Mali

The corporate financial framework of Mali is determined by legislation issued by two regional bodies: The West African Economic and Monetary Union (WAEMU) and the Organization for the Harmonization of Business Law in Africa (OHADA). Legislation issued at the regional level by WAEMU and OHADA has a significant impact on the legal and regulatory framework for commercial entities, banks, financial institutions, and insurance companies in Mali as well as on the accountancy profession. Mali, as a member of the two regional groups, harmonizes national laws with directives issued at the regional level.

OHADA and WAEMU are responsible for the development of member countries’ accounting standards while Member States are required to establish a Conseil National de la Comptabilité (CNC) with responsibility for implementation of accounting and auditing directives at the national level. The WAEMU Treaty gives responsibility to the WAEMU Council to set the accounting standards to be applied by the member states. In accordance with the WAEMU Regulation No. 3/97/CM/UEMOA, the WAEMU delegated its accounting standard-setting activities to the Conseil Comptable Ouest Africain (CCOA), which in turn now adopts the OHADA standards for application in the WAEMU member states.

Accounting Framework

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 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 accounts, combined accounts. The SYSCOHADA continue to differ from 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.

Auditing Framework

The OHADA Uniform Act Relating to Commercial Companies and Economic Interest Groups 4/1997 (revised January 2014) stipulates that statutory audits are mandatory for all public companies, limited liability companies (LLCs) and partnerships that exceed one of these three thresholds: (i) total balance sheet in excess of CFA franc 125 million; (ii) sales volume greater than CFA franc 250 million; or (iii) more than 50 permanent employees with a total balance sheet in excess of CFA franc 250 million and sales volume of CFA franc 500 million. Banking and insurance legislations also require mandatory audits of banks, financial institutions, and insurance companies.

Audit standard-setting at the regional level is determined by WAEMU Regulation No. 01/2009/CM/UEMOA of 2009, which established the Council of the Chartered Accountants Profession (le Conseil Permanent de la Profession Comptable, CPPC). The CPPC is responsible for defining auditing, ethics, and quality control standards for the WAEMU member states.

However, in June 2017, the 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 auditing standards with international best practice. The regulation, effective from January 1, 2018, states that all audits must be conducted in accordance with ISA as issued by the IAASB. Therefore, ISA as issued by IAASB are effective in Mali as of the date of the assessment.

Chartered Accountants in Mali are first regulated at the regional level by West African Economic and Monetary Union (WAEMU) Regulation No. 12/2000/CM/UEMOA. Mali, as a member country of the WAEMU, must apply the regional requirements at the national level. Law 86-16 / AN-RM and amended by subsequent laws Law 96 - 024 / AN RM of 21 February 1996 and Law 08-015 / AN-RM of 04 June 2008 establishes the Ordre National des Experts Comptables et Comptables Agréés du Mali (ONECCA-Mali) as the national professional accountancy organization (PAO) responsible for regulating professionals within Mali.

WAEMU Regulation No. 12/2000/CM/UEMOA introduced the Degree in Accounting and Finance (DECOFI) and the Higher Education Degree in Accounting and Financial Management (DESCOGEF) as requisites to practice in any WAEMU country. The DESCOGEF is for the Certified Accountant title and is received after a one year “Comprehensive Theoretical and Technical Training” program at an institution accredited by the Regional Commission for the Formation of the Accounting and Financial Experts (CREFECF), an external body recognized by WAEMU. Subsequently, to qualify as a Chartered Accountant, DESCOGEF-holders are eligible to complete a three-year internship under the supervision of a professionally qualified accountant. Individuals complete two years in an audit firm and one year in an accounting firm. Finally, individuals with an internship certificate must pass a final examination leading to the DECOFI and Chartered Accountant qualification. The final examinations are also overseen by the CREFECF. The title of Chartered Accountants is only granted to those registered by a PAO in WAEMU countries.

Additionally, WAEMU Regulation No. 01/2009/CM/UEMOA of 2009 grants the Conseil Permanent de la Profession Comptable (CPPC) the responsibility for defining auditing, ethical, and quality control standards. The CPPC has yet to adopt these standards and has recommended that PAOs within member states pursue the adoption and implementation of quality assurance (QA) systems and quality control standards at a national level. 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 membres de l’OHADA to harmonize regional auditing and ethical standards with international best practice.

In Mali, ONECCA-Mali is responsible for: (i) implementing initial professional development and setting continuing professional development requirements; (ii) monitoring compliance with technical standards; (iii) proposing ethical requirements to the Ministry of Finance for approval; (iv) establishing a quality assurance review system; (v) maintaining a register of Chartered Accountants and Certified Accountants; and (vi) establishing an investigation and discipline system for its members.

Only ONECCA-Mali is permitted to offer qualified individuals the title of Chartered Accountant if they satisfy the regional educational requirements and the national legal conditions such as citizenship and no criminal record. The institute has also determined that those holding the DEC issued by the Conseil Supérieur de l’Ordre des Experts-Comptables (CSOEC-French institute) may also apply for membership.

There is no independent audit oversight arrangement or entity in Mali.

Auditors are regulated at the regional level by West African Economic and Monetary Union (WAEMU), and at the national level by Ordre des Experts Comptables et Comptables Agréés du Mali (ONECCA-Mali).

Please see the Regulation of the Accountancy Profession section for further details.

Ordre National des Experts Comptables et Comptables Agréés du Mali (ONECCA-Mali)

ONECCA-Mali was founded in 1986 by Law 86-16 / AN-RM and amended by subsequent laws Law 96 - 024 / AN RM of 21 February 1996 and Law 08-015 / AN-RM of 04 June 2008.

ONECCA-Mali is responsible for (i) implementing initial professional development and setting continuing professional development requirements; (ii) monitoring compliance with technical standards; (iii) proposing ethical requirements to the Ministry of Finance for approval; (iv) establishing a quality assurance review system; (v) maintaining a register of Chartered Accountants and Certified Accountants; and (vi) establishing an investigation and discipline system for its members.

Only ONECCA-Mali is permitted to offer qualified individuals the title of Chartered Accountant if they satisfy the regional educational requirements and the national legal conditions such as citizenship and no criminal record.

ONECCA-Mali is a member of the regional accountancy body Pan African Federation of Accountants (PAFA) and the International Federation of Francophone Accounting Bodies (FIDEF).

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. Draft regulation establishing this requirement was finalized by the Council of Ministers of the WAEMU in 2014. However, due to delays the CPPC has recommended that professional accountancy organizations (PAOs) within member states pursue the adoption and implementation of QA systems and quality control standards at a national level.

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 May 2020, the institute conducted its first QA pilot reviews. In 2020 it conducted QA reviews on a voluntary basis with 20 firms. ONECCA-Mali indicates that when operationalizing its QA reviews the procedures will meet the SMO 1 requirements and OHADA QA regulations. ONECCA-Mali expects the IAASB’s new quality management standards to have an impact on the OHADA QA manual.

Current Status: Partially Adopted

Chartered Accountants in Mali are first regulated at the regional level by West African Economic and Monetary Union (WAEMU) Regulation No. 12/2000/CM/UEMOA, which introduced the Degree in Accounting and Finance (DECOFI) as a mandatory qualification for Chartered Accountants. Mali, as a member country of the WAEMU, must apply the regional requirements at the national level. Law 86-16 / AN-RM and amended by subsequent laws Law 96 - 024 / AN RM of 21 February 1996 and Law 08-015 / AN-RM of 04 June 2008 establishes the Ordre National des Experts Comptables et Comptables Agréés du Mali (ONECCA-Mali) as the national professional accountancry organization (PAO) responsible for regulating professionals within Mali.

As noted, WAEMU Regulation No. 12/2000/CM/UEMOA introduced the Degree in Accounting and Finance (DECOFI) and the Higher Education Degree in Accounting and Financial Management (DESCOGEF) as requisites to practice in any WAEMU country. The DESCOGEF qualification is for the Certified Accountant designation and is received after one year “Comprehensive Theoretical and Technical Training” program at an institution accredited by the Regional Commission for the Formation of the Accounting and Financial Experts (CREFECF), an external body recognized by WAEMU. Subsequently, to qualify as a Chartered Accountant, DESCOGEF-holders are eligible to complete a three-year internship that must be verified by a professionally qualified accountant. Individuals complete two years in an audit firm and one year in an accounting firm under the supervision of a qualified Chartered Accountant. Finally, individuals with an internship certificate must pass a final examination leading to the DECOFI and Chartered Accountant qualification. The final examinations are also overseen by the CREFECF. The title of Chartered Accountants is only granted to those registered by a PAO in WAEMU countries. These are also the only individuals permitted to conduct audits.

At the national level, ONECCA-Mali is responsible for implementing the initial professional development set by regional regulations and setting continuing professional development requirements for its members. The institute has determined that individuals that satisfy the regional educational requirements or hold the Conseil Supérieur de l’Ordre des Experts-Comptables (CSOEC-French institute) qualification may apply to join the institute and use the title of Chartered Accountant. The institute indicates that it has set CPD obligations for 120 hours over three years.

The 2019 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 2019 IES requirements. Moreover, within the OHADA and WAEMU there is a Chartered Accountant Diploma and curriculum reform under consideration that would enable accountancy education (IES 1–4) to align with the 2019 IES requirements.

Current Status: Partially Adopted

The Organization for the Harmonization of Business Law in Africa (OHADA) Uniform Act Relating to Commercial Companies and Economic Interest Groups 4/1997 (revised January 2014) stipulates that statutory audits are mandatory for all public companies and limited liability companies (LLCs) that exceed determined thresholds. Banking and insurance legislations also require mandatory audits of banks, financial institutions, and insurance companies.

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

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.

Current Status: Adopted

At the regional level, West African Economic and Monetary Union (WAEMU) Regulation No. 01/2009/CM/UEMOA grants authority to the Conseil Permanent de la Profession Comptable (CPPC) to determine ethical requirements for member states. The CPPC has not yet adopted a Code of Ethics and it is not clear if it will do so given the adoption of ethical standards by the Organization for the Harmonization of Business Law in Africa (OHADA).

In June 2017, the 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, as well as the relevant parts of the OHADA Uniform Act on Accounting Law and Financial Information (AUDCIF).

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 regulations that would harmonize the applicable ethical requirements with the 2018 International Code of Ethics. The revisions are pending approval by the General Assembly and the Ministry of Finance.

The 2018 International Code of Ethics is available in French on the IESBA website.

Current Status: Partially Adopted

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 IPSAS. PAOs within WAEMU countries report that the regulation has undergone revisions in order 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 are that are currently applied are national standards on a cash-basis with intentions to transition to accrual (IFAC, CIPFA 2020).

The 2018 version of the IPSAS are available in French.

Current Status: Not Adopted

At the regional level, the World Bank is supporting the Organization for the Harmonization of Business Law in Africa (OHADA) in the development of an I&D system for its member states. There is no further information available currently on the status of a regional I&D system. The West African Economic and Monetary Union (WAEMU) will adopt the OHADA system for its member states. There are provisions within the OHADA’s Uniform Act on Accounting Law and Financial Information (AUDCIF) that stipulate sanctions for non-compliance with the Act and these have been transposed into legislation at the national law.

At the national level, Law 08-015 / AN-RM of 04 June 2008, which establishes ONECA-Mali as the national PAO, creates the investigation and discipline (I&D) procedures for the accountancy profession.

ONECCA-Mali 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 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; composition of its Disciplinary Chamber; public interest considerations; and regular reviews of the procedures.

Current Status: Partially Adopted

The corporate financial framework of Mali is determined by legislation issued by two regional bodies: The West African Economic and Monetary Union (WAEMU) and the Organization for the Harmonization of Business Law in Africa (OHADA). Mali, as a member of the two regional groups, harmonizes national laws with directives issued at the regional level.

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 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.

Current Status: Partially Adopted

Relevant Organizations

Central Bank of West African States

Organization for the Harmonization of Business Law in Africa (OHADA)

Ordre National des Experts Comptables et Comptables Agréés du Mali (ONECCA-Mali)

West African Economic and Monetary Union (WAEMU)

Relevant Legislation

Law 08-015 / AN-RM of 04 June 2008

HYPERLINK "http://www.juriscope.org/uploads/pdf/ohada/OHADA_en/comptable-gb.pdf" OHADA Uniform Act on Accounting and Financial Information (AUDCIF)

OHADA Uniform Act Relating to Commercial Companies and Economic Interest Groups

Regulation No. 01/2017/CM/OHADA Pratiques Professionelles de la Comptabilité et de l’Audit dans les pays membres de l’OHADA

Relevant Publications

IFRS Foundation, IFRS Application Around the World Jurisdictional Profile: Mali, 23 Jan 2018.

Koné, Seydou Karamoko, “ONECCA-Mali : A la croisée des chemins, après 30 ans d’existence!” 2016.

OHADA, “Online publication of harmonization tools on the practices of accounting and audit professionals”, n.d.

ONECCA-Mali, SMO Action Plan, 2019.

Ouattara, Abdoulaye, “Assemblée Générale De L’ordre Des Experts Comptables: Un Second Mandat De 3 Ans Pour Faty Cissé”, 3 September 2018.

World Bank, Implementation Status & Results: WAEMU Development of Accounting Regulation Institutions and Auditing Profession, 2013.

World Bank, Implementation Status & Results Report: Improved Investment Climate within the Organization for the Harmonization of Business Law in Africa (OHADA), 2014.

World Bank, Implementation Status & Results Report: Improved Investment Climate within the Organization for the Harmonization of Business Law in Africa (OHADA) (P126663), January 2016.

World Bank, Report on the Observance of Standards and Codes—Accounting and Auditing: Mali, 2009.