Auditing and Accountants’ Reports
Business accounts are subject to either an audit or an accountant’s report. The CIMA qualification does not include audit, and members therefore cannot perform an audit.
In most jurisdictions however, there are Government specified audit exemption criteria which enable a business (usually a small business) to avoid the expense of an audit and the time it takes.
If a business meets the criteria for exemption from audit, in any specific jurisdiction, a CIMA Member in Practice may be able to act as a reporting accountant for a client (also known as an independent accountant or independent examiner).
CIMA does not confirm or otherwise a Member’s ability to provide an accountant’s report as this is dependent upon the legislation for each country. We require our members to know and comply with the laws of the jurisdictions in which they work, and it is your responsibility as a member to check any audit exemption thresholds which may apply.
The laws addressing audit requirements (including exemption thresholds) are most likely to be found in a country’s Companies Act or equivalent. Actual thresholds may change from time to time and therefore may be embodied in subordinate regulations.
Some sectors have their own requirements on audit (for example in the UK this includes estate agencies and solicitors). The law covering these sectors may specify that any accountants report must be performed by an accountant that holds an audit qualification.
Audit exemption criteria, set in legislation, will enable a company to make a commercial decision about whether or not to have a statutory audit. Members should note that individual company requirements will be set by its management or board. For those business that are legally exempt from a statutory audit, many still opt to have one and this is their right. You, as a CIMA member may signpost a company towards the relevant legislation to help a company decide. You can use your CIMA membership to confirm your professionalism. The ultimate decision always rest with the business.
UK Audit Exemption criteria/thresholds:
EU Audit exemption thresholds
A quick reference point for Europe is Accountancy Europe which published a factsheet in 2016. https://www.accountancyeurope.eu/wp-content/uploads/1605_Audit_exemption_thresholds_update.pdf
This factsheet should be read alongside an update, published in October 2019 which provides information on any EU Member states that amended their thresholds after the 2016 guide was published.
Members based outside the UK and European Union
The laws addressing audit requirements (including exemption thresholds) are most likely to be found in a country’s Companies Act or equivalent. Actual thresholds may change from time to time and therefore may be embodied in subordinate regulations. It is your responsibility as a member to ensure that you are using up to date information.
The above guidance was updated March 2020
Signing off accounts as a MiP
Find information on four key areas:
Sector specific guidance around accounts and audit (UK)
References for business mortgage lenders
The current CIMA position is that if a company is exempt from needing an audit, then there is no reason why a CIMA member, acting as a reporting accountant should not provide a business mortgage reference.
Solicitors and client monies
If you are a CIMA MiP providing services for a solicitor that meets the criterion below you may wish to consider advising the solicitor make such an application.
The Solicitors Regulation Authority accounts rules state (under rule 34: qualifications for making a report) that the accountant must be a member of an accountancy body that does not include CIMA and must also be a registered auditor or a partner or employee of the registered auditor.
Under these rules it is therefore not normally possible for CIMA members to act as reporting accountants for solicitors holding client monies. Guidance note (ix) under rule 32.2 (pertaining to delivery of accountants' reports) states that: 'When only a small number of transactions is undertaken or a small volume of client money is handled in an accounting period, a waiver of the obligation to deliver a report may sometimes be granted. Applications should be made to the [SRA’s] information directorate'.
Reporting accountants to the ABTA
The Association of British Travel Agents (ABTA) requires its member travel agents to provide copies of their annual audited accounts (or equivalent). CIMA members may act as reporting accountants for ABTA members provided that they:
- Hold a current practising certificate
- Are independent of the member travel agent
Estate agent accounts involving clients' monies must be examined and reported on by a qualified auditor. This is under the provisions of:
This is the case even if the annual turnover of the business falls below the audit threshold. CIMA members are therefore unable to provide accountants' reports in such circumstances, even if they have been responsible for examining a client's accounts.
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Club and charity accounts
As a MiP, you can sign off club and charity accounts when the income is under £1 million, provided you use the term 'examiner' (do not represent yourself as the auditor).
Points to note:
- If the charity's rules state that an audit is required then it must be done by an auditor.
- If you receive no fee then you do not need to register as a member in practice. However, there are still risks in acting as an examiner, for which you could be held liable, so professional indemnity insurance may be wise.
Accounts for a charity with an income above £1 million
In the UK, the Charity Commission advice line explains that for charitable companies there are two sets of requirements - those of Companies House and those of the Charities Commission. These rules currently prevent MiPs examining the accounts of a charitable company with an income above £1 million.
However, tests of audit are not completely straightforward. Members are advised to refer to the Charity Commission guidelines, in particular publications CC31 and CC32.
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Can I become a registered auditor and regulated by another body without joining it?
As a MiP, you can become a member of another body, but all have exacting requirements of additional examinations and supervised training in an audit office for a number of years before audit recognition can be given.
CIMA members are allowed to signoff the accounts of companies with turnovers up to GBP5.6m as examiners (not auditors), but not beyond.
External audit is not covered by CIMA's qualification. Any member who wishes to move into this field can only do so by virtue of membership of another more appropriate body.
Please note that none of these bodies will simply reciprocate membership, and that qualification to perform audit usually involves several years' practical experience in an audit firm, as well as taking examinations.
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Client reference mortgage applications
MiPs cannot always sign client reference mortgage applications, as they are not registered auditors (as required by the Estate Agents Act 1979), and therefore some banks and building societies will not accept these applications.
The current procedure is to send a standard letter to the institution concerned, detailing why CIMA should be added to the list of recognised bodies that can sign these types of references to the bank/building society involved and attempt to make changes in this way.
If the request is rejected by the bank/building society, there is unfortunately nothing further CIMA can do immediately, but we may look into this area of regulation in the future.
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