BOA Resolution passed requiring CPA FS preparers to submit certificate

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.

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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.

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? 🙂

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

40 Responses to "BOA Resolution passed requiring CPA FS preparers to submit certificate"

  1. 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?

    Reply
  2. 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.

    Reply
    1. 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.

      Reply
  3. 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.

    Reply
      1. 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.

  4. 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

    Reply
    1. 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.

      Reply
    2. 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.

      Reply
  5. Cuarteros Mark Anthony · Edit

    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

    Reply
    1. 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.

      Reply
  6. Sir, I am a CPA employed in one corporation. I am responsible in preparing its financial statements. The CEO/owner has also a separate business entity, which is a single proprietorship, where I also prepare its financial statements. Question: When I submit my requirements for BOA Accreditation for CPAs in Commerce and Industry, shall I include those two business entities in my application form?

    Reply
  7. Sir, Ask ko lang, what if for FS 2017, the company's FS shall be handle by me, A CPA but not Accredited by commerce and industry. When should I apply for accreditation?

    Just to explain why I ask this, For 2015 and 2016, it will be my senior, however, 2017 FS preparation shall be transfer to me, as the previous preparer shall be promoted and I will took his place., So I wont take accreditation this year.

    Reply
  8. So, FS preparers with BOA Certificates can be just another contracting partner, the same just like a contracting external audit for BIR FS submission especially if there is a regular Accounting Head/Department Manager who really does the consolidation of financial statements for attest audit of an external/independent auditing body? Please clarify? Thanks.

    Reply
  9. Philippine Accounting Updates

    This clarifies it. Thanks alot for your help!

    2) If you are accredited in Public Practie and have non-audit clients for compilation and IS AN EMPLOYEE AS WELL in another compay, no need to obtain accreditation as far as your non-audit CLIENTS are concern, but needs to obtain accreditation as far as your EMPLOYER is concern.

    Reply
  10. Hazel Jayag If they are employed by the contracting firms, they their employer is the one that needs to be accredited, considering the fact that they are only 'reporting' to a partner in that firm. There is a separate accreditation required for firms submitted for comment by BOA, but as far as your question is concern, the Partner is the one signing and NOT the staff employees, even if it's for compilation.

    The another version you are saying is already clear:
    1) If you are accredited in Public Practie and have non-audit clients for compilation, no need to obtain accreditation
    2) If you are accredited in Public Practie and have non-audit clients for compilation and IS AN EMPLOYEE AS WELL in another compay, no need to obtain accreditation as far as your non-audit CLIENTS are concern, but needs to obtain accreditation as far as your EMPLOYER is concern.

    Reply
  11. Philippine Accounting Updates i get the difference, the question was just simplified and phrased wrongly. What i meant applies to fresh CPA board passers/ or old CPA passers but was in different but related track for many years but substantially starting on Public Practice only later, assisting and employed in contracted firms with already accredited CPAs but do not have the accreditation for Public Practice YET, given the reqts, and yrs of experience, meaning they are not accredited for Public Practice yet, and are not legible for COmmerce & industry either correct? And there are also another version of if there's a need to have a separte accreditation even if you are already accredited in public practice but FS preparer of non-audit clients. Will await Q&A to be released by BOA. Thank you so much for your response.

    Reply
  12. Hazel Jayag, First, they are NOT ALLOWED to render compilation services without being accredited in Public Practice. Public Practice is not limited to auditing (or what you call signing FS), rather it extends to other audit, assurance and non-assurance services to "clients". Thus, if they are rendering such service to their "clients", it's already a violation of the accountancy law. If you (and them) interprets accreditation for Public Practice to be limited to Audit (or anything related to signing FS), you are very wrong and you need to rectify your belief. Read the accountancy act and it's implementing rules for you to enlighten that, when you are handling clients, regardless if assurance or non-assurance, it is already considered Public Practice.

    Second, accreditation for CPAs in Commerce and Industry are for those CPAs that acts as employee of the company, rather than those contracted (which falls under Public Practice).

    Reply
  13. Philippine Accounting Updates yes, but im referring to cpas who are not in public practice and do not have accreditation for public pratice ie not auditing or signing certifications but merely rendering compilation services, are they classified as public practicioner or CPAs in commerce and industry? Difference lies in requirements of obtaining accreditation, esp 3yrd public pratice experience which most of those in compilation services do not have yet.

    Reply
  14. The reso annex C is only for CPAs in "commerce and industry," but for preparers that are contracted CPAs, ie multiple clients but not the external auditor, what requirements are required to be submitted? What is indicated in the reso, or the reqt for CPAs in Public Practice?

    Reply

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