Accountants Association in Poland

Although AAP has no direct responsibility for quality assurance (QA) reviews, it actively promoted the importance of establishing a QA system amongst relevant authorities. In line with the Act on Statutory Auditors, Audit Firms, and Public Oversight of 2017 as amended, a mandatory QA review system for all audits has been established and is operated by the Polish Audit Oversight Agency (PANA).

The AAP has developed specific activities to assist its members that also are members of the PIBR, and therefore, subject to QA reviews, in improving the quality of the audit services they deliver. Examples of such activities include the delivery of continuing professional development courses and seminars for statutory auditors, cooperating with the PIBR on the ongoing training of joint members and recommending pertinent training topics, and the development of publications on statutory audit activities.

The AAP is encouraged to continue supporting its members who provide audit services in enhancing the quality of the audit services they deliver and to incorporate in its SMO Action Plan specific examples of activities it has planned in this respect. As IAASB is revising its standards on quality control, AAP should consider following the developments and incorporating the revisions and prepare for the implementation of the revised standards. Staff reiterate its recommendation that the association consider reviewing, in coordination with other stakeholders, the existing QA review system against the revised SMO 1 requirements and work with the PANA to develop actions to address any areas that may require improvement

Current Status: Review & Improve

Education of accounting professionals other than auditors is not regulated by law. AAP has developed its own certification program and offers the following voluntary certifications: Certified Accountant, Chief Accountant, Accounting Specialist, Certified Expert of Accounting Services, and Certified Specialist of Accounting and Tax Bookkeeping based on passing the relevant examinations and practical experience. AAP reports that the curriculum aligns with IES 2.

Those obtaining the certificates of Certified Accountant, Certified Expert of Accounting Services and Certified Specialist of Accounting and Tax Services are required to be members of the AAP and are subject to continuing professional development (CPD).

AAP advises that the CPD for Certified Accountants has been developed based on IES 7 without specifying the version of the standards. Certified Accountants are required to attend 90 hours of training in three successive years after qualification. In each year, at least 20 hours must be dedicated to CPD.

Members of AAP holding the certificates of Certified Expert of Accounting Services and Certified Specialist of Accounting and Tax Services are required to attend 60 hours of training during the three years following their certification. At least 10 hours of the training must be activities organized by the AAP. Other members of the AAP may attend different CPD activities on a voluntary basis.

The AAP maintains an awareness of the market needs for qualified accountants and established the Employers' Council as an advisory body. The AAP updates the curricula on an ongoing basis to incorporate the requirements of IES and labor market demands including expectations of the course participants and employers. Also, the AAP actively participates in the work of the Ministry of National Education and the Institute of Educational Research on the National Qualification Standards.

Staff reiterate its recommendation that the AAP consider bringing its IPD and CPD requirements in line with IES for all categories of professionals it certifies and to this effect develop a plan, with specific timeframe. It is also recommended that AAP conduct an assessment of its educational programming against revised IES that become effective in 2021 and raise awareness of other stakeholders about the need to bring educational requirements overall in line with IES. The AAP is encouraged to use the IES Checklist and the Accountancy Education E-Tool developed by IFAC to conduct the assessment and to consider available implementation support materials.

Current Status: Execute

The AAP has no direct responsibility for the adoption of ISA and reports that it in general supports implementation of ISAs.

Although the AAP was not directly responsible for the translation of ISA, until 2010 it was individually performing the translations of ISA thus contributing to the implementation of international standards in Poland.

The AAP also indicates that it raises members’ awareness of the activities of the IAASB by disseminating new pronouncements and organizing conferences and seminars on ISA as needed. The AAP also has been a participant at World Bank trainings on ISA.

The AAP has demonstrated that, within the scope of its authority, it is committed to meeting the SMO 3 obligations. If deemed practical and needed, AAP could consider assisting with the translation process to reduce the time lag between the issuance of new IAASB pronouncements and their application in Poland.

Current Status: Review & Improve

Unlike auditors, accountants in Poland are not subject by law to ethical requirements. Nevertheless, AAP, a PAO uniting accountants on a voluntary basis, requires its members to abide by its Code of Professional Ethics in Accounting (CPEA) is supplementary to the IESBA Code translated by Polish Chamber of Statutory Auditors (PIBR) to address the fact that its membership is mostly comprised of accountants. AAP indicates that the CPEA is consistent with the IESBA Code.

All of the AAP members are signatories of CPEA and, based on the AAP statute provisions, are required to follow the CPEA. In addition, professional ethics have been included in all the certification programs of AAP.

The AAP has developed a wide range of activities to raise the public’s awareness of CPEA and to assist its members with the implementation of ethical standards. The AAP has created the Bank of Ethical Dilemmas which features case studies as an educational tool to facilitate the teaching of ethical principles. Moreover, the Association has established the title of an Ambassador of Professional Ethics in Accounting to encourage individuals and firms to comply with and popularize its ethical standards.

The AAP issues a newsletter on ethics (Courier of Ethics) and participates in regional and international conferences to promote its ethical requirements. The Association also monitors IESBA activities and pronouncements in order to share developments with its members and other stakeholders.

In 2020, as recommended, the AAP’s Ethics Commission prepared an analysis to detail the similarities between the CPEA and the IESBA Code of Ethics as of March 2019. The report advises that the AAP Code is essentially compatible with the IESBA Code and detailed that AAP members in addition to adhering to the CPEA are regularly updated on changes to the IESBA Code.

The AAP’s efforts to introduce ethical requirements for its members in the absence of legal requirements are commendable. The AAP is encouraged to consider developing ongoing processes to ensure that the latest IESBA pronouncements are adopted for application by the AAP with a minimal time lag and to continue to work with other relevant stakeholders in the jurisdiction to raise awareness about the need to legally extend ethical requirements to all members of the profession.

Current Status: Review & Improve

The AAP has no responsibility for the adoption of public sector accounting standards and reports that it uses its best endeavors to promote the adoption of IPSAS, which have not been adopted in Poland.

The AAP reports that it has developed activities to monitor the activities of the International Public Sector Accounting Standards Board and promotes the international standards via the Research Council Commission and its participation in the Public Finance Forum.

The AAP reports that the MoF is considering the adoption of IPSAS and intends to translate the IPSAS Handbook as a first step. The MoF has approached the AAP to support its training and professionalization efforts in the public sector.

The AAP is encouraged to continue to liaise with the Ministry of Finance as a resource to translate IPSAS into Polish and advocate for IPSAS adoption in Poland. The AAP has demonstrated that, within the scope of its authority, it is committed to meet the SMO 5 obligations. The association is encouraged to further consider opportunities in the area of public sector accounting and, if deemed feasible, develop a plan with a defined timeline and specific activities in the area.

Current Status: Review & Improve

The AAP carried out a review of its investigating (I&D) systems which resulted in amended regulations to clarify the rules and operating procedures with their system including the Peer Courts and a better alignment with SMO 6. However, the extent of alignment of SMO 6 remains to be established.

Within the AAP structure, there are two types of Peer Courts (Main Peer Court and Regional Peer Court) which hear disciplinary cases for acts violating the provisions of the generally applicable law, the AAP Statute and the AAP Code of Professional Ethics in Accounting (CPEA), including the dignity of the accountancy profession and good professional behavior. The Peer Courts hear cases on an ongoing basis without delays or postponements; and their members are elected every four years. The Peer Courts operate with full independence and autonomy.

The Peer Courts issue disciplinary actions which may result in a warning, reprimand, or suspension of the member’s rights for a period of up to 1 year or for a period of 1 to 3 years or exclusion of AAP membership.

The AAP also adopted the By-laws of Peer Courts of the Accountants Association in Poland which details the individual elements of the I&D process including the (i) jurisdiction and composition of the courts, (ii) exclusion of a member of the adjudicating panel of the court, (iii) parties to the proceedings, disciplinary spokesperson, (iv) evidentiary proceedings, (v) deadlines and delivery, (vi) decisions, penalties, (vii) suspension of proceedings, discontinuation of proceedings, (viii) explanatory proceedings, (ix) appeal procedure, (x) enforcement of decisions, and (xi) organizational and administrative support for disciplinary proceedings.

Staff reiterate its previous recommendation that the AAP carry out an assessment of the I&D system it operates in order to clearly indicate the level of compliance with SMO 6 requirements. It is then encouraged to include plans to address any gaps in compliance in its SMO Action Plan. It also should include specific planned actions or initiatives to support the implementation of the I&D mechanisms and disseminate information on I&D procedures to its members and the public.

Current Status: Plan

While the AAP has no responsibility for setting accounting standards in Poland, it plays an active role in supporting the Accounting Standards Committee, which issues National Accounting Standards (NAS), and supporting the implementation of IFRS.

From 2001–2016, the AAP maintained a licensing agreement with the IFRS Foundation and translated and published IFRS in Poland. The AAP continues to support the implementation of IFRS by sharing IASB developments with their members and on their website. To obtain the Certified Accountant classification issued by AAP students must pass the IFRS module, which is updated on an ongoing basis.

Also, the AAP conducts trainings and courses to promote IFRS including organizing outreach events with the Ministry of Finance and Polish Chamber of Statutory Auditors (PIBR) upon invitation from the European Financial Reporting Advisory Group.

The AAP is encouraged to continue to promote the adoption of IFRS and IFRS for SMEs in the jurisdiction and to provide specific examples in its SMO Action Plan of activities it has planned to support the implementation of IFRS amongst its members in the upcoming year. The AAP also is encouraged to consider promoting the adoption of IFRS for SMEs in the jurisdiction and to indicate in its SMO Action Plan any activities it has undertaken in this regard.

Current Status: Review & Improve