Why is this important?
Independence, objectivity and professional scepticism
are at the heart of the credibility of, and public trust in,
the audit profession and the statutory audit. We
wholeheartedly believe the statutory auditor should
continually be looking at ways to improve
independence safeguards and rules to increase market
confidence in the quality of audits, companies’ financial
reporting and trust in the statutory auditor.
Regulators, supervisory authorities and legislators are
considering ways to enhance the independence,
objectivity and professional scepticism of auditors and
to address market concerns of over-familiarity between
the auditor and management. The financial crisis
raised particular concerns about the robustness and
quality of the audits of the banks.
Some legislators and regulators have proposed or
introduced mandatory audit firm rotation as a solution.
Certain stakeholders contend that more proscriptive
requirements regarding mandatory audit firm rotation
should be adopted more widely specifically for banks
because of their importance to the capital markets.
Others suggest it for all financial institutions.
Why not mandatory audit firm rotation?
Mandatory audit firm rotation is not an appropriate or
proportionate solution as it puts audit quality at
significant and unnecessary risk without addressing the
issues, because:
It does not improve independence – it threatens it
by reducing choice and competition, reducing the
role and responsibilities of the audit committee,
and making achieving independence more complex
and complicated. The latter increases the risk of
breaches occurring and subsequent risks to the
integrity of the audit and capital market confidence
• It does not improve the auditor’s objectivity and
scepticism – to be truly objective the auditor has to
have sufficient knowledge of the company’s
activities and approaches and confidence in the
security of their relationship with the audit
committee and management to effectively
challenge decisions and argue judgements
• It does not address over-familiarity between
management and the auditor – this argument is
flawed. It is based on two assumptions: that long
tenure equates to increased over-familiarity
resulting in a lower quality audit; and that the
threat of the loss of a client incentivises the auditor
to perform better. Neither have been proven
• It does not improve audit quality – too frequent
change can undermine the quality of the audit and
ultimately its value to the capital markets by
reducing the auditor’s:
o Knowledge of the company, its processes and
risks, increasing the risks of failure to detect
misapplication of policies and processes by
management, whether accidental or deliberate
o Incentive to invest in improvements to the
audit process and in its skills and expertise
Why more proscriptive rotation requirements
would have more adverse consequences for
financial institutions in the EU?
We believe for larger, more complex companies, and in
particular for financial institutions, that the adverse
impact of more proscriptive requirements regarding
mandatory audit firm rotation, and in particular
substantially shorter periods, is likely to be the most
severe, bringing even greater risks. Such measures:
Go against the principle of ‘good regulation’
Banks and financial services companies are already
subject to a range of additional regulatory
requirements to enhance reporting and oversight,
including new measures currently being introduced and
considered. This includes ‘Basel III & the Fourth Capital
Requirements Directive’ (CRDIV), the ‘Dodd Frank Act’,
and the potential structural ring-fencing of certain
wholesale and retail services, and more are anticipated.
We believe these measures need time to become
embedded and for supervisors and regulators to
evaluate their effectiveness before more are
introduced. This would avoid further unsettling of the
capital markets, undermining any benefits secured, and
unnecessarily distracting the bank’s operational and
risk management, its financial reporting leadership and
those charged with governance.
Undermine audit quality in systemically important
entities, with risks outweighing any perceived benefits
Unnecessary additional administrative burden and
complexity - particularly the larger financial institutions
tend to engage one accounting network that has