Ordre National des Experts Comptables et des Comptables Agréés du Mali

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. 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 Mali, to develop and implement QA review systems.

ONECCA-Mali, as the national PAO, has established a QA Commission. In 2020, with support from the African Development Bank (AfDB) it conducted QA reviews on a voluntary basis with 20 firms. Action plans have been collected from all firms and implementation is being monitored. The pilot QA review process is being assessed and gaps will be corrected before extending the QA reviews to all members in 2022. ONECCA-Mali indicates that once it operationalizes its QA reviews the procedures will meet the SMO 1 requirements and OHADA QA regulations.

To support its members, the institute plans to provide a national guide on QA reviews. With support from OHADA and the World Bank, ONECCA-Mali has been able to offer trainings on quality control standards, an OHADA-issued QA manual and communicate the purpose of the QA review system to its member firms. It intends to make trainings on ISQC 1 recurring. Five quality control reviewers have already been trained through OHADA seminars and two of the reviewers are from France with experience in carrying out QA reviews. This will help to build up the capacity and transfer knowledge to local reviewers.

Translated versions of the IAASB’s quality management standards have been shared with all members and training sessions on the standards have been held. The impact of the new standards on QA reviews will be considered in early 2023.

ONECCA-Mali is taking the necessary steps to begin operationalizing its QA review program. As it continues to advance this initiative, 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. The institute is also encouraged to consider regional engagements and collaboration to learn how other PAOs in the African region built up the capacity to execute their QA review systems. Lastly, ONECCA-Mali 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: Execute

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-Mali 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. The training for these degrees is only offered at universities in Senegal and Cote d’Ivoire. ONECCA-Mali is supporting the assessment and accreditation of two universities in Mali in order to offer the DESCOGEF/DECOFI qualification educational programming nationally. This would significantly decrease the costs of studying accountancy and help attract younger students.

Furthermore, as part of its engagement with national universities, the institute will train accountancy educators on any new standards to support up-to-date curriculum. For example, with the passage of new OHADA legislation in 2017 that revised the accounting and auditing framework, ONECCA-Mali states that it offered training to university lecturers on the new standards.

In addition, ONECCA-Mali notes that among OHADA and WAEMU member states there is a curriculum reform under consideration that would enable the DECOFI diploma and IPD to better align with the IES requirements. The institute attended a regional workshop in 2017 on the initiative. At the national level, ONECCA-Mali indicates that it meets with the government to highlight the need to comply with IES requirements.

With regards to CPD, the ONECCA-Mali reports that it requires its members to fulfill at least 40 hours per year. The institute states that it provides regular training on international standards as well as topics such as tax, business law, anti-money laundering, ISQC1 and specific sectors (e.g. banking, microfinance). Its CPD Commission is responsible for implementing and monitoring the CPD activities, and verify and report to the Board on the accepted hours for each member. The annual enrollment on the membership register is subject to the member’s fulfilment of their CPD obligations.

ONECCA-Mali has noted that it is carrying out initiatives to incorporate IES requirements where it is authorized to at the national level. There is still opportunity to further review educational requirements and execute initiatives that would enable to it further fulfill the SMO 2 obligations.

The revised (2015) 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 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 as OHADA is reviewing the Chartered Accountant qualification and curriculum.

Current Status: Execute

The Organization for the Harmonization of Business Law in Africa (OHADA) has been revising regional regulation in order 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 beginning in January 2018. ONECCA-Mali indicates that in the jurisdiction the regional requirement is in force and that ISA are effective as issued by the IAASB. ONECCA-Mali also indicates that auditors must adhere to a national audit guide published by the Comptroller General and the Ministry of Finance. The local guide is based on ISA.

ONECCA-Mali has been committed to the adoption of ISA at the national level prior to the OHADA’s adoption of the standards. In 2010, the institute successfully advocated for the Ministry of Finance to adopt ISA and national auditing guides based on ISA as issued by the IAASB. With adoption now effective at the regional level, ONECCA-Mali indicates that it has been readily able to attend trainings and receive audit tools and guidance complying with ISA from OHADA. ONECCA-Mali has demonstrated that it has implemented initiatives to further meet the SMO 3 obligations and is committed to continued improvement. The institute particularly notes that changes from 2016, such as Key Audit Matters, are being applied in the jurisdiction.

It has trained and disseminated this information to its members and firms. In 2019, ONECA-Mali has also provided seminars on ISA with the support of the French DPPI. The institute indicates that seminars will be offered on a recurring basis as well as regular communications to members on new standards issued by the IAASB.

With the new OHADA regulations now effective, the ONECCA-Mali is encouraged to ensure that it incorporates and highlights current implementation support (such as trainings and guides) activities for its members within its SMO Action Plan. The 2018 Handbook is available in French, as are the more recently issued suite of quality management standards (ISQM 1, ISQM 2, ISA 220 (revised) and conforming amendments). The institute is encouraged to disseminate the French translations to further support proper application. Finally, the ONECCA-Mali is encouraged to continue preparing members for the change from quality control standards to quality management standards described above (effective December 15, 2022).

Current Status: Review & Improve

The Organization for the Harmonization of Business Law in Africa (OHADA) has been revising regional regulation in order to harmonize ethical standards with international best practice. In June 2017, OHADA issued regulations stating that its member states, which includes Mali, 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 Mali, ONECCA-Mali is authorized by Law 08-015 / AN-RM of 04 June 2008 to propose ethical requirements to the Ministry of Finance for approval and subsequent application by its members. ONECCA-Mali indicates that the OHADA Code of Ethics is applicable in the jurisdiction as a minimum benchmark. The institute proposed revised bylaws that would harmonize the applicable ethical requirements with the 2018 International Code of Ethics. The revisions are pending approval by the Ministry of Finance.

While working to formally adopt an updated Code, the institute indicates that it offers trainings to its members on the Code of Ethics and application of its requirements the OHADA note and guidance. It also actively speaks out on the importance of adhering to ethical obligations. The twelve-installment publication series exploring the IESBA Code and translated into French are communicated to the members. Regular emails are sent to members to highlight any change or tool published on IFAC, FIDEF and OHADA websites regarding the Code. ONECCA-Mali has indicated 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 would enable the institute to further meet the SMO 4 obligations.

ONECCA-Mali is encouraged to provide an update on the revised bylaws it submitted to the Ministry of Finance that would adopt the 2018 International Code of Ethics.. Additionally, since OHADA regulations incorporate only up to the 2015 version of the IESBA Code, ONECCA-Mali is encouraged to continue its advisory and advocacy role by sharing the 2021 version of the International Code of Ethics with OHADA. The 2021 version differs from the 2018 & 2020 Handbook by including revisions to Part 4B and Parts 1 & 2 on the role and mindset of professional accountants that became effective December 2021. The 2021 Handbook also includes approved revisions that will become effective in December 2022, such as: revisions to non-assurance services, fees, and objectivity of an engagement quality reviewer. In addition. ONECCA-Mali is encouraged to include actions to promote the need to adopt the IESBA Code of Ethics for all professional accountants to relevant authorities and stakeholders

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 Mali. Article 6 of that directive indicates that the government’s general accounting should be based on international accounting standards. PAOs within WAEMU countries report 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, decree N°2014-0774/P-RM adopted the WAEMU directive in Mali. However, the standards that are currently applied are national standards on a cash-basis with intentions to transition to accrual (IFAC, CIPFA 2020).

Although ONECCA-Mali has no standard-setting authority in this area nor do its members work in the public sector, the institute indicates that it has a collaborative relationship with the government. For example, the institute has two representative members on the government steering commission established to support the transition and eventual implementation process of IPSAS. Additionally, the government will send staff to participate in ONECCA-Mali’s trainings and support ONECCA-Mali’s attendance at events pertaining to public financial management.

ONECCA-Mali’s engagement with the government and public sector authorities with regards to IPSAS is positive. Pending approval of the revised standards by WAEMU’s Accounting Council, the ONECCA-Mali is encouraged to indicate if there is a timeline for the adoption of the IPSAS in Mali and how it might support the Ministry of Finance in its implementation plan. For example, a 2018 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

Within Mali, ONECCA-Mali is authorized to carry out investigative and disciplinary (I&D) procedures for its members. As such, the institute has a Disciplinary Commission that will investigate any complaint and make a recommendation to the ONECCA-Mali Board. The Board may impose the following disciplinary measures: warning, reprimand with or without record, and temporary suspension of license. Depending on the severity of the case, the Council may refer the complaint to its National Chamber of Discipline, which may impose: 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 Board. For appeals resulting from decisions made by the National Chamber, individuals refer to the Administrative Chamber of the Supreme Court.

ONECCA-Mali indicates that while its system is operational there are areas of its I&D procedures that do not fully meet the SMO 6 best practices such as: linkage with the QA review system which it is still operationalizing; composition of its Disciplinary Chamber; public interest considerations; and regular reviews of the procedures. The institute reports that it is reviewing its bylaws and legislation to make changes were feasible. For example, the institute is planning to engage with private and public sector stakeholders on the I&D procedures of the institute, consequences of non-compliance, and the need to deter illegal practice. In the case of the composition of its Disciplinary Chamber, the institute states it has repeatedly requested that the Ministry of Justice appoint a judge to serve on the committee. However, because legislation does not require this, the institute’s request has been declined. When there are appeals, a lawyer will participate in the appeals process.

Additionally, ONECCA-Mali 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. As ONECCA-Mali proceeds with the review of its bylaws and adapting its I&D procedures, it should continue to refer to the SMO 6 best practices to ensure its procedures align to the extent permitted. The institute should update the Action Plan with a timeline for this review process. The institute is also encouraged to plan and indicate clear examples of outreach and awareness raising to the public, business, private, and public sector stakeholders on the I&D processes and how to submit any complaints while also ensuring its members are aware of the consequences of non-compliance and misconduct.

Current Status: Plan

As a member state of West African Economic and Monetary Union (WAEMU) and the Organization for the Harmonization of Business Law in Africa (OHADA), Mali’s corporate accounting standards are defined in regional directives. 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 in order 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.

ONECA-Mali is active in supporting the transition to IFRS as part of the SYSCOHADA. The institute has participated in trainings offered by OHADA on the new standards and subsequently organized trainings for its members. Additionally, the institute has provided its members with implementation manuals, case studies, and guides issued by the OHADA. To raise greater awareness of IFRS, it intends to engage with relevant companies in the jurisdiction and disseminate communications issued by the IASB.

ONECCA-Mali 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, ONECCA-Mali 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 in order to bring SME reporting in line with international best practices.

Current Status: Review & Improve