Togo

The corporate financial framework of Togo 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 Togo as well as on the accountancy profession. Togo, 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 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.

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 the International Standards on Auditing (ISA) as issued by the International Auditing and Assurance Standards Board (IAASB). Therefore, ISA as issued by IAASB are effective in Togo as of the date of the assessment.

Entry requirements for the accountancy profession are set at the regional level by the West African Economic and Monetary Union (WAEMU) Regulation No. 12/2000/CM/UEMOA. Togo, as a member country of WAEUMU, must apply the regional requirements.

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 professional accountancy organization (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.

At the national level, Law No. 2001-001 of January 2001 establishes the Ordre National des Experts Comptables et des Comptables Agréés du Togo (ONECCA-Togo) and sets the supervision of its activities under the authority of the Ministry of Finance. Membership in the institute is mandatory for all professional accountants in the country.

According to Law 2001-001, ONECCA-Togo is required to (i) register all accountancy professionals (individuals and firms); (ii) improve the quality of accounting and financial information; (iii) set ethical requirements for members; (iv) promote fair accounting practices and compliance with international standards; (v) establish an investigation and discipline framework for members; (vi) establish a quality assurance review system; and (vii) enforce initial professional development requirements (IPD) and establish continuing professional development (CPD) requirements for members. The law also states the rights and responsibilities of members.

Law No. 2001-001 states IPD and CPD requirements for the profession which are supplementary to those of WAEMU. In Togo, the Ministry of Secondary Technical and Professional Training and the Ministry of High-Level Education and Scientific Research are responsible for the development of the accountancy education programs.

To register as a Chartered Accountant with ONECCA-Togo, candidates must have a certified public accounting DECOFI degree, which is obtained after completing a five-year professional accountancy program culminating in written and oral tests, and three years of practical experience. In line with WAEMU requirements, only Chartered Accountants may conduct audits in Togo.

Certified Accountants are required to hold the DESCOGEF qualification, or the equivalent diploma recognized by the Ministry of High Level Education and Scientific Research and complete a three-year internship which is formally recognized by a certificate issued by a registered professional of ONECCA-Togo.

Individuals holding a DEC from France or Tunisia and the equivalent qualification from the United States or Canada may also register with the institute as Chartered Accountants after the Ministry of High-Level Education and Scientific Research confers equivalency. ONECCA-Togo is considering allowing Certified Accountants to qualify as Chartered Accountants if they have ten years of experience, participate in training sessions related to audit work, and pass an oral exam to demonstrate knowledge of local business law and audit work.

Finally, there are additional requirements for auditors of banks set by the Banque Centrale des États de l’Afrique de l’Ouest (the Central Bank of West African States (BCEAO)) and the WAEMU Banking Commission. Banks are required to appoint two auditors, who are subject to prior approval by the Banking Commission.

There is no independent audit oversight body in Togo.

Auditors are first regulated at the regional level by WAEMU Regulation No. 12/2000/CM/UEMOA, which introduced the Degree in Accounting and Finance (DECOFI) as a mandatory qualification for Chartered Accountants, who are the only individuals permitted to publicly practice auditing in WAEMU countries. The WAEMU Conseil Permanent de la Profession Comptable (CPPC) is responsible for defining auditing, ethics, and quality control standards based on WAEMU Regulation No. 01/2009/CM/UEMOA. However, the CPPC has yet to adopt these standards and has recommended that professional accountancy organizations (PAOs) within member states pursue the adoption and implementation of quality assurance (QA) review 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 standards with international best practice. The regulation, effective from January 1st, 2018, states that all audits must be conducted in accordance with the International Standards on Auditing (ISA) as issued by the International Auditing and Assurance Standards Board (IAASB). Further, 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).

At the national level, auditors are regulated by the Ordre National des Experts Comptables et des Comptables Agréés du Togo (ONECCA-Togo) in accordance with Law No. 2001-001. Only registered Chartered Accountants of ONECCA-Togo are permitted to conduct audits in Togo.

Under Law No. 2001-01, ONECCA-Togo’s responsibilities related to auditing include to: (i) register all accountancy professionals (individuals and firms); (ii) set ethical requirements for members; (iii) promote compliance with international standards; (iv) establish an investigation and discipline framework for members; (v) establish a QA review system; and (vi) enforce initial professional development requirements and establish continuing professional development requirements for members. Law No. 2001-001 authorizes the Ministry of Finance to supervise ONECCA-Togo’s activities.

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

ONECCA-Togo was established following the adoption of the Act of Parliament 2001-001 on January 23, 2001, which implemented the West African Economic and Monetary Union (WAEMU) Directive N.04/97/CM/UEMOA of November 2, 1997. ONECCA-Togo’s membership is comprised of Chartered Accountants and Certified Accountants and membership is mandatory for all professional accountants in the country.

According to the law, ONECCA-Togo is required to (i) register all accountancy professionals (individuals and firms); (ii) improve the quality of accounting and financial information; (iii) set ethical requirements for members; (iv) promote fair accounting practices and compliance with international standards; (v) establish an investigation and discipline framework for members; (vi) establish a quality assurance review system; and (vii) enforce initial professional development requirements and establish continuing professional development requirements for members. The law also states the rights and responsibilities of members. Furthermore, it authorizes the Ministry of Finance to supervise ONECCA-Togo’s activities.

In addition to being an Associate of IFAC, ONECCA-Togo is a member of the Pan-African Federation of Accountants, the Association of Accountancy Bodies in West Africa, and the Fédération Internationale Des Experts-Comptables Francophones.

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 Togo, to develop and implement QA review systems.

Ordre National des Experts Comptables et des Comptables Agréés du Togo (ONECCA-Togo) has been working to establish a QA review system since 2009 by introducing quality control standards, setting up a mentoring program for audit firms, and conducting voluntary pilot reviews. In 2014, ONECCA-Togo’s General Assembly approved the establishment of a QA review system and adopted ISQC 1 and ISA 220. In 2018 and 2019, the institute reviewed the internal quality control requirements and procedures of its member firms.

Unfortunately, due to the outbreak of the pandemic, the review cycle of its member firms was postponed to September 2021. The institute intends to establish a permanent QA review team and procedures that are aligned with the SMO 1 requirements.

Current Status: Partially Adopted

Chartered Accountants in Togo are first regulated at the regional level by West African Economic and Monetary Union (WAEMU) Regulation No. 12/2000/CM/UEMOA. Togo, as a member country of the WAEMU, must apply the regional requirements at the national level.

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 DECOFI is a regional prerequisite to offer services in any WAEMU country that is in line with the IES. 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, the Togolese Law No. 2001-001 stipulates initial professional development (IPD) and continuing professional development (CPD) requirements for the profession. In Togo, the Ordre National des Experts Comptables et des Comptables Agréés du Togo (ONECCA-Togo) regulations supplement those of WAEMU. In addition, the Ministry of Secondary Technical and Professional Training and the Ministry of High-Level Education and Scientific Research are responsible for the development of educational programs.

With World Bank assistance, ONECCA-Togo, the Ministry of Secondary Technical and Professional Training, and the Ministry of High-Level Education and Scientific Research developed and launched a national accountancy education program in August 2013, which the institute reports partially aligns with IES.

The institute also reports that Law No. 2001-01establishes CPD requirements which are in line with the IES—ONECCA-Togo members must complete 120 hours of CPD over three years.

Overall, while requirements of earlier versions of the IES appear to be in place — e.g., an accountancy program, exams, and practical experience — further information is needed to assess the extent of alignment and incorporation of the 2019 IES requirements (effective January 2021), which emphasize learning-outcomes approaches for initial professional development especially.

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

Ordre National des Experts Comptables et des Comptables Agréés du Togo (ONECCA-Togo) indicates that in the jurisdiction the regional requirement is in force and that ISA are effective as issued by the IAASB.

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. Since CPPC has yet to establish the ethical requirements, 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 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).

At the national level, Law No. 2001-01 requires the Ordre National des Experts Comptables et des Comptables Agréés du Togo (ONECCA-Togo) to set ethical requirements for members. Prior to June 2017, as empowered by Law No. 2001-01, ONECCA-Togo revised its Code of Ethics to fully 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 of the date of the assessment, there are no stated plans to adopt the 2018 IESBA Handbook (in effect as of June 2019).

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 Togo. Article 6 of that directive indicates that the government’s general accounting should be based on IPSAS. Ordre National des Experts Comptables et des Comptables Agréés du Togo (ONECCA-Togo) reports that the regulation has undergone revisions to integrate a significant number of IPSAS. It was reported that the revised standards were finalized in November 2018 by the West African Accounting Council and would be subject to the review of the WAEMU in 2020. It is unclear if the review proceeded as planned in 2020.

At the national level, the Ministry of Finance is responsible for the adoption of public sector accounting standards and implementation of the WAEMU regulation. As of the date of this assessment, IPSAS have not been adopted in Togo; however, the authorities have undertaken reforms around public financial management to work towards the adoption of accrual accounting in the public sector with the support of different institutions, including the World Bank and the International Monetary Fund.

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 No. 2001-001 grants authority to Ordre National des Experts Comptables et des Comptables Agréés du Togo (ONECCA-Togo) to establish I&D procedures for its members.

While ONECCA-Togo is responsible for professional breaches and infractions, the Judiciary handles civil and criminal acts. ONECCA-Togo’s Council is responsible for making disciplinary decisions. As of the date of this assessment, ONECCA-Togo self-assessed its I&D system against the SMO 6 requirements and noted several areas that require improvements, such as the separation of investigative and disciplinary procedures, the implementation of its planned appeals mechanism (the National Discipline Commission), as well as public interest communications and considerations.

In cases of civil and criminal decisions, individuals may appeal a decision of the Commission to the Administrative Chamber of the Supreme Court.

Current Status: Partially Adopted

The corporate financial framework of Togo 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). Togo, 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 to serve as a single accounting reference in all OHADA member states. The OHADA AUDCIF will come into effect on January 1, 2018, for individual accounts and on January 1, 2019, for consolidated accounts, combined accounts, and financial statements prepared in accordance with IFRS. 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.

Current Status: Partially Adopted

Relevant Organizations

African and Malagasy Council for Higher Education (CAMES)

Central Bank of West African States

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

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

West African Economic and Monetary Union (WAEMU)

Relevant Legislation

OHADA Uniform Act on Accounting and Financial Information (AUDCIF)

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

Relevant Publications

ONECCA-Togo, SMO Action Plan, September 2021.

World Bank, Report on the Observance of Standards and Codes (ROSC) – Accounting and Auditing (A&A): Togo, 2010.

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