Ordre des Comptables Professionnels Agréés d'Haïti

In the absence of a legal framework which grants authority to an entity or entities to establish a quality assurance (QA) review system, the OCPAH has undertaken the initiative to implement a QA review system for its members. However, given the institute’s lack of operational and institutional capacity, there have been significant delays in its implementation.

Since 2013, the OCPAH has reported that it focuses its activities on training members on ISQC 1 and ISA 220, which the institute has adopted as self-regulatory requirements, and promoting the need for a QA review system that is compliant with SMO 1 requirements to relevant authorities. For example, in April 2015, as part of the ongoing drive to pass the Accountancy Reform Law—a new, updated law for the accounting profession—the development of a QA review system was discussed in a workshop with the members of the Council. In addition, OCPAH reports that it has ensured that the new law specifically states that the OCPAH will adopt the relevant standards as issued by the IAASB thereby ensuring ongoing adoption of international best practices.

OCPAH states that it is working to develop a quality control implementation guide which could be adapted for varying sizes of firms. In 2014, the institute obtained and shared French translations of ISQC 1 and ISA 220 as well as additional documentation to support the implementation process.

Additionally, in 2014, the OCPAH developed train the trainers training materials and launched a campaign to encourage member participation in the trainings. In October 2015, with the support the World Bank and the Direction du Développement et des Partenariats Internationaux (DDPI), the OCPAH organized a training of 65 trainers on ISQC 1 and ISA 220. Subsequent trainings were also held October 2015–June 2017 with approximately 150 members receiving training.

Establishing and operating its own QA review system may be too advanced of a step for OCPAH at this time. OCPAH is encouraged to continue promoting the adoption of a mandatory external QA review system that incorporates SMO 1 requirements to the relevant entities, such as the Central Bank which already conducts periodic reviews of bank audits. As part of this effort, OCPAH could also consider conducting studies of other PAOs’ experiences with establishing a QA review system. Lastly, in its next Action Plan update, OCPAH should provide more information about the new draft Accountancy Reform Law and any update on the status of the review of the new law by Parliament.

Current Status: Plan

The OCPAH is responsible for implementing the initial professional development (IPD) requirements set in law and, although not required by law, OCPAH has established mandatory continuing professional development (CPD) requirements for its members.

OCPAH has been reporting since 2014 that it was analyzing the gaps in compliance between its CPD requirements and final examinations with the IES requirements. OCPAH has noted that its final examinations do cover areas such as taxation, financial analysis, and ethics and assess practical application in addition to theoretical knowledge as recommended in IES 6. In 2017, OCPAH and the Direction du Développement et des Partenariats Internationaux (DDPI) reported that the analyses were part of a long-term project and were discussed during a workshop in April 2015 with the institute’s Council as part of the ongoing deliberations regarding the Accountancy Reform Law and overall regulatory reforms around the accounting profession.

From this workshop, the institute reports that it promoted the inclusion of language within the new, proposed law to stipulate that OCPAH members fulfill CPD requirements that are aligned with the IES and report on their compliance with these requirements to OCPAH annually.

In 2016, OCPAH began to implement a monitoring system whereby the institute maintained a log of all members who attended CPD activities organized by OCPAH.

The OCPAH also indicated that it is promoting the IES to the Ministry of Education and universities in Haiti that are involved in providing accountancy education although it recognizes that the adoption of IES requirements is a long-term process and public policy consensus among national stakeholders takes time to achieve. The institute reported that it shared the IES with universities to encourage their incorporation into accountancy curricula and ensure that professional accounting courses cover subjects such as finance and related knowledge, organizational and business knowledge, and information technology knowledge and competencies as outlined in the IES.

Despite an oftentimes tenuous operating environment, OCPAH has committed to organizing CPD courses for its members on the international standards and the taxation laws in Haiti. The institute envisions working with individuals who will act as “champions” for particular topics and can organize future Train the Trainer programs to promote long-term sustainability. The institute states that it also regularly arranges for “Les Jeudis Comptable” (Accounting Thursdays) where members come to debate specific topics. OCPAH notes that these events usually bring together over 100 members. Finally, in September 2016, the institute organized a conference on the role of the professional accountant in Haiti’s economic progress and hosted six speakers on the topic of the importance of financial information and services as part of Haiti’s economic growth.

OCPAH has demonstrated it is making good efforts to offer its members the necessary CPD training. In its next Action Plan submission, the institute is encouraged to provide an update on how it is progressing with bringing its examinations and CPD in line with the IES requirements as well as a status update on the Accountancy Reform Law. Additionally, OCPAH could consider seeking external assistance to review the revised IES requirements, now in effect, to promote and disseminate the standards amongst relevant stakeholders. Lastly, OCPAH, with external assistance, could also consider engaging in dialogues with the Ministry of Education and universities with the objective of assessing universities’ accounting curricula and programming against the IES.

Current Status: Plan

In the absence of legally required auditing standards, OCPAH has taken a proactive role in this area by having its members apply ISA as a self-regulatory requirement although the version of the standards that were adopted and are supposed to be applied are unknown. The institute has indicated that establishing ongoing processes to update the standards is an objective, but it reports it has not adopted new and revised standards.

As part of the Accountancy Reform Law initiative, the role of OCPAH as the standard-setter is being evaluated and OCPAH indicates that it has ensured the law has specifically included direct references to ISA as issued by the IAASB and that the OCPAH will adopt the relevant standards as issued by the IAASB to ensure that applicable auditing standards remain aligned with the international standards.

Since 2015, OCPAH states that it has been working on developing training tools and materials and holding train the trainer trainings in addition to trainings for its members on ISA and IAASB pronouncements to support implementation of the standards.

With the assistance of the Direction du Développement et des Partenariats Internationaux (DDPI) and the World Bank, OCPAH has made progress in organizing trainings on ISA for its members. In July 2016, a week-long training on ISA was held and subsequent trainings on ISA were organized in February 2017.

Additionally, OCPAH has stated that it has been working on developing tools to monitor the proper implementation of ISA and address issues as needed. For example, OCPAH members have expressed interest in adopting the Compagnie Nationale des Commissaires aux Comptes’ (CNCC-France) audit tool (“Pack PE”) for small- and medium-sized entities although the initiative is still in the initial discussion phases.

Lastly, OCPAH indicates that it has been monitoring international developments in the area with the goal of updating its adopted standards.

OCPAH should continue organizing trainings on ISA for its members. However, in its Action Plan, OCPAH should clarify what version of ISA it has adopted as a requirement for its members. In addition, as part of maintaining its requirement of ISA application, OCPAH should prioritize establishing ongoing procedures to update the standards. OCPAH should also indicate in its Action Plan if it disseminates information on the updates to the ISA and international developments in the area to its members through printed materials and/or its website.

Current Status: Plan

OCPAH sets ethical requirements for its members in addition to ethical requirements established by law although these requirements have not been specified. OCPAH has adopted a Code of Ethics, known as the “Golden Book”, which is not aligned with the IESBA Code of Ethics. However, the institute has outlined detailed plans to update the ethical requirements to adopt the IESBA Code of Ethics.

As part of the Accountancy Reform Law initiative, which began in 2012, the OCPAH worked with the Ministry of Economy and Finance to ensure that the new law was drafted to include direct references to the IESBA Code of Ethics and would consequently supersede the current Golden Book. At the time of the assessment, OCPAH reports that the law is in the final stages of development and will be presented to the institute’s General Assembly in August 2018. OCPAH is simultaneously promoting its adoption to the Parliament and Ministry of Finance to secure its adoption once approved by the General Assembly.

To support its members with the implementation of the proposed ethical requirements, OCPAH has organized Train the Trainers seminars on the IESBA Code. Two Train the Trainers workshops on the IESBA Code of Ethics were organized in September 2016 with the assistance of the Direction du Développement et des Partenariats Internationaux (DDPI) and the World Bank. The institute also notes that it will request DDPI’s assistance to develop a monitoring plan by mid-2018 to ensure members’ compliance with the revised ethical requirements.

Additionally, the institute also intended to disseminate the IESBA Code to its members using printed material and televised programs. However, these activities have been rescheduled pending the adoption of the IESBA Code. Finally, OCPAH indicates it has plans to establish procedures to monitor IESBA pronouncements to incorporate revisions into the Code.

In its next Action Plan submission, OCPAH is encouraged to provide an update on the status of adoption of the Accountancy Reform Law and the IESBA Code of Ethics. OCPAH is encouraged to continue its trainings on the IESBA Code ahead of the expected adoption of the new requirements. OCPAH may also consider promoting the incorporation of ethics-related topics in accountancy curricula to the Ministry of Education and universities.

Current Status: Plan

In Haiti, public sector entities must prepare financial statements in accordance with the accounting standard system—the Plan Comptable National (PCN)—although OCPAH reports that in practice each institution utilizes its own reporting format. The OCPAH states that it works to promote the adoption of IPSAS to the Direction Générale du Trésor et de la Comptabilité Publique (DGTCP)—the entity responsible for their adoption.

In 2015, the Minister of Economy and Finance (MEF) invited the Board of OCPAH to designate two members to join the Commission d'Elaboration des Normes Comptables de l'Administration Publique Nationale and to participate in weekly meetings at the DGTCP to produce a final document that established the Normes Comptables de l'Administration Publique Nationale. The OCPAH Board nominated its President and an advisor to join the Commission to advocate for the adoption of IPSAS. However, OCPAH reports that the DGTCP never proceeded with establishing the Commission and the institute intends to follow-up with the DGTCP about restarting this initiative.

In addition, OCPAH indicates that it has planned to raise general and public sector accountants’ awareness of IPSAS by organizing seminars on IPSAS, distributing the standards to its members, and sharing information about the standards via its magazine and website. It also reports that it is encouraging the Ecole Nationale en Administration et Finance (ENAF)—the university from which the MEF largely recruits its professional staff—to include IPSAS within its curricula. Additionally, the institute intends to collaborate with relevant entities like the ENAF and the DGTCP to organize the seminars on IPSAS by end of 2018. However, the execution of these plans has been stalled due to the delay in the adoption of the standards.

OCPAH also states that it has plans to develop tools for its members to ensure proper implementation of the IPSAS once adopted. Similarly, there has been a delay in this activity as the IPSAS have not yet been adopted.

OCPAH is encouraged to provide an update on the execution of its initiatives to promote the adoption of IPSAS to the relevant government authorities and incorporation of IPSAS into accounting curricula to universities within its next Action Plan submission.

Current Status: Execute

OCPAH is responsible for establishing an investigative and disciplinary (I&D) system for its members. While the institute’s I&D procedures are operational—for example, the OCPAH publicly censured one member in 2015—OCPAH states that these mechanisms do not include all SMO 6 requirements and do not always function as intended due to financial and institutional lack of capacity.

In 2017, OCPAH conducted a self-assessment of its current I&D procedures against the SMO 6 requirements and identified gaps in compliance regarding investigative, disciplinary, and administrative processes and committee members’ independence. This is largely because the institute’s I&D mechanics are outlined in the “Golden Book”—the legally binding document that stipulates the institute’s ethical and disciplinary requirements and dates from 1988. The book stipulates the establishment of a Disciplinary Committee and an appeals mechanism but makes no mention of investigative actions.

Accordingly, as part of the Accountancy Reform Law initiative, which began in 2012, OCPAH has collaborated with the Ministry of Economy and Finance to ensure that the draft law would provide for the incorporation of SMO 6 requirements and significantly enhance the I&D system. For example, OCPAH indicates that articles of the new bill address independence and conflicts of interest and will establish separate investigative, disciplinary, and appeals procedures as well as administrative processes for monitoring and recording cases. At the time of the assessment, OCPAH reports that the law is in the final stages of development and will be presented to the institute’s General Assembly in August 2018. Prior to the General Assembly, OCPAH will work to raise members’ awareness of the improved I&D system to ensure the bill is approved.

In its next Action Plan submission, OCPAH is encouraged to provide an update on the approval of the Accountancy Reform Law which would significantly enhance its I&D system. OCPAH could consider strategizing the actions it will take to address the gaps in the compliance and implement the changes in anticipation of the adoption of the new law. This may include conducting studies of other PAOs’ experiences with establishing an I&D system in line with SMO 6 requirements.

Current Status: Plan

Corporate accounting standards are set by law in Haiti and therefore, OCPAH is not responsible for their adoption. The current applicable accounting standards are stipulated in the Plan Comptable National (PCN), which does not align with the IFRS and is outdated. OCPAH indicates that the draft law on the accountancy profession refers to IFRS as the accounting standards to be used in the country. Accordingly, OCPAH’s activities are focused on promoting the passage of the draft law and assisting with the dissemination and future implementation of the international standards.

OCPAH states that it has raised awareness and communicated with its members on the IFRS by distributing the standards, making them accessible via OCPAH’s website, and including articles on the standards in its magazine. The institute indicates it has registered with the IFRS Foundation to execute the abovementioned actions.

Additionally, the OCPAH, in collaboration with the World Bank and the Direction du Développement et des Partenariats Internationaux (DDPI), organized trainings on IFRS. From October 2016 to January 2017, two groups of over 50 individuals were trained for a total of 3 weeks on the full IFRS.

Finally, the OCPAH stated that it has been encouraging universities to update their programs to include courses on IFRS by meeting with universities to emphasize the importance of IFRS.

OCPAH is encouraged to continue carrying out trainings on IFRS for its members. OCPAH should also continue advocating for the passage of the draft accounting law that would drive the adoption of IFRS. In line with this, OCPAH is encouraged to provide an update in its next Action Plan, if available, on the status of the amendments to the Tax Decree 29 of 2005 that would update the accounting standards and framework.

Current Status: Execute