FEE´s comment letter on the IESBA consultation Improving the Structure of the Code of Ethics for Professional Accountants

16 February 2015

FEE agrees with the consultation's emphasis on the importance of the principles-based conceptual framework.

FEE´s general comments:

• FEE welcomes the fact that the Paper emphasises the importance of the principles-based conceptual framework and how it serves to protect fundamental ethical principles


• The primary objective of this restructuring exercise should be to make the Code clearer and more understandable


• It would be advantageous to distinguish between the fundamental principles and other concepts derived from those principles – or, in other words, to differentiate between provisions that deal with ethical requirements and provisions that require formal compliance and enforceability (such as the independence provisions currently included in section 290 and 291 of the Code)


• The existing link between the Code, ISQC 1 and ISAs should be maintained


• It should be taken into account that EU countries are currently in the process of implementing major audit reforms and may therefore need more time to implement any changes to the structure of the Code. It should also be noted that, as yet, little feedback has been received from countries that implemented the Code in 2009


• For non-English speaking countries and countries that have only recently translated the Code, the benefits of any proposed changes to the structure of the Code must outweigh the likely costs of adapting their current provisions to the new structure of the Code

Full comment letter

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