BOA Resolution passed requiring CPA FS preparers to submit certificate

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Two (2) months ago, we wrote an article on Rules on Financial Statement Preparation now for Comments which was still for comments. Now, the Board of Accountancy has finally passed Board Resolution No. 3, Series of 2016, Requiring the Submission of Certificate by the Responsible CPAs on the Compilation Services for the Preparation of Financial Statements and Notes Thereto.

This is a game changer as we all know that there are so many companies employing accountants to prepare their financial statements who are not Certified Public Accountants (CPAs), and moreover, not accredited with the BOA.

The resolution provides, among others:

  1. Requirement of the attachment to the annual financial statement (FS) of a Certificate on the compilation services for the preparation of FS and notes to the FS.
  2. The Certificate shall be prepared only for issuers which/who have gross sales or revenues exceeding ten million pesos (P10,000,000) for a particular accounting year.
  3. The preparation of the FS and disclosure notes is a practice of accountancy in commerce and industry and shall be done only by Certified Public Accountants (“CPAs”).
  4. The reiteration of the rule that CPAs in public practice are prohibited from preparing or assisting in the preparation of FS and disclosure note of their clients which engaged them to render attest services for the same documents.
  5. The CPAs in public practice  who violate this prohibition rule shall be subject to stern sanctions by the Board of Accountancy.
  6. The CPAs rendering the compilation services for the preparation of the FS and signing the Certificate shall first be accredited with the Professional Regulatory Board of Accountancy after submitting the necessary application and complying with the Continuing Professional Development (CPD) requirements.
  7. These CPAs should apply for accreditation not later than February 29, 2016 and comply with the CPD requirements not later than June  30, 2016 after signing an affidavit of undertaking to that effect.
  8. The rules shall apply for the FS pertaining to year 2015.

This Resolution shall take effect after fifteen (15) days following its publication in the Official Gazette or in any major daily newspaper of general circulation in the Philippines.

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The question is – If the Practitioner or Employee is already accredited with BOA for Public Practice, is there a need to secure separate accreditation for Commerce and Industry in order to perform the compilation? BOA said:

  • “NO”, if you are a practitioner compiling for your clients
  • “YES” if you are an employee compiling for your employer, even if you are accredited in Public Practice

As it currently stands, BOA is giving all companies with revenue reaching P10 million to have the CPA preparers of their FS to accredit only until February 29, 2015 (update: until December 31, 2016). A very short period which will, again, expected to cause uproar especially from the Small and Medium Companies and Small and Medium Practices.

We’ll keep you posted for further developments with the game-changing resolution. What can you say? 🙂

Download the BOA Board Resolution No. 3, Series of 2016, here.


Disclaimer: Opinions expressed in this article are that of the author and information provided are for general conceptual guidance for public information and are not substitute for expert advice. Contact support@philcpa.org for more information and if you want to avail professional services. Find us on Facebook!



Orlando Calundan is a CPA who has exposures in FS audit of entities in various industries such as real estate, food/restaurants, manufacturing, service organizations and BPOs, automotive, holding/investment companies and more. He also has exposure on internal audit engagements.

  • Cuarteros Mark Anthony

    Greetings

    what if i am an employee of a company(entity 1) who rendered service to another company entity (2). we are now planing to render as a compiler of that entity 2. can i use my accreditation of BOA and BIR.. do i have to secure another accreditation for our company. (entity 1). ..

    I’m a CPA. working in a federation of COOP

    • Is your employer (entity 1) a CPA firm? If yes, then partners of that firm can sign the CPA certificate as compiler. Otherwise, since you are BOA and BIR accredited, you may contract with entity 2 directly as CPA in public practice and should sign in your personal capacity.

  • Sweny

    Sir question. I am currently employed in an auditing firm for more than a year now. And we have a family friend who will be needing a CPA to make their FS. It is just a small business and non-vatable and gross sales would not reach more than 1.9M during the whole year. Can I make and sign their FS for them even without the certification?

    Thanks

    • The requirement for certificate is P10 million and up.

      But to tell you honestly, if you are to follow the rules, even if the sales is not more than P10 million, the CPA who should prepare the FS should be “accredited” with the BOA. Now, management has to weigh the cost and benefit of undergoing that process.

    • Pero bakit mo i-sasign? of course you cannot express an opinion to that FS if you are not an accredited CPA in public practice. Yung SMR, tax returns naman, management should be the one signing that.

  • zel

    Sir, if for compiler lang, is bir accred a prereq also?

  • Flor

    Sir, good day! If I have to sign as compiler of other companies (not my employer), do I need to be accredited with BIR as it is already a public practice? I have a BOA accreditation in Public Practice. Thank you.

    • Hi Flor, as far as the current requirements are concerned, it’s not required. Such compilation report is not required by the BIR as stated in the recently issued RMC No. 16-2017. Thanks!

      • Flor

        Hi Sir, further clarification pls. Does RMC 16-2017 nullifies RMC 21-2016/RMC36-2016?
        If so what Government agency requires this Compilation Report? Is it SEC? What will be the use now of our BOA accreditation as compiler? Thanks again.

  • Flor

    Hi Sir, further clarification please. Does RMC 16-2017 nullifies RMC 21-2016/RMC36-2016? If so, what Government agency requires submission of Compilation Report aside from BIR? Is it SEC? If SEC won’t require either, what will be the use now of our BOA accreditation as Compiler? Thanks again.

    • Hi Flor, from the very beginning, it is the BOA that requires the compilation report. It does not nullify the RMC you cited but just amended to indicate the updated effective date and to clarify that it’s not required attachment of the ITR. The BOA, in response to RMC 16-2017, however, clarified that it is an attachment to the AFS, not to the ITR, and will continue to be required in compliance with the BOA requirements. SEC clarified from the beginning that they will not require it as well. But since BOA also has authority, BOA alone can require it.

  • Flor

    For reason that an ITR will not be accepted without an AFS therefore Compilation Report is still required in the filing of ITR for DEC. 2016. Am I right, Sir?

    • Makes sense. But probably even if you can’t find the link since it is required by BOA and BOA is in authority we need to comply. 🙂

      • Flor

        Thank you Sir!

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