by John McCarthy Consulting Ltd. | Dec 10, 2025 | Blog, News
As we reported in April 2025, the AMLA (Anti-Money Laundering Authority) had its first meeting in March 2025. Since then, it has been adding more personnel, growing to a current December 2025 complement of 100 staff (about 20 behind the original plan), with 70 joining in the last three months. The AMLA is based in Frankfurt.
The chair of AMLA is Milanese lawyer, Bruna Szego. Since commencing her role on 1 July 2025, she has visited 25 Member States and met supervisors, Financial Intelligence Units (FIUs), and industry representatives.
On 2 December 2025 she appeared before an EU Parliament Committee (video recording here – start at 10 minutes in) and her key takeaway was that ‘while the financial sector understands its role, the non-financial sector lags behind. The landscape there is fragmented, with many obliged entities facing real challenges in applying even basic controls due to cost and lack of reliable information.’
The future timeline for AMLAs development, according to its own website, is as follows:
- 2026 – Gradual ramping up of IT business service and assessment of AMLA’s future IT needs
- 2027 – 40 obliged entities are selected to be directly supervised
- 2027 – at the end of 2027 AMLA staff reaches a cruising capacity of about 430
- 2028 – Start of direct supervision, with AMLA fully operational
For audit cold file reviews and tailored training sessions explaining more about various topics like AML, Audit, FRS 102, please send a mail to john@jmcc.ie.
For more on engagement and representation letter templates and a variety of CPD webinars on money laundering and other accounting/audit related topics, please go to our website for:
ISQM TOOLKIT, or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard. We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements. Please contact John McCarthy FCA by email at john@jmcc.ie.
by John McCarthy Consulting Ltd. | Dec 2, 2025 | Blog, News
Auto enrolment is one of the many legislative changes that occur from time to time that cause existing letters of engagement to become out of date or no longer relevant. In the coming weeks we will be publishing a new payroll letter of engagement for accountants that provide auto enrolment to client s as part of their payroll services.
In the meantime, why not get your letters of engagement and other templates up to date by visiting our website at www.jmcc.ie/store? We are adding new products/webinars all the time.
Easily downloadable in Word format, there are over 100 complete templates available at €60 plus VAT each. There is a 20% discount for orders of five or more (including webinars) when purchased in a single order.
Depending on your requirements, we can also tailor other types of template letter to order. If you need a specially tailored template, please send an e-mail to john@jmcc.ie and you will receive a quotation. Once agreed we will deliver your template within a specified time limit.
For more details see https://jmcc.ie/publications-store/
There is also a search bar near the bottom of our home page (www.jmcc.ie) to quickly look up the product or webinar you require.
For audit cold file reviews and tailored training sessions explaining more about various topics like AML, Audit, FRS 102, please send a mail to john@jmcc.ie.
For more on engagement and representation letter templates and a variety of CPD webinars on money laundering and other accounting/audit related topics, please go to our website for:
ISQM TOOLKIT, or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard. We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements. Please contact John McCarthy FCA by email at john@jmcc.ie.
by John McCarthy Consulting Ltd. | Nov 16, 2025 | Blog, News
The Chartered Accountants Ireland last month filed its response to the FRC consultation about the draft Practice Note on the Audit of Less Complex Entities.
The PN is basically the updated version of the much loved PN 26 Guidance on Smaller Entity Audit Documentation which was withdrawn in 2016. The latest version still has the same hotel/restaurant case study example (Bulls Restaurant and Hotel) but with updated references to the latest ISAs and the latest technology.
While the Institute supports the development of additional guidance in principle as small and medium-sized practices need to be able to apply the ISA proportionately to the scale of their audit clients. The Institute prefers that the FRC would focus on the IAASB standard called the International Standard on Auditing for Audits of Financial Statements of Less Complex Entities (ISA for LCE’), which is better customized for the needs or SME audit market.
Among other things, in its response, the Institute has called for:
- Better alignment/mapping to the underlying ISAs, which would aid ease of reference when navigating the ISAs;
- More guidance and examples on the calculation of performance materiality including how firms should document the rationale for calculations used and use of associated benchmarks to support calculation of performance materiality;
- Enhancements to the PN such as examples regarding:
- documentation of professional judgement;
- further guidance and examples regarding scope of the PN, and
- dealing with IT general controls (ITGCs) in an SME audit environment; and
- examples need to be more innovative and not merely focus on straightforward circumstances to ensure they are useful in practice.
The Institute also calls for better coordination between the ISAs and the PN because as paragraph 4 of the PN states, the PN does not contain commentary on all the requirements in the ISAs and reading it should not be seen as an alternative to reading the relevant ISAs in their entirety.
Ultimately this means that SME auditors, inspectors, and software providers would still have to follow over 1,000 pages of the full ISAs and have regard to another 64 pages of the PN.
The response also draws attention to the fact that only nine ISAs are referenced in detail in the PN which could result in inconsistent interpretations and confusion when practitioners are performing SME audits. It would be more helpful for regulators also if there were better cross-referencing as to where requirements are not relevant or where requirements are scalable for SME audits in the form of a mapping document. This would remove the need for practitioners to review the entire series of ISAs when performing SME audits
For audit cold file reviews and tailored training sessions explaining more about various topics like AML, Audit, FRS 102, please send a mail to john@jmcc.ie.
For more on engagement and representation letter templates and a variety of CPD webinars on money laundering and other accounting/audit related topics, please go to our website for:
ISQM TOOLKIT, or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard. We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements. Please contact John McCarthy FCA by email at john@jmcc.ie.
by John McCarthy Consulting Ltd. | Nov 16, 2025 | Blog, News
Section 392 Companies Act 2014, requires auditors to file a notice with the Registrar of Companies when they form the opinion that a company has failed to keep adequate accounting records. The form used to make such a filing is called a H4. The average number of H4 reports filed with the CRO in the last 6 years is 4 per year.
Unfortunately, the latest CRO Annual Report, that for 2024, does not publish the statistics for the numbers of H4s filed in prior years. All it gives is the numbers filed for 2024 itself, but in 2020 and prior years the CRO report names the companies for which H4s were filed, but it has since discontinued that practice.
The numbers of H4s filed in recent years is as follows:
| Year |
No. of H4 Reports |
Year |
No. of H4 Reports |
| 2024 |
5 |
2021 |
0 |
| 2023 |
3 |
2020 |
7 |
| 2022 |
4 |
2019 |
5 |
In recent memory the best known H4, has to be the first one that was filed in 2019 which was for the Cumann Peile na hEireann, (otherwise known as the Football Association of Ireland). It was filed in April 2019 and over five years later, the investigation by the Corporate Enforcement Agency (CEA) into the situation at the FAI is still ongoing at the time of writing.
Auditors who fail to file such a note face a Category 3 penalty which is either up to six months in prison or a fine of up to €5,000 or both.
For audit cold file reviews and tailored training sessions explaining more about various topics like AML, Audit, FRS 102, please send a mail to john@jmcc.ie.
For more on engagement and representation letter templates and a variety of CPD webinars on money laundering and other accounting/audit related topics, please go to our website for:
ISQM TOOLKIT, or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard. We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements. Please contact John McCarthy FCA by email at john@jmcc.ie.
by John McCarthy Consulting Ltd. | Nov 5, 2025 | Blog, News
A new bill aimed at protecting the title “accountant” in Ireland has recently been introduced in the Dáil. The bill, if passed, will ensure that the title ‘accountant’ is reserved for those who meet stringently recognised standards and oversight.
The Bill is called The ‘Companies (Protection of Title: Accountant) Bill 2025’ and seeks to make it illegal for any individual or company to call themselves an “accountant” unless they are properly qualified and recognised by the Irish Auditing and Accounting Supervisory Authority (IAASA).
The general public are mostly unaware that they could be engaging with an accountant who is unqualified and who is not obliged to carry professional indemnity insurance. Architects and physiotherapists had the same problem up to some years ago until they got their professional titles protected in law.
The bill was introduced to the Dáil by Malcolm Byrne, TD for North Wexford, and seconded by Galway East TD Albert Dolan. Byrne told a local Wexford radio station that that consumers deserve to know they are engaging with a qualified professional who is accountable to a recognised regulatory body.
For audit cold file reviews and tailored training sessions explaining more about various topics like AML, Audit, FRS 102, please send a mail to john@jmcc.ie.
For more on engagement and representation letter templates and a variety of CPD webinars on money laundering and other accounting/audit related topics, please go to our website for:
ISQM TOOLKIT, or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard. We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements. Please contact John McCarthy FCA by email at john@jmcc.ie.
