FEE responds to IESBA's proposed revisions to the structure of the Code – Phase 1

18 April 2016

FEE submitted its comments on the IESBA ED: Improving the Structure of the Code of Ethics for Professional Accountants – Phase 1 proposing amendments to the IESBA Code of Ethics for Professional Accountants.

In its general comments, FEE states that it would like to assess Phase 2 of this project, as well as the outcome of the other EDs currently under consultation, before expressing any final opinion on the overall impact of the proposed changes to the Code. IESBA’s initiative on restructuring the Code is welcomed by FEE, as this is key to the objective of enhancing its understandability and usability and therefore contributing to wide spread application by professional accountants.

Below are some of the key views expressed in the letter:

• The title is misleading as the intention is not to develop standards for all parts of the Code. Mixing the terms “Code” and “Standards” in the title is not the right approach. 
• It is important to distinguish between the fundamental principles and those principles that may result in standards. Standards can be derived from such fundamental principles.
• Without losing sight of the importance of enforceability, the main concern of the Code should remain to address the mind-set and behaviour of the professional accountant instead of promoting mere compliance with a set of provisions. 
• FEE favours a ‘building block’ or a ‘layered’ approach that could be easily scalable – a core block for all professional accountants (including small- and medium-sized practices that do not deal with Public Interest Entities) and complementing blocks dealing with specific activities or circumstances.
• Regarding the allocation of responsibilities between firms and individuals, the existing link between the Code, ISQC 1 and ISAs should be maintained. 

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