The ICAEW’s recommendations
The vision of the Institute of Chartered Accountants of England and Wales (ICAEW) is that by 2025 there will be annual public disclosure on a true and fair basis of the public sector financial position of all EU member states. The Institute’s discussion paper on The Future of EU Public Sector Accounting in a Global Context seeks to generate a broad stakeholder consensus, and puts forward three policy recommendations.
First, we recommend that the idea of true and fair public sector reporting be anchored in a framework of EU law which sets out key principles on the form of harmonisation, enforcement and institutional structures. These principles could be implemented through international and/or national standards. To meet the 2025 deadline, legislation would need to be adopted before the end of the current EU legislature in 2019.
Second, within the overall framework of EU law, we think it is important that there be room for tailored member state implementation, including the use where needed of roadmaps for reform with clearly defined milestones. This approach will enable member states to maintain their national accounting traditions, in line with the overarching EU principle of subsidiarity. We also suggest that the reporting of a financial position can be through consolidated or combined financial statements, to suit individual member states’ constitutional arrangements, while respecting EU comparability.
Our third recommendation addresses issues of governance, institutions and technical expertise. The legislation should establish that International Public Sector Accounting Standards (IPSAS) are the basis of the new arrangements, and ensure appropriate legitimacy and accountability for the use of these standards. In this regard, the EU should think creatively, and a comparable structure to that of the European Financial Reporting Advisory Group (EFRAG) for private sector reporting could play a key role, with any necessary modifications in composition. Equally, the legislation should clarify the institutional arrangements and expertise needed to enforce the implementation of the new standards by member states.
We very much recognise Eurostat’s continuing efforts to progress member state accounting reforms, in particular to assist in the introduction of accruals-based reporting for member states which still operate a cash-based accounting system, and to facilitate interaction on many other technical issues. Still, at the EU legislative level, mandatory public sector accounting reform seems to have slipped far down the priority list – if not off entirely. Our recommendations are directed at this level. We believe it is important to proactively and creatively seek to address the challenges which have stood in the way of establishing an EU-wide consensus to date, by establishing an agreed framework and a target date for completing the reform.
The benefits of reform
We see clear advantages in having more than one viewpoint on public finances. To date, EU member states are required under the Maastricht criteria to prepare national accounts which are drawn up on a statistical basis according to information requirements set out by Eurostat in the European System of Accounts (ESA 2010). They have a different purpose to financial accounts and do not provide a full picture of assets, revenues, expenses and liabilities. Financial accounts, so called as they are prepared according to the broad, internationally-accepted principles of accounting used for private companies, record this full picture.
National accounts and financial accounts can and should be mutually reinforcing. If done properly and on the basis of comparability, the combination of these two elements creates a whole which is greater than the sum of the individual parts. This can give the EU a new, more robust “Maastricht Plus” framework to underpin financial stability, as well as improve government management of public finances and enhance democratic accountability.
The ICAEW believes that the international accounting standards route would deliver the best return on investment for the EU, not least given the shortage of expertise. It should allow the IPSAS Board to continue developing a more complete and robust set of international standards, making efficient use of existing structures, processes and skills. Of course, there will be costs for member states associated with introducing the reforms we recommend – even taking into account the proposed tailored roadmaps and reliance on national accounting institutions and practices. Nevertheless, there are critical advantages to using a model based on existing infrastructure and expertise. This approach will allow public money to be allocated most efficiently, increase transparency, and reduce the financial burden on taxpayers.
Get involved
Turning our recommendations into reality requires the wider stakeholder community to act as advocates for reform. We thus welcome all comments and suggestions on our recommendations. Our intention is to reflect on all feedback received in order to foster a wide stakeholder debate on the merits of adopting a new EU legal framework on public sector accounting.
[1] Martin Manuzi is ICAEW Director, Europe Region; Simon Tosserams is EU Affairs Executive at ICAEW.
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