Implications for audit registration

Dec 16, 2020

As the end of the Brexit transition period approaches on 31 December 2020, clarity is finally emerging in relation to the implications for audit registration in Ireland and the UK after the transition period. The important news for auditors and audit firms registered by this Institute is that the status quo will continue for the majority of firms in both Ireland and the UK after 1 January 2021.

Irish audit registration – after the Brexit transition period

Since 2018 Brexit has cast uncertainty over the position of ‘UK-based’ (however interpreted) auditors registered by the Institute vis-à-vis eligibility to audit Irish entities post Brexit.  The Institute has kept members informed of any developments in this regard and has outlined our position, i.e.  that there is no basis for the Institute to remove its ‘UK-based’ auditors from the Irish audit register as a consequence of Brexit unless there is a change in Irish company law or a formal direction from IAASA to the Institute.   

Recent engagement with IAASA has confirmed that there will not be any legislative change or regulatory direction in this regard. Therefore, the status quo will continue in Ireland from 1 January 2021 for the Institute’s UK-based auditors and audit firms, as long as those individuals and firms continue to meet the eligibility criteria (unchanged) set out in the Institute’s Audit Regulations and in the Companies Act 2014.  The Professional Standards department will be writing to audit compliance principals of statutory audit firms in more detail in the coming weeks.

It is welcome news for the auditors and audit firms registered by the Institute in Ireland and based outside of the jurisdiction, that there will be no change to their status on the Irish audit register from January 2021. In the longer term, however, Brexit may impact on the number of UK-based firms on the Irish audit register as the audit regulatory requirements in Ireland and the UK continue to diverge over time.   Audit firms who are registered in Ireland but do not have any Irish audit clients may find that the burden of complying with distinctly Irish regulatory requirements is no longer worthwhile and may choose to cease their Irish audit registration.

Related matters regarding Irish audit registration

While not of direct relevance to Institute members and audit firms, it is worth mentioning that Irish company law provides a mechanism for approval of third-country auditors in Ireland.  From 1 January 2021 auditors based in the UK who are not members of the Institute or another Recognised Accountancy Body will have to avail of this mechanism if they want to be eligible to audit Irish entities.

The Companies Act 2014 in Ireland provides for the approval of third-country auditors as Irish statutory auditors where certain criteria are met.  These criteria include the existence of reciprocal arrangements regarding auditor approval between Ireland and the third country concerned, as well as the completion of an aptitude test by the third-country auditor.  The Companies Act 2014 also allows for exemption from that aptitude test to be granted in certain circumstances.  We understand that IAASA and the Financial Reporting Council (“FRC”) in the UK are working on developing reciprocal arrangements which would support the operation of a regime in Ireland for approving third-country auditors from the UK.   The Institute currently administers an aptitude test for third-country auditors and is engaging with IAASA in relation to guidelines for granting exemptions from the aptitude test.

UK audit registration – after the Brexit transition period

After 31 December 2020, audit registration in the UK will continue without interruption for individual statutory auditors (responsible individuals) registered by Chartered Accountants Ireland given the status of the Institute as a Recognised Supervisory Body (‘RSB’) in the UK, regardless of whether the responsible individual is based in the UK or Ireland. 

There will be no change to the UK audit registration of the majority of audit firms registered in the UK by Chartered Accountants Ireland regardless of whether the audit firm is based in Ireland or in the UK.  Audit firms currently registered in the UK by the Institute can retain UK audit registration after 31 December 2020 if the UK firm ownership rules are met.  The ownership rules for a UK-registered audit firm after 31 December 2020 will require that the majority of the voting rights on the ownership body and management body of the firm are held by:

  • Individuals holding an audit qualification from a UK RSB (including Chartered Accountants Ireland)
  • Audit firms approved by a UK RSB (including Chartered Accountants Ireland)
  • Individuals who hold EEA qualifications, who have passed or applied to sit a relevant aptitude test by 31 December 2020.

The change in the ownership rules impacts firms who count EEA qualified auditors (who are not qualified by a UK RSB) and EEA audit firms in their majority of qualified owners and managers.  From 1 January 2021 the qualified majority of owners and managers can only include EEA auditors (who are not qualified by a UK RSB) if the EEA auditors have applied for, or passed, a relevant aptitude test before 31 December 2020. This change may affect a small number of firms.