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Irish third country draft registration application

Auditors of UK companies (ie, companies incorporated in the UK) with listings on the Irish Stock Exchange, (such as listed debt), will be required to register with IAASA as third country auditors at the end of the transition period (31 December 2020) unless their registration continues to be accepted on the Irish audit register.

IAASA has indicated they are prepared to review draft applications in advance of the end of the transition period so the registration can be effected quickly after 31 December 2020. A number of firms used this process in January 2019 in anticipation of a possible no-deal Brexit (at 31 March 2019); this would simply be a case of updating such applications. The period from 1 October 2020 would be the expected window for this should the main Irish registration for the firm appear to be invalid after 31 December 2020.

Who cannot use this process

This application process does not apply to registration for third country status to perform Irish statutory audits under section 1470(c) of the Companies Act 2014.

IAASA has advised (notice issued on 19 January 2018), the European Commission has stated that in the absence of a ratified withdrawal agreement, the UK will become subject to third country rules at the end of the transition period

Section 1572 of the Companies Act, 2014, states that a recognised accountancy body (RAB) may approve a third country auditor as a statutory auditor if that person furnishes proof that he or she complies with requirements equivalent to those specified in sections 1464 and 1472. A prerequisite to this is for the countries involved (in this case the UK and Ireland) to have a reciprocal arrangement agreement in place. A framework agreement has been made between the FRC and IAASA. However the detailed arrangements hare not currently in place and IAASA cannot estimate when these may be finalised.

How to apply (from October 2020)

To apply, please complete Form B and other relevant Form B annex documents 1-8 on the IAASA website.

The application requires fairly standard details about the firm and its responsible individuals (RIs).

The following points should be noted in completing the forms.

Management details (6.1), RI details (7.1), Fit and Proper 12.1

For ICAEW members listed in your application, copies of certificates are not required. IAASA has agreed this information can be confirmed directly from ICAEW.

  • The relevant IAASA schedules should be completed and sent to IAASA.
  • Send ICAEW, in Excel format a copy of the Forms B–4 (IE) and B-5 (IE) you have submitted to IAASA. These contain information about the firm management and individuals who require confirmations as part of their application. Please email them to information.centre@icaew.com. To help with processing, please include ‘IAASA Form B Registration - <name of firm>’ in the subject.

For each ICAEW member listed, ICAEW will confirm to IAASA the following:

  • ICAEW membership 
  • Audit qualification and audit registration number 
  • Training experience
  • Disciplinary history

We will provide confirmation of affiliates registered by ICAEW. Their history and standing will need to be obtained from their home professional body. 

You are not required to register all UK RIs with IAASA, only those whose audits are covered by the application.   

Fees

Currently these are;

  • €4,000 for annual registration assessment
  • €500 for annual registration fee

These should not be submitted while the application is draft. IAASA will advise when the application can be made in final form and fees will be payable at that point.

Application submission

Submit your application by email to barry_murphy@iaasa.ie or by post to IAASA at their office address (which is given at the top of the application form).

You should state that the relevant professional body confirmations from ICAEW will be submitted directly from ICAEW within your application in accordance with the procedure agreed between IAASA and ICAEW.

IAASA has indicated they will address each application on a first in first out basis.

Further information

Further information on the application can be found on IAASA’s website.