Earlier this year the FRC published an update to its Ethical Standard for auditors, effective from 15 December 2024. The updated ethical standard simplifies the existing ethical standard and provided additional clarity in a limited number of areas. the new standard takes into account recent revisions made to the international IESBA Code of Ethics. there is a new targeted restriction on fees from entities related by a single controlling party. Following feedback to their consultation, the FRC have amended the proposals to ensure that the requirements in the standard are better targeted and proportionate. For example, additional requirements in respect of ethical breach reporting by audit firms to the regulator have been removed. With regard to tax services provided to the controlling shareholders of unlisted companies the FRC is enhancing the independence risk assessment around these services rather than specifically prohibiting them. Alongside the revised Ethical Standard, the FRC has also released guidance for auditors on the application of the Objective, Reasonable and Informed Third Party test, which forms a key part of many requirements in the Ethical Standard. Read the updated Ethical Standard. Read the feedback statement and impact statement. CAI responded to the FRC consultation and you can read our response here.  

Increased global competition one of several challenges to FDI model Addressing infrastructural deficit critical to ensuring continued FDI growth Chartered Accountants Ireland launches FDI guide, highlighting critical role its members play in supporting investment   Ireland faces greater competition as a location for global Foreign Direct Investment (FDI) than ever before as we move into 2025, with other countries enhancing their offering at pace. While Ireland’s FDI policy has stood the country in good stead for decades, a slowdown in growth of the global economy coupled with accelerated industrial policy interventions by competitor countries means Ireland’s inward investment model is now at a crucial inflection point, according to Chartered Accountants Ireland.  The Institute, the largest professional body on the island of Ireland, representing over 38,400 members, has today launched its new guide to FDI in Ireland at an event in conjunction with IDA Ireland in Dublin.   Cróna Clohisey, Director Public Affairs, Chartered Accountants Ireland said  “Ireland’s record of attracting FDI has been the envy of other countries for decades and IDA Ireland has played a pivotal role. However, against a backdrop of heightened geopolitical uncertainty and intensifying global competition for inward investment, we cannot afford to be complacent about our offering. The significant deficits in the State’s crucial infrastructure, including housing, energy, water, childcare and nationwide public transport, need to be addressed with urgency if we are to remain fully competitive in the race for future FDI.” Barry Doyle, President, Chartered Accountants Ireland said  “We are all familiar with the advantages that Ireland holds in attracting FDI - EU membership, strategic location, young talented workforce and a stable business environment. Our members also represent a key competitive advantage, with Chartered Accountants playing a central role in supporting FDI the length and breadth of the country. “Competition has never been greater for the flow of FDI around the world, and with a new US administration taking office in a matter of weeks, there is an increased chance of disruption to the traditional flow of FDI globally. However, investors with a long term, sustainable outlook will look beyond short-term protectionism. Ireland as a safe and stable environment will continue to benefit greatly from FDI and we as Chartered Accountants will be there to lead and support such investments.”    

While I’m the youngest President in Chartered Accountants Ireland’s history, it’s still over twenty years since I sat Leaving Cert Accounting. Despite this passage of time, I studied the same syllabus, frozen in time since the 1990s, as the students who received their results today. Juxtapose this stasis with the absolute transformation of the accountancy profession in the last twenty years and you can see the mismatch. Add to this the fact that the Irish accountancy profession made a €19.8 billion contribution to the Irish economy in 2022, supporting over 83,000 jobs in Ireland and generating €1.8 billion in tax revenues, and the mismatch starts to have significant material impact. Back to the 90s Senior cycle is where most young people first interact with accounting as a subject, and the passage of time has not been kind to it. Students effectively need to “unlearn” much of what they learn at senior cycle and learn the subject anew at third level and in their professional training. The need for companies to provide reliable and transparent information beyond financial metrics has increased exponentially in the last decade, and the dated syllabus does not reflect the work that accountants do, and will do, in a modern economy. I want to acknowledge the work teachers around the country do to bring it to life for students, but they are nonetheless bound by the syllabus. We work closely with Leaving Cert students through our online second level accounting programme Boot Camp which now runs in every county in Ireland. Feedback from teachers we speak to indicates that in some cases, students were more attracted to Business at Leaving Cert as they saw Accounting as requiring a particular skillset, i.e. needing to ‘be good at maths’ to perform well in it. In speaking to our ACA students, many pursued accounting at third level despite, not because of, their experience at second level. Perception is critical. Chartered Accountant Ireland research among Gen Z respondents shows a clear gap in terms of how accounting is perceived by school leavers versus those who had commenced their professional training. Terms such as challenging, numbers-based, and boring were used by the former, dropping dramatically among the latter when they engage with a modern curriculum with the latest advances in technology and emerging accounting practices. Impact on the talent pipeline Anecdotally, the talent pipeline problem is clear right across the profession, from practices of all size to industry, resulting in attraction and retention challenges. It is driven by a huge increase in competition for talent from non-accounting roles; but also, this gap in perception of what accountants do. The accountancy profession is fundamental to Ireland’s economic prosperity. Our members support SMEs the length and breadth of the island, as well as playing a critical role in supporting investment from all corners of the world to Ireland. There is continued strong growth in demand for the services of the profession, but this demand can only be met if there is a strong pipeline of talent coming through, and this begins with our Leaving Cert students. I would say to students getting their exam results, employer demand for accountants is extremely strong. Salary levels for qualified accountants reflect this demand and the vitally important roles that accountants perform in all organisations. This demand continues to grow and so too does the range of opportunities. Reform is on the way This Institute has been engaged with the Department of Education for some time on the need to reform the Leaving Cert Accounting syllabus. Earlier this year we took our place on the National Council for Curriculum and Assessment’s Leaving Cert Accounting development group. We are now in the redevelopment process, but this change is so long overdue, and the rate at which the profession is innovating and transforming is in sharp contrast to the lack of agility over the last couple of decades at Department level in keeping pace.   It is envisaged that a revised specification for Leaving Cert Accounting will be introduced in schools from September 2026. It will provide a much-needed opportunity to ensure that the subject is relevant for students beyond second level education. And this is critical, as accountants are found across most business functions now, they are no longer confined to finance teams. There is an increased demand in industry roles, business process transformation, data analytics, regulatory technology, Fintech, compliance, risk management and ESG reporting. Senior cycle accounting of the future will feed a pipeline of students through the many entry routes into the profession, whether as school leavers or graduates, to meet this demand. So, the syllabus needs to reform, and then keep reforming. Remarkably, even with all the flaws of the current syllabus, accounting is the second most popular subject in the business suite for students in senior cycle and between 12-14% of students have been choosing the subject annually. It is exciting to imagine what a reformed syllabus could do to attract the best and brightest of our future business leaders.

“Auto Enrolment has been talked about for decades – now it is finally happening.” The words of Social Protection Minister Heather Humphreys after the Automatic Enrolment Retirement Savings System Bill passed through the Houses of the Oireachtas. Ireland is one step closer to catching up with every other OECD country that already has some form of auto-enrolment. It might be finally happening, but when is less clear. Momentum is needed to avoid the work of the last two decades being squandered. Two-thirds of Chartered Accountants Ireland’s members work in business, many of whom will be required to put such a scheme in place for their employees. The most recent formal communication from government suggests a start date sometime in 2025. And yet, putting in place the infrastructure to facilitate a system of pensions auto-enrolment is a mammoth task, and the list of outstanding deliverables at Department level is concerning before it even comes time for businesses to act. Hurdles to clear The legislative hurdle has now been cleared, but the Department of Social Protection has only in recent weeks appointed a company to build and run the new system. We are encouraged to see they have chosen a company that has a record of success in building the UK equivalent. We urge the Department to now expedite the appointment of a firm to manage the underlying investments. In recent weeks, it was reported that the Department of Finance has raised concerns that the auto enrolment legislation has been framed in a way that will force the regulator to apply a lower standard of oversight than that imposed on firms in the private pensions market. Other details also need to be clarified. In recent months, this Institute has requested such clarity in several areas. Many employers with staff who are likely to come within the remit of auto-enrolment will already have occupational pension schemes in place. To avoid the administrative complexity of setting up and operating a second staff pension scheme under auto enrolment, such employers may instead offer to extend participation in their current pension scheme to currently non-pensionable employees. However, if even just one of these employees refused to join the staff scheme in favour of being automatically enrolled, the employer would still be compelled to undertake the cost of setting up and operating a second scheme. We also sought more information around the meaning of “employee”, defined in the legislation as “a person in receipt of emoluments”. Such a definition would extend to individuals already in full-time pensionable employment who also undertake additional work who will therefore be required to contribute to a second pension scheme. Communication is going to be key The government’s recent SME package put a premium on the importance of consultation and dialogue with SMEs and other groups before introducing new legislation or policy affecting them. Auto enrolment is an opportunity to put this into practice. The government now needs to publish a road map and stick to it. While feedback was invited as part of an initial public consultation in 2018, since then only a very basic four-page guidance note for employers has been issued by government. To gain and maintain momentum, extensive and continuous stakeholder engagement is needed - not least with employers and payroll providers, upon whom the successful operation of the new system will be largely dependent. In a survey of small businesses conducted by Chartered Accountants Ireland, almost 90% felt that businesses had not been adequately informed of the steps needed to be taken by them to comply with pensions auto-enrolment in time for an early 2025 start date. Interestingly, three quarters of those surveyed will be required to introduce the new pension scheme, and for many this will be alongside their existing occupational pensions. Businesses need to see what the journey to implementation will look like. In a high-cost environment, this will give much needed reassurance and help to allay concerns. What is a realistic timeline? In its pre-legislative scrutiny report on the Bill introducing auto-enrolment, the Joint Committee on Social Protection recommended a two-year lead-in period, following the Bill being signed into law, to allow sufficient time for implementation. Payroll providers have been consistent in highlighting the need for an initial pilot phase to facilitate testing of the new system and to allow sufficient time to assimilate auto enrolment with current payroll systems. Neither of these fit into a 2025 implementation timeline. If officials truly want auto-enrolment to be a success, this timeline should be revisited and a 2026 or beyond start date announced. They may wish to avoid yet another postponement to the launch of auto enrolment but what should really matter here is getting it done right and giving businesses a chance to adapt. This additional time needs to be wisely used, by facilitating ongoing dialogue between departments, third party partners in implementation, and the many business groups and stakeholders who have walked this long road to auto enrolment.

As people across the world condemn the attack by Russia on Ukraine, they also want to show their support through donations and using their influence for humanitarian intervention. Professional accountants will find themselves in positions of influence with many stakeholders including clients, employers, employees, and local communities.  Níall Fitzgerald, Head of Ethics and Governance outlines some practical considerations for accountants and business leaders in this context:    Fundraising for humanitarian or other reliefs People and organisations are looking to help the millions of Ukrainians displaced by the invasion by donating directly or running fundraiser events. Be aware of fraud risk and recommend controls that ensure the safeguard of any monies raised and that they are used for the purpose for which they were raised. Ensure the necessary licences are obtained for any public fundraising activity. Be clear on the purpose for the funds and how they will be channelled to the beneficiaries. Ensure compliance with national charity law and check that charitable donations are only made to a properly registered charity in your jurisdiction. Social media Understandably, many people and corporates are sharing their views on Russia's  invasion of Ukraine via social media. The distinction between when a view is a personal view or that of the organisation where a person works is not always clear. If you are an officer of a company, e.g. a director, chief executive, or the public relations officer, and you are commenting on a matter related to your area of responsibility, then it is very difficult to separate your view from the corporate view. For this reason, many organisations will have clear corporate social media policies in place and that is the first reference point if in doubt. However, before reacting to a colleague's personal post, it is important to also consider their right to hold and express an opinion. There can be a cultural aspect to this within an organisation, especially where respect, tolerance, diversity and inclusion, and psychological safety are highly valued. The specific circumstances of the person expressing the view might also be taken into account, for example their emotional proximity to the issue.  Developing corporate positions Many organisations are using their influence for good by publicly denouncing the invasion of Ukraine, with some going further to withdraw from investments and business operations in Russia, and any dealings with Russian state-owned entities. These decisions are not always the most straightforward to implement. Legal and other expert advice should be sought to consider how an organisation can address contractual obligations, restructure, and relocate operations. Many Russian citizens are against the actions of the Russian Government, and Russian employees, contractors, etc., should receive fair treatment and not be discriminated against. Reporting progress and being transparent on these positions, including any setbacks, is very important as corporates will be held to account by stakeholders and members of the public to honour their commitments. Careful thought should be given before making any wide-sweeping statements. The global economy, with its complex interconnected markets, creates practical difficulties when seeking to divest of everything connected to Russia.   Whistleblowing and speaking up Clearly defined and well-communicated whistleblowing and speaking-up policies and procedures can increase an organisation’s awareness of any weaknesses in it’s internal controls and practices relating to sanctions, anti-money and anti-bribery and corruption compliance. Communicating to employees the organisation’s position in relation to this crisis and reminding them about whistleblowing and speaking-up policies and procedures, promotes a safe environment in which individuals feel comfortable to raise any concerns about the organisation’s actions, or inactions. Corporate reporting While the scale of the impact of this crisis on organisations will differ, it will dwarfed by the impact on millions of Ukrainians. Organisations have important social obligations and responsibilities to corporate stakeholders. Accountants should ensure transparency and accountability in corporate reporting by highlighting the impact of the crisis on the organisation’s operations, asset valuations and exposure to liabilities. Examples of the sources of this impact include: supply-chain disruption; the cost of ceasing operations in Russia or the conflict/invasion zones; rising commodity prices; inaccessibility of certain markets due to trade or travel restrictions; difficulty maintaining required levels of capital reserves; and loss of key customers. Accountants will have a central role in collecting, measuring, and reporting the necessary information and ensuring it is reported in accordance with legal and regulatory requirements and relevant reporting frameworks. They should also understand the limitations to their expertise and call for the involvement of experts where necessary. Directors and senior management will need to consider expert advice when making highly judgemental decisions on values and estimates and in determining the future implications for the organisation.    Boundaries between personal life and professional life Negative emotions, such as anger and fear, increase the risk of self-defeating behaviours. The developing situation in Ukraine will understandably evoke such emotions in many. In this context, it is useful to refer to guidance issued by the CCAB bodies, in July 2021, to help accountants consider and distinguish if their personal behaviour could be viewed as conduct that might discredit the profession. While the facts and circumstances of every situation will differ, the CCAB guidance provides some examples of such behaviours, including the use of seriously offensive or threatening language causing distress, or threatening behaviour, towards a client or a member of the public outside of the work environment.  This non-exhaustive list of considerations may need to be reconsidered as the crisis in Ukraine develops. In many situations, increasing ethical awareness or the ability to address an ethical dilemma requires reflection. Professional accountants may find it useful to refer to, or circulate to professional accountancy staff, the Chartered Accountants Ireland Ethics Quick Reference Guide available from our Ethics Resource Centre. This article was adapted for members overseas from an article written by Níall Fitzgerald on the Institute’s Ethics Resource Centre.

Background The Department of Children, Equality, Disability, Integration and Youth (the Department) has recently issued a document1 “Guidance Note for Core Funding Reporting Requirements Transitional Arrangements Year 1 and 2” (“the Department Guidance Note”) to entities providing childcare and early education services regarding the transitional arrangements for the application for funding under a new funding model called ‘Together for Better’.  These transitional arrangements will be in place for the next two reporting periods (years ended 31 August 2023 and 31 August 2024). Reporting regime This reporting regime includes a requirement that the childcare service providers (“client”) engage a professional accountant to submit a document called an ‘Income and Expenditure Template. CCAB-I have made the Department aware of the potential cost implications for an accountant providing this service to their client.  The following matters should be noted: The report is to cover expenses incurred on a cash basis for the year ended 31 August. The requirement is for expenditure incurred in the relevant period only, no accruals or prepayments. Income will be pre-populated in the online platform. Where your client has a different year end, time apportionment is not permitted. Important considerations for CCAB-I members CCAB-I has engaged with the Department over a number of months to discuss the nature and extent of work expected and the respective responsibilities of the client and the professional accountant and, in particular, the concerns regarding the request for the professional accountant to submit the report (as set out in the Department Guidance Note) on behalf of a client. There was positive engagement and much, but not all, of the feedback by CCAB-I on the process was reflected and incorporated into the final guidance. However, given the type of engagement, CCAB-I are making members aware of the potential issues and extant guidance which our members may consult. The Department Guidance Note sets out the responsibility for the data included in the report. See section 2 of the Guidance Note: “The Service Provider is responsible for fully complying with all financial transparency requirements in accordance with their Core Funding contractual obligations. The accountant relies on information provided by the Service Provider, who is responsible for disclosing all relevant information.” The Service Provider/client will make an online declaration on the platform provided by the Department that they have authorised a professional accountant2 to make the submission for them.  CCAB-I members are reminded of the relevant Code of Ethics issued by their professional body.  Independence The Department Guidance Note3 defines an accountant as someone who: "(a) has been admitted as, and is, a member of a prescriber accountancy body, (b) is currently practicing in the profession of accountant, (c) is not and never has been a principal officer or employee, or an owner or part owner, of the licensee in respect of whom he or she is preparing an accountant’s report, and (d) is maintaining such minimum level of professional indemnity insurance as is required by the prescribed accountancy body concerned." .Members should be cognisant of any conflicts with other engagements they may undertake for their clients.  When you are the Auditor  Where the accountant is the statutory auditor the Ethical Standard for Auditors (Ireland)4 applies and Section 5.129 prohibits the audit firm providing accounting services where the services would involve the firm undertaking part of the role of management or initiating transactions.  "S 1.24           In the case of a statutory audit, non-audit services shall not be provided that involve playing any part in management decision-taking of an entity relevant to an engagement. The firm shall not accept any engagement which includes the provision of services where it is probable that an objective, reasonable and informed third party would conclude that the firm or a covered person was playing a part in management decision-taking.  5.128          The provision of accounting services by the firm to an entity relevant to an engagement creates threats to the integrity, objectivity and independence of the firm and covered persons, principally self-review and management threats, the significance of which depends on the nature and extent of the accounting services in question and the level of public interest in the entity. 5.129            The firm shall not provide accounting services to an entity relevant to an engagement where: (a) the entity is a listed entity, relevant to an engagement by the firm, or a significant affiliate of such an entity; or (b) for any other entity: those accounting services would involve the firm undertaking part of the role of management, or initiating transactions; or the services are anything other than of a routine or mechanical nature, requiring little or no professional judgment.” When you are not the Auditor We recommend that members read the Department Guidance Note1 and that an appropriate letter of engagement and representation letter are in place where they undertake these engagements.  Members should refer to guidance documents issued by Chartered Accountants Ireland.  TA 06/2023 Grant Claims5 and the International Standard on Related Service ISRS 4400 (Revised) Agreed-Upon Procedures Engagements6 which give guidance on engagement acceptance and continuance and some general advice on agreeing the terms of engagement.  1 https://earlyyearshive.ncs.gov.ie/downloads/download-corefunding/   2 A professional accountant is defined as a member of a Prescribed Accountancy Body that comes within the supervisory remit of IAASA, •              Chartered Accountants Ireland. (CAI) •              Association of Chartered Certified Accountants (ACCA) •              CPA Ireland (CPA) •              Chartered Institute of Management Accountants (CIMA)  3 See Section of Guidance Note for Core Funding Reporting Requirements Transitional Arrangements Year 1 and 2. 4 https://iaasa.ie/wp-content/uploads/docs/media/IAASA/Documents/audit-standards/Ethical-Standard-Consultation/Ethical_Standard_Nov_2020_updated_June_3.pdf 5 https://www.charteredaccountants.ie/chariot/account/ta/TA06_2023.html 6 https://www.iaasb.org/publications/international-standard-related-services-isrs-4400-revised