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PN is basically the updated version of the much loved PN 26 Guidance on Smaller Entity Audit Documentation which was withdrawn in 2016.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.
by John McCarthy Consulting Ltd. | Nov 3, 2025 | Blog, News
The Financial Action Task Force (FATF) concluded its October Plenary meeting in Paris recently. Delegates attended the meeting from more than 200 jurisdictions around the world.
At the meeting, four jurisdictions were removed from the list of Jurisdictions Under Increased Monitoring. They are Burkina Faso, Mozambique, Nigeria and South Africa and they are no longer under increased monitoring. No new countries were added to the list.
There are twenty countries remaining on the list known as the Grey List. These jurisdictions are actively working with the FATF to address strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing
Three other countries which are known as High-Risk Jurisdictions are subject to a Call for Action at the 24 October meeting. They are the Democratic Republic of Korea (North Korea), Iran and Myanmar (formerly Burma). Some commentators call these countries the Red List.
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. | Oct 27, 2025 | Blog, News
The UK Government has last week decided to pursue an AML supervision model of having a Single Professional Services Supervisor (SPSS). The date from which the change will be implemented has not yet been announced.
It intends to appoint the Financial Conduct Authority (FCA) to carry out the new supervisory functions as part of its remit and will be tasked with working with the professional services sector, other regulators, and law enforcement agencies to improve the UK’s defences against money laundering.
How the FCA will carry out these functions is yet to be worked out. They currently regulate 17,000 entities and this new responsibility will add another 60,000 entities (according to estimates by the Financial Times – link may require a subscription) to their stable of supervised entities.
The supervised firms which will switch regulator to the FCA include Legal Service Providers (LSPs), Accountancy Service Providers (ASPs), and Trust and Company Service Providers (TCSPs). This means that all firms currently supervised for AML/CTF matters by a PBS, and all ASPs and TCSPs supervised by HMRC (including High Value Goods Dealers) will be supervised by the FCA.
This change will obviously impact accountancy firms in Northern Ireland, but will the Irish Government decide to do something similar in the Republic of Ireland? There are already (as in the UK at present) multiple AML regulators of professional service firms along with the Department of Justice and the Central Bank, among others. Watch this space for future developments.
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.
