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Audit policy update

December 2025

Highlights

  • Accountancy Europe publishes second paper on third party investors in accountancy and audit sector
  • CEAOB’s response on ICT requirements under DORA
  • EU co-legislators reach provisional agreement on Omnibus proposal
  • IAASB publishes sustainability assurance illustrative reports

Feature story

Accountancy Europe publishes second paper on third party investors in accountancy and audit sector

“Beyond private equity: third party ownership in the accountancy and audit sector” is our second publication that broadens the focus to external capital participation in the accountancy and audit professions. It follows our June 2025 publication on private equity (PE) investments.

This new publication analyses and highlights both risks and opportunities. It also examines the motivations driving third party ownership investors to enter the accountancy and audit market, and why parts of the profession are increasingly open to this evolution.

A key section explains the types of third party investors and provides a deeper look at PE structures. Typically, when a PE fund invests in an accountancy or audit firm, the business undergoes a legal restructuring into two entities: an audit firm and a non-audit firm. The non-audit firm usually provides professional services and resources to the audit firm under an Administrative Service Agreement (ASA).

Accountancy firms attract third party investors due to:

  • High client retention, stable and predictable cash flows
  • Market fragmentation and buy and build approach
  • Strong growth potential
  • Good reputation of the sector

From the firms’ perspective, engaging with external investors offers:

  • Access to capital for expansion
  • Brings operational expertise
  • Succession and ownership transition

Risk linked to third party investors:

  • Regulatory risk and early engagement
  • Quality risk
  • Ethical and independence concerns
  • Cultural misalignment
  • Engaging external advice and expertise
  • Market impact
  • Exit strategy risk

Opportunities linked to third party investors:

  • Investment in innovation and technology
  • Consolidation, efficiency and synergies
  • Talent retention
  • Enhanced brand visibility and market reach
  • Access to broader business networks

Read the publication

 

EU developments

CEAOB’s response on ICT requirements under DORA

The CEAOB has issued its response to the European Commission’s (EC) review of the Digital Operational Resilience Act (DORA) and its possible extension to statutory auditors and audit firms. While recognising that ICT and cyber-resilience are increasingly critical for the audit profession, the CEAOB cautions against automatically bringing all audit firms under DORA’s framework. Auditors have a different risk profile from financial institutions, and a blanket extension could impose disproportionate obligations, particularly on smaller firms.

Instead, the CEAOB highlights that enhancing ICT and cyber-security requirements may be more effectively achieved by revising the existing EU Audit Directive and Audit Regulation. A targeted, risk-based approach would reinforce digital resilience across the profession while avoiding unnecessary administrative burden. The CEAOB also calls for a careful impact and cost-benefit assessment before any regulatory expansion is considered.

Read more

 

EU co-legislators reach provisional agreement on Omnibus proposal

On 8 December, the European Parliament (EP) and the Council reached a political agreement on the Omnibus proposal amending sustainability reporting.

Below we share a summary of the key elements regarding the Corporate Sustainability Reporting Directive (CSRD) as per the provisional agreement:

  • It applies to undertakings with more than 1,000 employees and net turnover above €450 million; a further assessment of any scope extension is foreseen for 2031.
  • Member States may exempt undertakings which do not exceed 1000 employees and EUR 450 million net turnover (on a consolidated basis) for financial years between 1 January 2025 and 31 December 2026.
  • Covers non-EU companies generating €450 million EU net turnover for the last two consecutive years and operating through a subsidiary or branch generating more than €200 million net turnover in the preceding financial year.
  • Obligation to adopt a voluntary sustainability reporting standard for companies falling outside the CSRD.
  • Obligation to adopt a limited assurance standard by 1 July 2027.

The EP Legal Affairs (JURI) Committee approved the provisional agreement on 11 December. The EP plenary vote is scheduled on 16 December. The Council must also approve the agreement.

 

Commission seeks views on Skills Portability Initiative

The EC has launched a consultation on the Skills Portability Initiative (SPI), aimed at improving the transparency and digital portability of skills and qualifications across the EU.

The SPI’s work to modernise recognition procedures and introduce interoperable digital credentials may eventually facilitate smoother cross-border mobility for audit professionals and enhance the comparability of qualifications. Accountancy Europe will respond to this consultation.

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International developments

IAASB publishes sustainability assurance illustrative reports

The International Auditing and Assurance Standards Board (IAASB) recently released a set of illustrative assurance reports to support implementation of the ISSA 5000.

These reports demonstrate how practitioners can apply ISSA 5000 in real-world scenarios for example:

  • limited or reasonable assurance on full sustainability disclosures,
  • assurance on selected data, or
  • combined engagements under multiple frameworks.

They also include examples of modified conclusions (qualified, adverse or disclaimer), helping auditors navigate cases where sustainability information is incomplete or problematic.

Read more

Other news

This curated content was brought to you by Endrin Bitraj, Accountancy Europe Manager since 2025. You can send him tips by email.