Professional Standards have published Issue 41 of the Regulatory Bulletin. Please click on the link provided to access this publication.

The Institute has revised its Air Travel Organisers Licence (ATOL) Reporting Regulations with effect from 15 June 2025.  The revisions at this time are conforming amendments to align with the Institute’s suite of Regulations generally.  In particular, the ATOL Reporting Regulations are revised to reflect a simplification of the Institute’s affiliate regime across all Institute Regulations.  The simplification of the affiliate regime includes the following: A single category of ‘affiliate’ is now being used across all Institute Regulations.  Therefore, the revised ATOL Reporting Regulations refer to ‘affiliates’ where appropriate rather than ‘ATOL Registered Firm affiliate’. Across all Institute Regulations, it is a requirement that each principal at a firm regulated by the Institute should be either a member of the Institute or an affiliate - there is no longer an exemption from affiliate status for members of other professional accountancy bodies for example.  Therefore, the ATOL Reporting Regulations require each principal at an ATOL Registered Firm to be either a member of the Institute or an affiliate of the Institute. The obligations of all affiliates are be set out in a single place in Institute Regulations – that is chapter 7 of the Public Practice Regulations .  Therefore chapter 4 of the Institute’s ATOL Reporting Regulations is simplified as regards affiliate requirements and reference is made instead to the Public Practice Regulations. Institute firms can direct any queries in relation to the Institute’s Air Travel Organisers Licence (ATOL) Reporting Regulations to professionalstandards@charteredaccountants.ie.

The Institute’s UK Audit Regulations have been revised with effect from 1 June 2025.  The revision introduces a requirement for a sole practitioner firm with UK audit registration to put in place alternate arrangements.   Such arrangements enable a person/firm appointed as alternate to step in promptly where a sole practitioner is incapacitated by illness or other major event that would disrupt and disadvantage the service to their clients. The appointed alternate can be a member of any UK Recognised Supervisory Body (RSB) including the Institute and does not have to be a registered auditor.    In April 2022 the Institute’s Audit Regulations for Ireland introduced the requirement for sole practitioner audit firms in Ireland to put in place alternate arrangements.   Therefore, sole practitioner audit firms with audit registration in both Ireland and the UK should already be compliant with this mandatory alternate requirement now in the UK Audit Regulations. A transitional period of six month is allowed before the obligation becomes compulsory in the UK context. FAQs for Sole Practitioner Auditors (alternate arrangements) are available on the Institute’s website.

Is your audit firm compliant with the UK Audit Regulations provisions impacting eligibility for UK audit registration? Firms holding UK audit registration are reminded of the requirement to comply with certain provisions of the UK Audit Regulations by 1 April 2025.   These are important provisions relevant to a firm’s eligibility for UK audit registration.  As previously notified to firms, the UK Audit Regulations published in October 2024, include updates to improve alignment with the UK Companies Act 2006 and the FRC Eligibility Criteria.  The definitions of ‘majority’ and ‘voting rights’ for the purposes of determining the control of an audit firm were clarified, and related guidance expanded.  Audit firms with UK registration may be affected where a ‘super-majority’ (more than 50%) is required for certain decisions of the firm to take effect.  To summarise, decisions on all matters that direct the overall policy of the firm or alter its constitution need to be controlled by qualified persons.  If your firm has matters in its constitution that specify a higher than simple majority (50%), then qualified persons must hold the specified ‘super-majority’ (more than 50%).  In addition, if your firm is a limited company, it must also ensure that specific matters that require special resolution approval under company legislation (i.e., by a majority of not less than 75%) are controlled by qualified persons.  These matters will typically affect the firm’s constitution e.g. change of company name, amending the Articles of Association/Constitution, winding up of the firm, reduction in share capital etc.  As such, firms that are limited companies will need to ensure they have sufficient qualified persons to approve any decisions that require a special resolution to be passed.  A limited company firm may be able to include provisions in its Articles of Association/Constitution to deprive a certain class/type of shareholders of the right to vote in certain circumstances.  The Institute advises limited company firms, with audit registration in the UK, to obtain legal advice on whether changes are needed to their Articles of Association/Constitution to ensure qualified persons hold a majority of voting rights. The UK Audit Regulations are issued jointly by Chartered Accountants Ireland, the Institute of Chartered Accountants in England and Wales (ICAEW) and the Institute of Chartered Accountants of Scotland (ICAS).  While the UK Audit Regulations were revised with effect from 1 October 2024, a transition period of 6 months was incorporated so that these particular rules take effect from 1 April 2025.  This transition period allowed a period of time for firms to effect necessary governance changes.  Firms are reminded of the requirement to inform the Institute promptly in relation to changes to the firm’s structure, ownership or constitution in accordance with Audit Regulation 2.11. ICAEW has published some useful FAQs in relation to the UK Audit Regulations and eligibility criteria.     The FRC issued a position paper in this regard in August 2024.   The Firms with any questions about the application of these revised definitions to their firm should contact the Institute at authorisations@charteredaccountants.ie.

In recent months the Institute has approved certain Institute Registered Auditors (audit firms), and responsible individuals (RIs) at those firms, to carry out sustainability assurance engagements in Ireland, pursuant to the EU Corporate Sustainability Reporting Directive (CSRD) as transposed into Irish law.  These are referred to as ‘approved firms’ and sustainability assurance service providers (SASPs) respectively.   The recent Omnibus proposals from the EU Commission have created uncertainty over the scope of the CSRD going forward.  Audit firms should be alert to these emerging developments when considering whether and/or when to seek approval to carry out sustainability assurance engagements.  Transitional (‘grandfathering’) arrangements for SASP approval The EU Omnibus package does not include proposals to directly change the transitional (‘grandfathering’) arrangements for SASP approval. Therefore, it remains the case that an individual approved as a RI in Ireland before 1 January 2026 can avail of transitional arrangements when applying for approval as a SASP.   Under those transitional arrangements a RI is eligible for SASP status if he/she undertakes a minimum of 60 hours of CPD in the relevant subjects.   Note that a RI who is approved as RI in Ireland before 1 January 2026 does not have to apply for SASP status before 1 January 2026 to be eligible to avail of the transitional arrangements described above.  A person approved as RI on/after 1 January 2026 who applies for SASP status will be required, by law, to complete an examination and 8 months relevant practical experience to gain the sustainability assurance qualification. Eligibility for approval to carry out sustainability assurance engagements The eligibility criteria for SASP and firm approval are set out in the Institute’s Audit Regulations (incorporating assurance under CSRD) and Guidance, Ireland (the Audit Regulations).   The Institute has prepared FAQs to provide information for audit firms and RIs considering applying for approval to carry out sustainability assurance engagements. For audit firms who do wish to apply for approval at this time, the audit compliance principal can start the application process by contacting sasp-applications@charteredaccountants.ie to request the relevant application forms.    When an audit firm first applies for approval to carry out sustainability assurance engagements at least one RI at the firm must also submit an application for approval as a SASP. Ongoing obligations of approved firms and SASPs Once approved to carry out sustainability assurance engagements, an approved firm and SASP have ongoing obligations in relation to SASP CPD, compliance with relevant provisions of the Audit Regulations and annual regulatory fees relating to sustainability assurance approved status.  Regulatory Fees It is necessary for the Institute to collect regulatory fees to fund the Institute’s work in providing a robust regulatory framework for approved firms and SASPs.  Each application for SASP status is subject to an approval fee.  From 2026, ongoing annual regulatory fees will also be payable by approved firms. Applications for RI status in 2025 An applicant for SASP status must be a RI in Ireland.  As outlined above, an applicant who is approved as RI before 1 January 2026 can avail of transitional arrangements when applying for SASP status (even where that SASP application is made at a date after 1 January 2026).  If an audit firm wishes to designate new RI(s) during 2025 with the intention of ensuring that the RI status of that person is approved by the Institute before 1 January 2026, the firm is advised to submit application(s) for RI status to the Institute as soon as possible, and at the latest by   1 August 2025.    Early application allows time, in most cases, for assessment of the application by the Institute, including where necessary, consideration by the Quality Assurance Committee, before the end of 2025. The Professional Standards Department cannot provide guaranteed timelines for consideration and approval of RI applications as time required depends on the nature of the application.  Complex or incomplete applications for RI status may take longer to process than well-presented, detailed applications which clearly demonstrate an applicant’s competence and experience.  While the transitional arrangements for SASP status may encourage some firms to consider appointing more RIs during 2025 than might otherwise have been intended by the firm, firms are reminded that only appropriately qualified and experienced individuals can be granted RI status in accordance with the Institute’s Audit Regulations. Application forms for RI status are available on the Institute’s website.  Queries regarding RI applications can be directed to authorisations@charteredaccountants.ie.

If your firm wishes to file information at Companies House on behalf of clients or if you plan to verify the identity of certain individuals, you will need to register to be an Authorised Corporate Service Provider. Click here for more information. 

HMRC has become aware of a scam email purporting to come from HMRC asking firms to submit an Annual Supervisory Return with payment of fees as part of their AML supervision. This email is being sent to both HMRC supervised firms and accountancy service providers supervised by the professional bodies. Although the content of the fraudulent email looks very similar to the official gov.uk website it appears to be sent from a false email address ending on @taxuk-access.services. Should you receive a fraudulent email purporting to be from HMRC, please do not click on the links and report this via https://www.gov.uk/government/organisations/hm-revenue-customs/contact/reporting-fraudulent-emails

If your firm wishes to file information at Companies House on behalf of clients or if you plan to verify the identity of certain individuals, you will need to register to be an Authorised Corporate Service Provider. Please see the linked document for more information.

Recent trends The Institute’s Professional Standards Department has recently seen an increase in the frequency and complexity of proposed restructures of accounting and audit firms including: Institute firms acquiring or merging with other accounting and audit firms; Changes in a firm’s principals (retirements, additions); Creation of new firms within a firm network structure (including the splitting of an existing firm into a number of smaller firms sometimes with a focus on a particular business line or jurisdiction); Interests in a firm being fully or partially acquired by larger firms or other external investors including the involvement of private equity investors in firm/network ownership structures. These trends are observed in both Ireland and the UK. Early engagement with the Institute advised Firms who are considering a change in the firm’s structure or ownership are advised to engage with the Institute’s Professional Standards Department at an early stage in the process.  Such early engagement is important to ensure that any impact on existing or proposed firm authorisations, and/or on the AML supervision of any entities in the structure, is fully understood and properly planned for.  Law and Institute Regulations in both Ireland and the UK set out detailed eligibility criteria which must be met by firms authorised in reserved areas such as audit and investment business.  These eligibility criteria include specific requirements regarding the qualifications of principals and those having ownership/control at authorised firms.  While Institute Regulations require firms to notify the Institute promptly after a change in circumstance which could impact authorisations takes place, firms will benefit from early engagement with the Institute in relation to proposed restructuring transactions.  Firms will, no doubt, want to avoid a situation where a significant transaction concerning the firm’s structure has taken place only to discover that the revised structure negatively impacts the firm’s eligibility for authorisation in a key area. Firms considering a restructure should contact the Institute at authorisations@charteredaccountants.ie.  The Institute will advise the firm regarding the information which should be shared with the Institute initially and as the restructuring plans progress.  The Institute will request information to enable a full understanding of the proposed restructure and the impact on the firm’s eligibility for authorisation(s).  Such information is likely to include the detailed agreements and documentation underlying a transaction such as revised partnership agreements, constitutional documents such as articles of association and where relevant, service level agreements between entities within the revised structure. Frequently, the complexity of restructuring transactions requires that the Institute dedicates significant time to review the relevant documentation, engage with the firm’s principals and conclude in relation to ongoing or new authorisations as a result of a firm restructure.  A firm’s engagement with the Institute early in the restructuring process helps ensure sufficient time for Institute consideration and for the processing of any new applications for individual or firm authorisations arising. The Institute cannot provide legal advice in relation to potential firm structures.  The Institute assesses information provided to conclude whether the Institute can continue to provide authorisations to the restructured firm(s) in reserved areas in accordance with the Institute’s Regulations. Oversight bodies In certain cases, it may also be appropriate for a firm and/or the Institute to engage with relevant oversight bodies such as IAASA or the FRC.  For example, an audit firm which is registered with the FRC as a UK public interest entity (PIE) auditor will be obliged to share information with the FRC in relation to a transaction which could impact UK audit registration. Fees For new notifications of restructuring arrangements received on or after 1 January 2025, the Institute may charge a separate fee to firms for the consideration of the impact of a firm restructure on a firm’s authorisations in reserved areas and/or on AML supervision where relevant.  The fee will be dependent on the complexity of the proposed restructure and the work involved in the Institute’s assessment of all relevant information.  This fee will contribute to the cost incurred by the Institute in the consideration of the proposed restructure and may include a contribution towards any legal advice which the Institute needs to undertake in this regard. Further information Any queries in relation to any of the matters raised above can be directed by email to authorisations@charteredaccountants.ie

The Institute has revised the Public Practice Regulations with effect from 1 January 2025.  The key change (Regulation 6.19) relates to professional indemnity insurance (PII) requirements at firms authorised for investment business activities in Ireland.  Polices of PII taken out or renewed on or after 1 January 2025, by an authorised investment business firm whose investment business activities extend beyond referral only business,  must, at a minimum, provide cover for €1,564,610 (up from €1,300,380) per claim and €2,315,610 (up from €1,924,560) in aggregate.  This cover should be ring fenced in respect of the firms’ investment business activities.    This change arises from a recent revision by the Central Bank of Ireland of the Conditions and Requirements attached to the Institute’s recognition as an Approved Professional Body (APB).  The Professional Standards Department has recently written in this regard to investment business compliance principals at firms authorised by the Institute to carry out investment business in Ireland. Given the increase in PII requirements for firms generally from 1 September 2024 (PPRs revised effective 1 September 2024) this is not expected to have a significant impact on firms approved by the Institute for investment business in Ireland.    However, investment business firms are advised to discuss this requirement with the firm's PII provider to ensure compliance. Other revisions to the Public Practice Regulations can be summarised as follows: Practising certificate cessation: The list of circumstances in which a practising certificate (PC) will cease is amended to include where membership ceases under Institute Bye-Laws or other Institute Regulations (Regulation 5.5(c)) – this is consistent with other existing Institute Regulations. Practising certificate eligibility: Introduction of a provision for the Quality Assurance Committee (QAC) to require a PC applicant who is a reciprocal member to successfully complete an aptitude test where appropriate. (Regulation 5.10A). Disciplinary arrangements and affiliates: Clarification that a matter relating to an affiliate may be referred to another professional body, where appropriate, when an affiliate is subject to regulation by another professional body (Regulations 7.12 and 7.13) Sustainability assurance engagements:  Revision of definitions of 'reserved areas' and 'accountancy services' to include sustainability assurance work pursuant to CA 2014.  Therefore, consistent with the Audit Regulations (incorporating assurance under CSRD), effective 11 October 2024, a member who is a sustainability assurance service provider (SASP) is required to hold a practising certificate. Change to insolvency regulation: Revisions to reflect cessation of Institute’s role as a Recognised Professional Body (RPB) for the regulation of insolvency in the UK with effect from 1 January 2025. (Definitions: ‘insolvency practitioner’, ‘Insolvency Licensing Regulations and Guidance’, ‘Regulatory Committee’, Regulations 6.2 and 6.5(a)) Note the cessation of the Institute’s non-statutory insolvency practising certificate regime for Ireland was reflected in the Public Practice Regulations effective 1 September 2024. Miscellaneous:  The opportunity has also been taken at this time to make some minor editorial amendments. The Public Practice Regulations, effective 1 January 2025 are available on the Institute’s website.  Previous versions of the Public Practice Regulations remain available to read on the Archive page of the Institute’s website. Any member queries in relation to the revised Public Practice Regulations can be directed to professionalstandards@charteredaccountants.ie.

The Institute has revised the CPD Regulations with effect from 1 January 2025.  CPD Regulation 4.6 now specifically mentions 'sustainability assurance' as a subject area in which a member who is working in practice should undertake CPD if that member is involved in work of this nature.   This is an explicit application of the core principle that a member should undertake whatever CPD is necessary to ensure that he/she is competent for the work in which he/she is engaged.   Separate from this requirement, any individual who is approved by the Institute as a Sustainability Assurance Service Provider (SASP) should comply with CPD requirements for SASPs as set out in the Institute’s Audit Regulations (incorporating assurance under CSRD), effective 11.10.24.  The CPD Regulations, effective 1 January 2025 are available on the Institute’s website.  Previous versions of the CPD Regulations remain available to read on the Archive page of the Institute’s website. Any member queries in relation to the revised CPD Regulations can be directed to professionalstandards@charteredaccountants.ie.

UK  Recent communications with Insolvency Practitioners (IPs) authorised to take insolvency appointments in the UK have been advised of Council’s decision to revoke its status as a Recognised Professional Body (RPB) in the UK. This means that Chartered Accountants Ireland will not be authorising insolvency practitioners in the UK from 1st January 2025. The Professional Standards department has been communicating with these IPs to assist in the application process and to ensure a smooth transfer to an alternative RPB.   Ireland   In addition to UK insolvency regulation, Council has also decided to cease the proactive monitoring of members providing insolvency services in Ireland. Members will no longer be required to hold an Insolvency Practising Certificate (IPC) to take insolvency appointments in Ireland. To reflect the above policy change regarding IPCs, appropriate amendments have been made to the Institute’s Public Practice Regulations. Insolvency services will be included within the general definition of ‘accountancy services’ (therefore requiring the holding of a general ‘Practising Certificate’). This means that the Institute may review insolvency-related work of individual members at its discretion. These changes remain consistent with the provisions of section 633 of the Companies Act, 2014 which requires liquidators to hold a current practising certificate issued by a Prescribed Accountancy Body or specified other bodies. It is also consistent with the approach to insolvency regulation applied by other Prescribed Accountancy Bodies.

A revised IGP approved by JIC and each of the Recognised Professional Bodies (RPBs) relating to the control of cases has been issued by each of the RPBs. Introduction of the revised Insolvency Guidance Paper – Control of Cases

Professional Standards Department is pleased to publish its AML Supervision Report 2023/24. This Report summarises our AML supervisory activities in both jurisdictions, ROI and UK for the period April 2023 – April 2024.

The Institute has published the Audit Regulations (incorporating assurance under CSRD) and Guidance, Ireland with effect from 11 October.   These regulations replace the existing Audit Regulations for Ireland and introduce the Institute’s regulatory framework for the authorisation and oversight of firms and individuals undertaking sustainability assurance engagements pursuant to Part 28 of the Companies Act 2014 (which reflects the EU’s Corporate Sustainability Reporting Directive (CSRD)). In Ireland only statutory auditors and statutory audit firms can undertake sustainability assurance engagements.  The regulatory regime builds on the existing regulatory regime for statutory auditors and audit firms and this is reflected in the Institute’s revised Audit Regulations (incorporating assurance under CSRD).  The Audit Regulations (incorporating assurance under CSRD) provide for the authorisation, quality assurance and regulatory enforcement of firms and individuals carrying out sustainability assurance engagements and sets out the ongoing regulatory obligations of those firms and individuals. Applications for approval to carry out sustainability assurance engagements The Institute is accepting applications from Institute firms and responsible individuals (RIs) registered for audit in Ireland for approval to carry out sustainability assurance engagements.  Given the urgency of providing authorisation for eligible firms and RIs who have clients reporting under the CSRD in respect of financial year 2024 the Institute will prioritise applications from audit firms and RIs who have clients in this ‘first wave’ of sustainability reporting.  Application forms are available from sasp-applications@charteredaccountants.ie.  The Institute FAQs regarding approval to carry out sustainability assurance engagements provide useful information for potential applicants. Eligibility for approval to carry out sustainability assurance engagements: An Irish registered audit firm is eligible for approval to carry out sustainability assurance engagements if the firm has at least one RI who has been approved as a sustainability assurance service provider (SASP).  An individual approved as RI in Ireland before 1 January 2026 can avail of transitional arrangements and therefore is eligible for approval as a SASP if that RI has demonstrated competence in sustainability assurance by undertaking the appropriate relevant CPD.  A detailed CPD template is submitted by the RI on application for SASP status.   An individual approved as RI in Ireland on or after 1 January 2026 will not be able to avail of those transitional arrangements and will have to undertake a programme of education, including examination, and 8 months of practical training in relevant work. Background note: The CRSD was transposed into Irish law in July 2024 by SI 336 of 2024 which amended the Companies Act 2014.  New Part 28 of the Companies Act 2014 requires certain companies to prepare sustainability reports disclosing information about the company’s environmental, social and governance (ESG) activities in line with the European Sustainability Reporting Standards (ESRSs).  It also requires third party assurance (limited assurance initially) on these ESG disclosures and provides for a regulatory regime for the education, training, authorisation and oversight of sustainability assurance providers.   In Ireland only statutory auditors and statutory audit firms can undertake sustainability assurance engagements. 

The Institute has revised the Audit Regulations UK which set out the requirements for Institute firms and responsible individuals registered for audit in the UK, with effective date 1 October 2024.  The most important revision for UK audit firms relates to audit firm eligibility.  Audit firm eligibility – majority and voting rights The Audit Regulations, UK are updated to improve alignment with the UK Companies Act 2006 and the FRC Eligibility Criteria. The definitions of ‘majority’ and ‘voting rights’ for the purposes of determining the control of an audit firm have been clarified, and the guidance has been expanded.  Firms may be affected where a ‘super-majority’ (more than 50%) is required for certain decisions of the firm to take effect – in those cases firms will need to ensure that the relevant ‘super-majority’ of voting rights is held by appropriately qualified persons where those decisions direct the overall policy of the firm or alter its constitution.  The FRC issued a position paper in this regard in August 2024.     As some firms may need a period of time to effect necessary governance changes a transition period of 6 months has been incorporated so that these particular rules take effect from 1 April 2025.  Firms are reminded of the requirement to inform the Institute promptly in relation to changes to the firm’s structure, ownership or constitution in accordance with Audit Regulation 2.11.   The Audit Regulations UK are issued jointly by Chartered Accountants Ireland, the Institute of Chartered Accountants in England and Wales (ICAEW) and the Institute of Chartered Accountants of Scotland (ICAS).  ICAEW has published some useful FAQs in relation to the Audit Regulations UK and clarified eligibility criteria. Firms with any questions about the application of these revised definitions to their firm should contact the Institute at authorisations@charteredaccountants.ie Other changes to the Audit Regulations UK (all effective from 1 October 2024) include: Recognition of overseas audit qualifications Revisions have been made to reflect the provisions of the Professional Qualifications Act 2022 for the steps which professional bodies, including the Institute, have to take to recognise third country qualifications where there was agreement between the UK and the relevant third country.  These steps include requiring an adaptation period and/or aptitude test.  To date, Norway, Iceland and Liechtenstein are specified states under the Professional Qualifications Act.  The Professional Qualifications Act provisions are in addition to the role of the Financial Reporting Council (FRC) under section 1221 of the Companies Act 2006 to recognise certain third country qualifications.  The countries where the qualification has been approved in that regard by the FRC are set out on the FRC website on this link. Changes to the Audit Regulations UK in this regard include: ·new definition ‘adaptation period’, ·new definition ‘Professional Qualifications Act’, updated definition of ‘appropriate qualification’, and, updated guidance in chapter 4 regarding applications for responsible individual (RI) status. Changes to the Institute’s affiliate requirements: The Institute has made changes to its approach to affiliates such that there is a single affiliate status across all Institute regulations replacing multiple categories of affiliate.  Therefore, distinct categories such as ‘audit affiliate’ are replaced by ‘affiliate’ and this is reflected in the revised Audit Regulations, UK.  The requirements for Institute affiliates are set out in chapter 7 of the Institute’s Public Practice Regulations.    There is no longer any exemption from affiliate status for members of particular bodies – the overall requirement is that a principal at an Institute firm who is not a member of the Institute should be an affiliate of the Institute.  From the perspective of the Audit Regulations UK this means that the current exemption from affiliate requirements for ICAEW, ICAS and ACCA members who are principals at an Institute registered audit firm is removed. CPD obligations Additional material has been added at regulations 3.17 and 3.17A to clarify the obligations of UK audit firms and responsible individuals (RIs) in relation to CPD requirements – now more closely aligned with the Audit Regulations, Ireland. Guidance ISQM 1   At chapter 3 of the Audit Regulations UK, guidance in relation to quality management standards has been updated to reflect ISQM 1 instead of the previous standard, ISQC 1.  Also, the somewhat out of date guidance (Part 2, chapter 2) in relation to ‘Audit compliance reviews’ (ACR) has been removed.  It is considered that the relevant content is sufficiently contained within the ISQM 1 standard.   Amalgamation with CPA Ireland   A new paragraph has been added to guidance at regulations 2.03, 4.01 and 4.04 to draw attention to the amalgamation between the Institute and CPA Ireland on 1 September 2024 and the status of CPA qualifications in the UK (which is unchanged by the amalgamation). Future proposed changes to the Audit Regulations UK. In recent months, the attention of members was drawn to further proposed changes to the Audit Regulations UK as set out in a public consultation hosted by ICAEW.   That consultation (closed on 6 September) proposes to make changes to the UK Audit Regulations which would require UK audit registered firms to notify their registering body when they are appointed as auditors to certain entities. The consultation is available to read here.   Feedback received during the consultation period will be taken into consideration in the finalisation of next amendments to the Audit Regulations UK which are expected during 2025. Any queries in relation to the current or proposed revisions to the Audit Regulations UK can be directed to professionalstandards@charteredaccountants.ie

The Institute’s affiliate regime has been simplified to reduce the compliance burden for firms.   From 1 September a single status of ‘affiliate’ replaces the previous multiple categories of ‘audit affiliate’, ‘investment business affiliate’, ‘general affiliate’, ‘AML affiliate’ and ‘insolvency affiliate’.    Previously an individual might hold affiliate status in more than one category but effectively have the same obligations under each category.   Furthermore, the rules regarding which principals at a firm should become affiliates have been streamlined and the overall requirement is that a principal at an Institute firm who is not a member of the Institute should be an affiliate of the Institute.  Therefore, there is no exemption from affiliate status for members of particular bodies.  This is consistent with the approach taken from January 2024 with the introduction of the affiliate requirement for all principals at Institute AML supervised firms who are not Institute members.   As a consequence of the latter, principals at a number of Institute firms have been granted affiliate status (AML affiliate status) since 1 July 2024 and therefore will not be affected by this change in the approach.  The Institute does not anticipate any notable increase in affiliate numbers overall as a result of the current streamlining.  The recent revisions to Institute regulations (1 September 2024) give effect to this simplification of affiliate provisions.    The requirements for affiliates are now set out in a single chapter in the revised Public Practice Regulations rather than across a range of Institute regulations.   Other Institute regulations now refer affiliates to the Public Practice Regulations as appropriate.  For example, a person required to become an affiliate in accordance with the revised Audit Regulations is directed to the provisions of chapter 7 of the Public Practice Regulations as regards application for affiliate status, the ongoing regulatory obligations of affiliates and liability to regulatory and disciplinary action where appropriate.   Institute affiliates: Are not entitled to describe themselves as Chartered Accountant Agree to be bound by the Charter, the Principal Bye-Laws, the Disciplinary Bye-Laws and other any other rules, regulations, codes and standards of the Institute; Are required to observe and uphold the Institute’s Code of Ethics Are subject to the Institute disciplinary arrangements where appropriate. The rules regarding affiliates at firms approved to carry out investment business activities in the UK under the Designated Professional Body Handbook are unchanged. Institute firms and compliance principals can direct any queries in relation to the revised affiliate regime to professionalstandards@charteredaccountants.ie.

Recent amendments to the Institute’s CPD Regulations have facilitated simplification of how members confirm compliance with CPD requirements and the Institute’s Code of Ethics[1]. Henceforth, by paying the annual membership subscription, or permitting this to be paid on their behalf, or otherwise renewing their membership, members are automatically acknowledging CPD compliance and awareness of Code of Ethics obligations. As a consequence, members generally will no longer have to submit an annual declaration (the Individual Annual Return) in respect of these matters.  Further information on the Institute’s CPD requirements is on the CPD Support & Guidance webpage.  Documents on this page also sets out circumstances in which members may apply for an exemption from CPD requirements; there are no changes in this regard.   Members who have exemptions in this regard are considered to be compliant with the Institute’s CPD Regulations as they are availing of a waiver in accordance with the CPD Regulations. Similarly, there is no change to the Institute’s current approach to substantive testing of CPD compliance whereby a sample of member CPD records is selected for review on an annual basis.  Responsible Individuals (statutory auditors) in audit firms registered by the Institute remain subject to a separate CPD compliance regime based on company law and IAASA requirements. If anyone has any further queries in relation to the above, please contact us at professionalstandards@charteredaccountants.ie. [1] Additional requirements continue to apply to members holding Practising Certificates, and who are Responsible Individuals (statutory auditors).

Further to the notice in our most recent Regulatory Bulletin regarding proposed changes to the Institute’s Professional Indemnity Insurance (PII) requirements, these changes have now been approved by the Professional Standards Board and revised Public Practice Regulations will come into effect on 1 September 2024.  The revised Public Practice Regulations will be available on the Professional Standards website from 1 September 2024. Main changes The main changes to the PII requirements are as follows: The minimum limit of indemnity will increase from €2.14m (£1.5m) to €2.34m (£2m). For firms with a gross fee income which is below €936,000 (£800,000), the minimum limit will be two and a half times the firm’s gross fee income, subject to a minimum of €290,000 (£250,000) (this is an increase from €142,000 or £100,000). Larger firms with gross fee income over €58.5m (£50m) will not be required to put in place ‘qualifying insurance’ but must have in place appropriate arrangements which will be monitored. (Currently this approach is available to firms with 50+ principals.) For firms that will be required to put qualifying insurance in place, the maximum aggregate excess should not exceed the higher of €3,500 (£3,000) or 3% of a firm’s gross fee income. Firms insuring in a group arrangement can be treated as single entity for the purposes of the regulations providing that certain criteria are met.  Firms in the structure can: (a) demonstrate common ownership, control or management; and (b) can demonstrate that they are aimed at co-operation, and (c) meet at least one or more of the following criteria: ·        the firms within the structure are clearly aimed at profit or cost sharing; ·        the firms within the structure share common quality control policies and procedures; ·        the firms within the structure share a common business strategy; ·        the firms within the structure share the use of a common brand-name; ·        the firms within the structure share a significant part of professional resources. Firms continue to be required to have run off cover in place for the first two years after cessation.  Firms should then take “all reasonable steps” to put run off cover in place for a further four years. The existing additional PII requirements for firms licensed under the Designated Professional Body Handbook or authorised by the UK Financial Conduct Authority to conduct insurance distribution activities (extant Public Practice Regulation 7.18) and firms authorised under the Investment Business Regulations (excluding firms that perform referral only business) (extant Public Practice Regulation 7.18A) continue to apply and are unchanged at this time.  Firms within the scope of 7.18A can however expect increases to the prescribed limits for policies renewing on or after 1 January 2025.  Firms will receive further information on these changes in due course. Timeline There will be a transitional period and the new requirements relating to minimum limits and excess will only apply to new policies once a firm renews its PII after 1 September 2024.  These new requirements will therefore apply to all firms from 1 September 2025.  Preparing for the changes In view of the changes, it is more important than ever for firms to engage early with their broker to identify if any changes will need to be made to the policy at next renewal, work out the relevant level of cover needed going forward, as well as carrying out the usual risk assessment. Members or firms who have any queries in relation to these changes should email professionalstandards@charteredaccountants.ie

Both Irish and UK AML legislation requires firms to take the appropriate steps to identify and assess the risk that they could be used for money laundering and terrorist financing, and in the UK, also proliferation financing. The Accountancy AML Supervisors Group (AASG) in the UK has recently updated its Risk Outlook Guidance which identifies those circumstances where there might be a high risk of money laundering, terrorist financing or proliferation financing in the accountancy sector. (Although drafted pursuant to UK AML legislation, many of the risks are also relevant in Ireland.) This Guidance has been updated to include risks associated with the following: Complex supply chains Crypto Register of Overseas Entity verification Services subject to trade sanctions Proliferation financing Contractors or agency workers paid by umbrella companies

Under the Joint Insolvency Committee’s (JIC’s) strategic work plan, Insolvency Guidance Papers (IGPs) are subject to periodic review to ensure they remain relevant to changing legislation and market conditions.  In 2024 all the IGPs are being reviewed and this notice is to advise you of the changes that have been approved by the JIC to date. Withdrawal of IGPs “Bankruptcy – The Family Home” and “Retention of Title” Following such a review, the JIC is withdrawing the Insolvency Guidance Papers entitled “Bankruptcy – The Family Home” and “Retention of Title” with effect from 1 August 2024.  These Guidance Papers were introduced in October 2005 and November 2014 respectively, but the JIC feels that the appropriate approach to both topics is now so widely accepted that separate guidance papers are no longer required. Revised IGP “Succession Planning” A revised IGP related to succession planning has been issued today by each of the Recognised Professional Bodies (RPBs) following approval by the JIC and the RPBs.  Summary of Changes – "Succession Planning” IGP The “Succession Planning” IGP has remained in place since 2005 during which time the insolvency market and profession have significantly changed.  The principal revisions to the IGP emphasise the importance of contingency planning and documentation to ensure the continuity of case management in the event that an insolvency practitioner is unable to act for one or more reasons and in different contexts including retirement, incapacity, death, loss of licence and the sale of a practice.  The revised IGP covers a variety of scenarios including sole practitioners, firms generally and firms where there are no other insolvency practitioners.   The IGP includes new sections on putting succession agreements or arrangements in place and guidance for alternates and potential alternates.  The style and language used has also been modernised to make it clearer and easier to apply. Implementation – “Succession Planning” IGP The revised IGP is published on 25 July 2024 and comes into effect on 1 August 2024.