC’s global crisis centre also included.
BDO Ireland has issued a COVID-19 Business Toolkit: Managing your business in uncertain times includes information on trading and working capital, cash flow management along with updates on banks and funding, employee costs and options, Revenue and turnaround options. The toolkit can be found here.
KPMG Ireland as developed practical guidance and support to help businesses in both Ireland and Northern Ireland manage the impact of COVID-19.
Mazars Ireland has published information and tips for business owners including resources on insolvency and director’s duties, crisis planning, communication, staff issues and supply chain management.
Grant Thornton Ireland’s website includes managing mobility in the face of coronavirus, the importance of strategic workforce planning, COVID-19: government supports and COVID-19: data protection. There is also specific resources for NI resources available on Grant Thornton’s NI website.
EY Ireland's online resources include webinar which discusses the business implications of COVID-19 and an article on how companies can reshape results and plan for recovery.
Deloitte Ireland's online resources include Local and Global guidance.
Chartered Accountants Ireland is continuing to monitor the advice being issued by the Health Protection Surveillance Centre (HPSC) and other Irish and international agencies. Please see our website for further information.