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Third country audit registration in EU

Author: ICAEW

Published: 17 Feb 2022

Firms seeking to secure the audit of an entity with an overseas listing that involves registration for the first time with a particular EU state need to allow the necessary timescales to get this through for their reporting period.

ICAEW recently prepared a report for Department for Business, Energy and Industrial Strategy (BEIS) setting out the experience across a number of EU states and drew attention to those states where there were some difficulties. BEIS is helping to ease the ground in those areas. As a rough guide we have set out the experience of a number of firms in securing registrations:

Degree of complexity



Denmark, Germany, Ireland, Luxembourg, Norway, Sweden


Czech Republic, France, Netherlands, Spain


Belgium, Italy, Poland

The registrations are something each firms needs to secure directly with the relevant state and may need the aid of a network firm in the country or a local legal firm. ICAEW can give advice and support where this is required particularly on fit and proper assessments.

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A number of the PIE audits in the UK involve listed entities with listings in the UK and also in overseas markets. Prior to Brexit and the end of the transition period, UK audit firms if registered in the UK were automatically recognised in the EU states where those additional listings might be held. However, after 31 December 2020 this automatic recognition ceased. Since then firms have had to go through a registration process with the relevant states. This process is set out in article 45 of the EU Audit Directive 2006 (as amended) and is supported by standard EU documentation known as Form B.

Application must be made to the ultimate competent authority in each state. Details of these oversight bodies are easiest found in Accountancy Europe’s recent guide to audit regulation in Europe ‘Organisation of the Public Oversight of the Audit Profession in 30 European Countries’. However, the state of readiness for these bodies to process third country auditor applications and the necessary steps they and the firms need to take vary considerably around the core Form B documentation.

In Ireland (as part of the planning for Brexit and the no deal Brexit scenarios) the Irish Auditing and Accounting Supervisory Authority (IAASA) required the regulatory bodies and the firms they supervise to put in place all necessary steps to minimise disruption to audit services. IAASA ensured well in advance there was a clear rehearsed third country registration process and consequently this has proved to be the most straight forward country with which to secure the necessary recognition. As a substantial part of EU listings for UK entities fall within Eire this has been highly important.

For Form B processes, ICAEW is required to give fit and proper assessments of members and those they regulate who are not members. Experience continues to show that the registrations are not straight forward.