professions in the field of accounting
DESCRIPTION
ÂTRANSCRIPT
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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
GUIDELINE FOR THE CERTIFICATION OF
COMPETENCIES AND THE RECOGNITION OF
QUALIFICATIONS FOR THE PROFESSIONS IN THE
FIELD OF ACCOUNTING
Author: Irina Dumitriu, Phd.
July 2013
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CONTENTS
Introduction..............................................................................................3
1. Statement of regulations in Romania and other EU MS
of professions in the field of accounting............................................6
2. Procedures for the certification of competencies applied
by CA in the countries where the professions
are regulated....................33
3. Processes for the recognition of qualifications achieved in other
EU MS for practicing the professions in the field of
accounting.......................37
4. Exercising professions in accounting in the EU..............................53
5. Conclusions........................................................................................58
Bibliography...........................................................................................60
Abbreviations.........................................................................................66
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Useful Links..........................................................................................71
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INTRODUCTION
The guideline for the certification of competencies and the recognition of
qualifications for the professions in the field of accounting is one of the
results of the project “Network of Competent Authorities for Professional
Qualifications in Romania (IMI PQ NET Romania)” implemented by the
Ministry of National Education (MEN) in partnership the National
Qualifications Authority (ANC) and the Social Policies Institute (IPS),
co-funded from the European Social Fund through the Sectoral
Operational Programme Human Resources Development 2007 – 2013
(POSDRU).
The project IMI PQ NET Romania analyzed with the competent
authorities (CA) members of the project Work Group, the procedures for
the certification of the competencies and the processes for the
recognition of qualifications for each profession regulated partly on this
basis also, they developed standard schemes for the procedure for the
certification of the competencies and the processes for the recognition of
qualifications for each profession regulated. The final result of these
activities is the material entitled “Standard terms of reference for the
procedures of validation and certification of competencies and
processes of recognition of qualifications”, which can be accessed at
................................................ ....................................
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This material includes the basic terminology (the definitions of the terms
used in guidelines as well) and the standard schemes for the procedures
for the certification of the competencies and the processes for the
recognition of qualifications and this is why it was the basis of a number
of 30 guidelines for the certification and recognition of different
regulated professions, guidelines aiming at supporting the CA in
Romania in their efforts to standardize such procedures and processes, in
informing the, on the practices of the homologous CA in other EU
Member States (MS).
At the same time, each guideline separately addresses the people having
acquired the qualifications in that field of activity in Romania, wanting to
practice the profession in a EU MS, as presented in the guideline.
The analysis was performed from Romania and 8 other EU MS (Austria,
the Czech Republic, Denmark, Germany, Italy, Great Britain, the
Netherlands and Spain) but the guideline includes some general
information as well, resulting from the research of the database including
all the regulated professions in all the EU MS of the European Economic
Area (EEA) and the Swiss Confederation, develop by the European
Commission (EC), the DG Internal Market), at
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(http://ec.europa.eu/internal_market/qualifications/regprof/index.cfm?ne
wlang=en).
The authors of the guidelines researched the European laws and of the
respective states regarding the achievement of qualifications, the
Vocational Education and Training (VET), types of certification
documents (diplomas, certificates, certificates of competency,
professional titles) regulations in the certification of competencies and
the recognitions of qualifications, the professions regulated according to
the Directive 2005/36/EC on the recognition of professional
qualifications. In the case of several EU SMs analyzed (Denmark,
Germany, Italy, Great Britain, the Netherlands and Spain), there were
study visits attended by the representatives of the members of the IMI
PQ NET Ro Network, constituted within the project, as well as MEN and
ANC experts. The visits consisted of meetings with the representatives of
CA at the national level as well as CA managing different regulated
professions, occasions on which the authors of the guidelines were able
to collect more concrete information from a direct source.
In conclusion, the guide for the certification and recognition of
accounting professions aims at:
assisting the Body of Expert and Licensed Accountants of
Romania (Corpul Experţilor Contabili şi Contabililor Autorizaţi
din România - CECCAR) in their effort to standardize the
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procedure for the certification/award of the professional titles of
expert an licensed accountant and the process of recognition of
such qualifications, in informing them on the practices of the
homologous CA in other EU SMs;
informing the people having been conferred the necessary
qualifications and professional titles in Romania, wanting to practice
in the field of accounting services in one of the EU SMs presented in
the guideline.
1. STATEMENT OF REGULATIONS IN ROMANIA
AND OTHER EU MS
OF PROFESSIONS IN THE FIELD OF ACCOUNTING
The present European regulatory framework in the field of the
recognition of professional qualifications acquired in the EU MSs mainly
consists of the Directive 2005/36/EC of the European Parliament and of
the Council of 7 September 2005 on the recognition of professional
qualifications, as well as a series of sectoral directives in case of some
professions which are not covered or are only covered in certain specific
situations by the Directive 2005/36/EC (such as, Directive 2006/43/EC
on statutory audits of annual accounts and consolidated accounts,
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Directive 2002/92/EC on insurance mediation or the Directives
1977/249/EEC and 1998/5/CE in case of lawyers).
The Directive 2005/36/EC institutes a system for the recognition of
professional qualifications in order to contribute to the flexibility of the
EU labor market, in order to continue the liberalization in the field of
services (Directive 2006/123/EC on services in the internal market), in
order to encourage the autonomous recognition of qualifications and
simplify the administrative procedures. This directive applies to all the
European citizens wanting to exercise a regulated profession, either as a
free-lancer or an employee, in a MS different than that where they were
conferred the professional qualifications and distinguishes between the
“freedom to provide services” and the “freedom of establishment” based
on some criteria, such as duration, frequency, periodicity and continuity
of service.
From the point of view of the manner of recognizing the professional
qualifications subject to it, the Directive 2005/36/EC regulates the
following recognition systems:
the system of automatic recognition based on professional
experience in certain industrial, commercial and craft
activities – activities listed in chapter II, for which the elements
taken into consideration in the recognition of the professional
experience are the duration and the form (as free-lancer or
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employee) and the previous training (element which may reduce
the duration of the necessary professional experience), proven by
a certificate recognized by the MS or considered valid by a
competent professional body and the exercise conditions are
mentioned in the lists for different groups of sectors of activity
included in Appendix IV of the Directive;
the system of automatic recognition of the qualifications for
the professions of doctor, nurse, dental practitioner,
veterinary surgeon, midwife, pharmacist and architect –
professions provided in chapter III, for which the automatic
recognition of qualification titles is made on the basis of
coordination of minimum training conditions, including the
minimum duration of studies, the qualification titles mentioned
in appendices V and VI of the Directive;
The general system for the recognition of professional
qualifications – system which applies to the professions which
are not regulated by specific rules of recognition and certain
situations where the holder of the professional qualification does
not comply with the conditions provided in other recognition
systems, system based on the principal of mutual recognition,
without affecting the application of certain compensation
measures in case there are significant differences between the
training acquired by that individual and the training necessary in
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the host MS (adaptation period of up to three years or an aptitude
test).
From the point of view of the level of the qualifications subject to the
general system for recognition, the Directive 2005/36/EC distinguishes
among 5 levels of professional qualification:
an attestation of competence issued by a CA in the home MS,
attesting either that the holder has acquired general knowledge
corresponding to general primary or secondary education or that
they have attended 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;
a certificate attesting to a successful completion of a secondary
course, technical or professional in character, supplemented by
professional training;
a diploma certifying successful completion of training at post-
secondary level of a duration of at least one year or training
which provides a comparable professional standard and which
prepares the trainee for a comparable level of responsibilities and
functions;
a diploma certifying successful completion of training at post-
secondary or university level of at least three and not more than
four years' duration;
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a diploma certifying that the holder has successfully completed a
post-secondary or university course of at least four years'
duration.
The regulated professions in the field of accounting are subject to the
general system for the recognition of professional qualifications, on
several levels of qualification, from the certificate attesting to a
successful completion of a secondary course to a diploma certifying
that the holder has successfully completed a university course of at
least four years' duration.
As in the case of the other European directives, all the EU SMs had to
comply with the Directive 2005/36/EC through its transposition in the
national legislation. Hence, the relevant information on the procedure
and the rules of the processes for the recognition valid in each MS is
included in the national legislation transposing the Directive 2005/36/EC
and it may be obtained at the National Contact Points for the
recognition of qualifications all the MSs had to create (as listed at
http://ec.europa.eu/internal_market/qualifications/contact/national_conta
ct_points_en.htm).
Other European directives relevant for the accounting activity are: the
Directive 2013/34/EC on the annual financial statements, consolidated
financial statements and related reports of certain types of undertakings
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(care amending Directive 2006/43/EC on statutory audits of annual
accounts and consolidated accounts and repealing Directive 78/660/EEC
on the annual accounts of certain types of companies and Directive
83/349/EEC on consolidated accounts), Directive 2004/109/EC on the
harmonisation of transparency requirements in relation to information
about issuers whose securities are admitted to trading on a regulated
market, the Directive on Services 2006/123/EC, Directive 2005/60/EC
on the prevention of the use of the financial system for the purpose of
money laundering and terrorist financing, Directive 2011/83/EU on
consumer rights and Directive 2000/31/EC on electronic commerce.
According to the National Classification of Economic Activities
(NACE), the financial audit activities are part of the same group of
economic activities as accounting and tax consultancy (group 692 –
Accounting, bookkeeping and auditing activities; tax consultancy), group
which along with group 691 – Legal activities, makes up Division 69 –
Legal and accounting activities. That is why, from the point of view of
the activities reserved to different regulated professions corresponding to
the services of the NAME group CAEN 692, in practice, there are
overlappings between the accounting professions, those of financial audit
and tax consultancy, different from one country to the other. There are
few countries such as Romania, where there are distinctly regulated
professions on the three sub-fields of activity. In some countries,
although there are distinctly regulated professions, there is one CA where
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all the holders of professional title sin accounting, financial audit and tax
consultancy are members, in other countries the professions names
include the term “accountant”, however they are regulated only for the
activity, exclusively reserved to, of statutory financial audit, whereas the
accounting activities are not reserved to these professions (e.g. the
Netherlands). Moreover, all the studies identified and used as
information source treat the professions of the NACE group 692
altogether, as accounting professions. Also, from the point of view of the
knowledge necessary for the practice of the professions pertaining to the
NACE group 692, all these professions have a common basis (that is
why FEE – Fédération des Experts-comptables Européens/Federation
of European Accountant treats in its paper “Structure and
Organisation of the Accountancy Profession” both the proper
accounting professions and the financial auditor and tax consultant
professions (in the countries where the latter is a distinct profession).
For the same reason, in the IMI system – the electronic platform of the
exchange of information between the CA of the EU SMs, EEA and
Switzerland for the mutual recognition of the professional qualifications,
there are several generic categories for the regulated professions in the
accounting field: Auditor/accountant, Accountant/tax advisor,
Accounting technician, Commissioned bookkeeper, Management
accountant, Payroll accountant, Public finance accountant. As it
results from the name of the two generic categories Auditor/accountant
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and Accountant/tax advisor, MSs mentioned in these categories not only
the accounting professions but also the regulated professions of financial
audit and the tax consultancy professions respectively. Hence, in order to
treat the guideline dedicated to CECCAR (since in the project, there were
distinct guidelines for the Chamber of Financial Auditors of Romania
[Camera Auditorilor Financiari din România] – CAFR and for the
Romanian Chamber of Tax Consultants [Camera Consultantilor Fiscali
din România] - CCF) only for the professions regulated from the point of
view of the activities in the sub-field of accounting, it was necessary in
the two generic categories to identify and eliminate the professions in
financial audit and tax consultancy.
In exchange, the regulated professions which have exclusively (other
qualifications/professions do not have the right to carry the same
activity) or partly (only two or more regulated qualifications/professions
have the right to perform that activity but for the people holding no
qualification in the case) reserved both accounting activities and
financial audit and tax consultancy activities, were included in analysis
presented in this guide.
Table 1.1. depicts the situation of the accounting professions regulated
from the point of view of the Directive 2005/36/EC on the recognition
of professional qualifications, the professions extracted from the IMI
system database, in all the above-listed generic categories.
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Table 1.1
Regulated accounting professions recorded in the IMI system
MS
Name of the profession
in the MS/generic
category of the
profession/Romanian
translation
CA name Qualification level
ROMANIA
Contabil autorizat/ Auditor/accounatnt
Corpul Experţilor Contabili şi
Contabililor Autorizaţi din România (CECCAR) (Body of Expert and
Licensed Accountants of Romania)
www.ceccar.ro
SEC-secondary
education certificate,
art.11 b
Expert contabil/
Accountant/tax advisor
PS4 – Post-secondary diploma (exactly 4
years), Art.11 e
AUSTRIA
Gewerblicher Buchhalter/ Accounting technician/
contabil comercial
Bundesministerium für Wirtschaft, Familie und Jugend/Ministerul
Economiei, Familiei şi Tineretului
(Federal Ministry of Economy, Family and Youth)
www.bmwa.gv.at
Kammer der Wirtschaftstreuhänder
(KWT)/ Camera Contabililor
Publici (Chamber of Public Accountants)
www.kwt.or.at
DSE-Post-secondary
education diploma,
incl.Appendix II (ex.92/51, Appendix
C,D), Art.11 c
Selbständige Buchhalter /
Accounting technician/ contabil independent
Buchhalter/
Public finance accountant/ contabil
certificat
Paritaetische Kommission Bilanzbuchhaltungsberufe/ Comisia
Paritară pentru contabilitatea de
gestiune (Parity Commission for Management Accountancy
Professions)
Bilanzbuchhalter / Management
accountant/ Contabil de
gestiune certificat
Personalverrechner / Payroll Accountant/
contabil de personal/ salarizare
BELGIUM
Comptable agréé/
Erkend boekhouder/
Accountant/tax advisor/
contabil agreat
Institut professionnel des
comptables et fiscalistes agréés/
Insitutul Profesional al Contabililor
şi Fiscaliştilor Agreaţi (Professional
Institute of Accountants and Tax
consultants) www.ipcf.be
PS3 - Post-secondary
education diploma (3-
4years) , Art. 11 d
Comptable-fiscaliste
agréé/ Erkend boekhouder-fiscalist/
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MS
Name of the profession
in the MS/generic
category of the
profession/Romanian
translation
CA name Qualification level
Accountant/tax advisor/
contabil fiscalist agreat
PS3 - Post-secondary education diploma (3-
4years) , Art. 11 d
Expert-
comptable/accountant/
Accountant/tax advisor/
expert contabil
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/ Min. Economiei, IMM, Clasei Mijlocii şi Energiei –
Direcţia Generală Reglementarea şi
Organizarea Pieţei, serviciul de audit, drept contabil, cooperative
(FPS Economy
SMEs, Self-Employed and Energy, Maret Regulation)
Institut des experts-comptables et des conseils fiscaux/ Institutul
Experţilor Contabili şi
Consultanţilor Fiscali (Institute of Chartered Accountants and TAx
Consultants)
www.iec-iab.be
BULGARIA
Дипломиран експерт-
счетоводител (одитор)/
Auditor/accounatnt/ expert contabil diplomat
(auditor)
Institute of Certified Public
Accountants/ Institutul Contabililor
Publici Certificaţi
PS3 - Post-secondary
education diploma (3-
4years) , Art. 11 d
CZECH
REPUBLIC
Činnost účetních poradců, vedení
účetnictví, vedení
daňové evidence/ Auditor/accounatnt/
consultanţă în
contabilitate, servicii de
contabilitate,
contabilitate fiscală
Ministerstvo průmyslu a obchodu/
Ministerul Industriei şi Comerţului
(Ministry of Industry and Trade) www.mpo.cz
SEC-secondary education certificate,
art.11 b
CYPRUS Λογιστής/ Auditor/accounatnt/
Institute of Certified Public Accountants of Cyprus/ Institutul
PS3 - Post-secondary education diploma (3-
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MS
Name of the profession
in the MS/generic
category of the
profession/Romanian
translation
CA name Qualification level
contabil/auditor Contabililor Publici Certificaţi din
Cipru (Institute of Certified Public
Accountants of Cyprus) www.icpac.org.cy
4years) , Art. 11 d
FRANCE
Expert comptable/ Accountant/tax advisor/
expert contabil
Conseil supérieur de l’Ordre des
experts-comptables/ Consiliul Superior al Ordinului Experţilor
Contabili (Supreme Council of
Institute of Chartered Accountants)
PSM-Post-secondary
education diploma (at least 4 years), Art.11
e
GREECE
Ihdikos kostologissis sti viomichania/
Accounting technician/ contabilitatea costurilor
în industrie şi IMM
DSE-Post-secondary
education diploma, incl.Appendix II
(ex.92/51, Appendix
C,D), Art.11 c
PS3 - Post-secondary education diploma (3-
4years) , Art. 11 d
Ihdikos
mihanografimenou logistiriou/
Accounting technician/
contabilitate pe calculator
Logistís (AEI-TEI)/
Accountant/tax advisor/ contabil
IRLANDA
Accounting technician/
Accounting technician/
tehnician contabil
Institute of Chartered Accountants
in Ireland/ Institutul Experţilor
Contabili în Irlanda www.icai.ie
DSE-Post-secondary education diploma,
incl.Appendix II
(ex.92/51, Appendix C,D), Art.11 c
Technician accountant/
Accountant/tax advisor/ contabil tehnician
Institute of Certified Public
Accountants in Ireland/Institutul Contabililor Publici Certificaţi în
Irlanda
www.cpaireland.ie
Certified accountant/ Accountant/tax advisor/
contabil certificat
Association of Chartered Certified Accountants/ Asociaţia Experţilor
Contabili Certificaţi
www.ireland.accaglobal.com PS3 - Post-secondary education diploma (3-
4years) , Art. 11 d Incorporated Public
Accountant/
Accountant/tax advisor/ contabil public
incorporat/înregistrat
Institute of Incorporated Public
Accountants/ Institutul Contabililor
Publici Incorporaţi (Inregistraţi) www.iipa.ie
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MS
Name of the profession
in the MS/generic
category of the
profession/Romanian
translation
CA name Qualification level
ICELAND
Löggiltur
endurskoðandi/
Accountant/tax advisor/ expert contabil
Ministry of Finance/ Ministerul
Finanţelor
PS3 - Post-secondary
education diploma (3-
4years) , Art. 11 d
ITALY
Commercialista ed
esperto contabile/ Auditor/accounatnt/
contabil public şi expert
contabil
Ministero della Giustizia, Direzione
Generale della Giustizia civile, Libere Professioni/ Ministerul
Justiţiei, DG Justiţie civilă, Profesii
liberale (Ministry of Justice, General Department of Civil
Justice, Liberal Professions)
www.giustizia.it
Ordine dei Dottori Commercialisti e degli Esperti Contabili/ Ordinul
Contabililor Publici Diplomaţi şi al
Experţilor Contabili (Association of certified accountants)
PS4 - Post-secondary
education diploma
(exactly 4 years), Art.11 e
Ragioniere, perito commerciale/
Accountant/tax advisor/ contabil (înaintea
adoptării titlului de
expert contabil) PS3 - Post-secondary education diploma (3-
4years) , Art. 11 d Dottore commercialista/ Accountant/tax advisor/
contabil public diplomat
LIECHTEN-
STEIN
Buchhalter/
Accounting technician/ contabil
Amt für Volkswirtschaft (Office of
National Economy) www.llv.li/amstsstellen/llv-avw-
home.htm DSE-Post-secondary
education diploma,
incl.Appendix II (ex.92/51, Appendix
C,D), Art.11 c
Wirtschaftsprüfer/
Accountant/tax advisor/ contabil public
FMA Finanzmarktaufsicht
/Autoritatea pentru Pieţe Financiare (Financial Market Authority
Liechtenstein)
www.fma-li.li
LUXEMBOURG
Expert comptable/
Accountant/tax advisor/
expert contabil
Ministère des Classes moyennes/
Min. Claselor Mijlocii (Ministry of
the Middle Classes) www.mdt.public.lu
PS3 - Post-secondary education diploma (3-
4 years) , Art. 11 d
MALTA
Accountant/
Auditor/accounatnt/
Contabil
Accountancy Board/Consiliul
Contabilităţii
PS3 - Post-secondary
education diploma (3-
4 years) , Art. 11 d
GREAT
BRITAIN
Chartered Public finance
accountant/
Public finance
Chartered Institute of Public
Finance & Accountancy/ Institutul
Certificat pentru Finanţe Publice şi
PS3 - Post-secondary
education diploma (3-
4 years) , Art. 11 d
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MS
Name of the profession
in the MS/generic
category of the
profession/Romanian
translation
CA name Qualification level
accountant/ Contabil în
finanţe publice certificat
Contabilitate
www.cipfa.org.uk
Chartered management accountant/
Management
accountant/ Contabil de gestiune certificat
Chartered Institute of Management Accountants (CIMA)/ Institutul
Certificat al Contabililor de
Gestiune
www.cimaglobal.com
Chartered Certified
Accountant/ Auditor/accounatnt/
contabil expert certificat
Association of Chartered Certified
Accountants (ACCA)/Asociaţia Contabililor Experţi Certificaţi
www.accaglobal.com
Chartered accountant/
Auditor/accounatnt/
expert contabil
Institute of Chartered Accountants
in England and Wales (ICAEW)/
Institutul Experţilor Contabili în
Anglia şi Wales Institute of Chartered Accountants
of Scotland (ICAS)/ Institutul
Experţilor Contabili în Scoţia www.icas.org.uk
NORWAY
Autorisert
regnskapsfører/ Accountant/tax advisor/
contabil extern autorizat
Kredittilsynet/ Autoritatea de
Supraveghere Financiară a Norvegiei (The Financial
Supervisory Authority of Norway)
www.kredittilsynet.no
PS3 - Post-secondary education diploma (3-
4 years) , Art. 11 d
POLAND
Usługowe Prowadzenie Ksiąg Rachunkowych
(Aneks - A - Kodeks
dobrej praktyki)/ Commissioned
bookkeeper/
servicii de contabilitate (Anexa A – Codul de
bună practică)
(Appendix A - Code of good practice)
Minister Finansów/ Ministerul Finanţelor (Ministry of Fiannce)
www.mf.gov.pl
PSM-Post-secondary
education diploma (at least 4 years ), Art.11
e
PORTUGAL
Técnico oficial de
contas/ Accountant/tax advisor/ contabil oficial
(autorizat)
Ordem dos Técnicos Oficiais de
Contas/ Ordinul Contabililor Oficiali (Autorizaţi) (Order of
Chartered Accountants)
www.ctoc.pt
PS3 - Post-secondary education diploma (3-
4 years) , Art. 11 d
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MS
Name of the profession
in the MS/generic
category of the
profession/Romanian
translation
CA name Qualification level
HUNGARY
Mérlegképes könyvelő/
Auditor/accounatnt/ contabil certificat
Ministry for National Economy/
Ministerul Economiei Naţionale
DSE-Post-secondary
education diploma,
incl.Appendix II (ex.92/51, Appendix
C,D), Art.11 c
Source: processing of the author with information from the IMI system -
http://ec.europa.eu/internal_market/qualifications/regprof/index.cfm?action=pro
fession&id_profession=2100 (on April 30, 2013)
In those presented above, one notes the fact that in many countries, the
professions in the field of accounting services are regulated (19 countries
registered 36 professions in the IMI system), in some of them, there
being several regulated professions, on the one hand, on different
qualification levels, on the other hand, on different specialties on the
same basic qualification level. There are also MSs where of all the
accounting professions generally (the entire NACE group 692), only the
financial auditor’s activity is regulated, by the transposing of Directive
2006/43/EC on statutory audits of annual accounts and consolidated
accounts (e.g. Spain).
From the point of view of the basic qualification, there are different
requirements for the same title. For example, for the accountant in
France it is necessary to have a basic qualification in the state education
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system (diploma in accounting and management – DCG, conferred after
the baccalaureat - 3 years; higher diploma in accounting and
management – DSCG, conferred after DCG – 2 years; chartered
accountant diploma – DEC, conferred after DSCG), the higher diploma
in accounting and management DSCG granting the right to the condition
of intern chartered accountant and the registration with the Institute of
Chartered Accountants.
In Italy, in order to become an accountant it is necessary to have a
bachelor degree in economic and business management or bachelor or
economic sciences (general economics).
The manner of regulation as well is different from one country to the
other, covering practically all the regulation mechanisms identified by
the EC, DG Internal Market and Services1:
through the reservation of activities – exclusive or joint – to
professionals holding specific professional qualifications;
1 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, p.4
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through professional tiles protected by the law, the holders of
such titled having no specific activities reserved;
through self-regulation by the professional associations requiring
from the members certain professional standards and a code of
ethics and professional conduct (in observance of the national
laws and the EU laws, especially competition regulations);
regulation of the activities/services through licences and
authorizations (in the sense that the undertakers must have a
minimum number of people holding the experience and
qualification appropriate to the services in order to be licensed
for the operation).
Corroborating the information on the regulation of the accounting
professions in several comparative studies made at the EU level2 and
2 Mainly: FEE - Key Features on Structure and Organisation of the Accountancy
Profession across 30 European countries, 26 March 2012, la
http://www.fee.be/images/publications/qualification/Intro_Structure_and_Organ
isation_of_the_Profession2732012401312.pdf – sheets on the 9 EU MSs we
made a comparative analysis of; 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 - appendix H of the final report at
http://ec.europa.eu/internal_market/qualifications/docs/news/20120214-
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amending the, with information taken from the national documents (to be
updated), we will continue with the regulation of professions in the 9
MSs analyzed.
In Romania, the protected titles of expert accountant and licenced
accountant are regulated by the Government Ordinance (GO) no.
65/1994 on the organization of the accounting expertise and licensed
accountants activity, republished, as subsequentlu modified, and the CA
for the two professions is the Body of Expert and Licensed Accountants
of Romania – CECCAR. The two professional titles reflect the
regulation of the accounting activities on the two qualification levels,
deriving also the difference concerning the activities the expert
accountant may carry apart from those of the licenced accountants.
According to the GO no. 65/1994 republished, the expert accountant may
provide the following services to natural and legal persons:
keeps or supervises the bookkeeping and prepares or verifies and
approves the financial statements;
provides assistance for the accounting management and
bookkeeping;
performs economic and financial analyses and asset appraisals;
annex_en.pdf - sheets on the 7 MSs analyzed, Romania an Austria not being part
of the sample countries of analysis.
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undertakes accounting examinations required by judiciary bodies
or demanded by natural or legal entities, according to legal
requirements;
undertakes any other work of financial, accounting,
administrative or IT management nature as required;
fulfills the tasks provided for in the company censor’s mandate,
according to legal requirements;
provides technical expertise for the creation and restructuring of
trading companies;
provides accounting-related professional services to natural or
legal entities.
The licenced accountant may ensure the bookkeeping and develop the
works in order to prepare the financial statements.
Moreover, the Law no. 149/2013, published in the Official Journal no.
257 of May 9, 2013, completes the rules regulating the expert accounting
activities, appraisal of goods, financial audit, tax consultancy and
insolvency practitioner activities, clearly stipulating that the professional
of these fields may have a complementary activity only if qualified for it
and they are members of the organizations coordinating the respective
liberal professions. More exactly, the Law no. 149/2013 provides
punctually that “Expert accountants may perform the activities of
financial audit, tax consultancy and appraisal only after having
acquired, according to the law, the quality of financial auditor, tax
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consultant or authorized appraiser, as the case may be and having
registered as member of the organization coordinating such liberal
professions”3. It thus results on the one hand, that all the expert
accounting activities are exclusively reserved to the expert accountant
profession and, on the other hand, that the expert accountants do not have
other partly reserved activities or authorizations included in financial
audit, appraisal, legal reorganization and liquidation fields or tax
consultancy, since each of these activities is exclusively reserved to one
of the other liberal financial professions distinctly regulated in Romania.
The expert accountants and the authorized accountants must register
among the Members of CECCAR (among which are registered as well
the expert accounting companies and the accounting companies
authorized by CECCAR), the registration fee being approx. Euro 40 for
expert accountants and Euro 20 for authorized accountants.
3Law no. 149 of April 30, 2013, 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 rules, Official Journal no.
257 of May 9, 2013.
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As far as the public interest supervision of the activity of the accounting
professions – provisions in the Directive 2006/43/EC on statutory audits
of annual accounts and consolidated accounts – in Romania, according
to the GO no. 23/2013 for the modification and amendment of the GEO
no. 90/2008 (on the statutory audit of annual financial statements and
annual consolidated financial statements, as subsequently amended and
modified, GEO transposing the Directive 2006/43/EC) and of the GO
no. 65/1994, the Council for Public Supervision of the Statutory Audit
Activity (Consiliul pentru Supravegherea Publică a Activităţii de Audit
Statutar [CSPAAS]) has become Council for the Public Interest
Oversight of the Accountancy Profession (Consiliul pentru
Supravegherea în Interes Public a Profesiei Contabile [CSIPPC]),
with the view to widening the sphere of public oversight to the
CECCAR4 members as well.
4 However, it is still not clear to which extent CSIPPC already deals with the
public interest oversight of CECCAR members, since of CSIPPC website, apart
from the logo on the front page, the rest of the information is still on CSPAAS,
including in the presentation of the members of the Superior Council, there
appear the representatives of the National Securities Commission (Comisia
Naţionala de Valori Mobiliare), of the Insurance Supervisory Commission
(Comisia de Supraveghere în Asigurări) and of the Supervisory Commission of
the Private Pension System (Comisia de Supraveghere a Sistemului de Pensii
Private), supervisory bodies of the financial markets which in May 2013 merged
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In Austria, the accounting professions are regulated by
Bilanzbuchhaltungsgesetz - BibuG (Law on management accounting),
law which was substantially modified, the new form coming into force
on January 1, 2013. Thus, the 2 previously regulated professions -
Gewerblicher Buchhalter - GBH (Accounting technician) and
Selbständige Buchhalter - SBH (independent accounting technician)
were auppressed, and the holders of the commercial licences GBH and
SBH were transferred to one of the three new regulated professions:
Bilanzbuchhalter - Bibu (Management accountant), Buchhalter – BH
(Public finance accountant) and Personalverrechner – PV (Payroll
Accountant).
For these three professions a new CA was created, Paritaetische
Kommission Bilanzbuchhaltungsberufe - PK (Parity Commission for
Management Accountancy Professions) consisting of the representatives
of the two chambers involved in the management of these two
professions: Kammer der Wirtschaftstreuhänder - KWT (Chamber of
Public Accountants, CA for the regulated professions of financial
auditor - Wirtschaftsprüfer and tax consultant – Steuerberater) and
Wirtschaftskammer Österreich - WKO (Austrian Economic Chambers,
the representatives of all the companies and undertaking in Austria in
in one supervisory body of the three financial markets – the Financial
Supervisory Authority (Autoritatea de Supraveghere Financiară [ASF]).
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the social dialogue, chambers involved as well in the secondary and
tertiary vocational/professional education in Austria).
The manner of regulation of the three professions is the award of a
business licence/authorization (the basic qualification level being the
same) mentioning the services which may be rendered. The type of
licence depends on the number of years of experience and the different
examination the applicant must take. It is possible to go from one
licence to the other (superior) and the association of the holders of
different licences in the same company (including auditors and tax
consultants, members of KWT).
According to PK5, the new law was passed with the view to the
liberalization of the regulation framework of the liberal accounting
professions, the creation of a competitiveness situation and market
transparency and the provision of quality services, appropriate for the
different market segments, according to the requirements of the EU
Internal Single Market and the new regulation framework lead to the
increase of the number of licences from approx. 5000 (for GBH and
5 PK – Independent accountancy in Austria, at
http://www.bilanzbuchhaltung.or.at/Independant%20Accountancy%20in%20A
ustria.pdf
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SBH by January 1, 2013) to over 10.000 licences for the present three
professions.
Te new CA is responsible for the organization of exams, the award and
withdrawal of the commercial licence/authorization, the organization and
discipline aspects and the application of the international regulations.
In January 2013, PK made the transfer of the former holders of the GBH
and SBH authorizations (which were registered in the KWT register)
with WKO, in the IT economic, consultancy and accounting sector
(Unternehmensberater, Informationstechnologen und Buchhalter –
UBIT), the group of accounting professions.
In the Czech Republic, the professions in the field of accounting are not
regulated by the law there are only requirements related to the
professional experience, as provided by the Commercial Code (Trade
Licensing Act No. 455/1991), for the business authorization/provision
of services. Hence, the Czech authorities recorded in the IMI system the
generic category Činnost účetních poradců, vedení účetnictví, vedení
daňové evidence (accounting consultancy, accounting and tax
accounting).
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30
In Italy, the professional titles in the field of accounting, Dottore
commercialista (public chartered accountant) and Esperto contabile
(accountant), are regulated by the D.Lgs. 28 giugno 2005, n. 139.
Costituzione dell’Ordine dei dottori commercialisti e degli esperti
contabili (Law on the constitution of the Association of certified
accountants). Before the reform of 2005, there were separate regulations
for the professions of dottore commercialista and ragioniere, although
they had many common competencies. Since the Law 139/2005 was
passed, the regulations and the professional body become one and a new
professional title esperto contabile replaced the title of ragioniere.
From the point of view of the reserved activities, the title Dottore
commercialista includes all the activities the accountant may provide
and some reserved activities more. Hence, both professions may provide
services of accounting, judicial accounting expertise, tax consultancy,
management of the assets of the entities subject to special measures of
crime prevention, consultancy in the labour law, appraisal of assets,
non-statutory financial audit and the dottori commercialisti,
furthermore, may be insolvency practitioners, the may be part of the
councils of auditors of companies and may represent the customers
before the administrative authorities.
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The registration in the register of the professional body Consilio
Nazionale dei Dottori Commercialisti e degli Esperti Contabili –
CNDCEC (National Board of Chartered Accountants and Accounting
Consultants), Section A – Dottori commercialisti and Section B – Esperti
contabili, is compulsory and per territory branches of CNDCEC, the
registration fee being of approx. Euro 500.
Ministero della Giustizia, Direzione Generale della Giustizia civile,
Libere Professioni ( the Ministry of Justice, General Department of Civil
Justice, Liberal Professions) is the CA and the supervisory body for both
professions.
In the Netherlands, the professions of Accountant –
administratieconsulent (accounting consultant) and Registeraccountant
(chartered accountant) are regulated only as far as the exclusive
reservation of the financial audit activity, whereas the accounting
services may be provided by individual who are not registered with the
NBA Institute, the CA for the two professions. In other words, for the
permanent provisions of accounting activities exclusively, not also
financial audit, it is not required to recognize the accounting
qualifications in other MSs.
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In Denmark, Germany and Spain, the accounting professions are not
regulated.
In Great Britain, in most cases, the market access is not limited by the
reservation of certain regulated qualifications/professions but consumer
protection is provided through the existence of legally protected
professional titles, the holders of these titles being the members of the
professional associations/institutes granting the titles and regulating the
activity of their members. The statute of “chartered” (legally protected)
bodies shows that there is a distinct profession in that activity and the
body granting the title/titles has the capacity to establish and maintain
high technical and ethical standards among their members. The
“chartered” body statute also confirms that the organization and its
members are recognized as experts in that field of activity, which is of
public interest.
In the field of accounting, any person in Great Britain may be an
accountant and provide accounting services but there are 4 legally
protected (chartered) professional titles, their holders not having the
accounting activities reserved.
The titles and the associations/institutes granting them are the following:
Chartered Certified Accountant, title conferred by the
Association of Chartered Certified Accountants – ACCA;
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Chartered Management Accountant title conferred by the
Chartered Institute of Management Accountants – CIMA;
Chartered Public Finance Accountant title conferred by the
Chartered Institute of Public Finance and Accountancy –
CIPFA;
Chartered Accountant title conferred by the Institute of
Chartered Accountants in England and Wales – ICAEW and
the Institute of Chartered Accountants of Scotland – ICAS6.
Each institute separately is a regulation body for its members (and the
membership is voluntary), and their activity is supervised by the de
Professional Oversight Board – POB, a structure of the Financial
Reporting Council – FRC.
The registration fees and the fees for the issue of the practice certificate
(in the sense of the use of the professional protected title) are the
following7:
6 We used the two variants of translation of the titles and the CA in Great
Britain because in some specialty Romanian texts, the term “Chartered” is
taken as such and in others (e.g. CECCAR documents) the title “chartered
accountant” is assimilated to the professional title of expert accountant in
Romania.
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ACCA – the membership fee is £193 and the fee for the practice
certificate is £385;
CIMA – £234 for members and £85 for practicing members;
CIPFA – £285 the membership fee and £200 for the practice
scheme;
ICAEW - £300 membership fee and £268 for the practice
certificate;
ICAS - £396 the membership fee and £ 474 for the practice
certificate.
7 Information taken from FEE - Key Features on Structure and Organisation of
the Accountancy Profession across 30 European countries, 26 March 2012
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2. PROCEDURES FOR THE CERTIFICATION OF
COMPETENCIES APPLIED BY CA IN THE COUNTRIES
WHERE THE PROFESSIONS ARE REGULATED
As far as the Directive 2005/36/EC on the recognition of professional
qualifications, one may note in table 1.1 that the basic qualification level
varies in the case of the regulated accounting professions – some are
secondary level, others are post-secondary level, either higher
vocational/professional education or university level 3-4 years or at least
4 years.
In table 2.1 we presented comparatively the requirements for the award f
of the titles corresponding to the accounting professions and continuous
professional training/professional development only in Romania and
other EU MSs analyzed where the accounting professions are regulated,
i.e.: Austria and Italy.
We will also separately present, in the case of Great Britain, the
requirements of the 5 institutes granting the chartered titles.
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Table 2.1
Situation of qualifications necessary for the practice of regulated
accounting professions in the analyzed EU MSs
MS Austria Italy Romania
Compulsory
training
requirements
for the
title/practicing
authorization
All three professions
suppose the same
basic qualification
level through special
structured training in
the dual professional
and technical
system: total
education cycle of
18 years, of which
professional training
of at least 9 years (4
years secondary
technical studies and
5 years’ practice and
professional training
finished in a
professional exam)
+
Years of work
experience
(increased for PV-
BH-Bibu)
+
Differentiated exam
in PK
+
Commercial
licence/authorization
University degree in
economic studies
(bachelor degree for
esperto contabile,
master’s degree for
dottore
commercialista)
+
3 years’ practice
+
State examination
for the professional
title
University degree
in economic
studies (bachelor)
for expert
accountant /
secondary
education diploma
for licensed
accountants,
recognized by
MEN
+
Exam for
internship
+
3 years’ internship
+
Aptitude test for
the professional
title
FPC/ continuing
professional
development
Yes, the law
provides at least
30 hours of
FPC/year
Yes, organized by
the territory
representative office
of CNDCEC
Yes, according
to the National
Programme for
Continuing
Professional
Development
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(Programul
Naţional de
Dezvoltare
Profesională
Continuă
(PNDPC) of
CECCAR, at the
level of the 42
county
representative
offices, based on
the Professional
Standard no. 3,
transposing the
standard IES 7
of IFAC
Application of
the
professional
standards
CNDCEC sets and
applies the
professional
standards under the
supervision of the
Ministry of
Economy and
Finance and Consob
in case of public
interest audit
companies
Yes, CECCAR
develops and
applies
professional
standards based
on the IFAC
standards
Disciplinary
measures
Yes, the
responsibility of
PK
Yes, CNDCEC
oases disciplinary
measures under the
supervision of the
Ministry of
Economy and
Finance and Consob
in case of public
interest audit
companies
yes
Source of information: FEE – Key Features on Structure and Organisation of
the Accountancy Profession across 30 European countries, 26 March 2012;
DG Internal Market and Services – Final Report – Study to provide an
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Inventory of Reserves of Activities linked to professional qualifications
requirements in 13 Member States &assessing their economic impact, January
2012 – appendix H (for Italy, because Austria and Romania were not include
in the sample of analyzed countries), the national legislation in case of Austria
In the case of the 5 British, the Recognised Qualifying Bodies, the
requirements for access and achievement of the chartered qualification
are synthetically presented in the following table.
Table 2.2
Access requirements and qualification programs for the professional
chartered titles in Great Britain
ACCA CIMA CIPFA ICAEW ICAS
Conditions
for access
to
qualificaio
n
a)secondary education
diploma b)
university/p
ostgraduate diploma
c) calificare
de Certified
Accounting
Technician
(CAT)
a)Free access but students
must obtain Certificates in
Business
Accounting before attending
the
qualification
programme
b) AAT
qualification
a)secondary education
diploma b)
university/postgra
duate diploma c) AAT
qualification
a)secondary education
diploma b)
university/post
graduate diploma
c) ICAEW
certificate in
Finance,
accounting and
business (CFAB)
d) AAT
qualification
a)secondary education
diploma b)
university/post
graduate diploma
c) AAT
qualification
Compulsor
y training
for
qualificatio
n
Study and 14 ACCA
qualification
exams + professional
ethics model
+3 years of relevant
practical
experience
5 exams for the Certificates in
Business
Accounting + study and 10
qualification
exams + 3 years of
relevant
practical
12 modules, 3 stages: 1. Prof.
certificates;
2.Prof. diploma;
3.Strategic
phase + employment for
relevant
practical
ACA qualification
programme:
15 modules training+
450 days of
practice+ initial
professional
development
Internship agreement
with an
employee authorized
by ICAS (3
years usually) +
study and şi
3 exam
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experience experience (usually 3
years)
+ structured training in
ethics
stages + course in
business
ethics
Source: FEE, Key Features on Structure and Organisation of the Accountancy
Profession across 30 European countries, 26 March 2012
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3. PROCESSES FOR THE RECOGNITION OF
QUALIFICATIONS ACHIEVED IN OTHER EU MS FOR
PRACTICING OF PROFESSIONS IN THE FIELD OF
ACCOUNTING
The statistics in the IMI system, made based on the data on the
movement of professionals on the two manners of provision (through
permanent establishment/exercise of their profession in a different EU
MS, EEA and Switzerland or temporary/occasional provision) and per
each generic category of professions separately, registered in the
database until now, they are not relevant as such in the case of
accounting professions, because, as we showed in chapter 1 of the
guideline, the EU MSs, EEA and Switzerland, they registered regulated
professions in accounting in different generic categories, of which only
some include proper accounting professions, whereas others reflect not
only the movement of accountants but also of the regulated professions
of financial auditor and tax consultant which were registered in those
generic categories. Hence, the statistics presented herein are based on the
processing of the data strictly in the recognition registered by the EU
MSs, EEA and Switzerland, on the professions regulated for the
accounting activity.
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The situation of the decisions for the recognition of qualification for the
permanent establishment/exercise, in the period 2008 – 2012, of the
accounting professions as [resented in table 3.1.
Table 3.1
Statistics of the decisions for the recognition of qualification achieved in
other EU MSs, EEA ad Switzerland for the accounting professions
(2008 – 2012)
Host country:
regulated
professions
Profession for
which the
recognition
decision was
passed
Home country of
the qualification
No. of
positive
decisions
No. of
negative
decisions
No. of
neutral
decisions
Total
decisions
Belgium:
21= 5 + 4 +
12
applications
of 7 MSs
din 7 SM
Comptable-
fiscaliste agree/
Erkend
boekhouder-
fiscalist
11=4+2+5
Bulgaria 1 0 1 2
Italy 0 1 1 2
Luxembourg 0 0 1 1
The Netherlands 1 0 1 2
Romania 2 1 1 4
Expert-
comptable/
accountant/
10=1+2+7
France 0 1 4 5
Luxembourg 0 0 1 1
Great Britain 0 0 1 1
The Netherlands 1 1 1 3
Czech
Republic:
8 positive
decisions to
Činnost účetních
poradců, vedení
účetnictví, vedení
daňové evidence
France 1 0 0 1
Germany 3 0 0 3
Italy 3 0 0 3
Poland 1 0 0 1
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applications
from 4 MSs
8 0 0
Cyprus:
249 positive
decisions to
applications
from 1 MS
Λογιστής
249 0 0
Czech Republic 1 0 0 1
Great Britain 249 0 0 249
France:
47 = 31 + 8
+ 8
din 11 SM
Expert
comptable
47=31+8+8
Austria 1 0 0 1
Belgium 3 0 2 5
Germany 2 0 0 2
Ireland 2 0 0 2
Italy 2 2 1 5
Luxembourg 3 4 0 7
Malta 1 0 0 1
Great Britain 12 1 3 16
Poland 1 0 0 1
Portugal 1 0 0 1
Romania 4 1 1 6
Greece:
23 = 2 + 4 +17
din 2 SM şi
Elveţia
Logistís
(AEI-TEI)
23=2+4+17
Switzerland 1 0 1 2
Great Britain 1 3 15 19
The Netherlands 0 1 1 2
Italy:
24 = 2 + 7
+ 15
din 7 SM
Commercialista ed
esperto contabile
24= 2+7+15
Bulgaria 1 0 0 1
Greece 0 0 1 1
Luxembourg 0 2 1 3
Great Britain 1 0 1 2
Poland 0 0 1 1
Romania 0 0 5 5
Spain 0 5 6 11
Poland: Usługowe Germany 3 1 6 10
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21 = 8 + 3 + 10
of 4 MS
Prowadzenie Ksiąg
Rachunkowy
21=8+3+10
Ireland 2 0 1 3
Poland 2 2 3 7
Slovakia 1 0 0 1
Portugal:
1 positive
decision from 1
MS
Técnico oficial de
contas
14=3+4+7
Poland 1 0 0 1
Romania:
7 positive
decisions to
applications
from 4 MSs
Expert contabil
7 0 0
Cyprus 1 0 0 1
Finland 1 0 0 1
Frane 2 0 0 2
Italy 3 0 0 3
Hungary:
1 neutral
decision from
mérlegképes
könyvelő :
0 0 1
positive
decisions to
applications
from 1 MS
0 0 1 1
10 host
countries
11 professions 20 countries 313 26 63 402
Source: data processed based on the IMI system on July 16, 2013, by the author,
the situation of the decisions of permanent provision, only for the accounting
professions in all the generic categories where they were registered - at
http://ec.europa.eu/internal_market/qualifications/regprof/index.cfm?action=pro
fession&id_profession=2100&tab=countries&quid=2&mode=asc&maxRows=*
#top
Note: in the case of Romania, the data in the IMI system were amended with
information provided by CECCAR
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In these statistics we may note the fact the Romania is among the 10
MSs of the EEA receiving applications for the recognition of
qualification achieved in Italy, France, Cyprus and Finland but it is not
in the top 5 of passed decisions. Cyrus is the first in this top with 62% of
the total decisions for the recognition passed in the period 2008 – 2012.
If we consider however that all these 249 decisions – all positive and
without any aptitude test – refer to individuals achieving the
qualification in Great Britain, it might be that Cypriot citizens obtained
one of the British qualifications even in Cyprus or studied in Great
Britain, reflecting not necessary the movement of professional but also
the quality of British qualifications and their recognition at the
international level.
As a home country of accounting qualifications, Romania is the second
(4% of the total applications for recognition), after Great Britain and just
as Germany, with 15 applicants for the recognition of their qualification:
4 applications in Belgium, for the practice of the tax accountant
profession (2 positive decisions, a rejection and a pending application),
6 applications in France for the practice of the expert accountant
profession (4 positive decisions, a rejection and a pending application)
and 5 applications in Italy for the practice of the expert accountant
profession (according to the registrations made by the CA in Italy in the
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IMI system, all applications were drawn in 2011 and they are pending in
2012).
Per total, the majority of qualifications achieved in other MSs were
recognized (78% of the decisions were positive) which reflects a high
degree of mutual trust between the MSs of the EEA, as far as the
professional training in accounting.
The chart, the statistics of the mobility for permanent establishment
provision of accounting professions is the following:
Chart 3.1 – Structure of the recognition of the accounting qualifications
per types of decisions, 2008 - 2012
78%
6%
16%
Dec iz ii poz itive
Dec iz ii negative
Dec iz ii neutre
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Chart 3.2 – Structure per host countries of the accounting qualifications
per types of decisions, 2008 – 2012
62%12%
6%
6%
5%5% 4%
C ipru
F ranta
Italia
G rec ia
B elgia
P olonia
R es tul de 4 tari
Chart 3.3 – Structure per home countries of applications for the
recognition of accounting qualifications, 2008 – 2012
74%
4%
4%
3%3%
3%9%
Marea B ritanie
G ermania
R omania
Italia
L uxemburg
S pania
R es tul de 14 tari
Source: all the three charts are made based on the data processed by the author
in - the EC database with the regulated provisions presented in table 3.1
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In the top of the most mobile professions in permanent provision
(establishment) throughout the reporting period, the generic categories
existing in the IMI system containing the accounting professions, they
occupied the following positions:
position 45 – auditor/accountant, with 460 decisions;
position 70 – accountant/tax advisor, with 198 decisions.
Out of the 448 generic categories in the top (for which there were
recognition application in the period 2008 - 2012), with the 402 passed
decisions, only the accounting provisions selected out of these generic
categories would be in position 51.
The process of the recognition of the qualification is required only in the
case of the permanent establishment/provision of services. As we
mentioned in chapter 1 of this guideline, the regulated accounting
professions are subject to the general system for the recognition of
professional qualifications provided in the Directive 2005/36/EC on the
recognition of professional qualifications. In this case, the recognition is
not automatic but it needs a comparison between the professional
training provided for in the two countries – the one where the applicant
achieved the qualification (the home country) and the ne where they
want to exercise permanently their profession (the host country), as well
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as the possibility, in case of “substantial differences” of applying
compensation measures (adaptation period of up to three years or an
aptitude test – article 23 of the Directive).
For the recognition in the general system, the application for recognition
is addressed to the CA in the host MS. This application must be
accompanied by a series of documents and certificates provided in
appendix VII to the Directive 2005/36/EC.
The documents that may be requested with the submission of the
application for recognition are:
proof of the nationality
proof of establishment in a different EU MS, EEA or
Switzerland
documents regarding the professional qualification, the
competencies and the practical experience: certificate of
competence or the proof of qualification issued by the CA in the
home MS;
other documents, if required to those having achieved the
qualification in the host MS – good reputation attestations,
solvency certificates, the proof that the applicant is medically
capable, financial statement, professional insurance.
The CA in the host MS may request only for the most important
documents, the copies and notarized translations, except for the
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standardized documents (e.g passport, identity card). Also, original
documents may not be requested, only copies. In case the applicant may
not provide all the information the CA in the host country must try to
obtain them from the CA in the home MS in the IMI system.
As a recognition procedure, the CA in the host CA must, within one
month, confirm the receipt of the file and draw attention to the missing
documents, if applicable. The deadline for the CA to grant the
recognition or to decide on the application of any compensation measure
is 4 months. Any rejection must be motivated. The rejection or the failure
to make a decision, within the above-mentioned term, may be objected
against in the national courts.
The aptitude test may be applied on the conditions that the CA in the
host MS, based on the documents received, determined which are the
differences between the two qualifications that must be covered by the
compensation measures. As the accounting activities require the
knowledge of the applicable national legislation, the aptitude test is a
compensation measure used in most of the cases of recognition of such
qualifications. In the opinion of the European Commission, the CA in the
host MS must organize at least two sessions of aptitude test per year. For
this process of recognition and the organization of the aptitude test, the
CA must levy a tax on condition it does not exceed the costs and it is not
discriminatory to their own nationals in similar situations.
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Once obtained the recognition of the qualification, the applicant may
practice the profession on the same conditions with the ones having
achieved the qualification in the host MS, the professional regulations in
the host MS being applicable, including the professional title in that
country.
In table 3.2 we present the characteristics of the process of the
recognition of the accounting qualifications in the 3 analyzed MSs which
have regulated professions, because in a country where the profession is
not regulated (Denmark, Germany, Spain), the access to the market is
free. A person wanting to provide accounting services in Great Britain
must not go through the process of the recognition of the qualification
unless they want to become a member of the 5 institutes to use the
professional title they confer.
Table 3.2
Requirements for the recognition of the qualification for the permanent
establishment/provision of accounting services in the analyzed MS which
have regulated accounting professions
MS Austria Italy Romania CA for the
recognition of the
qualifications
PK Ministry of Justice
CECCAR
Procedure for the
recognition of
qualifications
Aptitude test Aptitude test Aptitude test
CA for the aptitude
test
PK CNDCEC CECCAR
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Test form Oral Written and oral Oral (interview)
Main subjects Relevant Austrian
legislation
Commercial, tax,
profession laws, civil
right, insolvency, ethical aspects and
professional
deontology
Commercial,
accounting and tax
laws + case study of accounting issues, tax,
organization and
operation of companies
and the operation and
organization of
CECCAR
Test language German Italian N/A
Frequency of the
aptitude tests
Upon request Twice a year As per requests
Possibility of taking
the tests
- Yes Yes
Source of information: FEE – Key Features on Structure and Organisation of the
Accountancy Profession across 30 European countries, 26 March 2012 for Italy;
PK for Austria, CECCAR for Romania
In case of the temporary/occasional provision of accounting services,
there is no obligation of requesting the recognition of the qualification
but in some countries, the obligation to submit a statement in the host
country and to renew it annually if applicable. In the IMI system there
has been no registration of temporary provision in case of the accounting
professions, that is why there are no statistics of the mobility for
temporary provision.
In table 3.3. we present the provisions on the temporary provision of the
accounting services in the analyzed 3 MSs with regulated accounting
professions.
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Table 3.3
Requirements for the temporary provision of accounting services in the
analyzed EU MSs where the professions are regulated
MS Austria Italy Romania Pro-forma
statement
NO Yes – annual renewal Yes – annual renewal
Requested
data
No, only requests for
information to
the client
Personal data Qualification
Services to be provided Professional insurance
Personal data Services to be provided
Professional insurance
Requested
documents
NO Upon the first statement or modification: identity
document, establishment
in the home country, proof
that there is no
temporary/final
interdiction of practice or penalty
Proof of citizenship in the MS of the EEA, Switzerland;
Attestation of proficiency in
Romanian; proof of
professional qualification;
proof of stable domicile in a
MS of the EEA/Switzerland proof that there is no
temporary/final interdiction of practice,
proof of activity specific to the
accounting position of at least 2 years in the last 10 years, if
the profession is not regulated
in the residence country
CA for the
right of
temporary
provision
- Ministry of Justice
CECCAR
Verifications - Permits Yes, in cooperation with other
CA in other MSs
Compliance
with the
regulations in
the host MS
- Cooperation with
CNDCEC and territory branches
Yes
Source of information: FEE – Key Features on Structure and Organisation of the
Accountancy Profession across 30 European countries, 26 March 2012
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A possibility, simpler than the legal way, to make claims against a
decision on the recognition of the qualification, considered not compliant
with the Directive 2005/36/EC on the recognition of professional
qualifications, is to address the SOLVIT syste,.
SOLVIT is an online network, operating since July 2002, where the EU
MSs cooperate to settle, in a pre-legal phase the problems created by the
incorrect application of or the failure to apply by the public authorities,
the community law regarding the Internal Market. There is SOLVIT
centre in each EU MS, as well as in Norway, Iceland and Liechtenstein.
The centres are part of the central administration and must provide
solutions to the problems raised by citizens or the companies within 10
weeks, and the use of the network is free.
The SOLVIT centre in Romania is with the Ministry of European Affairs
(it may be contacted at e-mail [email protected]).
The conditions for the operation of the SOLVIT mechanism are:
to deal with the non-application or the improper application of
the European law by the administration of a member state,
to deal with cross-border case,
there must not be any action for settlement.
The cross-border character does not suppose that the petitioner must be
in a different MS that the one of the issue. It is enough there to be a
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strange element to make applicable the provisions of the community law
(for example, a Romanian citizen wants to practice in Germany and they
have difficulties of employment). The operation of the SOLVIT system
is presented in the chart below.
Source: http://www.romania-actualitati.ro/conceptul_de_cetatenie_europeana-
50325 (on July 17, 2013)
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For example, if a Romanian citizen has a complaint against the internal
market regulations, they will approach SOLVIT ROMANIA
(organization dealing with the case depending on the nationality of the
petitioner). If a Romanian citizen obtained the qualification in Austria,
they want to be employed in Germany and there is a complaint in this
sense, they will approach the centre in Austria. The request will be
analyzed and if considered that this case is a breach of the community
law, they will contact the centre LEAD SOLVIT (the responsible
SOLVIT centre). If they agree to the proposal, they will move forward,
to the defendant authority. The client is assisted in a language they
understand but it is more important there to be a responsible SOLVIT
centre to be aware of the procedures to be followed and the authorities to
be contacted to solve the problem. In order to obtain a good result,
SOLVIT is based on the relation with the defendant authority. And this
because it is an informal network and it does not have the authority of a
judge.
The reasons for which not all claims may be settles:
certain issued depending on the legislation of a member state; if
there can be no rapid solution, the case is considered non-settled;
the defendant authority is not willing to collaborate, when the
petitioner is advised to address the courts able to make the CA
modify the conduct pertaining to the aspect in question.
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4. EXERCISING PROFESSIONS IN ACCOUNTING IN THE EU
The regulated accounting professions are generally part of the category
of liberal financial professions, which is why the accounting activity may
be exercised either as a freelancer or as a partner or employee of an
accounting services company (or accounting, financial audit, tax
consultancy services company, according to the NACE code 692, which
is registered and authorized to provide all these types of services).
Hence, all the national registers where all those exercising regulated
accounting professions are registered, include both natural entities and
legal entities – authorized accounting companies.
In spite of the differences in the regulation of the accounting services in
the EU MSs, a high level of harmonization/standardization was obtained
at the sectoral level, by the efforts of the international and European
professional organizations in the field of accounting and financial audit.
At the global scale, International Accounting Standards Board – IASB,
the independent body for the normalization of standards within the IFRS
Foundation, elaborates and publishes the international accounting
standards (IAS), the international financial reporting standards (IFRS)
and the corresponding undertakings (SICIFRIC).
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At the EU level, in order to harmonize the financial information
presented by the entities applying IFRS, in order to provide a high level
of transparency and comparability of the financial statements and, thus,
an efficient operation of the capital market of the Community and the
Internal Market, the accounting standards issued by IASB are subject to
an analysis, as well as the official vote in the especially constituted
committees at this level, the process finalizing in community regulations
for the passing of standards. All the European regulations for the passing
of standards published by IASB are issued based on the (CE) Regulation
no. 1606/2002, where the international accounting standards are defined
as the International Accounting Standards (IAS), the International
Financial Reporting Standards (IFRS) and the corresponding
undertakings (SICIFRIC), the subsequent amendments to the respective
standards and the corresponding undertakings, the future standards and
the appropriate undertakings issued or passed by IASB.
The International Federation of Accountants, incorporated in 1977 by
63 founding members in 51 countries, has now 173 members and
associated organizations in 129 countries and jurisdictions in the world,
representing 2.5 million of accounting professionals in the public sector,
education, in government structures and the private sector. In turn, the
Fédération des Experts-comptables Européens/Federation of
European Accountants - FEE represents over 700,000 professionals in
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Europe through the 45 member organizations in 33 European countries
and at the same time it plays the role of Regional Organization of IFAC.
IFAC provides the development of the public interest accounting
professions:
the development of the international public sector accounting
standards (IPSA), international standards on auditing (ISA),
international ethical standards (IES) and technical assistance for
passing and use;
facilitating the collaboration and cooperation of member professional
organizations;
collaboration and cooperation with other international organizations;
representing the interests of accounting and financial audit
professionals at the international level.
That it\s why, they passed, practically at the international level, the
Ethical Code of IFAC developed by The International Ethics
Standards Board for Accountants (IESBA), independent body for the
development of ethical standards and professional conduct of
accountants and auditors, the 8 International Education Standards
(IESs) developed (and presently under review) by International
Accounting Education Standards Board (IAESB):
IES1 - entry requirements to professional accounting education,
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IES2 - initial professional development-technical competence,
IES3 - initial professional development-professional skills,
IES4 - initial professional development-professional values,
ethics, and attitudes,
IES5 - initial professional development—practical experience,
IES6 - initial professional development – assessment of
professional competence,
IES7 - continuing professional development,
IES8 - professional development for engagement partners
responsible for audits of financial statements.
In table 4.1, we took from the FEE study and national sources, some
additional information regarding the conditions for the exercise of
accounting professions, as well as statistic data suggesting the dimension
of the professional community of the qualified accounting in the 3
analyzed MSs with regulated accounting professions.
Table 4.1
Conditions for the exercise of accounting professions in the analyzed
MSs with regulated professions
MS Austria Italy Romania Professional address Yes, in any MS of
EEA
Yes, professional
residence or address
in Italy
Yes, residence or
permanent residence
in Romania
Compulsory business
infrastructure
The regulated
accounting
professions may be
As freelancers or
specialty companies,
the majority of
Freelancers (PFA) or
in trade companies
authorized by
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exercised as shareholders in
companies (which
may include all the three professions and
tax consultants and
auditors members of
KWT), as a sole-
shareholder company
(and employee) or as a freelancer, all traders
being members of
WKO
which small companies
CECCAR (NACE code 6920, the
majority of the
shareholders must be members of
CECCAR, at leats
51% of the share
capital held by them,
the majority of the CA
must be members of CECCAR)
Professional liability
insurance
Yes Yes, for certain
activities
Yes for all activities
Number of qualified
accountants
At the beginning of
2013, approximately
10,000 authorizations
were issued fr the
three new regulated
professions
198 esperto
contabile + approc. 112,000 dottore
commercialista
35,249 expert
accountants (of which 25,835 active)
5,342 licensed
accountants (of which 1,387 active)
Number of interns/year - Approx. 26,000 Approx. 1,000 expert
accountants + approx.
50 licensed accountants /year
Source of information: FEE – Key Features on Structure and Organisation of the
Accountancy Profession across 30 European countries, 26 March 2012; PK –
Independent accountancy in Austria
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5. CONCLUSIONS
One of the main issues of the recognition of the profession of
“accountant” is that, at first sight, the legal framework of the accounting
services seems unitary in Europe, whereas in reality it considerably
varies in the context of the differences in the tax regulation and the legal
system of the trade companies.
The CA for the accounting professions are public structures in some MSs
or the professional associations competent according to the law in some
MSs. If there is a ministry (e.g. Italy), the professional organizations may
be invited to be involved in decisions.
In the field of continuing education and training, the assessment of the
results is already largely used, due especially to the development of
procedures independently, at the sectoral level, at the international plan
(the international education standards developed by IAESB, the
professional ethical code developed by IESBA, the high quality
qualification offered by the British institutes and recognized
internationally, especially those of ACCA). Thus, the national authorities
tend to trust the diplomas and certificates issued by the national bodies of
other MSs, facilitating thus the mobility of the professionals in the field
of accounting services on the Single Internal Market of EU.
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From the point of view of the Directive 2005/36/EC on the recognition of
qualifications, the accounting professions are subject to the general
system for the recognition of professional qualifications, at the
qualification level attesting the graduation of training courses at the
secondary, post-secondary level, either in the technical and professional
education or the university with a duration of 3 or 4 years or at least 4
years. Considering that the provision of accounting services supposes the
knowledge of the commercial, tax and labour laws in the host MS, the
aptitude test as a compensation measure in the recognition of
qualifications achieve din a different member state is largely practiced.
The statistics of the IMI system on the processes of the recognition of
qualifications between 2008 and 2012 for the permanent
establishment/provision, show that the accounting professions have been
among the most mobile professions registered in the IMI system up to
now.
Moreover, the globalization process, on the one hand, and the new
international regulation of the financial services, from the beginning of
the financial and economic crisis in 2007, determine the need for the
accounting professionals to follow the clients in the process of business
internationalization.
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AMPOSDRU
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63
Bibliography
Directive 2013/34/CE on the annual financial statements,
consolidated financial statements and related reports of certain types
of undertakings, at
http://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2013:182:0019:
0076: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/faq_en.
European Commission – User Guide, Directive 2005/36/EC, at
http://ec.europa.eu/internal_market/qualifications/docs/guide/users_g
uide_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
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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/sta
ff-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_devel
opments/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/201202
14-report_en.pdf; appendix H to the final report at
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http://ec.europa.eu/internal_market/qualifications/docs/news/201202
14-annex_en.pdf
CECCAR - Codul etic naţional al profesioniştilor contabili (National
Ethical Code of Accounting Professionals), Ed.a V-a revizuită şi
adăugită (5th edition revised and amended), Ed. CECCAR 2011
CECCAR - GHID pentru pregătirea candidaţilor la examenul de
acces la stagiul pentru obţinerea calităţii de expert contabil şi de
contabil autorizat (GUIDE for the preparation of applicants to the
examination for the access to the quality of expert accountant and
licenced accountant), ediţia a II-a, revizuită (2nd
edition, revised), Ed.
CECCAR, Bucharest, 2013
CECCAR – Raport anual 2011 (Annual report 2011), at
http://ceccar.ro/ro/wp-
content/uploads/2011/09/Raport_anual_2012_ro.pdf
CECCAR - Professional standard no. 21 – Mission of keeping books,
drawing up and presenting the financial statements – Application
Guide – 4th Edition, revised and amended, Ed. CECCAR, Bucharest,
2011
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CECCAR - Professional standard no. 22 – Mission of examining
accounting, drawing up, signing and presenting the financial
statements – Application Guide – 4th Edition, revised and amended,
Ed. CECCAR, Bucharest, 2011
CECCAR - Professional standard no. 35 – Accounting expertise –
Application Guide – 4th Edition, revised and amended, Ed.
CECCAR, Bucharest, 2011
CECCAR - Professional standard no. 37 – Mission of assessing the
company – Application Guide, Ed. CECCAR, Bucharest, 2011
FEE - Key Features on Structure and Organisation 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
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
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ROMANIAN GOVERNMENT MINISTRY OF LABOUR, FAMILY,
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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%20
1_0.pdf
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CFE Professional Affairs Committee, editor Rudolf Reibel -
European Professional Affairs Handbook for Tax Advisers, 2nd
edition, March 2013
Law no. 149 of April 30, 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 rules, Official Journal no.
257 of May 9, 2013
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Abbreviations
AAT - Association of Accounting Technicians
AC – Competent Authority (for one/several regulated professions)
ACA - Associate of the Institute of Chartered Accountants in England
and Wales (ICAEW intermediary qualification)
ACCA – Association of Chartered Certified Accountants
ANC – Autoritatea Naţională pentru Calificări (National Qualifications
Authority) (din România)
ASF - Autoritatea de Supraveghere Financiară (Financial Supervisory
Authority) (in Romania)
BH - Buchhalter (Public finance accountant, profession registered in
Austria on January 1, 2013)
Bibu – Bilanzbuchhalter (Management accountant, profession registered
in Austria on January 1, 2013)
BibuG - Bilanzbuchhaltungsgesetz - (Law on management accounting in
Austria)
CAEN - Clasificarea Activităţilor din Economia Naţională (National
Classification of Economic Activities)
CAFR – Camera Auditorilor Financiari din România (Chamber of
Financial Auditors of Romania)
CAT - Certified Accounting Technician (qualification in Great Britain)
CCF - Camera Consultanţilor Fiscali din România (Romanian Chamber
of Tax Consultants)
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ROMANIAN GOVERNMENT MINISTRY OF LABOUR, FAMILY,
SOCIAL PROTECTION AND ELDERLY
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CE – Comisia Europeană (European Commission)
CECCAR – Corpul Experţilor Contabili şi Contabililor Autorizaţi din
România (Body of Expert and Licensed Accountants of
Romania)
CFAB – Certificate in Finance, Accountancy and Business (qualification
in Great Britain)
CIMA - Chartered Institute of Management Accountants
CIPFA - Chartered Institute of Public Finance and Accountancy
CNDCEC - Consilio Nazionale dei Dottori Commercialisti e degli
Esperti Contabili (National Board of Chartered Accountants
and Accounting Consultants in Italy)
CSIPPC – Consiliul de Supraveghere în Interes Public a Profesiei
Contabile (in Romania) (Council for the Public Interest
Oversight of the Accountancy Profession)
CSPAAS - Consiliul pentru Supravegherea Publică a Activităţii de Audit
Statutar (Council for Public Supervision of the Statutory
Audit Activity) (in Romania, transformed in CSIPPC)
DCG - diploma in accounting and management obtained in FRance
DEC - chartered accountant diploma obtained in France after DSCG
DG – General Directorate
DSCG - higher diploma in accounting and management obtained after
DCG in France
EFP – professional education and training
EUROPEAN
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ROMANIAN GOVERNMENT MINISTRY OF LABOUR, FAMILY,
SOCIAL PROTECTION AND ELDERLY
AMPOSDRU
European Social Fund
POS DRU 2007-2013
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FEE – Fédération des Experts-comptables Européens/ Federation of
European Accountants
FPC – continuing professional training
FRC – Financial Reporting Council
GBH - Gewerblicher Buchhalter (Accounting technician, profession
existing in Austria before January 1, 2013)
IAESB – International Accounting Education Standards Board
IAS - International Accounting Standards
IASB - International Accounting Standards Board
ICAEW - Institute of Chartered Accountants in England and Wales
ICAS - Institute of Chartered Accountants of Scotland
IESs – International Education Standards (developed by IAESB)
IESBA - The International Ethics Standards Board for
IFAC – International Federation of Accountants
IFRS – International Financial Reporting Standards
IMI – Internal Market Information system (information system of the
Single Market in the EU)
IPS - Institutul pentru Politici Sociale (in Romania) (Social Policies
Institute)
JO – Official Journal of EU
KWT - Kammer der Wirtschaftstreuhänder (Chamber of Public
Accountants in Austria)
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MEN – Ministerul Educaţiei Naţionale (in Romania) (Ministry of
National Education)
MO – Monitorul Oficial (in Romania) (Official Journal)
OG - Ordonanţa Guvernului (in Romania) (Government Ordinance)
OUG - Ordonanţă de Urgenţă a Guvernului (in Romania) (Emergency
Government Ordinance)
PK - Paritätischen Kommission Bilanzbuchhaltungsberufe (Parity
Commission for Management Accountancy Professions in
Austria)
PNDPC - Programul Naţional de Dezvoltare Profesională Continuă al
CECCAR (National Programme for Continuing Professional
Development of CECCAR)
POB - Professional Oversight Board
PV - Personalverrechner (Payroll Accountant, profession registered in
Austria on January 1, 2013)
SBH - Selbständige Buchhalter (independent accounting technician,
profession existing in Austria before January 1, 2013)
SEE – Spaţiul Economic European (European Economic Area, all the
MS of EU + Iceland, Liechtenstein, Norway)
SICIFRIC - related interpretations of the International Financial
Reporting Standards
SM – Member State (of the European Union)
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UBIT - Unternehmensberater, Informationstechnologen und Buchhalter
(Economic sector of information technology, consultancy and
accounting of the Austrian Economic Chambers – WKO)
UE – European Union
WKO - Wirtschaftskammer Österreich (Austrian Economic Chambers)
WT-Arl – Directive on the practice of accounting professions public in
Austria
WTBG - Wirtschaftstreuhandberufsgesetz (Public Accountants’ Statute
of Professional Practice)
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ROMANIAN GOVERNMENT MINISTRY OF LABOUR, FAMILY,
SOCIAL PROTECTION AND ELDERLY
AMPOSDRU
European Social Fund
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Useful Links
CE Regulations for the international accounting standards –
http://ec.europa.eu/internal_market/accounting/legal_framework/
regulations_adopting_ias/original_text_en.htm
List of national bodies for public interest supervision -
http://ec.europa.eu/internal_market/auditing/links/index_en.htm
EC database with regulated professions in the MS –
http://ec.europa.eu/internal_market/qualifications/regprof/index.
cfm?newlang=en
National Contact Points for the recognition of qualifications in
the MS –
http://ec.europa.eu/internal_market/qualifications/contact/nationa
l_contact_points_en.htm
SOLVIT centers in the MS - http://ec.europa.eu/solvit
PK Austria –
http://www.bilanzbuchhaltung.or.at/de/desktopdefault.aspx
CECCAR - http://ceccar.ro/ro
CNDCEC - http://www.cndcec.it/Portal/Default.aspx