EP 100 Implementation Guidances (IGs)

ISCA sets standards and guidance relating to professional ethics which are issued as Ethics Pronouncements (EPs). EPs set out high quality ethical standards, including the fundamental principles of ethics, for professional accountants. These are integral for professional accountants to act in the public interest. The process in setting and revising EPs is robust, which promotes public confidence. 

From time to time, ISCA may also issue Implementation Guidances to support the accountancy profession in implementing the requirements in EP 100.

Notes: 

1.    EP 100 IG 1 

The pro-forma paragraphs in EP 100 IG 1 are issued with the objective of providing guidance to public accountants who have provided non-assurance services to audit or assurance clients, to obtain acknowledgement of management responsibility from the client management. 

The pro-forma paragraphs in EP 100 IG 1 may be included in (1) the audit engagement letter or (2) the separate stand-alone engagement letter for NAS. 

2.    EP 100 IG 2 

EP 100 IG 2 is issued to provide clarification on the definition and identification and determination of KAPs. 

Matters discussed include “key decisions or judgment” and indicators to identify significant subsidiaries and divisions. In certain situations, an audit partner responsible for the audit of significant subsidiaries or divisions may not be determined to be an “other KAP” of the group audit engagement. Paragraph 1.2 of EP 100 IG 2 highlights the need for the engagement team to document its basis in arriving at this conclusion. 

The FAQs in EP 100 IG 2 are meant to provide broad guidance when assessing if a partner is a KAP. They address certain illustrative scenarios and are not meant to be an exhaustive list.  

3.    EP 100 IG 3 

EP 100 IG 3 provides guidance to address the concerns that professional accountants may face when adopting the NOCLAR Pronouncement in EP 100, which is expected to be effective as of 1 April 2020. 

The concerns were brought to ISCA’s attention through its various outreach initiatives with the relevant stakeholders. ISCA Ethics Committee examined the concerns raised and deliberated on how best to address them in the IG 3. 

Below are the key areas addressed in the IG 3: 

• addressing conflicts between NOCLAR requirements and existing laws and regulations;
• what is considered “clearly inconsequential”;
• the concept of “public interest”;
• the professional clearance between predecessor and proposed successor auditors with respect to tipping-off;
• the legal protection available to whistle-blowers; and
• the disclosure of NOCLAR to an appropriate authority with respect to group audit. 

4.    EP 100 IG 4 

EP 100 IG 4 clarifies the scope of entities that falls within the definition of financial institutions (FIs) in EP 100 (Revised on 14 August 2020), and hence, are considered as public interest entities (PIEs). 

Professional firms auditing PIEs are subject to higher independence requirements, such as stricter rotation requirements and prohibition from providing certain non-assurance services.  

FIs are included within the definition of PIEs in EP 100 (Revised on 14 August 2020). ISCA Ethics Committee embarked on an initiative to perform an analysis on the FIs extracted from the MAS Financial institutions Directory to assess whether they fall within the definition of FIs in EP 100 (Revised on 14 August 2020).  

5.    EP 100 IG 4 (Revised) 

The Glossary of EP 100 (Revised on 7 July 2021) contains amendments to the definition of a financial institution (FI) to be aligned with the Revised ACRA Code issued on 26 February 2021 to spell out the respective legislation for each FI and to re-order the categories of FIs in alphabetical sequence. 

EP 100 IG 4 (Revised) contains an updated list of FIs in Table 1 which corresponds to the definition of a FI in EP 100 (Revised on 7 July 2021).