SMP Committee Response to the IESBA Exposure Draft on Professional Skepticism

The IFAC Small and Medium Practices (SMP) Committee submitted this comment letter to the International Ethics Standards Board for Accountants in response to its Exposure Draft, Proposed Application Material Relating to Professional Skepticism and Professional Judgment.

The SMP Committee has followed this particular project since its inception and provided comment letters for the IESBA and Professional Skepticism Working Group’s consideration. We appreciate the importance of professional skepticism and note the intention for the effective date for the changes in this ED to be the same as that for the restructured Code of Ethics for Professional Accountants. In general, if the Code is to be implemented effectively once the Structure project has been completed, we believe that the IESBA should refrain from making further changes for a sufficient period of time.

Therefore, the IESBA’s commitment that any new changes to the Code after the completion of the restructuring project will not take effect until after June 15, 2020, unless there is an urgent need to respond to new or unforeseen circumstances is welcomed. This anticipated pause will allow time for accountancy firms, national standard setters, IFAC member organizations and professional accountants to consider and implement the necessary changes.