Ordre National des Experts-Comptables et des Comptables Agréés du Togo

As of 2017, regional regulation set by the Organization for the Harmonization of Business Law in Africa (OHADA) stipulates that national professional accountancy organizations should establish and implement quality assurance (QA) review systems to ensure compliance with adopted standards. However, ONECCA-Togo, under the supervision of the Ministry of Finance, has played a leading role in promoting the establishment of a national QA review system since 2011. ONECCA-Togo established Committee 1 which oversees ensuring fulfillment of SMO 1 and developing and implementing a QA review system.

In 2013, two ONECCA-Togo members received training and guidance from a World Bank consultant on how to conduct QA reviews of firms. Subsequently, in 2014—2015, ONECCA-Togo reports that it incorporated QA review system requirements and ISQC 1 into its by-laws, but the full implementation of the QA system is still in progress. During this period, volunteer firms were selected to go through a voluntary QA review process and training tools and information sessions were offered to members.

Between 2017-2020, the instituted assisted all member firms to undergo a mandatory quality control review—carried out by its two qualified reviewers. In 2021, due to challenging operational circumstances, the review cycle of its member firms was postponed. The institute intends to establish a permanent QA review team and procedures that are aligned with the SMO 1 requirements.

To support its members, the institute notes that it will continue to offer training sessions on relevant standards and the QA mechanism. ONECCA Togo has done training on ISQM 1, 2, and ISA 220 (revised) and is advocating for the adoption of quality management standards at the regional level.

ONECCA-Togo has steadily progressed with the implementation of its QA review system. Because the public places greater interest in audits of financial statements, it is encouraged to continue executing its plans in this area to operate a QA review system that meets the SMO 1 requirements and provide updates on its progress. It is also encouraged to continue to support the adoption and implementation of ISQM1. Resources on the quality management standards are available on the IAASB website – many of them in French.

Current Status: Execute

With initial professional development (IPD) requirements established at the regional level by the West African Economic and Monetary Union (WAEMU), ONECCA-Togo is responsible for setting continuing professional development (CPD) requirements for its members and closely collaborates with other organizations in Togo that are involved in initial education and training to better align national educational programs with the IES requirements.

In 2013, the institute received a grant from the World Bank to finance and support the revision of national accounting and finance programs. Throughout 2014 and 2015, the Ministry of Secondary Technical and Professional Training and the Ministry of High-Level Education and Scientific Research trained approximately 500 teachers to operationalize the program. The revised education program was able to commence during the academic year of 2015–2016; however, the institute indicates that the program does not yet fully align with IES requirements. ONECCA-Togo is working with universities to align their curriculum and syllabi with IES and reports that it regularly goes to universities to explain the Degree in Accounting and Finance (DECOFI) qualification—a regional prerequisite to offer auditing services in any WAEMU country that is in line with the IES.

To assist students seeking the DECOFI the institute organizes trainings sessions to prepare for the exam. ONECCA-Togo also supports members’ continuing education and has established CPD requirements that are in line with the IES and publishes a calendar of annual training events. The institute emphasizes that it will continue to provide trainings for members and education providers on the Organization for the Harmonization of Business Law in Africa (OHADA) regulations given that the regulations affect the applicable accounting, auditing, and ethical standards within the country.

Finally, ONECCA-Togo also notes that it offers training for members on other specific sectors and topics such as tax law, microfinance, public sector standards, and labor law.

ONECCA-Togo is encouraged to consider working with the Ministry of Secondary Technical and Professional Training and the Ministry of High-Level Education and Scientific Research to conduct a comprehensive review of existing educational requirements in the jurisdiction against those of 2019 IES (effective as of January 2021). For areas of less than full compliance, specific actions to close the gaps, if any, with a defined timeframe should be developed and included in the SMO Action Plan. The IES self- assessment 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

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 Togo, must be conducted in accordance with ISA as issued by the IAASB.

ONECCA-Togo had been committed to the adoption of ISA at the national level prior to OHADA’s recent regulatory decision. The institute indicated that it began collaborating with CPA Canada in 2013 to provide its members with translated versions of IAASB pronouncements, Exposure Drafts, and technical guidance and in 2014, ONECCA-Togo adopted ISA as issued by the IAASB as a requirement for its members. After adopting the ISA for application by its members, the institute had proposed legislation to the government to officially adopt the ISA as the auditing standards for Togo.

Between 2018-2019, ONECCA Togo conducted education and training courses to raise awareness of the new OHADA regulation, as well as ISA 540, ISA 560, and ISA 570. To further support its members with the implementation of the auditing standards, ONECCA-Togo reports that it maintains an ongoing process of updating educational material with regards to new and amended IAASB standards. In 2021, ONECCA Togo indicates that it completed the update of its educational materials and continues to inform its members about the latest developments.

ONECCA-Togo has demonstrated that it is using its best endeavors to fulfill the requirements under SMO 3.

Current Status: Sustain

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 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).

Prior to June 2017, as empowered by Law No. 2001-01, ONECCA-Togo revised its Code of Ethics to comply with the requirements of the 2012 IESBA Code of Ethics. All professional accountants in Togo must adhere to ONECCA-Togo’s Code of Ethics.

As part of its self-regulatory process and best practice, the institute reports it established an SMO 4 Committee to review its by-laws, Code of Ethics, and Constitution to ensure that ethical requirements comply with the IESBA Code. ONECCA-Togo reports that it disseminates the French translation of the Code to its members, accountants in business, trainee accountants, public and private sector bodies as well as other relevant stakeholders to support the implementation of the Code and delivers trainings on the Code to its members. Although not yet adopted, ONECCA-Togo reports it provided training and CPD events for members on the 2018 International Code of Ethics – which was revised and restructured – and noted the NOCLAR standard. The institute has also introduced AML training.

Within its scope of national responsibility, OECCA-Togo is encouraged to review the latest International Code for adoption in Togo and form plans to support its implementation. Additionally, 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 latest International Code of Ethics with the OHADA so that it might update its regulations accordingly.

Current Status: Execute

ONECCA-Togo has no direct responsibility for the adoption of public sector accounting standards, which are set at the regional level by the West African Economic and Monetary Union (WAEMU) Regulation No.09/2009/CM/UEMOA and transposed at the national level by the Ministry of Finance. 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.

IPSAS have not been adopted in Togo but ONECCA-Togo promotes the adoption and implementation of IPSAS at the national level. In 2013, the institute began collaborating with the State Comptroller General (IGE), the World Bank representation in Togo, and the National Accounting Council (CNC) to promote the adoption of IPSAS and it states it will continue to work with these entities once the WAEMU directive is transposed into national law. The SMO 5 Committee of ONECCA-Togo is responsible for promoting the adoption of ISPAS in Togo.

ONECCA-Togo reports that it will continue to provide education and training sessions on the WAEMU Chart of Accountants and IPSAS to support its members. At a regional level, the institute has participated in several initiatives organized by PAFA, including: participation on the PAFA Public Value Management (PVM) Technical Advisory Group (TAG); hosting the 3rd PAFA conference on Public Financial Management Reforms, the Francophone agenda in Africa in Lomé in 2022; and attending the 4th PAFA conference on Public Financial Management Reforms, the Francophone agenda in Africa in Algiers in 2024. Togo has also been selected as a pilot country for the implementation of the PAFA Public Sector Engagement Framework and ONECCA-Togo is actively supporting this initiative.

ONECCA-Togo has demonstrated that it is using its best endeavors to fulfill the requirements under SMO 5 and should continue to highlight how it is advancing the adoption and implementation of IPSAS in the jurisdiction.

Current Status: Review & Improve

ONECCA-Togo is responsible for establishing an investigative and disciplinary (I&D) system for its members and its Discipline Commission, which is comprised of Council members, has been operational since 2013. ONECCA-Togo self-assessed its I&D system against the SMO 6 requirements and noted several areas that require improvements: the separation of investigative and disciplinary procedures, the inclusion of non-professional accountants in the disciplinary process, the implementation of its planned appeals mechanism (the National Discipline Commission) and investigative committee, as well as public interest communications and considerations.

The institute indicates that its Council is proposing several activities to strengthen the I&D processes and alignment with the SMO 6 requirements, most notably the creation of a separate investigative committee and implementation of the appeals mechanism.

ONECCA-Togo states that its founding legislation makes no reference to an investigation committee and therefore, its Council is exploring how it can address this matter. The institute explained that the appeals committee comprises seven members from six different institutions who no longer convene. In 2021, 3 members were sanctioned but ONECCA was not able to enforce the sanctions as the members fought the decision through the judicial system. The Council is also considering how to move forward in reestablishing this mechanism.

The institute is also planning to increase the public’s awareness of types of professional misconduct through more communications and intends to link its I&D system with its quality assurance (QA) review results once well-established.

While ONECCA-Togo has taken a notable first step in identifying areas in its I&D procedures that require improvements, the institute is now encouraged to outline the actions it will take to execute and implement the proposed and necessary changes within its Action Plan. Enforcement mechanisms that meet the SMO 6 best practices are important to public trust and confidence in the accountancy profession. The institute’s plans should include concrete timelines for their execution to enable the institute to track its progress against its plans and make strategic adjustments as needed.

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), Togo’s accounting standards are defined in regional directives. 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 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 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 apply IFRS in consolidated statements. All other companies are permitted but not required to use IFRS.

The institute 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. ONECCA Togo assisted the Conseil National de la Comptabilité (CNC) of Togo—the national body which reports to the OHADA—and the Togolese Ministry of Finance to review, compare, and analyze the SYSCOHADA and IFRS.

In addition, ONECCA-Togo has been raising awareness of IFRS amongst its members since 2015 while also providing trainings on the implementation of SYSCOHADA. Now, the institute offers trainings on IFRS to support members with the implementation. In 2024, ONECCA-Togo emphasized IFRS training regarding bank’s financial statements.

ONECCA-Togo has demonstrated that it is using its best endeavors to fulfill the requirements under SMO 7.  The institute could 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: Sustain