Memorandum by the Department for Business,
Innovation and Skills (ADT 47)
GOVERNMENT MEMORANDUM OF EVIDENCE
INTRODUCTION
1. The Government welcomes this inquiry,
which is one of a number of initiatives looking at the role of
audit in the aftermath of the financial crisis. The Government
has not reached firm conclusions on the need for changes to the
present role of audit, since it would be wrong to do so until
the conclusions of the present debates are clear. Any response
to the financial crisis needs to be based on sound evidence, not
knee jerk reactions or partial analysis. The Government is willing
to consider alternatives, with the aim of ensuring high quality,
but cost effective audit assurance for UK companies, in order
to ensure the maximum economic benefits to companies and the UK
economy.
2. Apart from the work of the Select Committee,
there are several other important streams of work presently ongoing,
amongst which are:
(a) the Financial Services Authority (FSA) and
the Financial Reporting Council (FRC) have issued a Discussion
Paper on "Enhancing the auditor's contribution to prudential
regulation";
(b) the European Commission is scheduled to publish
a wide ranging Green Paper on audit in the Autumn; and
(c) the FRC has announced that it expects to
publish, also in the Autumn, a discussion document to examine
the lessons learned from the credit crisis and other market developments
as they impact corporate reporting, accounting and auditing of
non-financial services companies.
3. The Government asked its officials to
review the evidence base on the role and value of audit in order
to assist in determining the direction of future policy. The discussion
of the academic and other papers referred to in this memorandum
is a result of this exercise. The results of the review of the
evidence base have also been sent to the European Commission and
the FRC.
THE REGULATION
OF AUDIT
AND THE
GOVERNMENT'S
ROLE
4. The present structure for statutory audit
in the UK is based on the Companies Act 2006. Shareholders of
companies (unless exempt—such as most small companies) are
required to appoint external auditors for each financial year.
The auditor is required to report to shareholders on whether the
accounts have been properly prepared and constitute a true and
fair view of the state of the company's affairs.
5. The auditor is required to follow the
technical and ethical standards as set by the Auditing Practices
Board, and an audit firm wishing to be appointed as a statutory
auditor in the UK must be registered with, and supervised by,
their Recognised Supervisory Body.[1]
Auditors are subject to inspection by the Recognised Supervisory
Body (RSB) to which they belong, and these RSBs are in turn overseen
by the Professional Oversight Board (POB), part of the FRC. Through
its own Audit Inspection Unit, the POB reviews the quality of
the audits of listed and other major public interest entities.
Smaller audits are subject to review by the monitoring units of
the RSBs. A further part of the FRC, the Accounting and Actuarial
Discipline Board provides for independent investigation of important
cases of poor auditing.
6. The Department for Business, Innovation
and Skills has the following roles in relation to audit:
(a) It is responsible for the Companies Act 2006
and associated regulations.
(b) It takes the UK seat on the Audit Regulatory
Committee, which assists the European Commission in its adoption
of measures under the Statutory Audit Directive using the comitology
procedure.
(c) It is responsible for the regulatory framework
of UK law on audit, and for ensuring that it remains consistent
with EU law, by implementing into UK law the 2006 EU Statutory
Audit Directive and associated Commission Decisions.
(d) It keeps abreast of audit issues as an observer
on the UK's Auditing Practices Board and through contacts with
stakeholders.
(e) It sponsors the Financial Reporting Council.
7. We have attempted to estimate the costs
of audit in the UK: information provided to the Professional Oversight
Board by 31 of the larger UK audit firms, shows that together
they earned in excess of £2 billion in 2009 in audit fees.[2]
THE PRESENT
CHALLENGE
8. The aftermath of the financial crisis
has raised questions about the role of audit, in particular why
banks failed shortly after having clean audit reports, and what
the role of audit is, if it is unable to warn of such incidents.
These questions were articulated very clearly by the 2009 report
of the House of Commons Treasury Select Committee. Alongside the
questions raised by the economic crisis, there are other current
pressures for change: the investor community has been expressing
concern about audit reports, including that they should contain
much more useful qualitative information about the company, rather
than just the "pass or fail" opinion on the numbers
in the accounts that is currently provided. Alongside that, there
is the longstanding concern, discussed later in this evidence,
about the concentration of supply of major audits in the hands
of a very small number of audit firms.
9. The present crisis is not, of course,
the first to result in challenges to the audit structure. It is
notable that the reaction to this and previous crises or scandals
has been to tighten the regulation of accounting and audit. The
present system came into being largely as a result of the Enron
and other corporate scandals in the last decade: amongst other
measures, the ethical standards of the Auditing Practices Board
have been revised; the Audit Inspection Unit was formed for monitoring
the audits of all listed and other major public companies; and
law now contained in the Companies Act 2006 increased the rights
and powers of auditors in relation to information from employees,
officers, directors and subsidiaries. Nevertheless, these steps
have not prevented some parties from criticising audit and the
auditors for failing to stop the most recent crisis from occurring.
Others feel that the crisis cannot be attributed to a failure
in audit and auditors.
10. As a result, the Government is inclined
to be cautious about adding to the role of audit or its regulation
in relation to published accounts enhancements, which have the
potential to increase costs to the economy, unless it is clear
there are significant benefits, and these have been demonstrated
by a robust assessment of the economic impacts, in line with the
Government's commitment to better regulation. The outcome of this,
and other current debates will inform Government thinking.
THE ROLE
OF AUDIT
11. Ideally, the current debate on the role
of audit would be based on a clear understanding of exactly what
value audit adds to the economy. Unfortunately, the academic and
other evidence on this is not conclusive.
12. The theoretical rationale[3]
for audit is that it is demanded under two conditions:
(a) accountability, whereby an agent gives an
account of his actions to a principal; and
(b) complexity, where principals are distant
from the actions of an agent and unable to verify them.
This leads to two consequences:
(a) moral hazard, when agents may act against
the principals' interests; and
(b) information asymmetries, when agents know
more than principals.
Thus audit is a risk reduction practice which
benefits the principal because it inhibits the value reducing
actions by agents. The categories of principal and agent can be
filled out in a variety of ways. Principals can comprise, for
example shareholders, creditors and tax authorities.
13. In voluntary audit environments:[4]
— where a company has an audit voluntarily,
it does benefit from a reduction in its cost of capital because
of the signalling effect of the audit,[5]
and
— the bigger the company the more likely
it is to have a voluntary audit.[6]
14. The theoretical justification for mandating
audit is that it increases confidence in, and the strength of,
the financial system, but it is not clear, for instance, what
value is added by a mandatory (rather than voluntary) audit regime:
for example, whether mandating audit works to decrease the cost
of capital across the economy.[7]
15. In mandatory audit environments, the
signalling effect of voluntary audit is lost, because all comparable
firms have to have an audit, but voluntarily opting for higher
quality audit[8]
enables companies to regain some of the effect. This research
also demonstrates that bigger companies gain disproportionately
more from higher quality audits than smaller companies do. Bigger
audit firms are perceived to offer higher quality audits[9]
partly because of their increased expenditure on training, systems
and branding, partly because they have more to lose in reputation[10]
and partly because they have more to lose via litigation[11]
(auditor liability). It is difficult to split these effects.[12]
There is some evidence that audit firms that specialise in industry
sectors deliver audits that are acknowledged to be higher quality,
but the effect is reduced in regulated industries (eg banking)
because regulation acts as another substitute.[13]
Financial directors and investors do however find audit valuable
in checking company compliance with accounting standards and other
regulatory requirements,[14]
while they do not find value in the very limited (and often boiler-plate)
qualitative assessment currently provided.[15]
16. There are other modes of assurance available
for regulators, companies and investors as an additional support
or substitute for audit and vice versa. These include accounting
standards, dispersed ownership, risk management committees, audit
committees,[16]
internal auditors, credit ratings, insurance markets, investment
analysts, or additional disclosures above those mandated by accounting
standards and the law, and regulatory and supervisory bodies.
Hence, rather than having a unique role to play in corporate reporting,
the importance of audit is as one element in a multi-faceted regime
of corporate governance and regulation.[17]
17. Mautz and Sharaf, in their seminal work
on auditing (1961),[18]
suggest that audit works best in normal environments—that
is, in non-collapsing systems and non-fraudulent firms—where
auditors can expect that normal audit procedures will uncover
normal errors and normal managerial misstatements. This suggests
that audit cannot provide a defence against systemic risk in an
economy.[19]
Audit also provides only a limited defence against material fraud
in a company, especially where there is significant collusion
by senior management. These issues give rise to the much quoted
expectation gap, which arises where people expect to get more
assurance out of an audit than is in reality provided, or can
be provided—there is an expectation gap in as much as the
audit is often assumed to provide a greater degree of assurance
than it can actually provide.
WAY FORWARD—DEBATE
ON MANDATING
AUDIT?
18. Given this evidence, it seems to the
Government that there is value in a debate about the extent to
which audit should be mandatory, and what the nature of any mandated
audit should be. The Government's view is that audit has an important
but not unique role to play in ensuring vibrant capital markets.
It is less clear that a modern audit, designed largely for listed
companies with diverse shareholders, should necessarily be imposed
on, for instance, a medium sized owner-managed company. This is
a debate which will need to take place at EU level; the current
accounting directives do not allow the audit requirement to be
lifted, other than from small companies or subsidiaries. At the
same time, given the importance of key financial institutions
to the economy, the Government recognises the need for auditors
to contribute to prudential supervision as described in the FSA/FRC
Discussion Paper.
AUDITOR INDEPENDENCE
19. Professor Ray Ball suggested that both
the fact that auditors are remunerated by companies and the total
level of that remuneration inevitably affect auditor independence
and judgement.[20]
This has the potential to make it hard for auditors, who are in
reality selected by management,[21]
and who are commercial organisations, to stand up to management,
particularly when financial results are poor.[22]
Lennox (2000) shows that companies are able to engage in opinion
shopping[23]
in their choice of auditor. However, opinion shopping in the UK
is likely to be infrequent, given the very low switching rates
for auditors described later in this paper. Geiger and Raghundan
(2002) find some supporting evidence that auditors are more likely
to issue a clean audit report prior to a bankruptcy filing in
the early years of the auditor-client relationship.[24]
However, there are a number of reasons that there may be problems
in the first year of an audit relationship, as the auditor builds
familiarity with the client's business, and audit and its regulation
have changed significantly since Enron.[25]
20. The Government's view is that while
there is no evidence of systematic problems of auditor independence,
the body best placed to bolster auditor independence is a strong
audit committee.
WAY FORWARD—WHAT
SHOULD BE
IN THE
REPORT?
21. The challenge to auditors that they
should have seen the bank collapse coming is linked to the question
about what should be said in the audit report, which has been
raised by investors and other users. Elements of the developing
investor view are that the standard audit report is not very useful
at present in that it is of standardised form, and could be reformed
to include useful company-specific information and the auditor's
view as to the degree of aggression in the company's accounting
choices. There could also be more disclosure about the risk position
of the company, and the key judgements taken during the course
of the audit. Such an approach, it could be argued, might have
provided some forewarning of the collapse of the banks, but it
is hard to see that audit alone could provide a defence against
systemic risk of that kind. However, the Government is committed
to the objective of improving bank corporate governance and will
continue to work closely with the EU and internationally to increase
transparency and accountability in a consistent and proportionate
manner. The joint Discussion Paper by the FSA and FRC already
referred to explores wider ideas about the contribution of audit
to prudential regulation.
22. The audit profession concedes that there
may be some room for improvement in making audit reports more
informative, but it has concerns that by providing more information
or assurance, it will be exposed to greater liability. This could
tend to push up fees, or increase pressure for more liability
protection for auditors, or both. Ian Powell, the Chairman of
PWC in the UK is quoted as saying "On a bilateral basis,
you will not see an auditor start making a more informative audit
report while the rules are as they are and there's unlimited liability".[26]
There would need to be clear evidence that the information benefit
exceeded the cost either in fees or liability capping before Government
would act.
23. It is not clear that the company specific
information sought by users is best provided by an auditor. There
is an argument that such issues and information about the company
are more properly disclosed by the audit committee and management,
with the auditors then possibly providing some assurance over
the accuracy of the information. Whether information were to be
disclosed by the company or by the auditor, it would be a challenge
to ensure that genuinely useful company specific information is
provided, and not just boiler plate. It is by no means clear that
a mandatory requirement is the best route to securing disclosure
of the information. Some form of voluntary route could be considered,
perhaps by an amendment to the UK Corporate Governance Code.
24. Research on a sample of listed companies
published in 2009 by the Financial Reporting Council shows that
for many listed companies there is much room for improvement in
their narrative reporting as required by the Companies Act. In
the reporting of the principal risks facing their business, 66%
of companies were technically compliant with the law, but fell
short of the spirit of the requirements. In providing a description
of their business, 58% of companies were either not compliant
with the law, or were technically compliant but fell short of
the spirit.[27]
25. It is therefore not obvious exactly
how to achieve more informative disclosure of the affairs of companies,
either by management or by the auditors. There are clearly costs
associated with the various routes, and it may be hard to achieve
the benefits desired. It is for these reasons that the Government
has not come to a firm view on the way forward, and wishes to
see the outcome of this inquiry by the House of Lords and other
debates.
AUDIT MARKET
26. The market for the supply of audit for
public interest companies in the UK is very concentrated. Just
four firms undertake the audits of 99% of FTSE100 companies and
95% of FTSE 350 companies. Complex sectors such as finance are
already reduced to two or three audit firms that have the necessary
expertise to undertake these audits while auditor independence
rules can further reduce this choice.
27. In the late 1980s there were eight major
accounting firms that provided audit services. Since 2003, there
have only been four. This is a result of a series of mergers including
Price Waterhouse and Coopers & Lybrand, which was approved
by the EU in 1998 and the collapse of Arthur Andersen in 2002,
which resulted in the UK firm merging with Deloitte. The Deloitte
merger was approved by the EU who raised competition concerns
but concluded there was no better alternative as the international
Andersen network had effectively collapsed.
28. The share of the audit market held by
the Big 4 differs across G8 countries. In 2007, Canada, Italy,
UK and US had the greatest concentration of the Big 4, accounting
for a market share of 95% or higher, followed by Russia at 90%,
Japan at 84% and France at 61%.
29. The high concentration levels in the
UK audit market are limited to the audit of FTSE 350 companies.
Smaller companies have access to a much wider selection of firms,
for example there are 119 medium sized audit firms with between
11 and 50 Principals.[28]
30. The Government has been concerned about
competition for FTSE 350 audits for some time. BIS and the FRC
jointly commissioned an independent analysis[29]
of competition in the audit market. This paper was published in
April 2006 and the main findings were:
(a) The FTSE350 market for audit services is
highly concentrated.
(b) Switching rates are low at around 4% on average
for all listed companies, and 2% on average for FTSE100 companies.
(c) A limited number of UK listed companies,
primarily in the financial services sector of the FTSE100, have
no effective choice of auditor in the short run. This elimination
of choice is driven by high market concentration, auditor independence
rules, supply-side constraints, and the need for sector expertise.
(d) Higher concentration has led to higher audit
fees (although this finding of the report has been disputed).
While there is a degree of price sensitivity among companies,
and some bargaining on fees takes place during the annual audit
firm reappointment process, in general the focus of audit committee
chairs is more on quality (and reputation) than on price. Separately
from the impact of concentration, audit fees seem to have risen
in recent years as a result of cost increases, caused by factors
such as change in regulation.
(e) A range of barriers to entry to new competitors
helps to sustain this concentration, in particular:
(i) Acquiring a credible reputation/perception
of reputation;
(ii) Establishing an extensive, integrated network;
and
(iii) Resource and technical expertise in audit.
31. In response to the competition issue,
the FRC established the Market Participants Group (MPG), which
comprised representatives from companies, investors and audit
firms. They were tasked with advising the FRC on possible action
to mitigate the risks arising from the concentration. Their advice
was limited to market-led solutions with responsibility for implementation
of their recommendations falling to the FRC. Most of the recommendations[30]
have now been implemented and the FRC recently published their
fifth progress report.[31]
They have found that the market-led approach has not had a significant
impact on market concentration and the FRC are currently undertaking
a review with the aim of developing further proposals. This review,
alongside the Commission Green Paper, will feed into HMG's future
policy on competition in the audit market.
32. The Government will be working closely
with the FRC on its review. Without in any way wishing to prejudice
the outcome of that review, the Government's initial view is that,
with the current (four-player) state of the audit market, it may
be difficult to identify measures that will be effective in increasing
choice for the largest audits without also imposing major costs.
Those costs might be hard to justify.
10 September 2010
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