financial auditor
DESCRIPTION
ÂTRANSCRIPT
GOVERNMENT OF ROMANIA Ministry of Education
European Union
GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
and Elderly MASOPHRD
European Social Fund SOP HRD 2007-2013
Structural Instruments 2007 - 2013
Project co financed by the European Social Fund
Sectoral Operational Programme Human Resources Development
2007 - 2013
Invest in people!
http://www.imipqnet.ro
1
Invest in people!
EUROPEAN SOCIAL FUND
Sectoral Operational Programme Human Resources Development 2007 - 2013
Priority Axis 3 "Increasing adaptability of workers and enterprises"
Key Area of Intervention 3.3 " Development of partnerships and encouraging initiatives for
social partners and civil society."
Project Title: “Network of Competent Authorities for Professional Qualifications in Romania
(IMI PQ NET Romania)"
Beneficiary: Ministry of National Education
Contract no. POSDRU/93/3.3/S/53132
GUIDE ON COMPETENCE CERTIFICATION AND QUALIFICATION RECOGNITION
FOR THE FINANCIAL AUDITOR PROFESSION
Author: Dr. Irina Dumitriu
July 2013
GOVERNMENT OF ROMANIA Ministry of Education
European Union
GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
and Elderly MASOPHRD
European Social Fund SOP HRD 2007-2013
Structural Instruments 2007 - 2013
Project co financed by the European Social Fund
Sectoral Operational Programme Human Resources Development
2007 - 2013
Invest in people!
http://www.imipqnet.ro
2
TABLE OF CONTENTS
INTRODUCTION..............……………………………………………...…………………….3
1. REGULATORY SITUATION IN ROMANIA AND OTHER EU MS OF THE
FINANCIAL AUDITOR PROFESSION………...…………………………………………....5
2. COMPETENCES CERTIFICATION PROCEDURES APPLIED BY THE CA IN THE
ANALYZED COUNTRIES.....................................................................................................18
3. RECOGNITION PROCESSES FOR QUALIFICATIONS ACQUIRED IN OTHER EU
MS IN ORDER TO PRACTICE THE FINANCIAL AUDITOR
PROFESSION...........................................................................................................................22
4. EXERCISE OF THE FINANCIAL AUDITOR PROFESSION IN THE EU......…...…….32
5. CONCLUSIONS.…………………………………………………………………………..37
BIBLIOGRAPHY…………………………………………………………………………….39
ABBREVIATIONS...………………………………………………………………………...41
USEFUL LINKS……………………………………………………………………………...44
GOVERNMENT OF ROMANIA Ministry of Education
European Union
GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
and Elderly MASOPHRD
European Social Fund SOP HRD 2007-2013
Structural Instruments 2007 - 2013
Project co financed by the European Social Fund
Sectoral Operational Programme Human Resources Development
2007 - 2013
Invest in people!
http://www.imipqnet.ro
3
INTRODUCTION
The Guidelines on competence certification and qualification recognition for the financial
auditor profession is one of the results of the “Network of Competent Authorities for
Professional Qualifications in Romania (IMI PQ NET Romania) Project” implemented by the
Ministry of National Education (MEN) in partnership with the National Qualifications
Authority (ANC) and the Institute for Social Policy (IPS), co-financed by the European Social
Fund through the Sectoral Operational Programme Human Resources Development 2007-
2013 (SOP HRD)
Within the IMI PQ NET Romania project there have been analyzed, together with the
competent authorities (CA) members of the project working group, the procedures for
validation and certification of competences and qualifications recognition processes for each
regulated profession separately and, on that basis, there have been developed standard scheme
for validation / certification of competences procedure and for the qualifications recognition
process for corresponding regulated professions. The final result of these activities is the
paper "Standard guiding terms of reference for the procedures validation and certification of
competences and qualifications recognition processes", which can be accessed
at…………………………………………………………
This paper includes the basic terminology (definitions of terms used also in the guidelines)
and standardization schemes for the certification of competences and qualifications
recognition processes and therefore it was the basis for the elaboration a number of 30
guidelines for certification and recognition for different regulated professions, guidelines
aimed at supporting CA from Romania in their efforts to standardize these procedures and
processes by informing them about the practices of counterparts CA from other Member
States (MS) of the EU.
However, each individual guideline will address individuals which have acquired
qualifications in the respective areas of activity in Romania and want to practice the
profession in one of the EU MS presented in the guide.
The analysis was performed for Romania and another 8 EU MS (Austria, Czech Republic,
Denmark, Germany, Italy, United Kingdom, Netherlands and Spain), but the guidelines also
includes some general information resulting from researching the database with regulated
professions from all MS of the EU, the European Economic Area (EEA) and the Swiss
Confederation, developed by the European Commission (EC) Directorate General for Single
Internal Market (DG Internal Market) (http://ec.europa.eu/internal_market/qualifications/
regprof/index.cfm?newlang =en). The authors of the guidelines have studied the European
legislation and of the respective states regarding the acquiring of qualifications, education and
vocational training system, types of documents for competences certification (diplomas,
certificates, certificates of competency, professional titles), regulations regarding the
recognition of qualifications and the regulated professions under Directive 2005/36/EC on
recognition of professional qualifications. In the case of some EU MS analyzed (Denmark,
Germany, Italy, UK, Netherlands and Spain); there have been organized study visits with the
participation of the representatives of IMI PQ NET Ro Network members established within
GOVERNMENT OF ROMANIA Ministry of Education
European Union
GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
and Elderly MASOPHRD
European Social Fund SOP HRD 2007-2013
Structural Instruments 2007 - 2013
Project co financed by the European Social Fund
Sectoral Operational Programme Human Resources Development
2007 - 2013
Invest in people!
http://www.imipqnet.ro
4
the project, and also MEN and ANC experts. During the visits, meetings were organized with
representatives of the national CA but also CA which manages various regulated professions;
occasions on which the guidelines authors were able to gather more specific information from
the source.
In conclusion, the realization of the Guidelines on competence certification and qualification
recognition for the financial auditor profession aims to:
• supporting the Chamber of Financial Auditors of Romania (CAFR) standardization efforts
of the certification procedure / granting the financial auditor professional title and recognition
of the qualifications for this regulated profession which is managed by it, through its
information about counterparts CA practices from other MS;
• inform all persons who have acquired the financial auditor qualification in Romania and
wish to perform financial audits in one of the EU MS presented in the guide.
GOVERNMENT OF ROMANIA Ministry of Education
European Union
GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
and Elderly MASOPHRD
European Social Fund SOP HRD 2007-2013
Structural Instruments 2007 - 2013
Project co financed by the European Social Fund
Sectoral Operational Programme Human Resources Development
2007 - 2013
Invest in people!
http://www.imipqnet.ro
5
1. REGULATORY SITUATION IN ROMANIA AND IN THE OTHER EU MS OF THE
FINANCIAL AUDITOR PROFESSION
The current European regulatory framework on the recognition of professional qualifications
acquired in EU MS is composed primarily by the Directive 2005/36/EC of the European
Parliament and of the Council of 7 September 2005 on the recognition of professional
qualifications but also by a number of sectoral directives in the case of some professions that
are not covered or are covered only in some specific situations by the Directive 2005/36/EC
(such as, for example, the Directive 2006/43/EC on statutory audits in the case of the financial
auditor profession, Directive 2002/92/EC in the case of from insurance intermediaries or
directives 1977/249/CEE and 1998/5/CE for lawyers).
The Directive 2005/36/EC establishes a system for recognition of professional qualifications
in order to improve the EU labor market flexibility, to continue liberalization of the provision
of services (Directive 2006/123/EC on the free movement of services), to encourage
automatic recognition of qualifications and simplify the administrative procedures. This
directive applies to all European citizens who wish to exercise a regulated profession either as
self-employed or as an employee in other MS than that in which they obtained their
professional qualifications and make distinction between "freedom to provide services "and"
freedom of establishment” based on criteria such as duration, frequency, regularity and
continuity of service provision.
From the point of view of the way in which can be done the recognition of professional
qualifications covered by it, the Directive 2005/36/EC covers the following recognition
systems:
• The automatic recognition system of certified qualifications by professional experience in
certain industrial, craft and commercial activities – activities which are listed in Chapter II,
for which the items taken into account for the recognition of professional experience are the
length and its type (self-employed basis or as an employee) and prior formation (item that
may reduce the length of necessary professional experience) proven by a certificate
recognized by the Member State or considered valid by a professional body, and the
conditions to exercise mentioned in the lists for the various groups sectors and activities listed
in Annex IV of the Directive;
• The system of automatic recognition of qualifications for the professions of doctor, nurse,
dentist, veterinary surgeon, midwife, pharmacist and architect - professions referred to in
Chapter III, for which automatic recognition of qualifications is based on the coordination of
the minimum training conditions, including minimum duration of studies, evidence of formal
qualifications referred to in Annexes V and VI to Directive;
• The general system for qualifications recognition - system which applies to professions that
are not regulated by specific rules of recognition and to certain situations in which the holder
of professional qualification does not meet the conditions set out in other recognition systems
,system based on the principle of mutual recognition, without prejudice application of
GOVERNMENT OF ROMANIA Ministry of Education
European Union
GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
and Elderly MASOPHRD
European Social Fund SOP HRD 2007-2013
Structural Instruments 2007 - 2013
Project co financed by the European Social Fund
Sectoral Operational Programme Human Resources Development
2007 - 2013
Invest in people!
http://www.imipqnet.ro
6
compensatory measures when there are significant differences between the training acquired
by the person concerned and the necessary training in the host MS (adaptation period no more
than three years or aptitude tests).
In terms of the qualifications level subject to the general system of recognition, the Directive
2005/36/EC distinguish five levels of professional qualifications:
an attestation of competence issued by a competent authority in the home Member
State, certifying either that the holder has acquired general knowledge corresponding
to secondary or high school education, or a training course not forming part of a
certificate or diploma, or a specific examination without prior training, or full-time
pursuit of the profession for three consecutive years;
certificate attesting to a successful completion of technical or professional or general
secondary education supplemented by professional training;
diploma certifying successful completion of training at post-secondary level duration
of at least one year or training which prepares the trainee for an comparable level of
responsibilities and functions;
diploma certifying that the holder has successfully completed training of post-
secondary or university level of at least three and not more than four years' duration;
diploma certifying that the holder has successfully completed training of post-
secondary or university level of at least four years' duration.
The regulated professions in the field of financial audit fall under the qualifications
recognition general system, qualification level certifying successful completion of
training at post-secondary education, university education of 3-4 years or at least four
years.
As in the case of all the other European directives, all the EU MS were obliged to comply
with the Directive 2005/36/EC trough its transposition into national legislation. Therefore, the
relevant information on the procedure and the rules for the recognition processes valid in each
MS are contained in the national legislation through which it was transposed the Directive
2005/36/EC and can be obtained from the National Contact Points (National Contact Points)
for qualifications recognition, which all Member States were obliged to establish (they are
listed on http://ec.europa.eu/internal_market/qualifications/contact/national_contact_points_en.htm).
In the case of the statutory financial audit activity, this is a regulated activity in all EU MS by
the Directive 2006/43/EC on statutory audits of annual accounts and consolidated accounts.
Moreover, the Directive 2005/36/EC explicitly states1: “This Directive applies, concerning
the right of establishment and the provision of services, without prejudice to other specific
legal provisions regarding the recognition of professional qualifications, such as those
existing in the field of transport, insurance intermediaries and statutory auditors”.
1 Directive 2005/36/EC on the recognition of professional qualifications p. 7, (42), at
http://www.umftgm.ro/fileadmin/consultare_publica/bibliografie/Directiva_2036_2005_20privind_20recunoaste
rea_20calificarilor.pdf
GOVERNMENT OF ROMANIA Ministry of Education
European Union
GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
and Elderly MASOPHRD
European Social Fund SOP HRD 2007-2013
Structural Instruments 2007 - 2013
Project co financed by the European Social Fund
Sectoral Operational Programme Human Resources Development
2007 - 2013
Invest in people!
http://www.imipqnet.ro
7
Within the Directive 2006/43/EC, the provisions relating to the qualifications required for
evaluation / examination of professional competence, continuous vocational training (CVT)
and systems for investigation and for penalty of non conformity with the qualification
requirements and continuous training are the following2:
A natural person may be approved to carry out a statutory audit only after having
attained university entrance or equivalent level, then completed a course of theoretical
instruction, undergone practical training and passed an examination of professional
competence of university final or equivalent examination level, organized or
recognized by the Member State concerned(art.6); the Member State may approve a
person who does not satisfy these conditions, if he or she can demonstrate either that
he or she has been employed, for 15 years, in professional activities which have
enabled him or her to acquire sufficient experience in the fields of finance, law and
accountancy, and has passed the examination of professional competence or that he or
she has, for seven years, engaged in professional activities in those fields and has, in
addition, undergone the practical training and passed the examination of professional
competence(art.11);
The examination of professional competence guarantees the necessary level of
theoretical knowledge of subjects relevant to statutory audit and the ability to apply
such knowledge in practice. Part at least of that examination shall be written. (art.7);
In order to ensure the ability to apply theoretical knowledge in practice, a test of which
is included in the examination, a trainee shall complete a minimum of three years'
practical training in, inter alia, the auditing of annual accounts, consolidated accounts
or similar financial statements. At least two thirds of such practical training shall be
completed with a statutory auditor or audit firm approved in any Member State. (art.
10)
Member States ensure that statutory auditors are required to take part in appropriate
programs of continuing education in order to maintain their theoretical knowledge,
professional skills and values at a sufficiently high level, and that failure to respect the
continuing education requirements is subject to appropriate penalties(art.13);
Member States ensure that there are effective systems of investigations and penalties
to detect, correct and prevent inadequate execution of the statutory audit and, without
prejudice to Member States' civil liability regimes, the penalties are effective,
proportionate and dissuasive, including the possibility of the withdrawal of approval,
and are appropriately disclosed to the public (art.30).
Other European Directives of relevance in the financial audit are the Services Directive
2006/123/EC and Directive 2005/60/EC on measures to combat money laundering.
According to the National Classification of Economic Activities (NACE), financial audit
services are part of the same group of economic activities as the accounting and the tax
consultancy (group 692 - Accounting and auditing activities, tax consultancy) , group which,
together with the group 691 - legal activities, form the division 69 - legal and accounting
2 Directive 2006/43/EC of the European Parliament and of the Council of 17 May 2006 on statutory audits of
annual accounts and consolidated accounts JO L 157, 9.06.2006, p.87
GOVERNMENT OF ROMANIA Ministry of Education
European Union
GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
and Elderly MASOPHRD
European Social Fund SOP HRD 2007-2013
Structural Instruments 2007 - 2013
Project co financed by the European Social Fund
Sectoral Operational Programme Human Resources Development
2007 - 2013
Invest in people!
http://www.imipqnet.ro
8
activities. Therefore, in terms of the activities of various regulated professions reserved for
services in NACE group 692, in practice there is much interference between the professions
of accounting, the financial audit and tax consulting, different from one country to another.
There are quite a few countries with distinct professions on the three areas of activity
(between those analyzed in this guide, only Romania and the Czech Republic, but in the
Czech Republic the accounting professions are not regulated, but only the profession of
statutory auditor and tax consultant), in other countries, although they are distinct regulated
professions, there is only one AC to which all holders of professional qualifications from
accounting, auditing and tax consulting are required to be members (e.g. Austria until 1
January 2013, when the accounting professions regulated were transferred to another AC), in
other countries the professions are named with the term "accountant", but they is regulated
only for the activity exclusively reserved for statutory auditing, while accounting activities are
reserved to the respective professions (e.g. the Netherlands). In addition, all the identified
studies and used as an information resource deals the professions in NACE group 692
together as accounting professions. In fact, in terms of knowledge necessary to practice the
professions related to NACE group 692, all these professions have a common base (hence
FEE - Fédération des Experts-comptables Européens / Federation of European Accountants /
Federation of European Accountants - treated in his paper "Structure and Organization of the
accountancy profession " both the actual accounting professions and the professions of
financial auditor and tax consultant in the countries where the latter is a distinct regulated
profession), .
For the same reason, in the IMI system - the electronic platform for the exchange of
information between EU MS AC, SEE and the Swiss Confederation towards the mutual
recognition of professional qualifications, there are several generic categories of regulated
professions falling under NACE group 692 - accounting activities and financial audit, tax
consultancy, categories of occupations where some of EU MS have chosen to enroll their
regulated professions in the financial audit: accountant-lawyer (accountant - lawyer), auditor /
accountant (auditor / accountant ), Company auditor (Company auditor), public finance
accountant (public finance accountant) accountant / tax advisor (accountant / tax advisor).
In Table 1.1 is given only the situation of financial audit regulated professions that have been
submitted by the MS to the CE database, extracted by the author from all the generic
categories listed above, in which 25 MS of EEA and Swiss Confederation registered 39
professions that was reserved primarily for the financial audit activity:
GOVERNMENT OF ROMANIA Ministry of Education
European Union
GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
and Elderly MASOPHRD
European Social Fund SOP HRD 2007-2013
Structural Instruments 2007 - 2013
Project co financed by the European Social Fund
Sectoral Operational Programme Human Resources Development
2007 - 2013
Invest in people!
http://www.imipqnet.ro
9
Table 1.1
The regulated professions in the field of financial audit registered by the MS of EU, EEA and
Swiss Confederation in the IMI system
MS
Name of the profession in the
MS / generic category in
English / Romanian translation
Name of CA Qualification level
ROMANIA Financial auditor / Company
auditor
Chamber of Financial Auditors of Romania
(CAFR) www.cafr.ro
PS3 - Post-secondary diploma (3-
4years) , Article 11 d
AUSTRIA
Beeideter Wirtschaftsprüfer/
Certified Public Accountant /contabil certificat şi auditor
Kammer der Wirtschaftstreuhänder (KWT)/
Chamber of Public accountants
www.kwt.or.at
PS3 - Post-secondary diploma (3-4years) , Article 11 d
BELGIUM
Reviseur d’entreprise/ bedrijfsrevisor/
Auditor/accountant/ auditor de
firmă
SPF Economie, P.M.E., Classes moyennes et Energie, Direction générale de la régulation
et de l’organisation du marché, Service audit,
droit comptable, coopératives/ Federal Public Service Economy, SMEs, Self-employed and
Energy – General Directorate for regulation
and market organization, audit, accounting law, cooperative unit
PS3 - Post-secondary diploma (3-
4years) , Article 11 d
BULGARIA
Дипломиран експерт-
счетоводител (одитор)/
Auditor/accountant/ Expert contabil diplomat (auditor)
Institute of Certified Public Accountants/
Institute of Certified Public Accountants
PS3 - Post-secondary diploma (3-
4years) , Article 11 d
Одитор по смисъла на Закона
за Сметната палата/ accountant-lawyer/
Auditor în cf. cu Legea Oficiului
Naţional de Audit
Court of Audit/ Court of Audit
Вътрешен одитор в публичния сектор/ Public finance
accountant/ auditor intern în
sectorul public
Ministry of Finance/ Ministry of Finance
Одитор на специфични одитни
дейности по фондове и
програми на Европейския
съюз/ Public finance accountant/
auditor pentru programe finanţate
din fonduri UE
Служител в Централно
хармонизиращо звено за вътрешен одит/ Public finance
accountant/ angajat în Internal
Central Harmonization Unit Division
CZECH REPUBLIC
Auditorské služby /
Auditor/accountant/ servicii de audit
Czech Chamber of Auditors/ Czech Chamber of Auditors www.kacr.cz
PS3 - Post-secondary diploma (3-4years) , Article 11 d
CYPRUS Λογιστής/ Auditor/accountant/
Contabil (auditor)
Institute of Certified Public Accountants of
Cyprus/ Institute of Certified Public
Accountants of Cyprus
www.icpac.org.cy
PS3 - Post-secondary diploma (3-
4years) , Article 11 d
GOVERNMENT OF ROMANIA Ministry of Education
European Union
GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
and Elderly MASOPHRD
European Social Fund SOP HRD 2007-2013
Structural Instruments 2007 - 2013
Project co financed by the European Social Fund
Sectoral Operational Programme Human Resources Development
2007 - 2013
Invest in people!
http://www.imipqnet.ro
10
MS
Name of the profession in the
MS / generic category in
English / Romanian translation
Name of CA Qualification level
DENMARK
Statsautoriseret revisor/
Auditor/accountant/ Contabil
public autorizat de stat
Erhvervsstyrelsen/ Danish Commerce and Companies Agency/ Agenţia Daneză pentru
Comert şi Firme
www.erst.dk
PS3 - Post-secondary diploma (3-
4years) , Article 11 d Registrered revisor/
Auditor/accountant/ Contabil
public înregistrat
SWITZERLAND
Réviseur/ Revisor/ Company
auditor/ auditor
Federal Audit Oversight Authority (FAOA)/
Autoritatea Federală de Supraveghere a
Auditului
unspecified
Réviseur de SA (selon critère art.
727b CO)/ Revisoren für AG
(Kriterien gemäss Art. 727b OR)
/ Company auditor/ Auditor de societăţi pe acţiuni (cf. art. 727b
CO)
FINLAND
Julkishallinnon ja talouden
tilintarkastaja/revisor inom den
offentliga förvaltningen och ekonomin/ Public finance
accountant/ auditor
PS3 - Post-secondary diploma (3-4years) , Article 11 d
GERMANY
Wirtschaftsprüfer/
Auditor/accountant/ contabil
public
Wirtschaftsprüfer-kammer (WPK)/ Chamber
of Public Accountants
PS3 - Post-secondary diploma (3-4years) , Article 11 d
GREECE
Orkotós logistís/ Auditor/accountant/ contabil
public certificat
The Institute of Certified Public Accountants
of Greece (SOEL)/ Institutul Contabililor
Publici Certificaţi din Grecia
PS3 - Post-secondary diploma (3-
4years) , Article 11 d
HUNGARY
okleveles könyvvizsgáló/
Auditor/accountant/ auditor
statutar
Chamber of Hungarian Auditors (MKVK) /
Camera Auditorilor Maghiari
PS3 - Post-secondary diploma (3-
4years) , Article 11 d
IRELAND
Chartered and certified
accountants and other professional accountants registered as auditors/
Auditor/accountant/ contabili autorizaţi şi certificaţi şi alţi
contabili înregistraţi ca auditori
The Irish Auditing and Accounting
Supervisory Authority (IAASA)/Autoritatea Irlandeză de Supraveghere a Auditului şi
Contabilităţii
PS3 - Post-secondary diploma (3-
4years) , Article 11 d Chartered accountant/
Accountant/tax advisor/ contabil
autorizat
Institute of Chartered Accountants in Ireland/
Institutul Contabililor Autorizaţi în Irlanda
www.icai.ie
Certified public accountant/ Public finance accountant/
contabil public certificat
Institute of Certified Public Accountants in Ireland/ Institutul Contabililor Publici
Certificaţi în Irlanda
www.cpaireland.ie
ICELAND
Löggiltur endurskoðandi/ Tax
advisor/accountant/ contabil
certificat
Ministry of Finance/ Ministerul Finanţelor
PS3 - Post-secondary diploma (3-
4years) , Article 11 d
ITALY
Revisore legale/
Auditor/accountant/
Auditor legal
Ministry of Economy and Finance/Min.
Economiei şi Finanţelor
GOVERNMENT OF ROMANIA Ministry of Education
European Union
GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
and Elderly MASOPHRD
European Social Fund SOP HRD 2007-2013
Structural Instruments 2007 - 2013
Project co financed by the European Social Fund
Sectoral Operational Programme Human Resources Development
2007 - 2013
Invest in people!
http://www.imipqnet.ro
11
MS
Name of the profession in the
MS / generic category in
English / Romanian translation
Name of CA Qualification level
Revisore contabile/
Auditor/accountant/ auditor
contabil
Professional Order of Accountants and
Commercial Law Experts/Ordinul
Profesional al Contabililor şi Experţilor în Drept Comercial
PS3 - Post-secondary diploma (3-
4years) , Article 11 d
LATVIA
Zvērināts revidents/ Auditor/accountant/ auditor
certificat
Latvian Association of Certified Auditors (LZRA)/ Asociaţia Letonă a Auditorilor
Certificaţi
PS3 - Post-secondary diploma (3-
4years) , Article 11 d
LUXEMBOURG
Reviseur d’entreprise/
Auditor/accountant/ auditor de
firmă
Institut des Raviseurs d’Entreprises (IRE)/
Enterprise Auditors Institute
Commission de Surveillance du Secteur Financier (CSSF)/ Financial Sector
Supervisory Commission
PS3 - Post-secondary diploma (3-
4years) , Article 11 d
MALTA Auditor/ Auditor/accountant/ Auditor
Accountancy Board/Consiliul Contabilităţii
PS3 - Post-secondary diploma (3-4years) , Article 11 d
UNITED KINGDOM
Chartered accountant/
Auditor/accountant/ contabil
autorizat
Institute of Chartered Accountants in
England and Wales (ICAEW)/ Institutul
Contabililor Autorizaţi din Anglia şi Tara Galilor
Institute of Chartered Accountants of
Scotland (ICAS)/ Institutul Contabililor Autorizaţi din Scoţia
www.icas.org.uk
Institute of Chartered Accountants in Ireland (ICAI)/ Institutul Contabililor Autorizaţi în
Irlanda
www.icae.ie
PS3 - Post-secondary diploma (3-4years) , Article 11 d
Chartered Certified Accountant/
Auditor/accountant/ contabil autorizat certificat
Association of Chartered Certified
Accountants (ACCA)/Asociaţia Contabililor Autorizaţi Certificaţi
www.accaglobal.com
NORWAY
Registrert revisor/ Auditor/accountant/ auditor
înregistrat
Kredittilsynet/ Financial Supervisory Authority of Norway
www.kredittilsynet.no PS3 - Post-secondary diploma (3-
4years) , Article 11 d
Statsautorisert revisor/ Auditor/accountant/ auditor
autorizat de stat
PSM – Post-secondary diploma (over 4 yers) , Article 11 e
NEDERLANDS
Accountant – administratieconsulent/
Auditor/accountant şi la
Accountant/tax advisor /consultant în contabilitate
(învăţământ superior politechnic
–profesional)
NBA Institute (formal professional bodies Nederlandse
Orde van Accountants
Administratieconsulenten- NovAA/ The Netherlands Accounting Consultants Order +
Koninklijk Nederlands Instituut van
Registeraccountants – NIVRA/ Royal Institute of Registered Accountants)
PS3 - Post-secondary diploma (3-
4years) , Article 11 d Registeraccountant/
Auditor/accountant şi la
Accountant/tax advisor Contabil certificat
(învăţământ superior universitar –
academic)
POLAND
Audytorwewnętrzny / Internal
auditor/ auditor intern
Minister Finansów/ Ministry of Finance
www.mf.gov.pl
PSM- Post-secondary diploma (more than 4 years ), Art.11 e Biegły rewident / Auditor
Krajowa Izba Bieglych Rewidentów/
Auditors chamber
GOVERNMENT OF ROMANIA Ministry of Education
European Union
GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
and Elderly MASOPHRD
European Social Fund SOP HRD 2007-2013
Structural Instruments 2007 - 2013
Project co financed by the European Social Fund
Sectoral Operational Programme Human Resources Development
2007 - 2013
Invest in people!
http://www.imipqnet.ro
12
MS
Name of the profession in the
MS / generic category in
English / Romanian translation
Name of CA Qualification level
PORTUGAL
Revisor oficial de contas/
Auditor/accountant/ Auditor
oficial de conturi
Ordem dos Revisores Officiais de Contas/ The Order of the official auditor of Accounts
www.oroc.pt
PS3 - Post-secondary diploma (3-
4years) , Article 11 d
SLOVENIA
Državni notranji revizor/ Auditor/accountant/ auditor
intern de stat
Ministrstvo za Finance/ Ministry of Finance www.mf.gov.si
PS3 - Post-secondary diploma (3-
4years) , Article 11 d Preizkušeni državni notranji
revizor/Accountant/ auditor intern
de stat instruit
SPAIN
Auditor de cuentas/ Auditor/accountant/ auditor de
conturi
Instituto de Contabilidad y Auditoria de Cuentas (ICAC)/ Institute of Accounting and
Accounts Auditing PS3 - Post-secondary diploma (3-
4years) , Article 11 d
Source: done by the author with information from the IMI system, the legislative area of
professional qualifications, at http://ec.europa.eu/internal_market/qualifications/regprof/
index.cfm?action=profession&id_profession=2100 (at 30.05.2013)
By corroborating the information on the regulation of financial auditor profession from
several comparative studies conducted at EU level3 and supplementing them with information
from national documents (especially in the case of Romania in order to also update them), we
will further present the comparative situation on the 9 MS analyzed, on each defining item
separately.
Specific national legislation, the protected professional titles and the CA
In Romania, the financial auditor profession is regulated by Law no. 278 of 7 November 2008
approving the Government Emergency Ordinance (GEO) no. 90/2008 on statutory audits of
annual financial statements and consolidated annual financial statements and Law. 26/2010
amending and supplementing GEO no.75/1999 on the financial audit activity, and CA is the
Chamber of Financial Auditors of Romania - CAFR.
In Austria, the specific law is Wirtschaftstreuhandberufsgesets - WTBG (Statute of
professional practice of the Public Accountants) and is protected professional title
Wirtschaftsprüfer (Certified Public Accountant / chartered accountant and auditor). The CA
3 Mainly: FEE - Key Features on Structure and Organisation of the Accountancy Profession across 30 European
countries, 26 March 2012, to http://www.fee.be/images/publications/qualification/Intro_Structure_and_
Organisation_of_the_Profession2732012401312.pdf - files for the 9 EU MS on witch I realized the comparative
analysis, DG Internal Market and Services - Final Report - Study to Provide year Inventory of Reserves of
Activities linked to Professional Qualifications & Requirements in 13 Member States Assessing Their economic
impact, January 2012 - Annex H of the final report at http://ec.europa.eu/internal_market/qualifications/docs
/news/20120214-annex_en.pdf - files for 7 MS analyzed, Romania and Austria being neither part of the sample
countries across which the analysis was conducted within the study.
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for this profession is Kammer der Wirtschaftstreuhänder - KWT (Chamber of Certified Public
Accountants).
In the Czech Republic, the audit services are regulated by Law No. 93/2009 on auditors and
the protected title is Auditorské služby (audit services), . The CA is the Komora auditorů ČR -
KACR (Chamber of Auditors of the Czech Republic).
In Denmark, the professions in the field of financial audit are regulated by Lg. Audit no.
468/17 June 2008. In the field of financial audit there are two protected titles: Statsautoriseret
Revisor (auditor / state certified public accountant), and Registrered Revisor (auditor /
registered public accountant). For both professions there is only one CA - Erhvervsstyrelsen
(Danish Commerce and Companies Agency / Danish Commerce and Company Agency,
DCCA).
Germany has the same professional title as the Austria, ie. Wirtschaftsprüfer. The auditor may
also perform tax consulting activity, i.e. Wirtschaftsprüfer qualification is usually acquired
over qualification Steuerberater (tax consultant). But, unlike in Austria (where KWT is CA
for both regulated professions) in Germany the two regulated professions have different CA:
Wirtschaftsprüfer-Kammer - WPK for auditors and Steuerberaterkammer for tax consultants.
The specific legislation for auditing activity consists of the Gesetz über eine der
Wirtschaftsprüfer Berufsordnung - WPO (Law on Public Accountants), from 1961, the most
recent amended in December 2010, Handelsgesetzbuch - HGB (Commercial Code), from
1897, the most recent amended in March 2011, Berufssatzung WP / vBP (the Charter of
Professions), since 1996, amended in November 2009.
In Italy there is the protected professional title Revisore legale dei conti (statutory auditor of
accounts) that is reserved solely for the activity of legal / statutory financial audit, but in the
case of financial audit for other legal persons than those who are required to have legal /
statutory audit, this represents an reserved shared activity with Revisore contabile dei conti
(auditor of accounts) and the two professional titles in accounting field - Dottore
commercialista (certified public accountant) and Esperto contabile (accountant).
In the case of the statutory auditor of accounts, the specific legislation is the D.Lgs 27 gennaio
2010, n. 39 “Attuazione della direttiva 2006/43/CE, relativa alle revisioni legali dei conti
annuali e dei conti consolidate (transposition into national law of Directive 2006 / 43/CE) and
the CA for statutory auditors is the Ministry of Economy and Finance. In the case of the
auditor of accounts, according to registry of the IMI system, CA is the Chartered body of
Accountants and Commercial Law Experts (in neither of the comparative studies that
constituted the main documentary basis for this guide, revisore contabile dei conti profession
is however not included in the analysis).
The Netherlands has two professions regulated as regards the activity of auditing reservation:
Accountant - administratieconsulent (accounting consultant) and Registeraccountant
(registered accountant).
The main difference between the two professional titles consist of the initial training route
(presented in Chapter 2 of the guide) while the services the holders of these two titles can
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provide are common. The specific legislation consists of Wet toezicht accountantsorganisaties
(Law on supervision of accounting firms) and the Civil Code from 2010 (Volume 2, Chapters
9 and 11), and also the specific law for each profession - Wet op de Accountants-
Administratieconsulenten (Accounting Consultants Law) and respectively Wet op de
registeraccountants (Registered Accountants Law). Currently the two professions have a
single CA - NBA Institute, which resulted from the merger of the former professional bodies
Nederlandse Orde van Accountants Administratieconsulenten - NovAA (The Netherlands
Accounting Consultants Order) and Koninklijk Nederlands Instituut van Registeraccountants -
NIVRA (Royal Institute of Registered Accountants).
In Spain the financial auditor is the only regulated profession among professions in the NACE
group 692. The specific legislation is the Royal Decree 1/2011 which approves the revised
text of the Law on the financial audit. Title is the protected Auditor de cuentas (Auditor of
Accounts) and the CA is the Instituto de Contabilidad y Auditoria de Cuentas - ICAC (Institute
of Accounting and Auditing of Accounts).
The United Kingdom is a special case, because in most cases, the access to the market is not
restricted by reserving activities to certain regulated qualifications / professions, but
protection of consumers is ensured by legally protecting the professional titles, the holders
these titles are members of professional associations / institutions which are granting titles and
which regulates the activity of their members. "Chartered" status of the Body (legally
protected) demonstrates that there is a distinct profession in the respective field of activity,
and the body awarding the title / titles has the capacity to establish and maintain high ethical
and technical standards among its members. "Chartered" status of the Body also confirms that
the organization and its members are recognized as experts in their respective field of activity,
which is of public interest.
In the field of accounting any person in the UK might call itself accountant and can provide
accounting services, but there are six legally protected professional titles (chartered) without
their owners to have reserved accounting activities. Only the professions of statutory financial
auditor and insolvency practitioner are regulated (meaning that these activities can be carried
out only by those who hold a certain professional title). Statutory auditing services can be
provided only by the Registered Auditors (registered auditors) or by Chartered Certified
Accountants (chartered certified accountants) and Chartered Accountants (chartered
accountants) who have obtained additional professional qualifications and only the
professional associations authorized have the responsibility for supervision of the use of the
respective titles may authorize members to conduct statutory financial audit activity.
These are the Association of Chartered Certified Accountants - ACCA (Association of
Chartered Certified Accountants), Institute of Chartered Accountants in England and Wales -
ICAEW (Institute of Chartered Accountants in England and Wales) and the Institute of
Chartered Accountants of Scotland - ICAS (Institute of Chartered Accountants of Scotland).
The regulation of the activity of financial audit is given by transposition into national law of
the Directive 2006/43/EC on statutory financial audit of annual accounts and consolidated
accounts, trough the Companies Act 2006 (Companies Act), Section 1212 and Scheme 10.
The British government has the responsibility and the power to record, monitor and regulate
the statutory auditors, but through the Financial Reporting Council (Financial Reporting
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Council - FRC), these powers of government are delegated to professional bodies listed
above. Therefore, as CA for statutory auditors it occurs the Professional Oversight Board -
POB (Professional Oversight Board), the structure within the FRC who supervises the entire
activity of the professional bodies concerned.
Reserved activities and included authorizations
The common element of the financial audit professions regulated in the 9 MS analyzed is that
they are exclusively reserved (other qualifications / professions are not entitled to carry out
the activity) or shared (in Denmark, Netherlands, United Kingdom) auditing activity of
statutory / legal annual accounts statement and of the consolidated annual financial
statements, reservation resulting from the transposition of Directive 2006/43/EC, and are
shared reservation (also other professions are entitled to carry out that activity) or also
exclusively (Romania) and non-statutory financial audit. An exception is Italy, where the
profession / qualification that is exclusively reserved for statutory audit activity is revisore
legale dei conti ,and the other professions (revisore contabile dei conti, dottore
commercialista, esperto contabile) have only shared reservation for non-statutory financial
audit. In Denmark, of the two professions regulated in the financial audit field, the
Statsautoriseret revisor is exclusively reserved the audit activity for public listed companies
(at the stock exchange), and in Spain only the statutory audit activity is regulated, not the one
of non-statutory audit.
The other shared reserved activities as well as the authorizations included (by default) varies
from one country to another, especially depending on the interference between the
accounting, auditing and tax consulting professions: in Austria and Germany, the holder of the
title / qualification Wirtschaftsprüfer is entitled to conduct also the activities reserved to the
profession of tax consultant (Steuerberater), in other words it requires a qualification above
that of Steuerberater, in Germany, Czech Republic, Denmark, Great Britain, Spain, the expert
accounting activities are authorized by default, as the accounting services are not regulated; in
Denmark, as there is no separate profession of tax consultant, the two professions of financial
audit have also, by default, the authorization for the tax consultancy services, in the
Netherlands, as the two professional titles are for accountants (but they are regulated only for
the financial audit services), it is stated that the two protected titles also include the right to
use the title of accountant, in Spain, auditors have included the authorization for activities of
asset valuation and increase/decrease of capital in some cases of restructuring or bankruptcy
of some firms.
In the case of Romania, Law no. 149/2013, published in Official Journal (OJ) no. 257 of 9
May 2013, complement the normative acts regulating the activities of accounting expertise, of
assets valuation, of financial audit, tax consultancy and insolvency practitioner, stating clearly
that professionals in these fields can carry out an complementary activity only if they are
qualified for it and are members of the organizations that coordinate the liberal professions
concerned.
More precisely, the Law no. 149/2013 stipulates punctually that "the financial auditors may
carry out the activities of accounting expertise, valuation, judiciary reorganization and
liquidation as well as tax consultancy only after the acquiring, according to the law, the
quality of expert accountant, evaluator, insolvency practitioner or tax consultant, as
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appropriate, and enrolling as member of the organizations that coordinate the liberal
professions.” 4. It results, on the one hand, that all the financial audit activities are reserved
exclusively for the financial auditor profession, but, on the other hand, that the financial
auditors do not have shared reserved activities or authorizations included in the accounting
expertise, valuation, judiciary reorganization and liquidation or tax consultancy , because each
of these activities are exclusively reserved to one of the other liberal financial professions
distinctly regulated in Romania.
The oath when it is granted the title of financial auditor
The oath is compulsory in Austria, Czech Republic, Germany and Romania. In Denmark,
Italy, UK, Netherlands and Spain there is no such requirement.
The obligation of registration and the establishment of a regulatory body of public interest
These two obligations are set out by the Directive 2006/43/EC, therefore in all the MS
analyzed they are met as follows:
• Austria - KWT is the CA for recording of all financial auditors, supplemented by
Arbeitsausschuss für externe Qualitätsprüfungen –AeQ (Executive Committee for the quality
external audits) for the statutory auditors; the supervisory body is Qualitätskontrollbehörde -
OKB (The Austrian Authority for Auditors Supervision );
• Czech Republic - KACR is the CA for recording (which perceives a registration fee of
approx. 200 euro), and the supervisory body is The Public Council of Audit Supervision
(APOC);
• Denmark - the CA for recording is the Danish Commerce and Companies Agency - DCCA
(which does not perceives any registration fee) and the supervising body is The Supervisory
Authority on Auditing - DSAA (The Supervisory Authority on Auditing);
• Germany - the CA for recording is the Wirtschaftsprüfer-Kammer ((which perceives a fee of
230 euro) and the supervisory body is Abschlussprüfe-raufsichtskommission - Apak (Auditors
Supervisory Commission);
• Italy - the CA for registration of statutory auditors (revisore legale dei conti) is the Ministry
of Economy and Finance (which perceives a fee of approx. 25 euro) and the supervisory body
for the public audit firms is the Commissione Nazionale per la Societa it's Borsa - Consob (the
Investors Protection Supervisory Authority);
4 The Law no. 149/2013 for approving of the Government Ordinance no. 23/2012 for amending and
supplementing the Government Emergency Ordinance no. 90/2008 on statutory audit of annual financial
situations and the consolidated financial situations and the Government Ordinance no. 65/1994 on the
organization of accounting expertise activity and of the certified accountants and for amending other acts
Official Journal, no. 257, of May 9, 2013.
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GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
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• United Kingdom - the CA for recording are the three professional bodies to whom it was
delegated this power: ACCA (membership fee is 193 pounds and the fee for the license to
practice is 385 pounds), ICAEW (fee membership - 300 pounds , practicing certificate fee -
268 pounds), ICAS (membership fee - 396 pounds, practicing certificate fee - 474 pounds);
POB is the supervising body (Professional oversight Board);
• Netherlands - the CA for recording is the NBA for both regulated professions (which
perceives a fee of approx. 250 euro) and the supervisory body is the AFM (Dutch Authority
for the Financial Markets);
• Romania - the CA for recording is CAFR (the fee for individuals is about. 150 euro) and the
supervising body is in the Council for the Public Interest Oversight of the Accountancy
Profession - CSIPPC (by transformation CSPAAS - Council for the Public Oversight for
Statutory Auditing into oversight Council not only for public financial auditor profession, but
also for accounting professions);
• Spain - the CA for recording is ICAC (that does not perceives any fee) being an independent
structure, but within the Ministry of Economy and Taxation, ICAC also acts as a public
interest supervision body.
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2. COMPETENCES CERTIFICATION PROCEDURES APPLIED BY THE CA IN THE
COUNTRIES ANALYZED
The provisions related to the necessary qualifications for evaluation / examination of
professional competence and continuous vocational training (CVT) of the Directive
2006/43/EC on statutory audits of the annual accounts and consolidated accounts (presented
in Chapter 1) provides a relatively high degree of harmonization of the competences
certification procedures applied by the CA in all MS, and, with respect to the Directive
2005/36/EC on the recognition of professional qualifications, it can be seen from table 1.1
that the minimum qualification level is post-secondary diploma level 3 - 4 years or, in some
cases, more than four years (State Authorized Public Accountant in Denmark and the Internal
Financial Auditor in Poland).
In this chapter we will present within the synoptic table 2.1, in comparable format, only the
situation in the 9 analyzed MS.
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Table 2.1
The requirements for acquiring the qualification of financial auditor and those regarding CVT in the analyzed MS
MS Austria Czech
Republic
Denmark Germany Italy United Kingdom Netherlands Romania Spain
Mandatory
training
requirements
for acquiring
qualification
University degree or
equivalent +
3 years practice in
audit (2 years practice in audit for Tax
consultants /
Steuerberater) +
professional
examination
University
degree (Bachelor or
Master)
+ min. 3 years
practice in
audit (min.35 hrs /
wk.)
+ professional
examination
at the Chamber of
Auditors
University
degree in accountancy
obtained with
max. 8 years before
(master for.
Statsautoriseret Revisor,
bachelor for.
Registrered Revisor)
+
3 years practice in audit
+
qualifying exam (different
on the two
professions)
University
degree (Bachelor
or Master)
+ audit
practice (4
years for. the
Bachelor,
3 years. for
Master)
+ auditor
exam
University
degree in economics
+
3 years practice in
audit
+ State
exam
ACCA:
a) Diploma of Secondary
Education b) university/postuniv.
degree.
c) Certified Accounting Technician qualification
(CAT)
+ 14 ACCA qualification
examinations (depending on the route of admission)
+ professional ethical
module +
3 years relevant practical
experience
University degree (Bachelor
for.Administratieconsulent, Master for
Registeraccountant)
+ Part-time postuniv. program
(1,5 years
for.Administratieconsulent, 1 and 2 years for.
Registeraccountant)
+ 3 years of practice
+
final exam
University degree in
Economics +
4 years of experience in
the finance - accounting +
financial and accounting
knowledge test +
3 years practice
+ Aptitude test for. acquiring
the title of financial
auditor held to the CAFR with final approval of
CSIPPC
University degree +
min.3 years practice/ preuniv degree.+ min. 8 years
practice
+ theoretical training +
State exam
ICAEW:
a) Diploma of Secondary
Education
b) university/postuniv. degree.
c) ICAEW Certificate in
Finance, accountancy and business (CFAB)
d) AAT qualification
+ ACA qualification program
(Associate Chartered
Accountant): 15 training modules, 450 days of
practice, early professional
development, structured training in ethics
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ICAS:
a) Diploma of Secondary
Education
b) university/postuniv degree.
c) AAT qualification
+
Practice Agreement with an
ICAS authorized employer
(usually 3 years) + study and 3 stages of exams
(depending on the route of
admission) + business ethics course
CVT /
continuous
vocational
training.
KWT ensure CVT
trough Akademie der
Wirtschaftstreuhänder
Yes, min. 60
hours/year
organized by KACR
Yes, min. 120
hours within 3
years reported by the auditor
or its employer
Yes, IDW
(the
professional body) is
involved in
providing
CVT
Yes
Yes, al the three institutes
impose CVT to their
members,
Yes, NBA organize CVT for
both professions Yes, min.40 hours/year,
from which 20 hours
under CAFR supervision (incl. e-learning)
Yes, ICJCE (Auditors
professional body) provides
CVT together with its 16 regional branches
Application
of the
professional
standards
KWT is involved by
law in the development of professional
standards
KACR
develops its own
insurance
standards and it has
adopted
all the IAASB
standards
FSR (Auditors
professional body)
develops standards based
on the IFAC
standards
IDW
(Public Auditors
Institute)
develops audit and
quality
assurance standards
Min. of Econ.
and Finances and the
Consob in the
case of audit firms of
public
interest
FRC is responsible for
development of
professional standards
NBA develop the professional
standards CAFR has entirely
adopted the IFAC
standards
ICAC elaborate together with
ICJCE the professional
standards and is responsible for their adoption
Quality
Assurance
AeQ and QKB are involved, not the KWT
KACR
ensure quality under
supervision
of APOC
- WPK ensure quality under
supervision
of APAK
- The three institutes ensure
quality under supervision of POB
NBA ensure quality CAFR ensure quality
under supervision of CSIPPC
ICAC together with ICJCE ensure quality
disciplinary
measures
KWT take disciplinary
measures for those of eQ
and QKB related to
quality assurance
KACR take
disciplinary
measures
under supervision of
If the CVT
missing hours are
under 40, they must be done
within the time
- Min. Econ.
and Finances
and Consob in case of
audit firms of
The three institutes apply
disciplinary measures to
their members under the
supervision of POB
NBA apply disciplinary
measures to their members CAFR apply disciplinary
measures to their members
under the supervision of
CSIPPC
ICAC, bat also ICJCE apply
disciplinary measures
GOVERNMENT OF ROMANIA Ministry of Education
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GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
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APOC provided by CA; If the CVT
missing hours are
above 40 or have not been done
within the time provided by CA;
the CA can
withdrawal the Statutory auditor
authorization
public interest
Source: FEE – Key Features on Structure and Organization of the Accountancy Profession across 30 European countries, 26 March 2012; DG
Internal Market and Services – Final Report – Study to provide an Inventory of Reserves of Activities linked to professional qualifications
requirements in 13 Member States & assessing their economic impact, January 2012 – annex H; Chamber of Financial Auditors of Romania –
presentation sustained by CAFR for the study visit in Denmark, May 2013
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22
3. QUALIFICATIONS RECOGNITION PROCESSES ACQUIRED IN OTHER EU MS IN
ORDER TO PRACTICE THE FINANCIAL AUDITOR PROFESSION
The statistics in the IMI system, realized based on data on the professionals mobility on the
two modalities of performance (through establishment / the exercise with permanent character
of their profession in another Member of the EU, EEA and Switzerland, or temporary
performance) and for each generic profession category individually, in accordance with the
generic categories registered in the database until now, there are not relevant for the financial
auditors because, as shown in Chapter 1 of this guide, MS of EU, EEA and Swiss
Confederation registered the regulated professions in the financial audit on various generic
categories, of which only some cover only the financial auditors, while others reflect not only
the mobility of financial auditors, but also the other regulated accounting profession which
have been registered in those generic categories. Therefore, the statistics presented below are
based on own data processing regarding only the recognition decisions recorded by the MS of
the EU, EEA and Swiss Confederation on regulated professions mainly for financial audit.
The statement on the establishment / the exercise with permanent character during 1997/98 -
2012 of the accountancy profession is presented in Table 3.1.
Table 3.1
Statistics of decisions on qualifications recognition acquired in other EU MS, EEA and the
Swiss Confederation for the profession of financial auditor (1997/8 - 2012)
Host Country:
regulated
professions
The profession for which
has been adopted the
recognition decision
Qualification Country
of Origin
No. of positive
decisions
No. of negative
decisions
No. of neutral
decisions
Total decisions
Belgium:
20 = 6 + 12 +2 /
requests from 4 SM
Reviseur d’entreprise/
bedrijfsrevisor
20=6+12+2
France 2 11 1 14
Luxembourg 3 0 0 3
United Kingdom 1 0 0 1
Netherlands 0 1 1 2
Czech Republic :
8 = 7 + 0 + 1/
requests from 3 SM
Auditorské služby
8=7+0+1
Germany 2 0 0 2
United Kingdom 3 0 1 4
Slovakia 2 0 0 2
Cyprus
478 positive
decisions for
requests from 5 SM
Λογιστής
478 0 0
Czech Republic 1 0 0 1
Greece 2 0 0 2
Ireland 1 0 0 1
United Kingdom 470 0 0 470
Slovakia 1 0 0 1
Hungary 3 0 0 3
Denmark :
12 = 4 + 1 + 7/
requests from 3 SM
Statsautoriseret
revisor/registered revisor
12=4+1+7
Germany 1 0 0 1
Iceland 1 0 2 3
United Kingdom 2 1 4 7
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and Iceland Netherlands 0 0 1 1
Germany:
63 = 45 + 14 + 4
requests from 11 SM
and Switzerland
Wirtschaftsprüfer
63=45+14+4
Denmark 2 1 0 3
Switzerland 3 1 0 4
France 6 3 1 10
Greece 1 0 0 1
Ireland 3 0 0 3
Italy 2 0 2 4
Luxemburg 1 4 0 5
United Kingdom 21 0 1 22
Netherlands 4 3 0 7
Spain 1 0 0 1
Sweden 0 1 0 1
Hungary 1 1 0 2
Greece:
1 positive decision
for request form
1MS
Orkotós logistís
1 0 0
United Kingdom 1 0 0 1
Ireland:
22 = 19 + 1 + 2
requests from 5 SM
Chartered and certified
accountants and other
professional accountants registered as auditors
5 0 0
United Kingdom 5 0 0 5
Chartered accountant
14 = 11+1+2
France 1 1 0 2
Germany 1 0 0 1
Italy 1 0 1 2
United Kingdom 8 0 0 8
Spain 0 0 1 1
Certified public
accountant
3 0 0
United Kingdom 3 0 0 3
Italy:
12=3+3+6 requests
from 5 SM
Revisore contabile
12=3+3+6
France 0 1 2 3
Germany 1 0 2 3
Luxembourg 1 0 0 1
United Kingdom 1 1 1 3
Spain 0 1 1 2
United Kingdom:
119 = 53 + 19 + 47
requests from 12 MS
of EU, Iceland and
Norway
Chartered Certified
Accountant
37=21+3+13
France 0 0 2 2
Germany 1 0 0 1
Ireland 18 3 1 22
Italy 2 0 7 9
Luxemburg 0 0 3 3
Chartered accountant Denmark 0 1 1 2
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82=32+16+34
(neutral decision = under
examination)
France 5 1 1 7
Germany 2 0 1 3
Greece 0 0 1 1
Ireland 0 1 2 3
Iceland 0 0 1 1
Italy 19 12 14 45
Luxembourg 0 0 1 1
Norway 1 0 1 2
Netherlands 3 0 1 4
Portugal 0 0 8 8
Spain 0 0 1 1
Sweden 2 1 0 3
Hungary 0 0 1 1
Norway:
17 = 3 + 3 + 11
requests from 6 SM
Statsautorisert revisor
17=3+3+11
Denmark 0 1 0 1
France 0 0 3 3
Germany 1 0 0 1
Italy 0 0 2 2
United Kingdom 2 0 5 7
Sweden 0 2 1 3
Netherlands:
2 = 0 + 2 + 0
requests from 2 SM
Accountant –
administratieconsulent
0 2 0
Germany 0 1 0 1
United Kingdom 0 1 0 1
Portugal:
4 = 3 + 1 + 0
requests from 3 SM
Revisor oficial de contas
4=3+1+0
United Kingdom 1 1 0 2
Poland 1 0 0 1
Spain 1 0 0 1
Romania:
158 positive
decisions (all
positive general
system without
compensatory
measures) requests
from 7 SM
Financial Auditor
158 0 0
Bulgaria 2 0 0 2
Cyprus 2 0 0 2
Germany 2 0 0 2
Italy 2 0 0 2
United Kingdom 147 0 0 147
Poland 1 0 0 1
Slovakia 2 0 0 2
Spain:
11 positive decisions
requests from 2 SM
Auditor de cuentas
11 0 0
France 3 0 0 3
United Kingdom 8 0 0 8
TOTAL:
14 host countries
17 registered within the
IMI system
21 countries of origin
for the qualification
791 56 80 927
Source: made by the author with the data from the IMI system, the situation of decisions for
permanent provision only for the financial auditor profession in all generic categories in
which they were registered, on 16.07.2013, at http://ec.europa.eu/internal_market/
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qualifications/regprof/index.cfm?action=profession&id_profession=2100&tab=countries&qui
d=2&mode=asc&maxRows=*#top
From this statistical statement we can say the fact that Romania is among the 14 EEA MS
who had received requests for recognition of qualifications acquired in other MS, ranking the
second in number of decisions adopted, after Cyprus. If we consider, however, that out of the
158 decisions taken, 147 refers to individuals who have acquired the qualification in the UK,
it could in fact be about the Romanian citizens who have obtained the ACCA qualification in
Romania, that reflects not necessarily the mobility of professionals, but rather the quality of
ACCA qualifications and their international recognition.
The same situation could be also in the case of Cyprus, with those 470 decisions for
recognition of qualifications gained in the UK, out of the total of 478 decisions adopted by the
SM. What can be still noted is that both the case of Cyprus as well as of Romania, all 478,
respectively the 158 were positive recognition decisions without compensatory measures.
Romania, however, does not appear among the countries of origin of the financial auditor
qualifications, according to the records made by the CA included in IMI system. The fact that
the UK won the first place with 74% of applicants for recognition of their qualification
confirms reputation of British qualifications among the CA of EEA MS.
Graphically, the statistics on mobility based on establishing regime / permanent performance
of the financial audit professions is as follows:
Chart 3.1. - Structure of financial auditor qualifications recognition based on types of
decisions
85%
6%
9%
Dec iz ii poz itive
Dec iz ii negative
Dec iz ii neutre
Positive decisions
Negative decisions
Neutral decisions
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Chart 3.2. - Structure per host countries of the financial auditor qualifications recognition
decisions
52%
17%
13%
7%
2%2%7%
C ipru
R omania
Marea B ritanie
G ermania
Irlanda
B elgia
R es tul de 8 tari
Chart 3.3. - Structure per countries of origin of the financial auditor qualifications recognition
requests
74%
7%
5%
3%2%
9%
Marea B ritanie
Italia
F ranta
Irlanda
G ermania
R es tul de 16 tari
Source: all three charts are based on the data processed by the author from the EC database
with the regulated professions listed in Table 3.1
Among the most mobile professions by permanent provision regime (establishment), during
1997/8 - 2012 the existing generic categories in the IMI system which include also the
financial auditor profession were placed on the following positions:
• heading 46 - auditor / accountant, with 815 decisions;
Cyprus
Romania
United Kingdom
Germany
Ireland
Belgium
The other 8 countries
United Kingdom
Italy
France
Ireland
Germany
The other 16 countries
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• heading 74 - accountant / tax advisor with 416 decisions;
• heading 121 - company auditor, with 158 decisions (all adopted by Romania);
• heading 355 - public finance accountant, with 3 decisions (all taken by Ireland on financial
audit).
Out of the 448 generic categories listed (for which there have been recognition requests in this
period), with those 927 decisions, the financial auditor profession would have been in rank
45, which proves that compared with other accounting professions and tax consultancy
included in the generic categories which also include financial auditor profession, the latter
were the most mobile.
The temporary provision of statutory audit services is considered impossible (because the
auditor or the audit firm must be registered within the MS where it provides statutory audit
services). Non-statutory audit activity can be done however also temporary, case in which, if
the activity is regulated, the CA of the host MS may request cross-border provision
notification, but it is not mandatory, it is up to the CA of the respective country.
Among the MS analyzed, in the Czech Republic, KACR require written notification prior to
providing services, which must include the following information:
• name, surname;
• correspondence address in the Czech Republic;
• copies of formal qualifications which enable of the financial audit provision of services;
• the audit services to be provided;
• the place of supply and the estimated duration of service provision.
The process of qualification recognition is available but only in the case of establishment /
permanent provision. As already stated in the Chapter 1 of this guide, the financial auditor
profession fall under the general system of qualifications recognition referred to in Directive
2005/36/EC on recognition of professional qualifications. In this case, the recognition is not
automatic, but requires a comparison between the training provided in the two states – the one
in which the applicant has acquired the qualification (country of origin) and the one in which
it wants to permanent practice its profession (host country), and also the possibility, in the
case of "substantial differences", of the application of compensatory measures (aptitude test or
adaptation period - Article 23 of the Directive).
Moreover, in respect of the recognition of qualifications acquired in other MS, also the
Directive 2006/43/EC on statutory audits of annual accounts and consolidated accounts
provides that the CA of MS must establish procedures for the approval of statutory auditors
who have been authorized in another MS and that these procedures should not exceed the
requirement to pass an aptitude test according to the provisions of Directive on recognition of
professional qualifications test which is held in one of the languages permitted by the
language rules applicable in the Member State.5
5 Directive 2006/43/EC of the European Parliament and of the Council of 17 May 2006 on statutory audits of
annual accounts and consolidated accounts JO L 157, 9.06.2006, p.87 – art. 14
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For the general system of recognition, the application for recognition is submitted to the CA
of the host MS. This application must be accompanied by a series of documents and
certificates listed in Annex VII to Directive 2005/36/EC.
The documents that can be requested when submitting an application for recognition are:
• proof of nationality;
• evidence of establishment in another MS of the EU, EEA or Swiss Confederation;
• documents regarding professional qualification, competences and practical experience:
certificate of competence or evidence of formal qualification issued by the CA of the origin
MS;
• other documents, if they are required also to financial auditors from the host MS - evidence
of reputation, solvency, proof that the applicant is medically fit, financial status, professional
insurance.
The CA from the host MS may request, only for the most important documents, copies and
translations authenticated by a notary, but not for standardized documents (e.g. passport,
identity card). Also, there can not be required original documents, only copies. In the case
when the applicant can not provide all the requested information, CA of the host country
should try to obtain them from the CA of the origin MS trough the IMI system.
As recognition procedure, the CA of the host MS shall, within one month, to confirm the
receipt of the file and to draw attention to any missing documents, if applicable. The CA
deadline to grant recognition or decide to apply an aptitude test is 4 months. Any rejection
must be substantiated and the rejection or failing to take a decision within the time limit
mentioned above could be challenged before the national courts.
The aptitude test can be applied provided that the CA of the host MS, based on the documents
received determines the differences between the two qualifications which must be covered by
compensatory measures. As financial audit activity requires knowledge of the relevant
national legislation, the aptitude test is a compensatory measure used in most cases of
recognition of this qualification. In the vision of EC, the CA of the host MS should hold at
least two sessions of aptitude tests per year. In order to achieve the recognition and organize
the aptitude test, the CA may charge a fee provided that it does not exceed the costs involved
and is not discriminatory against its own nationals placed in similar situations.
Once obtained the qualification recognition, the financial auditor can practice the profession
in the same conditions as those acquired the qualification in the host MS, the professional
regulations of the host MS being applicable, including the use of professional titles in that
country.
In the Table 3.2 we present the characteristics of the qualification recognition process of
financial auditor in the 9 analyzed MS
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Table 3.2
Comparative analysis of the qualification recognition processes of financial audit in the 9 MS MS Austria Czech
Republic
Denmark Germany Italy United Kingdom Netherlands Romania Spain
CA for qualification
recognition
KWT,
AeQ
KACR DCCA WPK Ministry of Justice ACCA, ICAEW,
ICAS
AFM CAFR
ICAC
Qualification
recognition
procedure
Aptitude test Aptitude test Aptitude test Aptitude test Aptitude test Aptitude test Aptitude test Aptitude test Aptitude test
CA for the Aptitude
test
KWT KACR DCCA WPK Ministry of
economy and
finance
ACCA, ICAEW,
ICAS
Commissie
Eindtermen
Accountantsopleiding
(CEA)for admission for testing
NBAfor testing
CAFR
ICAC
Test type 2 written exams and one oral
exam
written oral written and oral oral ACCA: written and oral;
ICAEW: online
testing; ICAS: written and oral
oral for
Registeraccountant,
written and oral for
Administratieconsulent
written and oral written
The main topics Written: general
legal doctrine, tax legislation
Oral professional
law, quality assurance
The financial
reporting, the tax
and commercial, legislation audit
with focus on
national regulations
Tax, commercial
and professional legislation,
Tax, commercial
and professional legislation,
On a case by case
basis, usually tax,
commercial, professional,
ethical legislation,
Law and Taxation in
the UK
Civil, commercial,
fiscal, professional legislation, accounting
law
Financial audit,
internal audit,
fiscal code, commercial
code, accounting
law
Spanish
legislation applicable to
audit
Test language German Czech Danish German Italian English Dutch/ English for Registeraccountant,
Dutch for
Administratieconsulent
Romanian / English
Not specified
The frequency of
organizing the
aptitude tests
On request 2 times / year 2 times / year Once a year Once a year ACCA: 2 times / year written examination,
oral examination on
request; ICAEW: permanently
available online test;
ICAS: writing -
2 times / year 2 times / year (June and
November)
Every two years
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legislation 5 times / year, tax 3 times / year
oral examination on
request
The possibility of
re-testing
Yes Yes, but only
within 2 years
Yes , three times Yes, two times Yes Depending on the
professional body
Yes, unlimited Yes, unlimited Not specified
Source: FEE – Key Features on Structure and Organization of the Accountancy Profession across 30 European countries, 26 March 2012
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One possibility, simpler than legal / statutory approach for complaining against a decision
regarding the recognition of qualifications, considered as not in line with Directive
2005/36/EC on the recognition of professional qualifications, is the appeal to the SOLVIT
system.
The SOLVIT is an online network, operational since July 2002, in which the EU MS are
working together to solve in a pre-legal stage, problems caused by the misapplication or non-
application of Internal Market Community legislation by the public authorities. There is a
SOLVIT centre in every EU MS, as well as in Norway, Iceland and Liechtenstein. The
centers are part of the central government and must give solutions to the problems raised by
citizens or companies within 10 weeks, and the network utilization is free.
The Romanian SOLVIT Centre is located within the Ministry of European Affairs (can be
contacted at e-mail [email protected] ).
The SOLVIT mechanism operating conditions are:
• to be about the failure or misapplication of EU legislation by a Member State administration,
• to be about a cross border case
• that there is no action already in place for its settlement.
The cross border nature does not imply the petitioner to be in another MS than the one where
the problem has occurred. It is enough to have an international element that could make
applicable the provisions of Community legislation (e.g., a Romanian citizen wants to
practice in Germany and has difficulty on engagement). The functioning of the SOLVIT
system is shown in the diagram below.
Source: http://www.romania-actualitati.ro/conceptul_de_cetatenie_europeana-50325 (as of
07/17/2013)
How does it work
Country A Country A
Home
SOLVIT
centre
Lead
SOLVIT
centre
Work together to
find solutions
Work
together to
present
problem
and find
solutions
Work
together to
negotiate
problem
Problem
Natural or legal
person
Public
Authority
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For instance, if a Romanian citizen has a complaint regarding the rules of the internal market,
it will address SOLVIT ROMANIA (the organization that can handle the case depending on
the nationality of the person who submitted the complaint). If a Romanian citizen has
obtained the qualification in Austria, wishing to be employed in Germany and has a complaint
in this regard, it will address the centre in Austria. The application will be analyzed and if
deemed that the case is a breach of the Community law, it will contact LEAD SOLVIT centre
(responsible SOLVIT Centre). If they agree with the proposal, it will go further to the
respondent authority. The client is assisted in a language he understands, but more important
is that there is a SOLVIT centre responsible who knows what procedures should be followed
and which authorities should be contacted to resolve the issue. In order to obtain a good
result, SOLVIT rely on the relationship with the respondent authority. This is because it is an
informal network and does not have the authority of a judge.
The reasons for which not all the petitions are addressed include:
• certain issues related to the Member State legislation, if it can not give a quick solution, the
case is considered unsolved;
• the respondent authority is not willing to cooperate, in which case the petitioner is advised to
consult the courts which are able to oblige the CA to modify their behavior accordingly to the
reported aspect.
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4. EXERCISE OF THE FINANCIAL AUDITOR PROFESSION IN THE EU
The financial auditor is part of the financial liberal professions category, as the financial audit
can be performed either with a freelancer status, either as a partner or employee of a financial
audit firm (or accounting, financial audit, tax advice according to CAEN code 692, who is
registered and authorized to provide financial audit). Therefore, all national registries in
which are mandatorily registered the financial audit service providers, include both
individuals and legal auditor entities - companies authorized for financial audit.
At the EU level, also the manner of exercise of the financial auditor profession has a high
level of harmonization (compared to other categories of professionals in accounting and tax
consultancy services) provided by the transposition of the Directive 2006/43/EC on statutory
audits of annual accounts and consolidated accounts into the MS national legislation.
Thus, with respect to the exercise of the profession of statutory auditor, the minimum
obligations set out in Directive 2006/43/EC are the following:
The competent authorities of a Member State may grant approval only to natural persons
or firms of good repute. (art.4);
statutory auditors and audit firms are subject to principles of professional ethics, covering
at least their public-interest function, their integrity and objectivity and their professional
competence and due care. (art.21);
statutory auditors and audit firms must be independent when carrying out a statutory audit,
the statutory auditor and/or the audit firm is independent of the audited entity and is not
involved in the decision-taking of the audited entity, and if the significance of the threats
to her or its independence(direct or indirect financial interest to the audited entity,
provision of additional non-audit services the level of fees received from one audited
entity and/or the structure of the fees) even after the safeguards applied to mitigate those
threats, is to high, they must to resign or abstain to accept the audit mission; (art.22) the
owners or shareholders of an audit firm as well as the members of the administrative,
management and supervisory bodies of such a firm, or of an affiliated firm, do not
intervene in the execution of a statutory audit in any way which jeopardizes the
independence and objectivity of the statutory auditor who carries out the statutory audit on
behalf of the audit firm. (art.24);
statutory auditors and audit firms have the obligation to follow strict rules on
confidentiality and professional secrecy (art.23);
statutory audits to be carried out in compliance with international auditing standards
adopted by the Commission, Member States may adopt a national auditing standard as
long as the Commission has not adopted an international auditing standard covering the
same subject-matter (art. 26);
statutory auditors and audit firms are subject to a system of quality assurance which shall
be organized in such a manner that it is independent of the reviewed statutory auditors and
audit firms and subject to public oversight (art.29);
Statutory auditors and audit firms are responsible for carrying out their work with due care
and thus should be liable for the financial damage caused by a lack of the care owed, but
the auditors' and audit firms' ability to obtain professional indemnity insurance cover may
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be affected by whether they are subject to unlimited financial liability; for its part, taking
into account the fact that liability regimes of the Member States may vary considerably,
the Directive 2006/43/CE provide the EC commitment to make a report on the impact of
the liability limits, and to carry out, where appropriate, public consultation and , if
appropriate, to submit recommendations to the Member States (art.31).
This level of harmonization of the exercise of financial auditor profession in all EU MS,
facilitate the mobility of professionals across the single market, provided that any auditor who
wishes to establish themselves in another MS than that in which it acquired the qualification
and practiced the profession knows that:
• it must follow the process of recognizing of its qualification as detailed in Chapter 3 of this
guide;
• it will not be authorized by the CA of the host MS unless it has a good reputation;
• it will have to respect the code of ethics and professional conduct adopted by the MS CA
• it will exercise his profession on the same principles of independence, objectivity,
confidentiality and professional secrecy;
• it will continue to apply international auditing standards adopted by the EC (and published
in all languages in the Official Journal of the EU MS);
• it will have to undergo quality assurance reviews at least once every six years or every three
years if it carry out statutory audits for the public interest entities;
• it will need to be informed of the specific requirements of professional liability insurance,
because the liability regime still vary from one MS to another.
But an even higher degree of harmonization / standardization was achieved at the sectoral
level, through the efforts of international and european professional organizations of
professionals in the accounting and financial audit.
The International Federation of Accountants - IFAC (International Federation of
Accountants), established in 1977 by 63 founding members from 51 countries, has now
reached 173 members and associated organizations from 129 countries and jurisdictions
around the world, representing thus about 2.5 million professionals in accounting and
financial audit in the public sector, education, government and private sectors.
In turn, the Fédération des Experts-comptables Européens / Federation of European
Accountants - FEE (Federation of European Accountants) represents more than 700,000
professionals in Europe through its 45 member organizations from 33 European countries,
and also plays the role of Regional Organization of IFAC.
IFAC ensures the development of the accounting professions in the public interest by:
• development of international accounting standards for the public sector (IPSA), financial
audit (ISA), Ethics and Training (IES) , also provision of technical assistance for their
adoption and use;
• facilitating collaboration and cooperation between the member professional bodies;
• collaboration and cooperation with other international organizations;
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• representing the interests of accounting and financial audit professionals internationally.
Therefore, practically there have been adopted at international level:
• IFAC Code of Ethics developed by The International Ethics Standards Board for
Accountants (IESBA), an independent body for development of standards on ethics and
professional conduct for accountants and auditors;
• International Standards on Auditing (ISAs) developed by the International Auditing and
Assurance Standards Board (IAASB) independent body;
• International Training Standards (IESS) developed by the International Accounting
Education Standards Board (IAESB).
The 8 International Training Standards, currently under review, are:
IES 1, Entry Requirements to Professional Accounting Education
IES 2, Initial Professional Development-Technical Competence
IES 3, Initial Professional Development-Professional Skills
IES 4, Initial Professional Development-Professional Values, Ethics, and Attitudes
IES 5, Initial Professional Development—Practical Experience
IES 6 Initial Professional Development – Assessment of Professional Competence
IES 7 Continuing Professional Development
IES 8 Professional Development for Engagement Partners Responsible for Audits of
Financial Statements
In the Table 4.1, we took from the FEE study and from national sources some additional
information on conditions governing the financial auditor profession as well as statistical data
which suggests the size of the professional community of auditors in the 9 analyzed MS.
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Table 4.1
Requirements for the exercise the financial auditor profession in the MS analyzed
MS Austria Czech
Republic
Denmark Germany Italy United Kingdom Netherlands Romania Spain
Professional
address
Yes, in any MS of SEE
is requested for Czech residents,
not to foreigners
Not required (establishment /
residence in a MS is
sufficient)
Not required (establishment /
residence in a MS is
sufficient)
Yes, it is required Not necessary. only the contact address is
required
Yes, in the Netherlands
Yes, it is required Yes, necessary for registration into
register
Business
infrastructure
required
Yes - Not required
(establishment / residence in a MS is
sufficient)
Not required
(establishment / residence in a MS is
sufficient)
" stable
infrastructure " (there is no
definition)
Not necessary The auditor must be
in the service of an audit firm authorized
by AFM
Yes, authorized
person or within a financial audit firm
Not necessary
Professional
liability
insurance
Yes Yes Yes Yes Yes, for certain
activities
Yes yes, for statutory
audit
Yes, for. statutory
audit and the non-statutory financial
audit
Yes, 300.000
euro/auditor
Number of
qualified
auditors
2.711 natural and
legal persons
(1.01.2011)
1.350 (march
2012)
4.461 (both
professions in 2009)
aprox. 15.000 aprox. 149.000
revisore legale
7,239 registered audit
firms (31/12/2012)
Members from the United Kingdom and
Ireland 2012:
ACCA =77.269
ICAEW=119.179 ICAS=16.933
aprox. 20.500 both
professions
4.251 natural
persons
975 firms (may 2013)
19.616 (March
2011)
Number of
trainees / year
- 80 - 90 220 (both
professions in 2009)
aprox. 500 aprox. 13.000
revisore legale
No. members who have
obtained the
qualification in the audit,
2012:
ACCA = 147 ICAEW= 484
ICAS=1.209
aprox. 900 both
professions
1.640 (may 2013) 900 (aprox. 1.800
every 2 years)
Source: FEE – Key Features on Structure and Organization of the Accountancy Profession across 30 European countries, 26 March 2012; the CA
in the 9 MS For information about the number of members and trainees
GOVERNMENT OF ROMANIA Ministry of Education
European Union
GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
and Elderly MASOPHRD
European Social Fund SOP HRD 2007-2013
Structural Instruments 2007 - 2013
Project co financed by the European Social Fund
Sectoral Operational Programme Human Resources Development
2007 - 2013
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37
5. CONCLUSIONS
The regulation of professions from the field of accounting, financial audit and tax consultancy
(NACE code 692) is quite diversified in the EU MS - from the distinct regulation of the
accounting profession, of financial auditor profession and that of the tax consultant (e.g.
Romania) to the lack of regulation of any profession except those who have reserved the
statutory audit activity (e.g. Spain).
For the statutory audit services it was reached a high level of harmonization within the EU,
through the transposition of the Directive 2006/43/EC on statutory audits of annual accounts
and consolidated accounts into national legislation of the MS, which provides also the
regulatory framework for the profession of financial auditor, including requirements for
professional qualifications and mutual recognition of qualifications acquired in another MS
than that of establishment / permanent performance of statutory audit services.
The CA for auditors are public bodies in some MS or associations invested by law in other
MS. If it is a ministry or government agency (e.g. Denmark, Italy, UK), the professional
organizations may be invited to become involved in the decisions or have delegated tasks for
competences assessment and certification, registration, continuing professional development
(ex. Great Britain).
In the field of education and continuous vocational training, the assessment of learning results
is already widely used, especially due to the development of procedures independently on
sectoral level at international level (international training standards developed by the IAESB,
professional code of ethics developed by IESBA, international auditing standards developed
by the IAASB, high quality qualifications offered by British institutions, especially the
ACCA, and recognized at international level). Therefore, national authorities tend to have
confidence in the diplomas and the certificates issued by national bodies of other MS, thus
facilitating the mobility of the financial auditors in the EU's internal single market.
According to the Directive 2005/36/EC on the recognition of qualifications, the financial
auditor profession fall under the general system of recognition of qualifications, to a level of
qualification that certifies successful completion of training courses at post-secondary
education level, university level with a duration of 3-4 years or more than four years.
Taking into account the fact that the financial audit services implies knowledge of
commercial, fiscal and labor legislation of the host MS, the aptitude test as a compensatory
measure in the process of recognition of qualification acquired in another MS is widely used.
The statistics in the IMI system regarding qualifications recognition processes during 1997/8 -
2012 for the establishment / permanent performance demonstrates that the financial auditor
profession is relatively mobile in general terms and among the most mobile professions in the
field of accounting, auditing financial and the tax consultancy (position 45 of the 448 generic
categories of professions for which were recorded decisions of recognition during this period,
if we consider the 927 decisions were adopted strictly for financial auditor qualification
GOVERNMENT OF ROMANIA Ministry of Education
European Union
GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
and Elderly MASOPHRD
European Social Fund SOP HRD 2007-2013
Structural Instruments 2007 - 2013
Project co financed by the European Social Fund
Sectoral Operational Programme Human Resources Development
2007 - 2013
Invest in people!
http://www.imipqnet.ro
38
recognition, regardless of the generic category in which the respective regulated professions
were registered).
Moreover, the process of globalization, on the one hand and the international re-regulation of
financial services, from the financial and economic crisis in 2007, on the other hand,
determines the need for financial and audit professionals to follow the clients within the
internationalization process of their businesses.
GOVERNMENT OF ROMANIA Ministry of Education
European Union
GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
and Elderly MASOPHRD
European Social Fund SOP HRD 2007-2013
Structural Instruments 2007 - 2013
Project co financed by the European Social Fund
Sectoral Operational Programme Human Resources Development
2007 - 2013
Invest in people!
http://www.imipqnet.ro
39
BIBLIOGRAPHY
Directive 2006/43/EC of the European Parliament and of the Council of 17 May 2006 on statutory
audits of annual accounts and consolidated accounts, OJ L 157, 9.6.2006, at
http://www.justice.gov.md/file/Centrul%20de%20armonizare%20a%20legislatiei/Baza%20de%20
date/Materiale%202010/Legislatie/32006L0043-Ro.PDF
European Commission, Internal Market and Services DG (2010) – Group of Coordinators for the
Recognition of Professional Qualifications – Frequently Asked Questions (Update 22 October 2010
– MARKT D/3418/6/2006-EN) at http://ec.europa.eu/internal_market/qualifications/docs/future/f
aq_en.pdf
European Commission – User Guide, Directive 2005/36/EC, at http://ec.europa.eu/internal_market/
qualifications/docs/guide/users_guide_en.pdf
European Commission – Code of Conduct approved by the Group of Coordinators for the Directive
2005/36/EC on the Recognition of Professional Qualifications – National Administrative Practices
falling under Directive 2005/36/EC – at http://ec.europa.eu/internal_market/qualifications/docs/
future/cocon_en.pdf
European Commission – Commission Staff Working Document on the Transposition and
Implementation of the Professional Qualifications Directive (Directive 2005/36/EC), Brussels, 22
/10/2010, SEC(2010) 1292, at http://ec.europa.eu/internal_market/qualifications/docs/evaluation/
staff-working-doc_en.pdf
DG Internal Market and Services – Revised Final Report – Study Evaluating the Professional
Qualifications Directive against recent educational reforms in EU Member States, 28 October
2011, at http://ec.europa.eu/internal_market/qualifications/docs/policy_developments/final_report_en.pdf
DG Internal Market and Services - Final Report – Study to provide an Inventory of Reserves of
Activities linked to professional qualifications requirements in 13 Member States &assessing their
economic impact, January 2012, at
http://ec.europa.eu/internal_market/qualifications/docs/news/20120214-report_en.pdf; annex H of
the final report at http://ec.europa.eu/internal_market/qualifications/docs/news/20120214-
annex_en.pdf
FEE - Key Features on Structure and Organization of the Accountancy Profession across 30
European countries, 26 March 2012, at http://www.fee.be/images/publications/qualification/
Intro_Structure_and_Organisation_of_the_Profession2732012401312.pdf
GOVERNMENT OF ROMANIA Ministry of Education
European Union
GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
and Elderly MASOPHRD
European Social Fund SOP HRD 2007-2013
Structural Instruments 2007 - 2013
Project co financed by the European Social Fund
Sectoral Operational Programme Human Resources Development
2007 - 2013
Invest in people!
http://www.imipqnet.ro
40
FRC – Key Facts and Trends in the Accountancy Profession, June 2013, at http://www.frc.org.uk/
Our-Work/Publications/Professional-Oversight/Key-Facts-and-Trends-in-the-Accountancy-
Profession.aspx
IFAC, IAASB – 2012 Handbook of International Quality Control, Auditing, Review, Other
Assurance, and Related Services Pronouncements, July 31, 2012, at http://www.ifac.org/
publications-resources/2012-handbook-international-quality-control-auditing-review-other-
assurance-a
IFAC, IESBA™ - Handbook of the Code of Ethics for Professional Accountants, 2013 Edition,
May 2013, at http://www.ifac.org/sites/default/files/publications/files/2013-IESBA-Handbook.pdf
IFAC, International Accounting Education Standards Board - Handbook of International Education
Pronouncements, 2010 Edition, August 2010, at http://www.ifac.org/sites/default/files/publications/
files/handbook-of-international-e-2.pdf
IFAC, IAESB - 2012 IAESB Annual Report: Enhancing Professional Accounting Education,
August 2013, at https://www.ifac.org/sites/default/files/publications/files/IAESB-2012-Annual-
Report_0.pdf
IFAC - Handbook of International Public Sector Accounting Pronouncements, 2013 Edition, vol. I
at http://www.ifac.org/sites/default/files/publications/files/Volume%201_0.pdf
CFE Professional Affairs Committee, editor Rudolf Reibel - European Professional Affairs
Handbook for Tax Advisers, 2nd
edition, March 2013
The Law no. 149/2013 for approving of the Government Ordinance no. 23/2012 for amending and
supplementing the Government Emergency Ordinance no. 90/2008 on statutar audit of annual
financial situations and the consolidated financial situations and the Government Ordinance no.
65/1994 on the organization of accounting exprtise activity and of the certified accountants and for
amending other acts was published in the Official Journal, Part I, no. 257, of May 9, 2013.
GOVERNMENT OF ROMANIA Ministry of Education
European Union
GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
and Elderly MASOPHRD
European Social Fund SOP HRD 2007-2013
Structural Instruments 2007 - 2013
Project co financed by the European Social Fund
Sectoral Operational Programme Human Resources Development
2007 - 2013
Invest in people!
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41
ABBREVIATIONS
AAT - Association of Accounting Technicians (Association of Accounting Technicians from United
Kingdom witch award the AAT qualification)
AC/CA – Competent Authority (for one or more regulated professions)
ACA - Associate of the Institute of Chartered Accountants in England and Wales (intermediate
qualification of ICAEW)
ACCA – Association of Chartered Certified Accountants (Association of Chartered Certified
Accountants in the United Kingdom)
AeQ - Arbeitsausschuss für externe Qualitätsprüfungen (Executive Committee for quality external
audits in Austria)
AFM - Dutch Authority for Financial Markets
ANC/NAQ – National Authority for Qualifications (from Romania)
APAK - Abschlussprüfe-raufsichtskommission (Supervisory Commission of Auditors in Germany)
APOC - Audit Oversight Public Council (in Czech Republic)
CAEN/NACE - National Classification of Economic Activities
CAFR – Chamber of Financial Auditors of Romania
CAT - Certified Accounting Technician (Certified Accounting Technician, qualification in the United
Kingdom)
CE/EC – European Commission
CEA - Commissie Eindtermen Accountantsopleiding (Commission for admission to the aptitude
test held by the NBA in the Netherlands)
CFAB – Certificate in Finance, Accountancy and Business (Certificate in Finance, Accounting and
Business - qualification from the United Kingdom)
Consob - Commissione Nazionale per la Societa e la Borsa (Investor Protection Supervisory
Authority in Italy)
CSIPPC – Council for the Public Interest Oversight of the Accountancy Profession (in
Romania)
CSPAAS - Council for the Public Oversight for Statutory Auditing (in Romania, transformed to
CSIPPC)
DCCA - Erhvervsstyrelsen/Danish Commerce and Company Agency (Danish Commerce and
Companies Agency)
GOVERNMENT OF ROMANIA Ministry of Education
European Union
GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
and Elderly MASOPHRD
European Social Fund SOP HRD 2007-2013
Structural Instruments 2007 - 2013
Project co financed by the European Social Fund
Sectoral Operational Programme Human Resources Development
2007 - 2013
Invest in people!
http://www.imipqnet.ro
42
DG/GD – General Directorate
DSAA - The Supervisory Authority on Auditing (he Supervisory Authority on Auditing in Denmark)
EFP/EVT - Education and vocational training
FEE – Fédération des Experts-comptables Européens/ Federation of European Accountants (Federation
of European Accountants)
FPC/CVT – Continuous Vocational Training
FRC – Financial Reporting Council (Financial Reporting Council in United Kingdom)
HGB - Handelsgesetzbuch (German Commercial Code)
IAASA - The Irish Auditing and Accounting Supervisory Authority
IAASB - International Auditing and Assurance Standards Board
IAESB – International Accounting Education Standards Board
ICAC - Instituto de Contabilidad y Auditoria de Cuentas (Institute for Accounting and Auditing of
Accounts in Spain)
ICAEW - Institute of Chartered Accountants in England and Wales
ICAS - Institute of Chartered Accountants of Scotland
IESs – International Training Standards (developed by IAESB)
IESBA - The International Ethics Standards Board for Accountants
IFAC – International Federation of Accountants
IMI – Internal Market Information system (Internal Single Market Information system in EU)
IMM/SMEs – Small and Medium Enterprises
IPS - Institute for Social Policy (in Romania)
JO – Official Journal of UE
KACR - Komora auditorů ČR (Chamber of Auditors of the Czech Republic)
KWT - Kammer der Wirtschaftstreuhänder (Austrian Chamber of Public Accountants)
MEN – Ministry of National Education (in Romania)
MO – Official Journal (in Romania)
NBA - The Institute which is the CA for financial audit regulated profession in the Netherlands
NIVRA - Koninklijk Nederlands Instituut van Registeraccountants (Royal Institute of Chartered
Registered Accountants in the Netherlands, which merged with NovAA forming the
NBA Institute)
GOVERNMENT OF ROMANIA Ministry of Education
European Union
GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
and Elderly MASOPHRD
European Social Fund SOP HRD 2007-2013
Structural Instruments 2007 - 2013
Project co financed by the European Social Fund
Sectoral Operational Programme Human Resources Development
2007 - 2013
Invest in people!
http://www.imipqnet.ro
43
NovAA – Nederlandse Orde van Accountants Administratieconsulenten (The Netherlands Order of
Accounting Consultants in the Netherlands, which merged with NIVRA forming
NBA Institute)
OG/GO - Government Ordinance (in Romania)
OKB - Qualitätskontrollbehörde (Austrian Auditors Supervisory Authority)
OUG/GEO - Government Emergency Ordinance (in Romania)
POB - Professional Oversight Board (Professional Oversight Board in the United Kingdom)
SEE/EEA – European Economic Area (all EU MS + Iceland, Liechtenstein, Norway)
SM/MS – Member State (of the European Union)
UE/EU – European Union
WP/vBP - Berufssatzung (Charter of Professions in Germany)
WPK - Wirtschaftsprüfer-kammer (Chamber of Public Accountants, CA for financial auditors in
Germany)
WPO - Gesetz über eine Berufsordnung der Wirtschaftsprüfer (Law on Public Accountant in
Germany)
WT-Arl - Directive on practice of public accounting profession in Austrasia
WTBG - Wirtschaftstreuhandberufsgesets (Statute of public accountants’ professional practice in
Austria)
GOVERNMENT OF ROMANIA Ministry of Education
European Union
GOVERNMENT OF ROMANIA Ministry of Labour, Family, Social Protection
and Elderly MASOPHRD
European Social Fund SOP HRD 2007-2013
Structural Instruments 2007 - 2013
Project co financed by the European Social Fund
Sectoral Operational Programme Human Resources Development
2007 - 2013
Invest in people!
http://www.imipqnet.ro
44
USEFUL LINKS
• List of national supervisory bodies of public interest
http://ec.europa.eu/internal_market/auditing/links/index_en.htm
• EC Regulations adopting international accounting standards -
http://ec.europa.eu/internal_market/accounting/legal_framework/regulations_adopting_ias/ori
ginal_text_en.htm
• EC database of the regulated professions in the MS –
http://ec.europa.eu/internal_market/qualifications/regprof/index.cfm?newlang=en
• National Contact Points for qualifications recognition from MS
http://ec.europa.eu/internal_market/qualifications/contact/national_contact_points_en.htm
• MS SOLVIT Centers http://ec.europa.eu/solvit