Ordre National des Experts-Comptables et des Comptables Agréés du Burkina Faso

Regional regulation issued by the Organization for the Harmonization of Business Law in Africa (OHADA) in June 2017 stipulates that professional accountancy organizations within OHADA member states are to develop and implement quality assurance (QA) review systems.

Prior to the 2017 regulation, however, the ONECCA-BF had been proactive in the adoption of quality control standards and developing plans to establish a QA review system for its 186 members. The ONECCA-BF states it has adopted ISQC 1, with an effective implementation date of January 2016, and established a QA Committee in 2015. Since 2015, the institute has been working to prepare and train QA reviewers to commence QA reviews; it was able to do its first set of reviews for three firms on a voluntary basis in October 2019. Five (5) firms were inspected in July 2020 and the six (6) others have been selected for 2021 mandatory QA reviews. The institute reports that it has aligned its QA review procedures with SMO 1 requirements.

Four QA reviewers of the institute received training and draft guides on quality assurance from OHADA in June 2016 and received final versions of OHADA-issued QA manual in December 2017. Further training was provided by the Pan African Federation of Accountants (PAFA) in April 2018 and by ONECCA-BF in 2019 and 2020 as well.

ONECCA-BF states that it is assisting firms and individual practitioners in the implementation of ISQC1 by providing training, tools, and guidance on the standards. For example, it has disseminated to members a French translation of ISQC 1 provided by the Compagnie Nationale des Commissaires aux Comptes and l’Institut des Reviseurs d’Entreprises, a French PAO and Belgian PAO, respectively. It has also provided its members access to the Pack-PE tool to support implementation of audit standards and arranged for speakers from the DPPI to present on the benefits of undergoing a QA review and help set members’ expectations. The institute reports that it circulated to members the new Quality Management standards and provided links via its website to relevant implementation guidance material. ONECCA is planning training on the requirement of the Quality Management standards through its CPD courses.

ONECCA-BF has been undertaking QA reviews since 2019, and this is a significant achievement. As other Francophone PAOs in OHADA member states are also preparing to launch QA review systems, the ONECCA-BF may consider how it can collaborate in the exchange of tools, quality controllers, training, and information in French. Lastly, the new suite of IAASB Quality Management standards will require significant change management for regulators and firms. The ONECCA is encouraged to refer to the new changes from quality control standards to quality management standards as it progresses with implementing the QA reviews and preparing members and other relevant stakeholders for the change.

Current Status: Review & Improve

With initial professional development (IPD) requirements established at the regional level by the West African Economic and Monetary Union (WAEMU), the role of the ONECCA-BF is to implement 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) to pass the qualifications’ exam and practice within any of the West African Economic and Monetary Union (WAEMU) member states. Within the OHADA and WAEMU, there are curriculum reforms under consideration that would enable accountancy education to better align with the latest IES requirements. ONECCA-BF reports that the WAEMU adopted in June 2020 Regulation No. 03/2020/CM/UEMOA to reform the DECOFI curriculum and align it with international standards and licence-master-doctorat (Bachelor's-Master's-Doctorate (LMD)) education system. It also reports that the work undertaken by the Formation of the Accounting and Financial Experts (CREFECF), an external body recognized by WAEMU, to accredit training institutions and oversee the exam resulted in at least one training center per WAEMU country. It remains to be clarified, however, how the reforms will enhance the regional requirements alignment with the revised 2019 IES benchmarks.

Nationally, ONECCA-BF has been supporting the accreditation of Joseph Ki Zerbo University and the University of Ouagadougou by the WAEMU. The accreditation would verify that the university offers the same courses and syllabi of the regional Higher Education Degree in Accounting and Financial Management (DESCOGEF—for Certified Accountants) and Degree in Accounting and Finance Expertise (DECOFI—for Chartered Accountants) training that is necessary to pass the qualifications’ exam and practice within any of the WAEMU member states. In 2019, the accreditation was approved for the 2020–2021 school cycle, which is operational as of the date of the assessment. ONECCA-BF members serve as lecturers at the universities.

Additionally, the institute has been sharing guidance and information on best practices for exams that meet IES 6. It is encouraging the universities to comply with IES 6 when conducting examinations as part of initial training. It is also advocating for the incorporation of 2019 IES in the accounting education curriculum in colleges and universities (between January 2021-December 2021) and planning to cooperate with universities on a comparison study of the latest IES requirements and the DESCOGEF/DECOFI program by December 2022. ONECCA BF advocate with the regional bodies for the update of the DESCOGEF/DECOFI Program.

Law No. 48/2005/AN permits ONECCA-BF to adopt CPD requirements. All members must complete and record 120 hours of CPD over a three-year period. This is aligned with the revised 2019 IES 7 and 8. ONECCA-BF has a CPD Commission and a Training Commission that develop an annual CPD calendar to share among and inform members. It indicates it is signing an agreement with the Compagnie Nationale des Commissaires aux Comptes to support training offerings and has received feedback from members on offering taxation training.

The institute states that local business and tax regulations are included as part of IPD. ONECCA-BF will organize, after discussions with CREFECF, an integration session for any candidates who passed examinations in non-WAEMU countries. The institute is also preparing to establish a Training Institute for Accounting Technicians as part of the World Bank’s Foundational Accounting and Financial Management Skills Enhancement Program (FASE) Project.

Finally, ONECCA-BF indicates it is active on a regional level regarding educational matters. It has contributed to initiatives of the Pan African Federation of Accountants such as commenting on exposure drafts, establishing an educational committee within PAFA, and setting the framework for a common contents project for accountancy education.

The latest IES standards reflect the need for competency-based approaches as well as the increasing demand for accountants skilled in information and communications technologies and place further emphasis on professional skepticism skills and behaviors. These apply to both aspiring and professional accountants. ONECCA-BF is encouraged to review the standards and develop plans to incorporate the new requirements and to raise awareness of other stakeholders involved in lifelong development of professional accountants. The association could also drive/facilitate a comprehensive gap analysis of the overall national requirements against the revised IES in cooperation with other stakeholders. 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 must adopt ISA as issued by the IAASB.

ONECCA-BF has been committed to the adoption of ISA at the national level prior to 2017. In June 2015, the institute adopted ISA as issued by the IAASB without modifications, including the effective date. ONECCA-BF has adopted the English version of the standards so that all revisions to standards are adopted on an ongoing basis and become effective when issued by the IAASB to avoid a lag due to translations. Furthermore, the institute reports that auditors of public interest entities (PIEs) were early adopters of the 2016 ISA and the new auditor’s report.

With adoption now effective at the regional level, ONECCA-BF indicates that its role is to provide implementation support by disseminating information, such as the OHADA guides, and providing regular training on the applicable standards. It has established a Standards Commission for this purpose.

ONECCA-BF states that it promptly shares new and revised standards and pronouncements via its website and training. The institute participates in the adoption of the standards. The Institute monitors the work of the IAASB and is committed to submit comment letters at least three (3) per year. Regarding training, the OHADA offered a training on ISA based on the new OHADA regulation in December 2017 at which ONECCA-BF members were present. Furthermore, ONECCA-BF reports that it held three ISA trainings led by the Fédération Internationale des Experts Comptables et Commissaires aux Comptes Francophones (FIDEF) prior to the effective date of the new OHADA regulation on ISA. Since July 2018, the institute has offered eight training activities on audit standards for its members and it has shared the ISA 540 guidelines, which became effective in 2019, with members. It notes that the operationalization of its QA reviews will further permit the institute to monitor implementation of ISA. In July 2019 the institute trained the members on the ISA and the related tools provided by OHADA. In February 2020 members were trained on assurance engagements reporting. The institute offers a technical resources page on its website that directly links to the latest IAASB pronouncement and guides. CPD courses on ISAs are available on demand to members.

Additionally, the ONECCA-BF has received tools and audit software (Pack-PE tool) designed for small- and medium-sized entities from the Compagnie Nationale des Commissaires aux Comptes (CNCC) and indicates that it is signing an agreement with the CNCC to provide training on these materials by the end of 2020. It also shared auditing tools with its members such as questionnaires, templates, auditing procedures, and risk analyses that were provided by OHADA.

Current Status: Sustain

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 Burkina Faso, 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.

In Burkina Faso, Law No. 48/2005/AN stipulates that the ONECCA-BF is responsible for implementing and enforcing regulations set at the regional level. ONECCA-BF has determined that it will adopt all updates and revisions to the Code, including effective dates, when issued by the IESBA. The institute issues press releases to the public via the national press reiterating that its members’ adherence to the IESBA Code of Ethics is required and breaches of professional conduct are punishable offenses.

The institute completed implementation of the NOCLAR standard within Burkina Faso. It did not face significant challenges to NOCLAR implementation as Burkina Faso’s business laws already require auditors to report non-compliance and all professional accountants are required to comply with similar anti-corruption and anti-money laundering requirements.

In addition to providing members with the OHADA note and guidance on ethical requirements, it has included training on the Code in its 2020 and 2021 CPD calendar and is also working with the Compagnie Nationale des Commissaires aux Comptes (CNCC) to offer a mandatory training for all members on ethical requirements. Links directing the eCode and latest pronouncements and guides have been made available on the institute’s website.

ONECCA -BF submitted a response to the questionnaire on the IESBA’s Long Association Post-Implementation review (LAPIR).

The new OHADA regulations only incorporate up to the 2015 IESBA Code of Ethics. The ONECCA-BF might share the 2018 International Code of Ethics, available in French, with the OHADA so that it might update its regulations accordingly to better align with international benchmarks as the institute has done. Additionally, ONECCA-BF is encouraged to consider participating in the submission of comments on IESBA exposure drafts through PAFA’s Standard-Setter Forum.

Current Status: Sustain

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 Burkina Faso. Article 6 of that directive indicates that the government’s general accounting should be based on IPSAS. 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 subject to the review of the WAEMU.

At the national level, the Burkina Faso Government passed Decree No. 2005-255/PRES/PM/MFB in 2005, which established accrual-basis national accounting standards. In December 2019, the government released its first financial statements based on accrual accounting. Per the IFAC/CIPFA International Public Sector Financial Accountability Index 2020, Burkina Faso’s financial reporting framework national standards is on a partial accrual-basis.

The ONECCA-BF has no direct responsibility with regards to public sector accounting standard-setting and has very few members that work in the public sector. Therefore, it is generally not involved as much in public sector accounting matters as other areas. Nonetheless, the institute indicates it has been disseminating the IPSAS as they are issued by the IPSASB to keep stakeholders informed, primarily via its website.

Furthermore, ONECCA-BF is part of a high-level Monitoring Committee of the Public Financial Management (PFM) Enforcement Strategy. The Committee includes government representatives, and the institute is using this platform to monitor progress and initiate dialogue with the Ministry of Finance and the Treasury departments on adoption of accrual-IPSAS. ONECCA-BF attended all the Treasury department’s annual conferences between 2017-2020 in addition to several workshops.

In March 2021, the Board of the Institute met with the Minister of finance to discuss the way the PAO can assist the Government on matters related to the implementation of PFM reform and IPSAS implementation. The Institute is engaged therefore to submit a draft agreement on all relevant public interest items (accounting, finance, development) for the Ministry consideration and subsequently signature between the parties. However, this may be delayed due to coup that has led to the dissolution of the government.

In June 2021, ONECCA-BF facilitated a training for its members on IPSAS requirements. In October 2021, ONECCA-BF co-hosted with PAFA and IPSASB a roundtable for members and public sector accountants from the WAEMU region scheduled to take place in October 2021.

Additionally, the institute notes that it has started discussions during the PAFA Standard-Setters’ Forum among other WAEMU countries to discuss the ONECCA-BF’s assessment of Burkina Faso’s standards to strengthen its conclusions and subsequent outcomes given that the public sector framework is similar in other member states. ONECCA-BF indicates that it is collaborating with universities to conduct a comparison study between IPSAS and the local public accounting framework by December 2021.

ONECCA-BF is encouraged to continue its advocacy and support toward accrual-basis IPSAS. Adoption and implementation of accrual IPSAS as issued by the IPSASB would ensure application of global best practices. The IFAC’s Train the Trainers: Introduction to IPSAS resource might be helpful to ONECCA-BF to continue providing support to public sector accountants in the jurisdiction.

Current Status: Sustain

At the national level, ONECCA-BF has direct responsibility for establishing and implementing an investigative and disciplinary (I&D) system for its members.

ONECCA-BF states that it must abide by regional regulations regarding the set-up of its I&D committees. At the regional level, these committees are identified by the same name. To address regional regulations and SMO 6 requirements, ONECCA worked throughout 2017 to revise its bylaws to have two separate and independent sub-committees—one for investigation and one for discipline. During this time, previous I&D procedures were still implemented, and two members were sanctioned for wrongdoing.

As of January 2018, the institute reports that the new procedures and separate sub-committees have been established and are functional. Three individuals comprise the investigations sub-committee, which can then make recommendations to the discipline committee. Members may appeal decisions through the national court system. The ONECCA-BF conducted a self-assessment of its I&D system against the SMO 6 components and reports that its revised procedures are aligned.

While in 2019, the institute reported that no complaints were brought to the attention of the institute, in 2021 there were three (3) cases that were investigated and relayed to the PAO’s legal advisor for subsequent proceedings.

The institute states that it sensitizes its members and the public on its I&D system via newspaper articles explaining the role of a Chartered Accountant, the PAO, and how the public can file a complaint. The I&D system terms of reference will be accessible on the ONECCA-BF website by September 2021.

ONECCA-BF reports that it offered trainings to members of its investigations committee on their functions in March 2018. In 2021, members were also informed of an anonymous whistleblowing service available on the ONECCA-BF website.

As ONECCA-BF progresses with the implementation of its revised I&D procedures, it is encouraged to continue regularly reviewing its system against the SMO 6 requirements and to establish ongoing processes to ensure continued alignment.

Current Status: Review & Improve

Burkina Faso 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 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.

ONECCA-BF played a key role in promoting the adoption of IFRS at the regional level and had a representative on the OHADA committee that was responsible for the convergence process. The institute has and continues to monitor updates to the standards through its Standards’ Committee and provide training on both SYSCOHADA and IFRS through its CPD Commission. For example, in May 2017, ONECCA-BF sent two members to Cote d’Ivoire for a three-day training on the new standards and upon their return, ONECCA hosted a training for all members in June 2017. ONECCA-BF indicates that it includes several trainings on IFRS and SYSCOHADA standards in its continuing professional development program. Its most recent training was held in December 2019 on the standards that would be applicable from January 2020.

Additionally, the institute has provided its members with implementation manuals, case studies, and guidelines issued by the OHADA, and has disseminated IASB pronouncements via its website.

Furthermore, also at the regional level, ONECCA-BF indicates that it is actively involved in the Standard-Setters’ Forum of the Pan African Federation of Accountants—the regional accountancy organization—contributing to initiatives involving IFRS standard-setting developments and providing comments on IASB-issued exposure drafts. The PAO is planning to submit at least two (2) comments on exposure drafts per year.

ONECCA BF is using its best efforts to fulfill the SMO 7 requirements. Efforts to adopt the latest IFRS for all public interest entities are strongly encouraged to bring transparency, accountability, and efficiency to national, regional, and global markets. As part of its role in supporting adoption, ONECCA-BF is encouraged to continue its advocacy efforts with the regulators to promote the adoption of IFRS as the applicable accounting standards for regulated companies.

Current Status: Sustain