Ordre des Experts-Comptables et Comptables Agréés du Bénin

The OECCA-Benin has demonstrated a commitment to develop and implement a QA review system that is in line with SMO 1 best practices. Since 2014, after internal approval on the adoption of ISQC 1 and QA review procedures, it has advocated to the government to pass legislation that would make the regulations legally binding. Although this was not passed, with the passage of the Organization for the Harmonization of Business Law in Africa’s (OHADA) Regulation No. 01/2017/CM/OHADA in 2017 that mandates professional accountancy organization’s (PAO) in OHADA member states to develop and implement a QA review system, OECCA-Benin has been striving to operationalize its system and has begun to execute activities to fulfill the SMO 1 obligations.

There have been delays due to resources; however, in December 2018, OECCA-Benin sent out self-assessment questionnaires to members which were subsequently returned to the institute and its QA Committee. Based on these results, OECCA-Benin offered training in 2019 and developed a guide to support members in making corrections. It has also shard the OHADA-issued QA manual with its members. In 2020, the institute intends to update its quality control guide and begin a self-assessment campaign amongst firms. The results from the questionnaire will inform the selection of firms for compulsory QA reviews that are planned to commence in 2021. OECCA-Benin plans to select and train quality controllers by Q3 2020.

The President of OECCA-Benin continues to chair of the Conseil Permanent de la Profession Comptable’s (CPPC)—the regional auditing standard-setter—Quality Control Committee and therefore, works with other professional accountancy bodies to better understand and promote the adoption and implementation of QA review systems in the region. OECCA-Benin has participated in a West African Economic and Monetary Union (WAEMU) meetings for quality control.

OECCA-Benin has taken proactive steps in beginning its QA review system. Plans to carry out QA reviews in 2021, were delayed by the outbreak of the pandemic. It is encouraged to continue reviewing the SMO 1 best practices and preparing its members to undergo the review and understand the benefits of the review process. At this time, members may need more support in establishing quality control systems. The institute should continue including new developments its QA review plans into its Action Plan. As other Francophone PAOs in OHADA member states are also preparing to launch QA review systems, the OECCA-Benin may consider how it can collaborate in the exchange of tools, quality controllers, and information in French. Lastly, the OECCA-Benin is encouraged to continue monitoring and preparing members for the changes from quality control standards to quality management standards that being proposed and reviewed by the IAASB.

Current Status: Plan

With initial professional development (IPD) requirements established at the regional level by the West African Economic and Monetary Union (WAEMU), the role of the OECCA-Benin is to enforce the IPD requirements and establish continuing professional development (CPD) requirements for its members.

Presently, the regional IPD requirements include obtaining the Higher Education Degree in Accounting and Financial Management (DESCOGEF—for Certified Accountants) and the Degree in Accounting and Finance Expertise (DECOFI—for Chartered Accountants) in order to pass the qualifications’ exam and practice within any of the West African Economic and Monetary Union (WAEMU) member states. Within the OHADA, there are apparently curriculum reforms under consideration that would enable accountancy education to better align with the IES requirements. Currently, it is still in the consultation phase and OECCA-Benin attended an OHADA meeting in 2018 related to the project. The regional body is assessing what professionals are expected to do in their job and use this as a starting point for accountancy education.

At the national level, OECCA-Benin has determined that professionals that satisfy the regional educational requirements or hold the Conseil Supérieur de l’Ordre des either Experts-Comptables (CSOEC-French institute) qualification may join the institute and use the title of Chartered Accountant. According to the Compagnie Nationale des Commissaires aux Comptes (CNCC) and Conseil Supérieur de l’Ordre des Experts-Comptables (CSOEC), the DEC qualification is aligned with the 2019 IES requirements.

In support of IES 1 and the DESCOGEF examinations, the institute has partnered with Nantes Academy in France to review the content of students’ final reports and the Institute Français (French Cultural Centre) in Benin to host examination sessions. This has permitted more students in Benin to progress toward the qualification instead of having to go to France to study. The OECCA-Benin has also set a CPD requirement whereby all members must complete 48 hours of CPD per year. Fulfillment of CPD is monitored by the institute’s CPD Committee. The institute annually offers between 200-250 hours of CPD for its members to ensure that the CPD obligation is met.

OECCA-Benin indicates that it has served an advocacy and advisor role to the Ministry of High Education by providing information on the IES and the content of accountancy education programs. For example, after the passage of the new OHADA Regulation on accounting standards, the government organized a free, week-long capacity building workshop to train accountancy instructors on the new standards and thereby support IES 1. The Ministry of Higher Education and the institute have agreed to plan an evaluation of the current accountant education programming.

OECCA-Benin has demonstrated that it is carrying out initiatives to incorporate IES requirements where it is able to at the national level. There is still opportunity to further review educational requirements and approaches to identify and make changes that would enable to it further fulfill the SMO 2 obligations.

The 2019 IES emphasize the need for professional accountants to demonstrate competencies to carry out their roles and responsibilities throughout their initial professional development programs. It is not clear from the available information if the regional IPD requirements align with the IES requirements. Further, in 2019, newly revised IES address learning and development for information and communications technologies (ICT) and professional skepticism. As market expectation increases for ICT skills and professional skepticism, these standards were developed to address the competencies, skills, and behaviors for both aspiring and professional accountants in these critical areas. These revised standards become effective January 2021. The requirements may require both regional and national changes to accountancy education programming, which presently seems focused on theoretical training. The institute could take a lead role in advocating, assessing, and planning for the incorporation of these international requirements. The IES Checklist and the Accountancy Education E-Tool developed by IFAC may be used to conduct an assessment and to consider available implementation support materials.

Current Status: Execute

The Organization for the Harmonization of Business Law in Africa (OHADA) has been revising regional regulation to harmonize auditing standards with international best practice. In June 2017, OHADA issued regulation stating that all member states, which includes Benin, must adopt the International Standards on Auditing (ISA) as issued by the International Auditing and Assurance Standards Board (IAASB) beginning in January 2018. In accordance with the regional requirements, OECCA-Benin indicates that in the jurisdiction ISA are effective as issued by the IAASB.

OECCA-Benin has been committed to the adoption of ISA at the national level prior to 2017. The institute has required its members to apply ISA since 2012. With adoption now effective at the regional level, OECCA-Benin reports its role is to continue providing implementation support to its members. It is doing this by providing trainings, continuing professional development (CPD) courses, and access to OHADA guides and the Pack-PE tool. The institute offered targeted training on the new auditor’s reporting standards and revisions to standards in the 2018 Handbook.

OECCA-Benin has demonstrated that it has implemented new initiatives to further meet the SMO 3 obligations and is committed to continued improvement. For example, OECCA-Benin notes that there are ongoing efforts to obtain all French translation of IAASB standards, exposure drafts, and bilingual lexicon on auditing standards and disseminate them to members through various sources such as, the International Cooperation of the French Accountancy Profession (DDPI), the Conseil Supérieur de l'Ordre des Experts Comptables (CSOEC), International Federation of Francophone Accountants (FIDEF), and CPA Canada.

OECCA Benin is encouraged to comment on the Proposed International Standard on Auditing for Audits of Financial Statements of Less Complex Entities (ISA for LCE) Exposure Draft (due January 31, 2022)

Current Status: Review & Improve

The Organization for the Harmonization of Business Law in Africa (OHADA) has been revising regional rules to harmonize ethical standards with international best practice. In June 2017, OHADA issued regulations stating that its member states, which includes Benin, must adhere to the OHADA Code of Ethics—which is based on the 2015 IESBA Code of Ethics—as well as relevant ethical requirements within the OHADA Uniform Act on Accounting Law and Financial Information (AUDCIF) that relate to external auditors.

Meanwhile, at the national level, OECCA-Benin must ensure that its members adhere to established ethical standards and is also authorized by Law No. 2004-03 to establish its own ethical code. Having first issued its Code of Ethics in 2009, in 2012, the OECCA-Benin issued a revised Code of Ethics for its members to align with the French translation of the 2009 IESBA Code of Ethics. OECCA-Benin has since reviewed and revised its Code to align with the OHADA Code of Ethics. In 2020, the institute states it is considering how it can adopt the NOCLAR standard issued in 2017 by the IESBA and will review the 2018 International Code for adoption.

OECCA-Benin states that it has been assisting its members’ adherence with the Code by organizing training and awareness raising among stakeholders in business and government. New OECCA-Benin members are provided with a hardcopy of the revised Code and must attend a mandatory CPD training on the Code. All members may access the Code of Ethics via the institute’s website as well as the OHADA note and guidance on ethical requirements. OECCA-Benin has demonstrated that it is carrying out activities that support the adoption and implementation of the International Code of Ethics although there remain opportunities for updates to the adopted ethical requirements that enable the institute to further meet the SMO 4 obligations.

Additionally, OECCA-Benin reports that it has been an active member of several task forces to combat money laundering and corruption. The institute is participating in workshops and seminars on assessing risks of money laundering in Benin and finalizing the national strategy for combating corruption.

The 2018 International Code of Ethics, which has been revised and restructured from previous version and contains the NOCLAR standard issued in 2016, is now available in French. Within its scope of national responsibility, OECCA-Benin is encouraged to review IESBA’s revisions to Part B of the Code (effective June 2021) and revisions to Sections 100, 110, 120, and 220 (effective December 2021) to form plans to support members with implementation. Lastly, since OHADA regulations incorporate only up to the 2015 version of the IESBA Code, the institute is encouraged to continue its advisory and advocacy role by sharing the 2018 International Code (along with the 2020 revisions) with the OHADA so that it might update its regulations accordingly

Current Status: Execute

At the regional level, West African Economic and Monetary Union (WAEMU) Regulation No.09/2009/CM/UEMOA establishes public sector accounting standards for member states of the WAEMU, which includes Benin. Article 6 of that directive indicates that the government’s general accounting should be based on IPSAS. OECCA-Benin reports that the regulation has undergone revisions to integrate a significant number of IPSAS. The revised standards were finalized in November 2018 by the West African Accounting Council and will be subject to the review of the WAEMU in 2020.

However, at the national level, the government of Benin continues to apply the “Comptabilité publique”, the public sector standards issued by WAEMU in 2011 and are accrual-basis standards that differ from IPSAS. OECCA-Benin states that it is carrying out activities at three levels: (i) advocating for IPSAS to be considered as the accounting standards by national government; (ii) training members on IPSAS; and (iii) taking a lead role in engaging with West African Accounting Council to advance the adoption of IPSAS on a regional scale. For example, a representative of OECCA-Benin worked on the West African Accounting initiative to update the WAEMU chart of accountants that consider IPSAS.

At the national level, in 2017, 2018, and 2019, the institute reports that it participated in several regional conferences on public finance management and IPSAS to stay informed of the standards and raise awareness of national stakeholders. The institute intends to provide French translations of IPSAS and subsequent updates to the relevant authorities subject to availability and has also held training on IPSAS for its members. OECCA-Benin has demonstrated that it is implementing initiatives within its means for SMO 5 and is committed to continued improvements in this area.

OECCA-Benin’s advocacy efforts around IPSAS adoption are commendable. Pending approval of the revised standards by WAEMU’s Accounting Council, the OECCA-Benin is encouraged to indicate if there is a timeline for the adoption of the standards in Benin and how it might support the Ministry of Finance in its implementation plan. For example, a 2015 version of IPSAS is available in French that the institute may consider sharing with relevant stakeholders. Other activities for consideration include organizing roundtables to meet key stakeholders and users of financial information; and continuing to provide trainings and technical expertise.

Current Status: Review & Improve

Law No. 2004-03 grants authority to OECCA-Benin to establish I&D procedures for its members. The procedures outline initiation of proceedings, sanctions, and administrative actions. The institute has a Disciplinary Board, which may receive and investigate complaints and recommend sanctions to the institute’s Council. The Council may impose a limited set of disciplinary measures. Depending on the severity of the case, the Council may refer the complaint to its National Chamber of Discipline, which may impose more stringent sanctions such as, loss of professional designation, removal of practicing rights, and exclusion from membership. The National Chamber also serves as an appeal body for decisions made by the Council. For appeals resulting from decisions made by the National Chamber, individuals refer to the Administrative Chamber of the Supreme Court.

Previously, the National Chamber of Discipline had not been able to meet as the Chair of the Chamber, whom is a magistrate appointed by the Minister of Justice, was unavailable. However, OECCA-Benin indicates that it has strengthened its I&D procedures, with Council receiving recommendations regarding complaints in 2019 and convening the Chamber, as necessary. The Chamber also has representatives from the Ministry of Finance alongside OECCA-Benin.

The institute has conducted a self-assessment of its I&D system against the SMO 6 requirements and identified gaps in the initiation of proceedings (i.e. an information-based approach and linkage to QA reviews). It is currently making progress in the operationalization of its QA review system.

OECCA-Benin indicates that it has made any disciplinary information available to the public via the local gazette and informs the regional organization, West African Economic and Monetary Union (WAEMU). Additionally, OECCA-Benin plans to raise awareness of key stakeholders in the judiciary, the public, and its members of disciplinary procedures.

I&D procedures that meet the SMO 6 benchmark are foundational to maintaining public trust and confidence in the profession. It is positive that OECCA-Benin has made progress in strengthening its procedures in this area and is working to implement QA reviews that will eventually be linked to the investigations process. The institute is encouraged to continue demonstrating how it is raising awareness of the public, business, private, and public sector stakeholders on the I&D processes while also ensuring its members are aware of the consequences of non-compliance and misconduct.

Current Status: Execute

Benin is a member state of both the West African Economic and Monetary Union (WAEMU) and the Organization for the Harmonization of Business Law in Africa (OHADA), which are regional economic unions responsible for the development of member countries’ corporate accounting standards. In January 2017, the Commission de Normalisation Comptable de l’OHADA (CNC)-OHADA adopted the OHADA Uniform Act on Accounting and Financial Information (AUDCIF) to update the previous OHADA Uniform Act on Organizing and Harmonizing Company Accounting Systems 2/2000. The previous Act had outlined the OHADA Accounting System and applicable standards—known as SYSCOHADA.

The OHADA AUDCIF revised the SYSCOHADA, namely the OHADA general accounting plan, as well as the consolidated and combined accounting rules to serve as a single accounting reference in all OHADA member states. The OHADA AUDCIF became effective on January 1, 2018 for individual accounts and on January 1, 2019 for consolidated and combined accounts. The SYSCOHADA continue to differ from the International Financial Reporting Standards (IFRS) and are generally applied by small and medium-sized entities (SMEs); however, the AUDCIF now requires that listed companies and companies seeking financing in a public capital market to apply IFRS in consolidated statements. All other companies are permitted but not required to use IFRS.

The OECCA-Benin played a key role in advocating for the convergence of SYSCOHADA with IFRS and supporting the CNC-OHADA’s work in issuing the 2017 regulations. It was involved in regional discussions to benchmark local accounting standards against IFRS and to revise them to incorporate IFRS requirements. In collaboration with regional standard-setters, the OECCA-Benin prepared draft versions of the new SYSCOHADA standards and created implementation guidance, such as transition schedules. It has participated in Train-the-Trainers sessions at the regional level to facilitate training sessions on IFRS nationally.

In Benin, the OECCA-Benin works independently and together with the national standard-setter, the CNC-Benin, to offer training to members and students on IFRS with OHADA guidelines available for additional support. Furthermore, after the passage of the new OHADA Regulation, the government organized a free, week-long capacity building workshop to train accountancy instructors on the new standards.

OECCA-Benin has demonstrated that it is implementing initiatives within the scope of its authority for SMO 7 and is committed to continued improvements in this area.

With the recent adoption of IFRS for listed companies in OHADA member states, OECCA-Benin is encouraged to continue updating its Action Plan to demonstrate examples of implementation support, such as training and sharing resources, which it might provide for its members in cases where they need to apply the standards. The IFRS Foundation has French translations of the IFRS readily available that the institute may consider sharing amongst its members and other stakeholders to support understanding and implementation. The institute could also consider advocating for the regional adoption of IFRS for SMEs as a permissible framework to bring SME reporting in line with international best practices.

Current Status: Review & Improve