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. To spearhead this initiative, 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. By 2021, the institute plans to establish a larger, permanent QA review team that will carry out reviews in compliance with SMO 1 requirements and as suitable for the Togolese context.

To support its members, during the next three years, the institute notes that it will continue to offer training sessions on quality control standards and the QA mechanism. Specifically, ONECCA Togo plans to conduct training on the new quality management (QM) standards between August-September 2021 to prepare its members with the implementation of the standards before they come into effect in 2022.

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 monitor and support the implementation of ISQM1 among members who might be auditors when it becomes effective as of December 15, 2022. 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 (although further information is needed to assess the extent of alignment and incorporation of the 2019 IES requirements, which emphasize learning-outcomes approaches).

For example, 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 therefore 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 providing trainings for members and education providers on the Organization for the Harmonization of Business Law in Africa (OHADA) regulations that came into effect in January 2018 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 plans to conduct CPD and training events on all new ISA requirements between August-September 2021.

The IAASB has issued an exposure draft of the proposed separate standard for audits of Less Complex Entities. ONECCA-Togo is encouraged to participate in the public consultation process for this landmark new draft standard.

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. While not yet adopted, ONECCA-Togo states it has provided training sessions on the 2018 ethical requirements, which includes the NOCLAR standard.

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. Given the adoption of the new OHADA regulation, the institute plans to raise awareness amongst its members and will update its continuing professional development programming accordingly.

The 2018 International Code of Ethics, which has been revised and restructured from previous version and contains the NOCLAR standard issued in 2016, is now available in French. Within its scope of national responsibility, OECCA-Togo is encouraged to review the 2018 Code for adoption in Togo and form plans to support its implementation. ONECCA-Togo is also encouraged to review revisions to Part 4B of the Code?to reflect terms and concepts used in the IAASB's International Standard on Assurance Engagements (ISAE) 3000 (Revised), which are effective June 2021 and revisions to promote the role and mindset expected of all professional accountants which are effective in December 2021. Lastly, 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 2018 International Code (along with the 2020 revisions) 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 and planned for review by WAEMU in 2020. It is unclear if the review proceeded as planned in 2020 or was subject to delays due to the global COVID-19 pandemic.

As of the date of the assessment, the institute states IPSAS have not been adopted in Togo but that it 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 and in 2013, the institute distributed the 2005 version of IPSAS in French to the Committee’s members.

ONECCA-Togo reports that it will continue to provide education and training sessions on IPSAS to support its members.

ONECCA-Togo is encouraged to indicate in its Action Plan if there is a timeline in place for the adoption and implementation of IPSAS at the national level and consider, if feasible, the role ONECCA-Togo may have in this process. Several revisions to IPSAS have been issued since 2005 and the institute may consider providing relevant stakeholders with the French translation of the 2018 Handbook of International Public Sector Accounting Pronouncements. If the institute is involved in meetings and taskforces with the Ministry of Finance, this information should be included within its Action Plan. The institute is also encouraged to include further details of trainings it is holding for members to support their implementation of currently applicable standards.

Current Status: Execute

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 enhance 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. Similarly, its 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 by 2023—two years after the anticipated implementation of mandatory QA reviews for all members.

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 foundational 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 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 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. However, with the passage of the AUDCIF, the institute reports that it will hold trainings on the new law and work to support members with the implementation of IFRS.

ONECCA-Togo 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-Togo 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 to bring SME reporting in line with international best practices.

Current Status: Review & Improve