Senegal

The corporate financial framework of Senegal is determined by legislation issued by two regional bodies: The West African Economic and Monetary Union (WAEMU) and the Organization for the Harmonization of Business Law in Africa (OHADA). Legislation issued at the regional level by WAEMU and OHADA has a significant impact on the legal and regulatory framework for commercial entities, banks, financial institutions, and insurance companies in Senegal as well as on the accountancy profession. Senegal, as a member of the two regional groups, harmonizes national laws with directives issued at the regional level.

OHADA and WAEMU are responsible for the development of member countries’ accounting standards while Member States are required to establish a Conseil National de la Comptabilité (CNC) with responsibility for implementation of accounting and auditing directives at the national level. The WAEMU Treaty gives responsibility to the WAEMU Council to set the accounting standards to be applied by the member states. In accordance with the WAEMU Regulation No. 3/97/CM/UEMOA, the WAEMU delegated its accounting standard-setting activities to the Conseil Comptable Ouest Africain (CCOA), which in turn now adopts the OHADA standards for application in the WAEMU member states.

Accounting Framework

In January 2017, the Commission de Normalisation Comptable de l’OHADA (CNC)-OHADA, established in 2009 through an OHADA Uniform Act, 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 accounts, combined accounts. The SYSCOHADA continue to differ from 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.

Auditing Framework

The OHADA Uniform Act Relating to Commercial Companies and Economic Interest Groups 4/1997 (revised January 2014) stipulates that statutory audits are mandatory for all public companies, limited liability companies (LLCs) and partnerships that exceed one of these three thresholds: (i) total balance sheet in excess of CFA franc 125 million; (ii) sales volume greater than CFA franc 250 million; or (iii) more than 50 permanent employees with a total balance sheet in excess of CFA franc 250 million and sales volume of CFA franc 500 million. Banking and insurance legislations also require mandatory audits of banks, financial institutions, and insurance companies.

Audit standard-setting at the regional level is determined by WAEMU Regulation No. 01/2009/CM/UEMOA of 2009, which established the Council of the Chartered Accountants Profession (le Conseil Permanent de la Profession Comptable, CPPC). The CPPC is responsible for defining auditing, ethics, and quality control standards for the WAEMU member states.

However, in June 2017, the OHADA issued Regulation No. 01/2017/CM/OHADA Pratiques Professionelles de la Comptabilité et de l’Audit dans les pays membres de l’OHADA to harmonize regional auditing standards with international best practice. The regulation, effective from January 1, 2018, states that all audits must be conducted in accordance with ISA as issued by the IAASB. Therefore, ISA as issued by IAASB are effective in Senegal as of the date of the assessment.

Chartered Accountants in Senegal are first regulated at the regional level by West African Economic and Monetary Union (WAEMU) Regulation No. 12/2000/CM/UEMOA. Senegal, as a member country of the WAEMU, must apply the regional requirements at the national level. Law 2000-05 of January 10, 2000 establishes the Ordre National des Experts-Comptables et Comptables Agréés du Sénégal (ONECCA-Senegal) as the national professional accountancy organization (PAO) responsible for regulating professionals within Senegal.

WAEMU Regulation No. 12/2000/CM/UEMOA introduced the DECOFI and the Higher Education Degree in Accounting and Financial Management (DESCOGEF) as requisites to practice in any WAEMU country. he DESCOGEF qualification is for the Certified Accountant title and is received after a one year “Comprehensive Theoretical and Technical Training” program at an institution accredited by the Regional Commission for the Formation of the Accounting and Financial Experts (CREFECF), an external body recognized by WAEMU. Subsequently, to qualify as a Chartered Accountant, DESCOGEF-holders are eligible to complete a three-year internship that must be verified by a professionally qualified accountant. Individuals complete two years in an audit firm and one year in an accounting firm under the supervision of a qualified Chartered Accountant. Finally, individuals with an internship certificate must pass a final examination leading to the DECOFI and Chartered Accountant qualification. The final examinations are also overseen by the CREFECF. The title of Chartered Accountants is only granted to those registered by a PAO in WAEMU countries.

Additionally, WAEMU Regulation No. 01/2009/CM/UEMOA of 2009 grants the Conseil Permanent de la Profession Comptable (CPPC) the responsibility for defining auditing, ethical, and quality control standards. The CPPC has yet to adopt these standards and has recommended that professional accountancy organizations (PAOs) within member states pursue the adoption and implementation of quality assurance (QA) systems and quality control standards at a national level. Furthermore, in June 2017, the Organization for the Harmonization of Business Law in Africa (OHADA) issued Regulation No. 01/2017/CM/OHADA Pratiques Professionelles de la Comptabilité et de l’Audit dans les pays membres de l’OHADA to harmonize regional auditing and ethical standards with international best practice.

At the national level, ONECCA-Senegal is responsible for: (i) maintaining a register of Chartered Accountants and Certified Accountants; (ii) licensing qualified members to practice auditing; (iii) monitoring compliance with technical standards; (iv) setting ethical requirements for its members; (v) establishing an investigative and disciplinary (I&D) system; (vi) implementing initial professional development requirements; (vii) setting continuing professional development requirements; and (viii) monitoring conduct and performance of members, including quality assurance reviews of all audits and services carried out by members. Law 2000-05 stipulates that the institute’s activities are subject to the oversight and supervision of the Ministry of Finance.

Only ONECCA-Senegal is permitted to offer qualified individuals the title of Chartered Accountant if they satisfy the regional educational requirements. The three-year internship undertaken by Certified Accountants must be with a Chartered Accountant licensed by ONECCA-Senegal in order to have appropriate knowledge of Senegal’s business and legal environment.

There is no independent audit oversight arrangement or entity in Senegal.

Auditors in Senegal are first regulated at the regional level by West African Economic and Monetary Union (WAEMU) Regulation No. 12/2000/CM/UEMOA, which introduced the Degree in Accounting and Finance (DECOFI) as a mandatory qualification for Chartered Accountants, who are the only individuals permitted to practice auditing in WAEMU countries. The WAEMU Conseil Permanent de la Profession Comptable (CPPC) is responsible for defining auditing, ethical and quality control standards based on WAEMU Regulation No. 01/2009/CM/UEMOA. The CPPC has yet to adopt these standards and has recommended that professional accountancy organizations (PAOs) within member states pursue the adoption and implementation of quality assurance (QA) review systems and quality control standards at a national level.

Furthermore, in June 2017, the Organization for the Harmonization of Business Law in Africa (OHADA) issued Regulation No. 01/2017/CM/OHADA Pratiques Professionelles de la Comptabilité et de l’Audit dans les pays membres de l’OHADA to harmonize regional auditing standards with international best practice. The regulation, effective from January 1st, 2018, states that all audits must be conducted in accordance with ISA as issued by the IAASB. Further, the regulation states that effective from January 1, 2018, professional accountants in OHADA member states must adhere to the OHADA Code of Ethics, which is based on the 2015 IESBA Code of Ethics, as well as the relevant parts of the OHADA Uniform Act on Accounting Law and Financial Information (AUDCIF).

Law 2000-05 establishes Ordre National des Experts-Comptables et Comptables Agréés du Sénégal (ONECCA-Senegal) to regulate auditors at a national level subject to the oversight and supervision of the Ministry of Finance. Specifically, ONECCA-Senegal is responsible for (i) maintaining a register of Chartered Accountants; (ii) licensing qualified members to practice auditing; (iii) monitoring compliance with technical standards; (iv) setting ethical requirements for its members; (v) establishing an investigation and discipline system for its members; (vi) implementing initial professional development requirements; (vii) setting continuing professional development requirements for members; and (viii) monitoring conduct and performance of members through quality assurance reviews.

Ordre National des Experts-Comptables et Comptables Agréés du Sénégal (ONECCA-Senegal)

ONECCA-Senegal was established by Senegalese Law 2000-05 in January 2000, pursuant to a Community Directive issued in September 1997. Its membership comprises Certified Accountants and Chartered Accountants. Membership in the institute is mandatory and only Chartered Accountants registered with ONECCA-Senegal are permitted to offering audit services.

ONECCA-Senegal is responsible for: (i) maintaining a register of Chartered Accountants and Certified Accountants; (ii) licensing qualified members to practice auditing; (iii) monitoring compliance with technical standards; (iv) setting ethical requirements for its members; (v) establishing an investigative and disciplinary system; (vi) implementing initial professional development requirements; (vii) setting continuing professional development requirements; and (viii) monitoring conduct and performance of members, including quality assurance reviews of all audits and services carried out by members. Law 2000-05 stipulates that the institute’s activities are subject to the oversight and supervision of the Ministry of Finance.

In addition to being a member of IFAC, ONECCA-Senegal is a member of the Pan African Federation of Accountants, the International Federation of Francophone Accountants, and the Association of Accountancy Bodies in West Africa.

At the regional level, West African Economic and Monetary Union (WAEMU) Regulation No. 01/2009/CM/UEMOA authorizes le Conseil Permanent de la Profession Comptable (CPPC) to establish a quality assurance (QA) review system. Draft regulation establishing this requirement was finalized by the Council of Ministers of the WAEMU in 2014. However, due to delays, the CPPC has recommended that professional accountancy organizations (PAOs) within member states pursue the adoption and implementation of QA systems and quality control standards at a national level.

Furthermore, in June 2017, the Organization for the Harmonization of Business Law in Africa (OHADA) issued Regulation No. 01/2017/CM/OHADA Pratiques Professionelles de la Comptabilité et de l’Audit dans les pays membresde l’OHADA mandating PAOs within OHADA member states, which includes Senegal, to develop and implement QA review systems.

Prior to the 2017 OHADA regulation, in 2013, under the oversight of the Ministry of Finance, ONECCA-Senegal established a Quality Assurance Review System (QARS) for its members and adopted ISQC 1 and ISA 220 as quality control standards. QA reviews are to be conducted every three years for public interest entity (PIE) audit firms and every six years for all other audits.

The QARS was performed on a voluntary basis for PIE statutory audits in 2013. In 2014, the QAR extended to all ONECCA-Senegal members on a voluntary basis. This was done with the assistance of the French PAOs. In 2015, the institute’s Quality Assurance Commission took over the reviews but were unable to carry out reviews due to resource constraints. The institute states that the QA Commission has reconvened and will be determining the first cycle of reviews on a mandatory basis beginning in Q4 2019. At the time of the assessment, confirmation of QA reviews resuming is still pending.

The institute conducted a review of its QARS against the SMO 1 requirements and indicates that the system will be in line with SMO 1 requirements once it begins undertaking QA reviews again.

Current Status: Partially Adopted

Chartered Accountants in Senegal are first regulated at the regional level by West African Economic and Monetary Union (WAEMU) Regulation No. 12/2000/CM/UEMOA. Senegal, as a member country of the WAEMU, must apply the regional requirements at the national level.

WAEMU Regulation No. 12/2000/CM/UEMOA introduced the Degree in Accounting and Finance (DECOFI) and the Higher Education Degree in Accounting and Financial Management (DESCOGEF) as requisites to practice in any WAEMU country. The DESCOGEF qualification is for the Certified Accountant title and is received after one year “Comprehensive Theoretical and Technical Training” program at an institution accredited by the Regional Commission for the Formation of the Accounting and Financial Experts (CREFECF), an external body recognized by WAEMU. Subsequently, to qualify as a Chartered Accountant, DESCOGEF-holders are eligible to complete a three-year internship that must be verified by a professionally qualified accountant. Individuals complete two years in an audit firm and one year in an accounting firm under the supervision of a qualified Chartered Accountant. Finally, individuals with an internship certificate must pass a final examination leading to the DECOFI and Chartered Accountant qualification. The final examinations are also overseen by the CREFECF. The title of Chartered Accountants is only granted to those registered by a PAO in WAEMU countries. These are also the only individuals permitted to conduct audits.

At the national level, Law 2000-05 establishes the Ordre National des Experts-Comptables et Comptables Agréés du Sénégal (ONECCA-Senegal) as the national professional accountancy organization (PAO) responsible for regulating professionals within Senegal pursuant to a Community Directive issued in September 1997.

ONECCA-Senegal indicates it has stipulated that the three-year internship undertaken by Certified Accountants must be with a Chartered Accountant licensed by ONECCA-Senegal in order to have appropriate knowledge of Senegal’s business and legal environment. The institute has also established continuing professional development (CPD) requirements of 40 hours per year aligning with the input-based approach of IES 7 while noting that it is working to implement an output-based approach to CPD as well.

It is not clear from the available information if all the IPD requirements (e.g. university curricula; final assessment) align with the 2019 IES requirements. Moreover, within the Organization for the Harmonization of Business Law in Africa (OHADA), another regional group in Africa that Senegal has membership, there is a Chartered Accountant Diploma and curriculum reform under consideration that would enable accountancy education (IES 1–4) to align with the latest IES requirements.

Current Status: Partially Adopted

The Organization for the Harmonization of Business Law in Africa (OHADA) Uniform Act Relating to Commercial Companies and Economic Interest Groups 4/1997 (revised January 2014) stipulates that statutory audits are mandatory for all public companies and limited liability companies (LLCs) that exceed determined thresholds. Banking and insurance legislations also require mandatory audits of banks, financial institutions, and insurance companies.

In June 2017, the OHADA issued Regulation No. 01/2017/CM/OHADA Pratiques Professionelles de la Comptabilité et de l’Audit dans les pays membresde l’OHADA to harmonize regional auditing standards with international best practice. The regulation states that effective from January 1, 2018, all audits in member states, which includes Senegal, must be conducted in accordance with ISA as issued by the IAASB.

ONECCA-Senegal indicates that in the jurisdiction the regional requirement is in force and that ISA are effective as issued by the IAASB.

Current Status: Adopted

At the regional level, West African Economic and Monetary Union (WAEMU) Regulation No. 01/2009/CM/UEMOA grants authority to the Conseil Permanent de la Profession Comptable (CPPC) to determine ethical requirements for member states. Since CPPC has yet to establish the ethical requirements, Organization for the Harmonization of Business Law in Africa (OHADA) issued Regulation No. 01/2017/CM/OHADA Pratiques Professionelles de la Comptabilité et de l’Audit dans les pays membresde l’OHADA to harmonize regional ethical requirements with international best practice.

The regulation states that effective from January 1, 2018, professional accountants in OHADA member states must adhere to the OHADA Code of Ethics, which is based on the 2015 IESBA Code of Ethics and complemented by the ethical requirements related to the external auditor as contained in the OHADA Uniform Act on Accounting Law and Financial Information (AUDCIF).

Under Senegalese Law No. 2000-05, the ONECCA-Senegal is authorized to establish ethical requirements for its members subject to the approval of the Ministry of Finance. The ONECCA-Senegal had adopted the 2013 IESBA Code of Ethics for its members which was approved in 2016 by the Ministry of Finance. However, the institute indicates that in the jurisdiction the OHADA Code of Ethics is now the applicable standard alongside other ethical requirements outlined in national legislation such as the Companies Act.

Current Status: Partially Adopted

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 Senegal. Article 6 of that directive indicates that the government’s general accounting should be based on IPSAS. IFAC member organizations in the WAEMU member states indicate 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.

At the national level, the Ministry of Finance is responsible for adopting public sector accounting standards. The current standards used in Senegal are cash-basis with the intention to transition to accrual. IPSAS are not adopted (IFAC, CIPFA 2018).

Current Status: Not Adopted

At the regional level, the World Bank is supporting the Organization for the Harmonization of Business Law in Africa (OHADA) in the development of an investigative and disciplinary (I&D) system for professional accountants within its member states. There is no further information available as of the date of the assessment regarding the status of a regional I&D system.

At the national level, Law 2000-05, as approved by the Ministry of Finance, authorizes ONECCA-Senegal to establish an investigative and disciplinary system for its members. The institute’s bylaws stipulate the establishment of a Disciplinary Committee to hear cases of misconduct, investigate, and sanction members. The Disciplinary Committee is chaired by a judge appointed by Dakar’s Court of Appeals.

ONECCA-Senegal conducted a review of its I&D system against the revised SMO 6 best practices. Results of the review indicate that its I&D system is mostly compliant with the SMO 6 requirements, with gaps in the following areas: having a separate investigative and disciplinary committee, making results publicly available, and liaising with appropriate external entities in the case of serious offences.

Current Status: Partially Adopted

The corporate financial framework of Senegal is determined by legislation issued by two regional bodies: The West African Economic and Monetary Union (WAEMU) and the Organization for the Harmonization of Business Law in Africa (OHADA). Senegal, as a member of the two regional groups, harmonizes national laws with directives issued at the regional level.

OHADA and WAEMU are responsible for the development of member countries’ accounting standards while Member States are required to establish a Conseil National de la Comptabilité (CNC) with responsibility for implementation of accounting directives at the national level.

In January 2017, the Commission de Normalisation Comptable de l’OHADA (CNC)-OHADA, established in 2009 through an OHADA Uniform Act, 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 accounts, combined accounts. The SYSCOHADA continue to differ from 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.

Current Status: Partially Adopted

Relevant Organizations

• Ordre National des Experts-Comptables et Comptables Agréés du Sénégal (ONECCA-Sénégal)
• Organization for the Harmonization of Business Law in Africa (OHADA)
• West African Economic and Monetary Union (WAEMU)

Relevant Legislation

• Law 2000-05, January 2000
• OHADA Uniform Act on Accounting and Financial Information (AUDCIF)
• OHADA Uniform Act Relating to Commercial Companies and Economic Interest Groups
• Regulation No. 01/2017/CM/OHADA
• ONECCA-Senegal’s Rules

Relevant Publications

• IFAC, CIPFA, International Public Sector Financial Accountability Index, n.d.
• IFRS Foundation, IFRS Application Around the World Jurisdictional Profile: Senegal, n.d.
• International Finance Corporation, World Bank Group. “Legal and regulatory framework for 14 countries in Francophone Africa – CMIA (Regional insurance industry body).” N.d.
• ONECCA-Senegal, SMO Action Plan, August 2020.
• Sarr, Babacar. International Budget Partnership, Are New PFM Reforms in the WAEMU and the CEMAC Working? Lessons from the Open Budget Survey, February 2014.
• World Bank, Report on the Observance of Standards and Codes?Accounting and Auditing: Senegal, 2005.
• World Bank, Implementation Status & Results: WAEMU Development of Accounting Regulation Institutions and Auditing Profession, 2013.
• World Bank, Implementation Status & Results Report: Improved Investment Climate within the Organization for the Harmonization of Business Law in Africa (OHADA), 2014.
• World Bank, Implementation Status & Results Report: Improved Investment Climate within the Organization for the Harmonization of Business Law in Africa (OHADA) (P126663), January 2016.
• World Bank, Report on the Observance of Standards and Codes?Accounting and Auditing: Senegal, May 2016.