ODCE - audit committees

Ms Maria Leavy Office of the Director of Corporate Enforcement 16 Parnell Square Dublin 1 30 May 2006 AUDIT COMMITTEES - CONSULTATION PAPER C/2006/1 Dear Minister ACCA would like to comment on Consultation Paper C/2006/1, ‘Draft ODCE Guidance on Audit Committees’. We are limiting our comments to the draft text. We have not addressed some of the other issues relating to audit committees such as the fact that certain sections of the Companies Acts have not been commenced, and therefore certain aspects of the work that the audit committee is required to undertake cannot be carried out. We are also not commenting on the legislation itself which we feel is overly prescriptive and inflexible and already out of line with international best practice. 1. Guidance or interpretation 1.1 Overall the format of the guidance seems quite straightforward. It sets out to interpret the provisions of S42 in plain language. However, the draft guidance limits itself in the main to ‘what to do’ rather than ‘how to do’. Some ‘how to’ guidance is included but where it is included it is incomplete and not particularly useful for the user. ACCA would be of the opinion that the ‘how to do’ portion of the guidance, which is missing, is more important and useful to a user. 1.2 Reference is made in the draft guidance to other documents including ‘Shaping the Irish Audit Committee Agenda’ prepared by KPMG. There are also a number of other guides to ...