FEE comment letter on IESBA consultation on changes to part C of the ethics code for professional accountants

21 April 2015

FEE published its comment letter on the IESBA ED 'Proposed Changes to Part C of the Code Addressing Presentation of Information and Pressure to Breach the Fundamental Principles..

FEE's general comments are as follows:

• The distinction between fundamental principles and overarching principles must be made clear. The Code is based on five fundamental principles. All other requirements including the ‘fair and honest principle’ and the principles relating to pressure (section 370) emerge from one or more fundamental principles. Therefore, the newly introduced overarching principles or requirements should not be seen as standalone and cannot be described as such. The fundamental principles included in Part A are the only overarching ones. The terminology of ‘overarching principles/requirements’ are not only confusing, but also conceptually questionable.

• As Part C of the Code essentially provides more detailed guidance on how the fundamental principles should be applied in practice, it is of the utmost importance that the link between the extant Parts A and C be made clear. Any amendments or additions to Part C must have some connection with the fundamental principles set out in Part A and should not include any new requirement that cannot be traced back to a requirement included in Part A.

• As emphasised several times in FEE's responses to the questions below, the proposal contains a large number of long lists of examples. This may lead to users seeing them as exhaustive checklists. FEE suggests using wording such as ‘examples include, but are not limited to […]’ 

Full comment letter

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