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Audit Regulations for UK and Ireland 2020

Due to the introduction of the Irish Companies Act 2018 and the resulting changes to the Audit Regulations, only firms that have opted in to Irish audit registration and which meet the new eligibility criteria can carry out Irish audits. Firms are no longer automatically included on the Irish Audit Register.

The other resulting requirements are:

  • Tests for the control of firms by audit qualified personnel in regulation 2.03 have been modified to ones based on membership rather than voting rights. This is only in respect of firms that require registration in Ireland. They do not apply to firms that only perform UK audits.
  • CPD requirements have been tightened so that a greater emphasis is placed on Irish specific experience as part of the competencies. IAASA is empowered under the revised Act to issue guidelines on this. (expected Spring 2020). After IAASA publish their CPD guidelines, it is expected that this experience requirement may become more demanding.


As IAASA have expressed concern about Irish experience for those on the Irish Audit register (which has arisen in Brexit discussions), ICAEW has only registered firms for the Irish Audit Register that were able to demonstrate experience of dealing with Irish audits. 

ICAEW’s change in registration approach is in part to save firms from having to amend their constitution when they are unlikely to have any Irish audit work. 

Applications for Irish Audit Registration

Firms that wish to continue their registration on the Irish Audit Register should have applied separately for that registration by completing the relevant application forms and demonstrating eligibility. The closing date for receipt of applications was 31 January 2020.

Firms that applied but were not approved by 31 January 2020 will remain on the register but won’t be eligible to sign Irish audit reports until we have approved the application. Firms that did not apply before 31 January 2020 are no longer registered to carry out audit work in Ireland.

The new Irish audit application forms include a section for the applicant’s Irish experience. Note, the records maintained under IES8, in particular for elements (b) financial reporting and accounting, d) business environment, (e) taxation and (g) business law and regulations will be persuasive.

Transition period

Firms that need to amend their structure to meet the Irish control criteria will be allowed up to 30 June 2020 to complete the necessary changes.

Changes to firm stationery and websites

If your firm is no longer on the Irish Audit Register, you will need to need to update your stationery/website with the following ‘Registered to carry out audit work in the UK’ or similar to exclude Ireland.

Timing and manner of disclosure of penalties and sanctions

As part of procedures under the new Irish Companies Act, ICAEW, ICAS and ICAI have recently updated their summary of the principles applied regarding the timing and manner of disclosure of penalties and sanctions in respect of Irish audit regulation. These apply from 1 January 2020.