Professions in the field of accounting

EUROPEAN

UNION

ROMANIAN GOVERNMENT MINISTRY OF LABOUR, FAMILY,

SOCIAL PROTECTION AND ELDERLY

AMPOSDRU

European Social Fund

POS DRU 2007-2013

Structural Instruments 2007 - 2013

1

Invest in people!

EUROPEAN SOCIAL FUND

Sectoral Operational Programme Human Resources Development 2007 – 2013

Priority axis 3 „INCREASING ADAPTABILITY OF WORKERS AND ENTERPRISES”

Key area of intervention 3.3 “Development of partnerships and encouraging initiatives for social partners and

civil society”

Project Title: “Network of Competent Authorities for Professional Qualifications in Romania (IMI PQ NET

Romania)”

Beneficiary: Ministry of National Education

Contract no. POSDRU/93/3.3/S/53132

GUIDELINE FOR THE CERTIFICATION OF

COMPETENCIES AND THE RECOGNITION OF

QUALIFICATIONS FOR THE PROFESSIONS IN THE

FIELD OF ACCOUNTING

Author: Irina Dumitriu, Phd.

July 2013

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CONTENTS

Introduction..............................................................................................3

1. Statement of regulations in Romania and other EU MS

of professions in the field of accounting............................................6

2. Procedures for the certification of competencies applied

by CA in the countries where the professions

are regulated....................33

3. Processes for the recognition of qualifications achieved in other

EU MS for practicing the professions in the field of

accounting.......................37

4. Exercising professions in accounting in the EU..............................53

5. Conclusions........................................................................................58

Bibliography...........................................................................................60

Abbreviations.........................................................................................66

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Useful Links..........................................................................................71

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INTRODUCTION

The guideline for the certification of competencies and the recognition of

qualifications for the professions in the field of accounting is one of the

results of the project “Network of Competent Authorities for Professional

Qualifications in Romania (IMI PQ NET Romania)” implemented by the

Ministry of National Education (MEN) in partnership the National

Qualifications Authority (ANC) and the Social Policies Institute (IPS),

co-funded from the European Social Fund through the Sectoral

Operational Programme Human Resources Development 2007 – 2013

(POSDRU).

The project IMI PQ NET Romania analyzed with the competent

authorities (CA) members of the project Work Group, the procedures for

the certification of the competencies and the processes for the

recognition of qualifications for each profession regulated partly on this

basis also, they developed standard schemes for the procedure for the

certification of the competencies and the processes for the recognition of

qualifications for each profession regulated. The final result of these

activities is the material entitled “Standard terms of reference for the

procedures of validation and certification of competencies and

processes of recognition of qualifications”, which can be accessed at

................................................ ....................................

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This material includes the basic terminology (the definitions of the terms

used in guidelines as well) and the standard schemes for the procedures

for the certification of the competencies and the processes for the

recognition of qualifications and this is why it was the basis of a number

of 30 guidelines for the certification and recognition of different

regulated professions, guidelines aiming at supporting the CA in

Romania in their efforts to standardize such procedures and processes, in

informing the, on the practices of the homologous CA in other EU

Member States (MS).

At the same time, each guideline separately addresses the people having

acquired the qualifications in that field of activity in Romania, wanting to

practice the profession in a EU MS, as presented in the guideline.

The analysis was performed from Romania and 8 other EU MS (Austria,

the Czech Republic, Denmark, Germany, Italy, Great Britain, the

Netherlands and Spain) but the guideline includes some general

information as well, resulting from the research of the database including

all the regulated professions in all the EU MS of the European Economic

Area (EEA) and the Swiss Confederation, develop by the European

Commission (EC), the DG Internal Market), at

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(http://ec.europa.eu/internal_market/qualifications/regprof/index.cfm?ne

wlang=en).

The authors of the guidelines researched the European laws and of the

respective states regarding the achievement of qualifications, the

Vocational Education and Training (VET), types of certification

documents (diplomas, certificates, certificates of competency,

professional titles) regulations in the certification of competencies and

the recognitions of qualifications, the professions regulated according to

the Directive 2005/36/EC on the recognition of professional

qualifications. In the case of several EU SMs analyzed (Denmark,

Germany, Italy, Great Britain, the Netherlands and Spain), there were

study visits attended by the representatives of the members of the IMI

PQ NET Ro Network, constituted within the project, as well as MEN and

ANC experts. The visits consisted of meetings with the representatives of

CA at the national level as well as CA managing different regulated

professions, occasions on which the authors of the guidelines were able

to collect more concrete information from a direct source.

In conclusion, the guide for the certification and recognition of

accounting professions aims at:

assisting the Body of Expert and Licensed Accountants of

Romania (Corpul Experţilor Contabili şi Contabililor Autorizaţi

din România - CECCAR) in their effort to standardize the

http://ec.europa.eu/internal_market/qualifications/regprof/index.cfm?newlang=en


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procedure for the certification/award of the professional titles of

expert an licensed accountant and the process of recognition of

such qualifications, in informing them on the practices of the

homologous CA in other EU SMs;

informing the people having been conferred the necessary

qualifications and professional titles in Romania, wanting to practice

in the field of accounting services in one of the EU SMs presented in

the guideline.

1. STATEMENT OF REGULATIONS IN ROMANIA

AND OTHER EU MS

OF PROFESSIONS IN THE FIELD OF ACCOUNTING

The present European regulatory framework in the field of the

recognition of professional qualifications acquired in the EU MSs mainly

consists of the Directive 2005/36/EC of the European Parliament and of

the Council of 7 September 2005 on the recognition of professional

qualifications, as well as a series of sectoral directives in case of some

professions which are not covered or are only covered in certain specific

situations by the Directive 2005/36/EC (such as, Directive 2006/43/EC

on statutory audits of annual accounts and consolidated accounts,

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Directive 2002/92/EC on insurance mediation or the Directives

1977/249/EEC and 1998/5/CE in case of lawyers).

The Directive 2005/36/EC institutes a system for the recognition of

professional qualifications in order to contribute to the flexibility of the

EU labor market, in order to continue the liberalization in the field of

services (Directive 2006/123/EC on services in the internal market), in

order to encourage the autonomous recognition of qualifications and

simplify the administrative procedures. This directive applies to all the

European citizens wanting to exercise a regulated profession, either as a

free-lancer or an employee, in a MS different than that where they were

conferred the professional qualifications and distinguishes between the

“freedom to provide services” and the “freedom of establishment” based

on some criteria, such as duration, frequency, periodicity and continuity

of service.

From the point of view of the manner of recognizing the professional

qualifications subject to it, the Directive 2005/36/EC regulates the

following recognition systems:

the system of automatic recognition based on professional

experience in certain industrial, commercial and craft

activities – activities listed in chapter II, for which the elements

taken into consideration in the recognition of the professional

experience are the duration and the form (as free-lancer or

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employee) and the previous training (element which may reduce

the duration of the necessary professional experience), proven by

a certificate recognized by the MS or considered valid by a

competent professional body and the exercise conditions are

mentioned in the lists for different groups of sectors of activity

included in Appendix IV of the Directive;

the system of automatic recognition of the qualifications for

the professions of doctor, nurse, dental practitioner,

veterinary surgeon, midwife, pharmacist and architect –

professions provided in chapter III, for which the automatic

recognition of qualification titles is made on the basis of

coordination of minimum training conditions, including the

minimum duration of studies, the qualification titles mentioned

in appendices V and VI of the Directive;

The general system for the recognition of professional

qualifications – system which applies to the professions which

are not regulated by specific rules of recognition and certain

situations where the holder of the professional qualification does

not comply with the conditions provided in other recognition

systems, system based on the principal of mutual recognition,

without affecting the application of certain compensation

measures in case there are significant differences between the

training acquired by that individual and the training necessary in

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the host MS (adaptation period of up to three years or an aptitude

test).

From the point of view of the level of the qualifications subject to the

general system for recognition, the Directive 2005/36/EC distinguishes

among 5 levels of professional qualification:

an attestation of competence issued by a CA in the home MS,

attesting either that the holder has acquired general knowledge

corresponding to general primary or secondary education or that

they have attended a training course not forming part of a

certificate or diploma, or a specific examination without prior

training, or full-time pursuit of the profession for three

consecutive years;

a certificate attesting to a successful completion of a secondary

course, technical or professional in character, supplemented by

professional training;

a diploma certifying successful completion of training at post-

secondary level of a duration of at least one year or training

which provides a comparable professional standard and which

prepares the trainee for a comparable level of responsibilities and

functions;

a diploma certifying successful completion of training at post-

secondary or university level of at least three and not more than

four years' duration;

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a diploma certifying that the holder has successfully completed a

post-secondary or university course of at least four years'

duration.

The regulated professions in the field of accounting are subject to the

general system for the recognition of professional qualifications, on

several levels of qualification, from the certificate attesting to a

successful completion of a secondary course to a diploma certifying

that the holder has successfully completed a university course of at

least four years' duration.

As in the case of the other European directives, all the EU SMs had to

comply with the Directive 2005/36/EC through its transposition in the

national legislation. Hence, the relevant information on the procedure

and the rules of the processes for the recognition valid in each MS is

included in the national legislation transposing the Directive 2005/36/EC

and it may be obtained at the National Contact Points for the

recognition of qualifications all the MSs had to create (as listed at

http://ec.europa.eu/internal_market/qualifications/contact/national_conta

ct_points_en.htm).

Other European directives relevant for the accounting activity are: the

Directive 2013/34/EC on the annual financial statements, consolidated

financial statements and related reports of certain types of undertakings

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(care amending Directive 2006/43/EC on statutory audits of annual

accounts and consolidated accounts and repealing Directive 78/660/EEC

on the annual accounts of certain types of companies and Directive

83/349/EEC on consolidated accounts), Directive 2004/109/EC on the

harmonisation of transparency requirements in relation to information

about issuers whose securities are admitted to trading on a regulated

market, the Directive on Services 2006/123/EC, Directive 2005/60/EC

on the prevention of the use of the financial system for the purpose of

money laundering and terrorist financing, Directive 2011/83/EU on

consumer rights and Directive 2000/31/EC on electronic commerce.

According to the National Classification of Economic Activities

(NACE), the financial audit activities are part of the same group of

economic activities as accounting and tax consultancy (group 692 –

Accounting, bookkeeping and auditing activities; tax consultancy), group

which along with group 691 – Legal activities, makes up Division 69 –

Legal and accounting activities. That is why, from the point of view of

the activities reserved to different regulated professions corresponding to

the services of the NAME group CAEN 692, in practice, there are

overlappings between the accounting professions, those of financial audit

and tax consultancy, different from one country to the other. There are

few countries such as Romania, where there are distinctly regulated

professions on the three sub-fields of activity. In some countries,

although there are distinctly regulated professions, there is one CA where

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all the holders of professional title sin accounting, financial audit and tax

consultancy are members, in other countries the professions names

include the term “accountant”, however they are regulated only for the

activity, exclusively reserved to, of statutory financial audit, whereas the

accounting activities are not reserved to these professions (e.g. the

Netherlands). Moreover, all the studies identified and used as

information source treat the professions of the NACE group 692

altogether, as accounting professions. Also, from the point of view of the

knowledge necessary for the practice of the professions pertaining to the

NACE group 692, all these professions have a common basis (that is

why FEE – Fédération des Experts-comptables Européens/Federation

of European Accountant treats in its paper “Structure and

Organisation of the Accountancy Profession” both the proper

accounting professions and the financial auditor and tax consultant

professions (in the countries where the latter is a distinct profession).

For the same reason, in the IMI system – the electronic platform of the

exchange of information between the CA of the EU SMs, EEA and

Switzerland for the mutual recognition of the professional qualifications,

there are several generic categories for the regulated professions in the

accounting field: Auditor/accountant, Accountant/tax advisor,

Accounting technician, Commissioned bookkeeper, Management

accountant, Payroll accountant, Public finance accountant. As it

results from the name of the two generic categories Auditor/accountant

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and Accountant/tax advisor, MSs mentioned in these categories not only

the accounting professions but also the regulated professions of financial

audit and the tax consultancy professions respectively. Hence, in order to

treat the guideline dedicated to CECCAR (since in the project, there were

distinct guidelines for the Chamber of Financial Auditors of Romania

[Camera Auditorilor Financiari din România] – CAFR and for the

Romanian Chamber of Tax Consultants [Camera Consultantilor Fiscali

din România] - CCF) only for the professions regulated from the point of

view of the activities in the sub-field of accounting, it was necessary in

the two generic categories to identify and eliminate the professions in

financial audit and tax consultancy.

In exchange, the regulated professions which have exclusively (other

qualifications/professions do not have the right to carry the same

activity) or partly (only two or more regulated qualifications/professions

have the right to perform that activity but for the people holding no

qualification in the case) reserved both accounting activities and

financial audit and tax consultancy activities, were included in analysis

presented in this guide.

Table 1.1. depicts the situation of the accounting professions regulated

from the point of view of the Directive 2005/36/EC on the recognition

of professional qualifications, the professions extracted from the IMI

system database, in all the above-listed generic categories.

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Table 1.1

Regulated accounting professions recorded in the IMI system

MS

Name of the profession

in the MS/generic

category of the

profession/Romanian

translation

CA name Qualification level

ROMANIA

Contabil autorizat/ Auditor/accounatnt

Corpul Experţilor Contabili şi

Contabililor Autorizaţi din România (CECCAR) (Body of Expert and

Licensed Accountants of Romania)

www.ceccar.ro

SEC-secondary

education certificate,

art.11 b

Expert contabil/

Accountant/tax advisor

PS4 – Post-secondary diploma (exactly 4

years), Art.11 e

AUSTRIA

Gewerblicher Buchhalter/ Accounting technician/

contabil comercial

Bundesministerium für Wirtschaft, Familie und Jugend/Ministerul

Economiei, Familiei şi Tineretului

(Federal Ministry of Economy, Family and Youth)

www.bmwa.gv.at

Kammer der Wirtschaftstreuhänder

(KWT)/ Camera Contabililor

Publici (Chamber of Public Accountants)

www.kwt.or.at

DSE-Post-secondary

education diploma,

incl.Appendix II (ex.92/51, Appendix

C,D), Art.11 c

Selbständige Buchhalter /

Accounting technician/ contabil independent

Buchhalter/

Public finance accountant/ contabil

certificat

Paritaetische Kommission Bilanzbuchhaltungsberufe/ Comisia

Paritară pentru contabilitatea de

gestiune (Parity Commission for Management Accountancy

Professions)

[email protected]

Bilanzbuchhalter / Management

accountant/ Contabil de

gestiune certificat

Personalverrechner / Payroll Accountant/

contabil de personal/ salarizare

BELGIUM

Comptable agréé/

Erkend boekhouder/

Accountant/tax advisor/

contabil agreat

Institut professionnel des

comptables et fiscalistes agréés/

Insitutul Profesional al Contabililor

şi Fiscaliştilor Agreaţi (Professional

Institute of Accountants and Tax

consultants) www.ipcf.be

PS3 - Post-secondary

education diploma (3-

4years) , Art. 11 d

Comptable-fiscaliste

agréé/ Erkend boekhouder-fiscalist/

http://www.ceccar.ro/

http://www.bmwa.gv.at/

http://www.kwt.or.at/

mailto:[email protected]

http://www.ipcf.be/

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MS


in the MS/generic

category of the

profession/Romanian

translation



contabil fiscalist agreat

PS3 - Post-secondary education diploma (3-

4years) , Art. 11 d

Expert-

comptable/accountant/


expert contabil

SPF Economie, P.M.E., Classes

moyennes et Energie, Direction

générale de la régulation et de l’organisation du marché, Service

audit, droit comptable,

coopératives/ Min. Economiei, IMM, Clasei Mijlocii şi Energiei –

Direcţia Generală Reglementarea şi

Organizarea Pieţei, serviciul de audit, drept contabil, cooperative

(FPS Economy

SMEs, Self-Employed and Energy, Maret Regulation)

Institut des experts-comptables et des conseils fiscaux/ Institutul

Experţilor Contabili şi

Consultanţilor Fiscali (Institute of Chartered Accountants and TAx

Consultants)

www.iec-iab.be

BULGARIA

Дипломиран експерт-

счетоводител (одитор)/

Auditor/accounatnt/ expert contabil diplomat

(auditor)

Institute of Certified Public

Accountants/ Institutul Contabililor

Publici Certificaţi



4years) , Art. 11 d

CZECH

REPUBLIC

Činnost účetních poradců, vedení

účetnictví, vedení

daňové evidence/ Auditor/accounatnt/

consultanţă în

contabilitate, servicii de

contabilitate,

contabilitate fiscală

Ministerstvo průmyslu a obchodu/

Ministerul Industriei şi Comerţului

(Ministry of Industry and Trade) www.mpo.cz

SEC-secondary education certificate,

art.11 b

CYPRUS Λογιστής/ Auditor/accounatnt/

Institute of Certified Public Accountants of Cyprus/ Institutul


http://www.iec-iab.be/

http://www.mpo.cz/

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MS


in the MS/generic

category of the

profession/Romanian

translation


contabil/auditor Contabililor Publici Certificaţi din

Cipru (Institute of Certified Public

Accountants of Cyprus) www.icpac.org.cy

4years) , Art. 11 d

FRANCE

Expert comptable/ Accountant/tax advisor/

expert contabil

Conseil supérieur de l’Ordre des

experts-comptables/ Consiliul Superior al Ordinului Experţilor

Contabili (Supreme Council of

Institute of Chartered Accountants)

PSM-Post-secondary

education diploma (at least 4 years), Art.11

e

GREECE

Ihdikos kostologissis sti viomichania/

Accounting technician/ contabilitatea costurilor

în industrie şi IMM

DSE-Post-secondary

education diploma, incl.Appendix II

(ex.92/51, Appendix

C,D), Art.11 c


4years) , Art. 11 d

Ihdikos

mihanografimenou logistiriou/

Accounting technician/

contabilitate pe calculator

Logistís (AEI-TEI)/

Accountant/tax advisor/ contabil

IRLANDA



tehnician contabil

Institute of Chartered Accountants

in Ireland/ Institutul Experţilor

Contabili în Irlanda www.icai.ie

DSE-Post-secondary education diploma,

incl.Appendix II

(ex.92/51, Appendix C,D), Art.11 c

Technician accountant/

Accountant/tax advisor/ contabil tehnician

Institute of Certified Public

Accountants in Ireland/Institutul Contabililor Publici Certificaţi în

Irlanda

www.cpaireland.ie

Certified accountant/ Accountant/tax advisor/

contabil certificat

Association of Chartered Certified Accountants/ Asociaţia Experţilor

Contabili Certificaţi

www.ireland.accaglobal.com PS3 - Post-secondary education diploma (3-

4years) , Art. 11 d Incorporated Public

Accountant/

Accountant/tax advisor/ contabil public

incorporat/înregistrat

Institute of Incorporated Public

Accountants/ Institutul Contabililor

Publici Incorporaţi (Inregistraţi) www.iipa.ie

http://www.icpac.org.cy/

http://www.icai.ie/

http://www.cpaireland.ie/

http://www.ireland.accaglobal.com/

http://www.iipa.ie/

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MS


in the MS/generic

category of the

profession/Romanian

translation


ICELAND

Löggiltur

endurskoðandi/

Accountant/tax advisor/ expert contabil

Ministry of Finance/ Ministerul

Finanţelor



4years) , Art. 11 d

ITALY

Commercialista ed

esperto contabile/ Auditor/accounatnt/

contabil public şi expert

contabil

Ministero della Giustizia, Direzione

Generale della Giustizia civile, Libere Professioni/ Ministerul

Justiţiei, DG Justiţie civilă, Profesii

liberale (Ministry of Justice, General Department of Civil

Justice, Liberal Professions)

www.giustizia.it

Ordine dei Dottori Commercialisti e degli Esperti Contabili/ Ordinul

Contabililor Publici Diplomaţi şi al

Experţilor Contabili (Association of certified accountants)


education diploma

(exactly 4 years), Art.11 e

Ragioniere, perito commerciale/

Accountant/tax advisor/ contabil (înaintea

adoptării titlului de

expert contabil) PS3 - Post-secondary education diploma (3-

4years) , Art. 11 d Dottore commercialista/ Accountant/tax advisor/

contabil public diplomat

LIECHTEN-

STEIN

Buchhalter/

Accounting technician/ contabil

Amt für Volkswirtschaft (Office of

National Economy) www.llv.li/amstsstellen/llv-avw-

home.htm DSE-Post-secondary

education diploma,


C,D), Art.11 c

Wirtschaftsprüfer/

Accountant/tax advisor/ contabil public

FMA Finanzmarktaufsicht

/Autoritatea pentru Pieţe Financiare (Financial Market Authority

Liechtenstein)

www.fma-li.li

LUXEMBOURG

Expert comptable/


expert contabil

Ministère des Classes moyennes/

Min. Claselor Mijlocii (Ministry of

the Middle Classes) www.mdt.public.lu


4 years) , Art. 11 d

MALTA

Accountant/

Auditor/accounatnt/

Contabil

Accountancy Board/Consiliul

Contabilităţii




GREAT

BRITAIN

Chartered Public finance

accountant/

Public finance

Chartered Institute of Public

Finance & Accountancy/ Institutul

Certificat pentru Finanţe Publice şi




http://www.giustizia.it/

http://www.llv.li/amstsstellen/llv-avw-home.htm

http://www.llv.li/amstsstellen/llv-avw-home.htm

http://www.fma-li.li/

http://www.mdt.public.lu/

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MS


in the MS/generic

category of the

profession/Romanian

translation


accountant/ Contabil în

finanţe publice certificat

Contabilitate

www.cipfa.org.uk

Chartered management accountant/

Management

accountant/ Contabil de gestiune certificat

Chartered Institute of Management Accountants (CIMA)/ Institutul

Certificat al Contabililor de

Gestiune

www.cimaglobal.com

Chartered Certified

Accountant/ Auditor/accounatnt/

contabil expert certificat

Association of Chartered Certified

Accountants (ACCA)/Asociaţia Contabililor Experţi Certificaţi

www.accaglobal.com

Chartered accountant/

Auditor/accounatnt/

expert contabil

Institute of Chartered Accountants

in England and Wales (ICAEW)/

Institutul Experţilor Contabili în

Anglia şi Wales Institute of Chartered Accountants

of Scotland (ICAS)/ Institutul

Experţilor Contabili în Scoţia www.icas.org.uk

NORWAY

Autorisert

regnskapsfører/ Accountant/tax advisor/

contabil extern autorizat

Kredittilsynet/ Autoritatea de

Supraveghere Financiară a Norvegiei (The Financial

Supervisory Authority of Norway)

www.kredittilsynet.no



POLAND

Usługowe Prowadzenie Ksiąg Rachunkowych

(Aneks - A - Kodeks

dobrej praktyki)/ Commissioned

bookkeeper/

servicii de contabilitate (Anexa A – Codul de

bună practică)

(Appendix A - Code of good practice)

Minister Finansów/ Ministerul Finanţelor (Ministry of Fiannce)

www.mf.gov.pl

PSM-Post-secondary

education diploma (at least 4 years ), Art.11

e

PORTUGAL

Técnico oficial de

contas/ Accountant/tax advisor/ contabil oficial

(autorizat)

Ordem dos Técnicos Oficiais de

Contas/ Ordinul Contabililor Oficiali (Autorizaţi) (Order of

Chartered Accountants)

www.ctoc.pt



http://www.cipfa.org.uk/

http://www.cimaglobal.com/

http://www.accaglobal.com/

http://www.icas.org.uk/

http://www.kredittilsynet.no/

http://www.mf.gov.pl/

http://www.ctoc.pt/

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MS


in the MS/generic

category of the

profession/Romanian

translation


HUNGARY

Mérlegképes könyvelő/

Auditor/accounatnt/ contabil certificat

Ministry for National Economy/

Ministerul Economiei Naţionale

DSE-Post-secondary

education diploma,


C,D), Art.11 c

Source: processing of the author with information from the IMI system -

http://ec.europa.eu/internal_market/qualifications/regprof/index.cfm?action=pro

fession&id_profession=2100 (on April 30, 2013)

In those presented above, one notes the fact that in many countries, the

professions in the field of accounting services are regulated (19 countries

registered 36 professions in the IMI system), in some of them, there

being several regulated professions, on the one hand, on different

qualification levels, on the other hand, on different specialties on the

same basic qualification level. There are also MSs where of all the

accounting professions generally (the entire NACE group 692), only the

financial auditor’s activity is regulated, by the transposing of Directive

2006/43/EC on statutory audits of annual accounts and consolidated

accounts (e.g. Spain).

From the point of view of the basic qualification, there are different

requirements for the same title. For example, for the accountant in

France it is necessary to have a basic qualification in the state education

http://ec.europa.eu/internal_market/qualifications/regprof/index.cfm?action=profession&id_profession=2100

http://ec.europa.eu/internal_market/qualifications/regprof/index.cfm?action=profession&id_profession=2100

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system (diploma in accounting and management – DCG, conferred after

the baccalaureat - 3 years; higher diploma in accounting and

management – DSCG, conferred after DCG – 2 years; chartered

accountant diploma – DEC, conferred after DSCG), the higher diploma

in accounting and management DSCG granting the right to the condition

of intern chartered accountant and the registration with the Institute of

Chartered Accountants.

In Italy, in order to become an accountant it is necessary to have a

bachelor degree in economic and business management or bachelor or

economic sciences (general economics).

The manner of regulation as well is different from one country to the

other, covering practically all the regulation mechanisms identified by

the EC, DG Internal Market and Services1:

through the reservation of activities – exclusive or joint – to

professionals holding specific professional qualifications;

1 DG Internal Market and Services - Final Report – Study to provide an

Inventory of Reserves of Activities linked to professional qualifications

requirements in 13 Member States & assessing their economic impact, January

2012, p.4

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through professional tiles protected by the law, the holders of

such titled having no specific activities reserved;

through self-regulation by the professional associations requiring

from the members certain professional standards and a code of

ethics and professional conduct (in observance of the national

laws and the EU laws, especially competition regulations);

regulation of the activities/services through licences and

authorizations (in the sense that the undertakers must have a

minimum number of people holding the experience and

qualification appropriate to the services in order to be licensed

for the operation).

Corroborating the information on the regulation of the accounting

professions in several comparative studies made at the EU level2 and

2 Mainly: FEE - Key Features on Structure and Organisation of the Accountancy

Profession across 30 European countries, 26 March 2012, la

http://www.fee.be/images/publications/qualification/Intro_Structure_and_Organ

isation_of_the_Profession2732012401312.pdf – sheets on the 9 EU MSs we

made a comparative analysis of; DG Internal Market and Services - Final Report

– Study to provide an Inventory of Reserves of Activities linked to professional

qualifications requirements in 13 Member States &assessing their economic

impact, January 2012 - appendix H of the final report at

http://ec.europa.eu/internal_market/qualifications/docs/news/20120214-

http://www.fee.be/images/publications/qualification/Intro_Structure_and_Organisation_of_the_Profession2732012401312.pdf


http://ec.europa.eu/internal_market/qualifications/docs/news/20120214-annex_en.pdf

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amending the, with information taken from the national documents (to be

updated), we will continue with the regulation of professions in the 9

MSs analyzed.

In Romania, the protected titles of expert accountant and licenced

accountant are regulated by the Government Ordinance (GO) no.

65/1994 on the organization of the accounting expertise and licensed

accountants activity, republished, as subsequentlu modified, and the CA

for the two professions is the Body of Expert and Licensed Accountants

of Romania – CECCAR. The two professional titles reflect the

regulation of the accounting activities on the two qualification levels,

deriving also the difference concerning the activities the expert

accountant may carry apart from those of the licenced accountants.

According to the GO no. 65/1994 republished, the expert accountant may

provide the following services to natural and legal persons:

keeps or supervises the bookkeeping and prepares or verifies and

approves the financial statements;

provides assistance for the accounting management and

bookkeeping;

performs economic and financial analyses and asset appraisals;

annex_en.pdf - sheets on the 7 MSs analyzed, Romania an Austria not being part

of the sample countries of analysis.


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undertakes accounting examinations required by judiciary bodies

or demanded by natural or legal entities, according to legal

requirements;

undertakes any other work of financial, accounting,

administrative or IT management nature as required;

fulfills the tasks provided for in the company censor’s mandate,

according to legal requirements;

provides technical expertise for the creation and restructuring of

trading companies;

provides accounting-related professional services to natural or

legal entities.

The licenced accountant may ensure the bookkeeping and develop the

works in order to prepare the financial statements.

Moreover, the Law no. 149/2013, published in the Official Journal no.

257 of May 9, 2013, completes the rules regulating the expert accounting

activities, appraisal of goods, financial audit, tax consultancy and

insolvency practitioner activities, clearly stipulating that the professional

of these fields may have a complementary activity only if qualified for it

and they are members of the organizations coordinating the respective

liberal professions. More exactly, the Law no. 149/2013 provides

punctually that “Expert accountants may perform the activities of

financial audit, tax consultancy and appraisal only after having

acquired, according to the law, the quality of financial auditor, tax

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consultant or authorized appraiser, as the case may be and having

registered as member of the organization coordinating such liberal

professions”3. It thus results on the one hand, that all the expert

accounting activities are exclusively reserved to the expert accountant

profession and, on the other hand, that the expert accountants do not have

other partly reserved activities or authorizations included in financial

audit, appraisal, legal reorganization and liquidation fields or tax

consultancy, since each of these activities is exclusively reserved to one

of the other liberal financial professions distinctly regulated in Romania.

The expert accountants and the authorized accountants must register

among the Members of CECCAR (among which are registered as well

the expert accounting companies and the accounting companies

authorized by CECCAR), the registration fee being approx. Euro 40 for

expert accountants and Euro 20 for authorized accountants.

3Law no. 149 of April 30, 2013, 149/2013 for approving of the Government

Ordinance no. 23/2012 for amending and supplementing the Government

Emergency Ordinance no. 90/2008 on statutory audit of annual financial

situations and the consolidated financial situations and the Government

Ordinance no. 65/1994 on the organization of accounting expertise activity and

of the certified accountants and for amending other rules, Official Journal no.

257 of May 9, 2013.

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As far as the public interest supervision of the activity of the accounting

professions – provisions in the Directive 2006/43/EC on statutory audits

of annual accounts and consolidated accounts – in Romania, according

to the GO no. 23/2013 for the modification and amendment of the GEO

no. 90/2008 (on the statutory audit of annual financial statements and

annual consolidated financial statements, as subsequently amended and

modified, GEO transposing the Directive 2006/43/EC) and of the GO

no. 65/1994, the Council for Public Supervision of the Statutory Audit

Activity (Consiliul pentru Supravegherea Publică a Activităţii de Audit

Statutar [CSPAAS]) has become Council for the Public Interest

Oversight of the Accountancy Profession (Consiliul pentru

Supravegherea în Interes Public a Profesiei Contabile [CSIPPC]),

with the view to widening the sphere of public oversight to the

CECCAR4 members as well.

4 However, it is still not clear to which extent CSIPPC already deals with the

public interest oversight of CECCAR members, since of CSIPPC website, apart

from the logo on the front page, the rest of the information is still on CSPAAS,

including in the presentation of the members of the Superior Council, there

appear the representatives of the National Securities Commission (Comisia

Naţionala de Valori Mobiliare), of the Insurance Supervisory Commission

(Comisia de Supraveghere în Asigurări) and of the Supervisory Commission of

the Private Pension System (Comisia de Supraveghere a Sistemului de Pensii

Private), supervisory bodies of the financial markets which in May 2013 merged

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In Austria, the accounting professions are regulated by

Bilanzbuchhaltungsgesetz - BibuG (Law on management accounting),

law which was substantially modified, the new form coming into force

on January 1, 2013. Thus, the 2 previously regulated professions -

Gewerblicher Buchhalter - GBH (Accounting technician) and

Selbständige Buchhalter - SBH (independent accounting technician)

were auppressed, and the holders of the commercial licences GBH and

SBH were transferred to one of the three new regulated professions:

Bilanzbuchhalter - Bibu (Management accountant), Buchhalter – BH

(Public finance accountant) and Personalverrechner – PV (Payroll

Accountant).

For these three professions a new CA was created, Paritaetische

Kommission Bilanzbuchhaltungsberufe - PK (Parity Commission for

Management Accountancy Professions) consisting of the representatives

of the two chambers involved in the management of these two

professions: Kammer der Wirtschaftstreuhänder - KWT (Chamber of

Public Accountants, CA for the regulated professions of financial

auditor - Wirtschaftsprüfer and tax consultant – Steuerberater) and

Wirtschaftskammer Österreich - WKO (Austrian Economic Chambers,

the representatives of all the companies and undertaking in Austria in

in one supervisory body of the three financial markets – the Financial

Supervisory Authority (Autoritatea de Supraveghere Financiară [ASF]).

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the social dialogue, chambers involved as well in the secondary and

tertiary vocational/professional education in Austria).

The manner of regulation of the three professions is the award of a

business licence/authorization (the basic qualification level being the

same) mentioning the services which may be rendered. The type of

licence depends on the number of years of experience and the different

examination the applicant must take. It is possible to go from one

licence to the other (superior) and the association of the holders of

different licences in the same company (including auditors and tax

consultants, members of KWT).

According to PK5, the new law was passed with the view to the

liberalization of the regulation framework of the liberal accounting

professions, the creation of a competitiveness situation and market

transparency and the provision of quality services, appropriate for the

different market segments, according to the requirements of the EU

Internal Single Market and the new regulation framework lead to the

increase of the number of licences from approx. 5000 (for GBH and

5 PK – Independent accountancy in Austria, at

http://www.bilanzbuchhaltung.or.at/Independant%20Accountancy%20in%20A

ustria.pdf

http://www.bilanzbuchhaltung.or.at/Independant%20Accountancy%20in%20Austria.pdf

http://www.bilanzbuchhaltung.or.at/Independant%20Accountancy%20in%20Austria.pdf

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SBH by January 1, 2013) to over 10.000 licences for the present three

professions.

Te new CA is responsible for the organization of exams, the award and

withdrawal of the commercial licence/authorization, the organization and

discipline aspects and the application of the international regulations.

In January 2013, PK made the transfer of the former holders of the GBH

and SBH authorizations (which were registered in the KWT register)

with WKO, in the IT economic, consultancy and accounting sector

(Unternehmensberater, Informationstechnologen und Buchhalter –

UBIT), the group of accounting professions.

In the Czech Republic, the professions in the field of accounting are not

regulated by the law there are only requirements related to the

professional experience, as provided by the Commercial Code (Trade

Licensing Act No. 455/1991), for the business authorization/provision

of services. Hence, the Czech authorities recorded in the IMI system the

generic category Činnost účetních poradců, vedení účetnictví, vedení

daňové evidence (accounting consultancy, accounting and tax

accounting).

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In Italy, the professional titles in the field of accounting, Dottore

commercialista (public chartered accountant) and Esperto contabile

(accountant), are regulated by the D.Lgs. 28 giugno 2005, n. 139.

Costituzione dell’Ordine dei dottori commercialisti e degli esperti

contabili (Law on the constitution of the Association of certified

accountants). Before the reform of 2005, there were separate regulations

for the professions of dottore commercialista and ragioniere, although

they had many common competencies. Since the Law 139/2005 was

passed, the regulations and the professional body become one and a new

professional title esperto contabile replaced the title of ragioniere.

From the point of view of the reserved activities, the title Dottore

commercialista includes all the activities the accountant may provide

and some reserved activities more. Hence, both professions may provide

services of accounting, judicial accounting expertise, tax consultancy,

management of the assets of the entities subject to special measures of

crime prevention, consultancy in the labour law, appraisal of assets,

non-statutory financial audit and the dottori commercialisti,

furthermore, may be insolvency practitioners, the may be part of the

councils of auditors of companies and may represent the customers

before the administrative authorities.

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The registration in the register of the professional body Consilio

Nazionale dei Dottori Commercialisti e degli Esperti Contabili –

CNDCEC (National Board of Chartered Accountants and Accounting

Consultants), Section A – Dottori commercialisti and Section B – Esperti

contabili, is compulsory and per territory branches of CNDCEC, the

registration fee being of approx. Euro 500.

Ministero della Giustizia, Direzione Generale della Giustizia civile,

Libere Professioni ( the Ministry of Justice, General Department of Civil

Justice, Liberal Professions) is the CA and the supervisory body for both

professions.

In the Netherlands, the professions of Accountant –

administratieconsulent (accounting consultant) and Registeraccountant

(chartered accountant) are regulated only as far as the exclusive

reservation of the financial audit activity, whereas the accounting

services may be provided by individual who are not registered with the

NBA Institute, the CA for the two professions. In other words, for the

permanent provisions of accounting activities exclusively, not also

financial audit, it is not required to recognize the accounting

qualifications in other MSs.

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In Denmark, Germany and Spain, the accounting professions are not

regulated.

In Great Britain, in most cases, the market access is not limited by the

reservation of certain regulated qualifications/professions but consumer

protection is provided through the existence of legally protected

professional titles, the holders of these titles being the members of the

professional associations/institutes granting the titles and regulating the

activity of their members. The statute of “chartered” (legally protected)

bodies shows that there is a distinct profession in that activity and the

body granting the title/titles has the capacity to establish and maintain

high technical and ethical standards among their members. The

“chartered” body statute also confirms that the organization and its

members are recognized as experts in that field of activity, which is of

public interest.

In the field of accounting, any person in Great Britain may be an

accountant and provide accounting services but there are 4 legally

protected (chartered) professional titles, their holders not having the

accounting activities reserved.

The titles and the associations/institutes granting them are the following:

Chartered Certified Accountant, title conferred by the

Association of Chartered Certified Accountants – ACCA;

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Chartered Management Accountant title conferred by the

Chartered Institute of Management Accountants – CIMA;

Chartered Public Finance Accountant title conferred by the

Chartered Institute of Public Finance and Accountancy –

CIPFA;

Chartered Accountant title conferred by the Institute of

Chartered Accountants in England and Wales – ICAEW and

the Institute of Chartered Accountants of Scotland – ICAS6.

Each institute separately is a regulation body for its members (and the

membership is voluntary), and their activity is supervised by the de

Professional Oversight Board – POB, a structure of the Financial

Reporting Council – FRC.

The registration fees and the fees for the issue of the practice certificate

(in the sense of the use of the professional protected title) are the

following7:

6 We used the two variants of translation of the titles and the CA in Great

Britain because in some specialty Romanian texts, the term “Chartered” is

taken as such and in others (e.g. CECCAR documents) the title “chartered

accountant” is assimilated to the professional title of expert accountant in

Romania.

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ACCA – the membership fee is £193 and the fee for the practice

certificate is £385;

CIMA – £234 for members and £85 for practicing members;

CIPFA – £285 the membership fee and £200 for the practice

scheme;

ICAEW - £300 membership fee and £268 for the practice

certificate;

ICAS - £396 the membership fee and £ 474 for the practice

certificate.

7 Information taken from FEE - Key Features on Structure and Organisation of

the Accountancy Profession across 30 European countries, 26 March 2012

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2. PROCEDURES FOR THE CERTIFICATION OF

COMPETENCIES APPLIED BY CA IN THE COUNTRIES

WHERE THE PROFESSIONS ARE REGULATED

As far as the Directive 2005/36/EC on the recognition of professional

qualifications, one may note in table 1.1 that the basic qualification level

varies in the case of the regulated accounting professions – some are

secondary level, others are post-secondary level, either higher

vocational/professional education or university level 3-4 years or at least

4 years.

In table 2.1 we presented comparatively the requirements for the award f

of the titles corresponding to the accounting professions and continuous

professional training/professional development only in Romania and

other EU MSs analyzed where the accounting professions are regulated,

i.e.: Austria and Italy.

We will also separately present, in the case of Great Britain, the

requirements of the 5 institutes granting the chartered titles.

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Table 2.1

Situation of qualifications necessary for the practice of regulated

accounting professions in the analyzed EU MSs

MS Austria Italy Romania

Compulsory

training

requirements

for the

title/practicing

authorization

All three professions

suppose the same

basic qualification

level through special

structured training in

the dual professional

and technical

system: total

education cycle of

18 years, of which

professional training

of at least 9 years (4

years secondary

technical studies and

5 years’ practice and

professional training

finished in a

professional exam)

+

Years of work

experience

(increased for PV-

BH-Bibu)

+

Differentiated exam

in PK

+

Commercial

licence/authorization

University degree in

economic studies

(bachelor degree for

esperto contabile,

master’s degree for

dottore

commercialista)

+

3 years’ practice

+

State examination

for the professional

title

University degree

in economic

studies (bachelor)

for expert

accountant /

secondary

education diploma

for licensed

accountants,

recognized by

MEN

+

Exam for

internship

+

3 years’ internship

+

Aptitude test for

the professional

title

FPC/ continuing

professional

development

Yes, the law

provides at least

30 hours of

FPC/year

Yes, organized by

the territory

representative office

of CNDCEC

Yes, according

to the National

Programme for

Continuing

Professional

Development

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(Programul

Naţional de

Dezvoltare

Profesională

Continuă

(PNDPC) of

CECCAR, at the

level of the 42

county

representative

offices, based on

the Professional

Standard no. 3,

transposing the

standard IES 7

of IFAC

Application of

the

professional

standards

CNDCEC sets and

applies the

professional

standards under the

supervision of the

Ministry of

Economy and

Finance and Consob

in case of public

interest audit

companies

Yes, CECCAR

develops and

applies

professional

standards based

on the IFAC

standards

Disciplinary

measures

Yes, the

responsibility of

PK

Yes, CNDCEC

oases disciplinary

measures under the

supervision of the

Ministry of

Economy and

Finance and Consob

in case of public

interest audit

companies

yes

Source of information: FEE – Key Features on Structure and Organisation of

the Accountancy Profession across 30 European countries, 26 March 2012;

DG Internal Market and Services – Final Report – Study to provide an

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Inventory of Reserves of Activities linked to professional qualifications

requirements in 13 Member States &assessing their economic impact, January

2012 – appendix H (for Italy, because Austria and Romania were not include

in the sample of analyzed countries), the national legislation in case of Austria

In the case of the 5 British, the Recognised Qualifying Bodies, the

requirements for access and achievement of the chartered qualification

are synthetically presented in the following table.

Table 2.2

Access requirements and qualification programs for the professional

chartered titles in Great Britain

ACCA CIMA CIPFA ICAEW ICAS

Conditions

for access

to

qualificaio

n

a)secondary education

diploma b)

university/p

ostgraduate diploma

c) calificare

de Certified

Accounting

Technician

(CAT)

a)Free access but students

must obtain Certificates in

Business

Accounting before attending

the

qualification

programme

b) AAT

qualification


diploma b)

university/postgra

duate diploma c) AAT

qualification


diploma b)

university/post

graduate diploma

c) ICAEW

certificate in

Finance,

accounting and

business (CFAB)

d) AAT

qualification


diploma b)

university/post

graduate diploma

c) AAT

qualification

Compulsor

y training

for

qualificatio

n

Study and 14 ACCA

qualification

exams + professional

ethics model

+3 years of relevant

practical

experience

5 exams for the Certificates in

Business

Accounting + study and 10

qualification

exams + 3 years of

relevant

practical

12 modules, 3 stages: 1. Prof.

certificates;

2.Prof. diploma;

3.Strategic

phase + employment for

relevant

practical

ACA qualification

programme:

15 modules training+

450 days of

practice+ initial

professional

development

Internship agreement

with an

employee authorized

by ICAS (3

years usually) +

study and şi

3 exam

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experience experience (usually 3

years)

+ structured training in

ethics

stages + course in

business

ethics

Source: FEE, Key Features on Structure and Organisation of the Accountancy

Profession across 30 European countries, 26 March 2012

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3. PROCESSES FOR THE RECOGNITION OF

QUALIFICATIONS ACHIEVED IN OTHER EU MS FOR

PRACTICING OF PROFESSIONS IN THE FIELD OF

ACCOUNTING

The statistics in the IMI system, made based on the data on the

movement of professionals on the two manners of provision (through

permanent establishment/exercise of their profession in a different EU

MS, EEA and Switzerland or temporary/occasional provision) and per

each generic category of professions separately, registered in the

database until now, they are not relevant as such in the case of

accounting professions, because, as we showed in chapter 1 of the

guideline, the EU MSs, EEA and Switzerland, they registered regulated

professions in accounting in different generic categories, of which only

some include proper accounting professions, whereas others reflect not

only the movement of accountants but also of the regulated professions

of financial auditor and tax consultant which were registered in those

generic categories. Hence, the statistics presented herein are based on the

processing of the data strictly in the recognition registered by the EU

MSs, EEA and Switzerland, on the professions regulated for the

accounting activity.

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The situation of the decisions for the recognition of qualification for the

permanent establishment/exercise, in the period 2008 – 2012, of the

accounting professions as [resented in table 3.1.

Table 3.1

Statistics of the decisions for the recognition of qualification achieved in

other EU MSs, EEA ad Switzerland for the accounting professions

(2008 – 2012)

Host country:

regulated

professions

Profession for

which the

recognition

decision was

passed

Home country of

the qualification

No. of

positive

decisions

No. of

negative

decisions

No. of

neutral

decisions

Total

decisions

Belgium:

21= 5 + 4 +

12

applications

of 7 MSs

din 7 SM

Comptable-

fiscaliste agree/

Erkend

boekhouder-

fiscalist

11=4+2+5

Bulgaria 1 0 1 2

Italy 0 1 1 2

Luxembourg 0 0 1 1

The Netherlands 1 0 1 2

Romania 2 1 1 4

Expert-

comptable/

accountant/

10=1+2+7

France 0 1 4 5

Luxembourg 0 0 1 1

Great Britain 0 0 1 1


Czech

Republic:

8 positive

decisions to

Činnost účetních

poradců, vedení

účetnictví, vedení

daňové evidence

France 1 0 0 1

Germany 3 0 0 3

Italy 3 0 0 3

Poland 1 0 0 1

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applications

from 4 MSs

8 0 0

Cyprus:

249 positive

decisions to

applications

from 1 MS

Λογιστής

249 0 0

Czech Republic 1 0 0 1


France:

47 = 31 + 8

+ 8

din 11 SM

Expert

comptable

47=31+8+8

Austria 1 0 0 1

Belgium 3 0 2 5

Germany 2 0 0 2

Ireland 2 0 0 2

Italy 2 2 1 5

Luxembourg 3 4 0 7

Malta 1 0 0 1


Poland 1 0 0 1

Portugal 1 0 0 1

Romania 4 1 1 6

Greece:

23 = 2 + 4 +17

din 2 SM şi

Elveţia

Logistís

(AEI-TEI)

23=2+4+17

Switzerland 1 0 1 2



Italy:

24 = 2 + 7

+ 15

din 7 SM

Commercialista ed

esperto contabile

24= 2+7+15

Bulgaria 1 0 0 1

Greece 0 0 1 1

Luxembourg 0 2 1 3


Poland 0 0 1 1

Romania 0 0 5 5

Spain 0 5 6 11

Poland: Usługowe Germany 3 1 6 10

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21 = 8 + 3 + 10

of 4 MS

Prowadzenie Ksiąg

Rachunkowy

21=8+3+10

Ireland 2 0 1 3

Poland 2 2 3 7

Slovakia 1 0 0 1

Portugal:

1 positive

decision from 1

MS

Técnico oficial de

contas

14=3+4+7

Poland 1 0 0 1

Romania:

7 positive

decisions to

applications

from 4 MSs

Expert contabil

7 0 0

Cyprus 1 0 0 1

Finland 1 0 0 1

Frane 2 0 0 2

Italy 3 0 0 3

Hungary:

1 neutral

decision from

mérlegképes

könyvelő :

0 0 1

positive

decisions to

applications

from 1 MS

0 0 1 1

10 host

countries

11 professions 20 countries 313 26 63 402

Source: data processed based on the IMI system on July 16, 2013, by the author,

the situation of the decisions of permanent provision, only for the accounting

professions in all the generic categories where they were registered - at

http://ec.europa.eu/internal_market/qualifications/regprof/index.cfm?action=pro

fession&id_profession=2100&tab=countries&quid=2&mode=asc&maxRows=*

#top

Note: in the case of Romania, the data in the IMI system were amended with

information provided by CECCAR

http://ec.europa.eu/internal_market/qualifications/regprof/index.cfm?action=profession&id_profession=2100&tab=countries&quid=2&mode=asc&maxRows=*#top



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In these statistics we may note the fact the Romania is among the 10

MSs of the EEA receiving applications for the recognition of

qualification achieved in Italy, France, Cyprus and Finland but it is not

in the top 5 of passed decisions. Cyrus is the first in this top with 62% of

the total decisions for the recognition passed in the period 2008 – 2012.

If we consider however that all these 249 decisions – all positive and

without any aptitude test – refer to individuals achieving the

qualification in Great Britain, it might be that Cypriot citizens obtained

one of the British qualifications even in Cyprus or studied in Great

Britain, reflecting not necessary the movement of professional but also

the quality of British qualifications and their recognition at the

international level.

As a home country of accounting qualifications, Romania is the second

(4% of the total applications for recognition), after Great Britain and just

as Germany, with 15 applicants for the recognition of their qualification:

4 applications in Belgium, for the practice of the tax accountant

profession (2 positive decisions, a rejection and a pending application),

6 applications in France for the practice of the expert accountant

profession (4 positive decisions, a rejection and a pending application)

and 5 applications in Italy for the practice of the expert accountant

profession (according to the registrations made by the CA in Italy in the

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IMI system, all applications were drawn in 2011 and they are pending in

2012).

Per total, the majority of qualifications achieved in other MSs were

recognized (78% of the decisions were positive) which reflects a high

degree of mutual trust between the MSs of the EEA, as far as the

professional training in accounting.

The chart, the statistics of the mobility for permanent establishment

provision of accounting professions is the following:

Chart 3.1 – Structure of the recognition of the accounting qualifications

per types of decisions, 2008 - 2012

78%

6%

16%

Dec iz ii poz itive

Dec iz ii negative

Dec iz ii neutre

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Chart 3.2 – Structure per host countries of the accounting qualifications

per types of decisions, 2008 – 2012

62%12%

6%

6%

5%5% 4%

C ipru

F ranta

Italia

G rec ia

B elgia

P olonia

R es tul de 4 tari

Chart 3.3 – Structure per home countries of applications for the

recognition of accounting qualifications, 2008 – 2012

74%

4%

4%

3%3%

3%9%

Marea B ritanie

G ermania

R omania

Italia

L uxemburg

S pania

R es tul de 14 tari

Source: all the three charts are made based on the data processed by the author

in - the EC database with the regulated provisions presented in table 3.1

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In the top of the most mobile professions in permanent provision

(establishment) throughout the reporting period, the generic categories

existing in the IMI system containing the accounting professions, they

occupied the following positions:

position 45 – auditor/accountant, with 460 decisions;

position 70 – accountant/tax advisor, with 198 decisions.

Out of the 448 generic categories in the top (for which there were

recognition application in the period 2008 - 2012), with the 402 passed

decisions, only the accounting provisions selected out of these generic

categories would be in position 51.

The process of the recognition of the qualification is required only in the

case of the permanent establishment/provision of services. As we

mentioned in chapter 1 of this guideline, the regulated accounting

professions are subject to the general system for the recognition of

professional qualifications provided in the Directive 2005/36/EC on the

recognition of professional qualifications. In this case, the recognition is

not automatic but it needs a comparison between the professional

training provided for in the two countries – the one where the applicant

achieved the qualification (the home country) and the ne where they

want to exercise permanently their profession (the host country), as well

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as the possibility, in case of “substantial differences” of applying

compensation measures (adaptation period of up to three years or an

aptitude test – article 23 of the Directive).

For the recognition in the general system, the application for recognition

is addressed to the CA in the host MS. This application must be

accompanied by a series of documents and certificates provided in

appendix VII to the Directive 2005/36/EC.

The documents that may be requested with the submission of the

application for recognition are:

proof of the nationality

proof of establishment in a different EU MS, EEA or

Switzerland

documents regarding the professional qualification, the

competencies and the practical experience: certificate of

competence or the proof of qualification issued by the CA in the

home MS;

other documents, if required to those having achieved the

qualification in the host MS – good reputation attestations,

solvency certificates, the proof that the applicant is medically

capable, financial statement, professional insurance.

The CA in the host MS may request only for the most important

documents, the copies and notarized translations, except for the

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standardized documents (e.g passport, identity card). Also, original

documents may not be requested, only copies. In case the applicant may

not provide all the information the CA in the host country must try to

obtain them from the CA in the home MS in the IMI system.

As a recognition procedure, the CA in the host CA must, within one

month, confirm the receipt of the file and draw attention to the missing

documents, if applicable. The deadline for the CA to grant the

recognition or to decide on the application of any compensation measure

is 4 months. Any rejection must be motivated. The rejection or the failure

to make a decision, within the above-mentioned term, may be objected

against in the national courts.

The aptitude test may be applied on the conditions that the CA in the

host MS, based on the documents received, determined which are the

differences between the two qualifications that must be covered by the

compensation measures. As the accounting activities require the

knowledge of the applicable national legislation, the aptitude test is a

compensation measure used in most of the cases of recognition of such

qualifications. In the opinion of the European Commission, the CA in the

host MS must organize at least two sessions of aptitude test per year. For

this process of recognition and the organization of the aptitude test, the

CA must levy a tax on condition it does not exceed the costs and it is not

discriminatory to their own nationals in similar situations.

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Once obtained the recognition of the qualification, the applicant may

practice the profession on the same conditions with the ones having

achieved the qualification in the host MS, the professional regulations in

the host MS being applicable, including the professional title in that

country.

In table 3.2 we present the characteristics of the process of the

recognition of the accounting qualifications in the 3 analyzed MSs which

have regulated professions, because in a country where the profession is

not regulated (Denmark, Germany, Spain), the access to the market is

free. A person wanting to provide accounting services in Great Britain

must not go through the process of the recognition of the qualification

unless they want to become a member of the 5 institutes to use the

professional title they confer.

Table 3.2

Requirements for the recognition of the qualification for the permanent

establishment/provision of accounting services in the analyzed MS which

have regulated accounting professions

MS Austria Italy Romania CA for the

recognition of the

qualifications

PK Ministry of Justice

CECCAR

Procedure for the

recognition of

qualifications

Aptitude test Aptitude test Aptitude test

CA for the aptitude

test

PK CNDCEC CECCAR

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Test form Oral Written and oral Oral (interview)

Main subjects Relevant Austrian

legislation

Commercial, tax,

profession laws, civil

right, insolvency, ethical aspects and

professional

deontology

Commercial,

accounting and tax

laws + case study of accounting issues, tax,

organization and

operation of companies

and the operation and

organization of

CECCAR

Test language German Italian N/A

Frequency of the

aptitude tests

Upon request Twice a year As per requests

Possibility of taking

the tests

- Yes Yes

Source of information: FEE – Key Features on Structure and Organisation of the

Accountancy Profession across 30 European countries, 26 March 2012 for Italy;

PK for Austria, CECCAR for Romania

In case of the temporary/occasional provision of accounting services,

there is no obligation of requesting the recognition of the qualification

but in some countries, the obligation to submit a statement in the host

country and to renew it annually if applicable. In the IMI system there

has been no registration of temporary provision in case of the accounting

professions, that is why there are no statistics of the mobility for

temporary provision.

In table 3.3. we present the provisions on the temporary provision of the

accounting services in the analyzed 3 MSs with regulated accounting

professions.

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Table 3.3

Requirements for the temporary provision of accounting services in the

analyzed EU MSs where the professions are regulated

MS Austria Italy Romania Pro-forma

statement

NO Yes – annual renewal Yes – annual renewal

Requested

data

No, only requests for

information to

the client

Personal data Qualification

Services to be provided Professional insurance

Personal data Services to be provided

Professional insurance

Requested

documents

NO Upon the first statement or modification: identity

document, establishment

in the home country, proof

that there is no

temporary/final

interdiction of practice or penalty

Proof of citizenship in the MS of the EEA, Switzerland;

Attestation of proficiency in

Romanian; proof of

professional qualification;

proof of stable domicile in a

MS of the EEA/Switzerland proof that there is no

temporary/final interdiction of practice,

proof of activity specific to the

accounting position of at least 2 years in the last 10 years, if

the profession is not regulated

in the residence country

CA for the

right of

temporary

provision

- Ministry of Justice

CECCAR

Verifications - Permits Yes, in cooperation with other

CA in other MSs

Compliance

with the

regulations in

the host MS

- Cooperation with

CNDCEC and territory branches

Yes


Accountancy Profession across 30 European countries, 26 March 2012

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A possibility, simpler than the legal way, to make claims against a

decision on the recognition of the qualification, considered not compliant

with the Directive 2005/36/EC on the recognition of professional

qualifications, is to address the SOLVIT syste,.

SOLVIT is an online network, operating since July 2002, where the EU

MSs cooperate to settle, in a pre-legal phase the problems created by the

incorrect application of or the failure to apply by the public authorities,

the community law regarding the Internal Market. There is SOLVIT

centre in each EU MS, as well as in Norway, Iceland and Liechtenstein.

The centres are part of the central administration and must provide

solutions to the problems raised by citizens or the companies within 10

weeks, and the use of the network is free.

The SOLVIT centre in Romania is with the Ministry of European Affairs

(it may be contacted at e-mail [email protected]).

The conditions for the operation of the SOLVIT mechanism are:

to deal with the non-application or the improper application of

the European law by the administration of a member state,

to deal with cross-border case,

there must not be any action for settlement.

The cross-border character does not suppose that the petitioner must be

in a different MS that the one of the issue. It is enough there to be a

mailto:solvit@

mailto:solvit@

mailto:[email protected]

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strange element to make applicable the provisions of the community law

(for example, a Romanian citizen wants to practice in Germany and they

have difficulties of employment). The operation of the SOLVIT system

is presented in the chart below.

Source: http://www.romania-actualitati.ro/conceptul_de_cetatenie_europeana-

50325 (on July 17, 2013)

http://www.romania-actualitati.ro/conceptul_de_cetatenie_europeana-50325

http://www.romania-actualitati.ro/conceptul_de_cetatenie_europeana-50325

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For example, if a Romanian citizen has a complaint against the internal

market regulations, they will approach SOLVIT ROMANIA

(organization dealing with the case depending on the nationality of the

petitioner). If a Romanian citizen obtained the qualification in Austria,

they want to be employed in Germany and there is a complaint in this

sense, they will approach the centre in Austria. The request will be

analyzed and if considered that this case is a breach of the community

law, they will contact the centre LEAD SOLVIT (the responsible

SOLVIT centre). If they agree to the proposal, they will move forward,

to the defendant authority. The client is assisted in a language they

understand but it is more important there to be a responsible SOLVIT

centre to be aware of the procedures to be followed and the authorities to

be contacted to solve the problem. In order to obtain a good result,

SOLVIT is based on the relation with the defendant authority. And this

because it is an informal network and it does not have the authority of a

judge.

The reasons for which not all claims may be settles:

certain issued depending on the legislation of a member state; if

there can be no rapid solution, the case is considered non-settled;

the defendant authority is not willing to collaborate, when the

petitioner is advised to address the courts able to make the CA

modify the conduct pertaining to the aspect in question.

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4. EXERCISING PROFESSIONS IN ACCOUNTING IN THE EU

The regulated accounting professions are generally part of the category

of liberal financial professions, which is why the accounting activity may

be exercised either as a freelancer or as a partner or employee of an

accounting services company (or accounting, financial audit, tax

consultancy services company, according to the NACE code 692, which

is registered and authorized to provide all these types of services).

Hence, all the national registers where all those exercising regulated

accounting professions are registered, include both natural entities and

legal entities – authorized accounting companies.

In spite of the differences in the regulation of the accounting services in

the EU MSs, a high level of harmonization/standardization was obtained

at the sectoral level, by the efforts of the international and European

professional organizations in the field of accounting and financial audit.

At the global scale, International Accounting Standards Board – IASB,

the independent body for the normalization of standards within the IFRS

Foundation, elaborates and publishes the international accounting

standards (IAS), the international financial reporting standards (IFRS)

and the corresponding undertakings (SICIFRIC).

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At the EU level, in order to harmonize the financial information

presented by the entities applying IFRS, in order to provide a high level

of transparency and comparability of the financial statements and, thus,

an efficient operation of the capital market of the Community and the

Internal Market, the accounting standards issued by IASB are subject to

an analysis, as well as the official vote in the especially constituted

committees at this level, the process finalizing in community regulations

for the passing of standards. All the European regulations for the passing

of standards published by IASB are issued based on the (CE) Regulation

no. 1606/2002, where the international accounting standards are defined

as the International Accounting Standards (IAS), the International

Financial Reporting Standards (IFRS) and the corresponding

undertakings (SICIFRIC), the subsequent amendments to the respective

standards and the corresponding undertakings, the future standards and

the appropriate undertakings issued or passed by IASB.

The International Federation of Accountants, incorporated in 1977 by

63 founding members in 51 countries, has now 173 members and

associated organizations in 129 countries and jurisdictions in the world,

representing 2.5 million of accounting professionals in the public sector,

education, in government structures and the private sector. In turn, the

Fédération des Experts-comptables Européens/Federation of

European Accountants - FEE represents over 700,000 professionals in

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Europe through the 45 member organizations in 33 European countries

and at the same time it plays the role of Regional Organization of IFAC.

IFAC provides the development of the public interest accounting

professions:

the development of the international public sector accounting

standards (IPSA), international standards on auditing (ISA),

international ethical standards (IES) and technical assistance for

passing and use;

facilitating the collaboration and cooperation of member professional

organizations;

collaboration and cooperation with other international organizations;

representing the interests of accounting and financial audit

professionals at the international level.

That it\s why, they passed, practically at the international level, the

Ethical Code of IFAC developed by The International Ethics

Standards Board for Accountants (IESBA), independent body for the

development of ethical standards and professional conduct of

accountants and auditors, the 8 International Education Standards

(IESs) developed (and presently under review) by International

Accounting Education Standards Board (IAESB):

IES1 - entry requirements to professional accounting education,

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IES2 - initial professional development-technical competence,

IES3 - initial professional development-professional skills,

IES4 - initial professional development-professional values,

ethics, and attitudes,

IES5 - initial professional development—practical experience,

IES6 - initial professional development – assessment of

professional competence,

IES7 - continuing professional development,

IES8 - professional development for engagement partners

responsible for audits of financial statements.

In table 4.1, we took from the FEE study and national sources, some

additional information regarding the conditions for the exercise of

accounting professions, as well as statistic data suggesting the dimension

of the professional community of the qualified accounting in the 3

analyzed MSs with regulated accounting professions.

Table 4.1

Conditions for the exercise of accounting professions in the analyzed

MSs with regulated professions

MS Austria Italy Romania Professional address Yes, in any MS of

EEA

Yes, professional

residence or address

in Italy

Yes, residence or

permanent residence

in Romania

Compulsory business

infrastructure

The regulated

accounting

professions may be

As freelancers or

specialty companies,

the majority of

Freelancers (PFA) or

in trade companies

authorized by

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exercised as shareholders in

companies (which

may include all the three professions and

tax consultants and

auditors members of

KWT), as a sole-

shareholder company

(and employee) or as a freelancer, all traders

being members of

WKO

which small companies

CECCAR (NACE code 6920, the

majority of the

shareholders must be members of

CECCAR, at leats

51% of the share

capital held by them,

the majority of the CA

must be members of CECCAR)

Professional liability

insurance

Yes Yes, for certain

activities

Yes for all activities

Number of qualified

accountants

At the beginning of

2013, approximately

10,000 authorizations

were issued fr the

three new regulated

professions

198 esperto

contabile + approc. 112,000 dottore

commercialista

35,249 expert

accountants (of which 25,835 active)

5,342 licensed

accountants (of which 1,387 active)

Number of interns/year - Approx. 26,000 Approx. 1,000 expert

accountants + approx.

50 licensed accountants /year


Accountancy Profession across 30 European countries, 26 March 2012; PK –

Independent accountancy in Austria

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5. CONCLUSIONS

One of the main issues of the recognition of the profession of

“accountant” is that, at first sight, the legal framework of the accounting

services seems unitary in Europe, whereas in reality it considerably

varies in the context of the differences in the tax regulation and the legal

system of the trade companies.

The CA for the accounting professions are public structures in some MSs

or the professional associations competent according to the law in some

MSs. If there is a ministry (e.g. Italy), the professional organizations may

be invited to be involved in decisions.

In the field of continuing education and training, the assessment of the

results is already largely used, due especially to the development of

procedures independently, at the sectoral level, at the international plan

(the international education standards developed by IAESB, the

professional ethical code developed by IESBA, the high quality

qualification offered by the British institutes and recognized

internationally, especially those of ACCA). Thus, the national authorities

tend to trust the diplomas and certificates issued by the national bodies of

other MSs, facilitating thus the mobility of the professionals in the field

of accounting services on the Single Internal Market of EU.

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From the point of view of the Directive 2005/36/EC on the recognition of

qualifications, the accounting professions are subject to the general

system for the recognition of professional qualifications, at the

qualification level attesting the graduation of training courses at the

secondary, post-secondary level, either in the technical and professional

education or the university with a duration of 3 or 4 years or at least 4

years. Considering that the provision of accounting services supposes the

knowledge of the commercial, tax and labour laws in the host MS, the

aptitude test as a compensation measure in the recognition of

qualifications achieve din a different member state is largely practiced.

The statistics of the IMI system on the processes of the recognition of

qualifications between 2008 and 2012 for the permanent

establishment/provision, show that the accounting professions have been

among the most mobile professions registered in the IMI system up to

now.

Moreover, the globalization process, on the one hand, and the new

international regulation of the financial services, from the beginning of

the financial and economic crisis in 2007, determine the need for the

accounting professionals to follow the clients in the process of business

internationalization.

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http://www.ifac.org/sites/default/files/publications/files/Volume%20

1_0.pdf

http://www.ifac.org/sites/default/files/publications/files/2013-IESBA-Handbook.pdf

http://www.ifac.org/sites/default/files/publications/files/2013-IESBA-Handbook.pdf

http://www.ifac.org/sites/default/files/publications/files/handbook-of-international-e-2.pdf

http://www.ifac.org/sites/default/files/publications/files/handbook-of-international-e-2.pdf

https://www.ifac.org/sites/default/files/publications/files/IAESB-2012-Annual-Report_0.pdf

https://www.ifac.org/sites/default/files/publications/files/IAESB-2012-Annual-Report_0.pdf

http://www.ifac.org/sites/default/files/publications/files/Volume%201_0.pdf

http://www.ifac.org/sites/default/files/publications/files/Volume%201_0.pdf

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CFE Professional Affairs Committee, editor Rudolf Reibel -

European Professional Affairs Handbook for Tax Advisers, 2nd

edition, March 2013

Law no. 149 of April 30, 2013 for approving of the Government

Ordinance no. 23/2012 for amending and supplementing the

Government Emergency Ordinance no. 90/2008 on statutory

audit of annual financial situations and the consolidated financial

situations and the Government Ordinance no. 65/1994 on the

organization of accounting expertise activity and of the certified

accountants and for amending other rules, Official Journal no.

257 of May 9, 2013

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Abbreviations

AAT - Association of Accounting Technicians

AC – Competent Authority (for one/several regulated professions)

ACA - Associate of the Institute of Chartered Accountants in England

and Wales (ICAEW intermediary qualification)

ACCA – Association of Chartered Certified Accountants

ANC – Autoritatea Naţională pentru Calificări (National Qualifications

Authority) (din România)

ASF - Autoritatea de Supraveghere Financiară (Financial Supervisory

Authority) (in Romania)

BH - Buchhalter (Public finance accountant, profession registered in

Austria on January 1, 2013)

Bibu – Bilanzbuchhalter (Management accountant, profession registered

in Austria on January 1, 2013)

BibuG - Bilanzbuchhaltungsgesetz - (Law on management accounting in

Austria)

CAEN - Clasificarea Activităţilor din Economia Naţională (National

Classification of Economic Activities)

CAFR – Camera Auditorilor Financiari din România (Chamber of

Financial Auditors of Romania)

CAT - Certified Accounting Technician (qualification in Great Britain)

CCF - Camera Consultanţilor Fiscali din România (Romanian Chamber

of Tax Consultants)

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CE – Comisia Europeană (European Commission)

CECCAR – Corpul Experţilor Contabili şi Contabililor Autorizaţi din

România (Body of Expert and Licensed Accountants of

Romania)

CFAB – Certificate in Finance, Accountancy and Business (qualification

in Great Britain)

CIMA - Chartered Institute of Management Accountants

CIPFA - Chartered Institute of Public Finance and Accountancy

CNDCEC - Consilio Nazionale dei Dottori Commercialisti e degli

Esperti Contabili (National Board of Chartered Accountants

and Accounting Consultants in Italy)

CSIPPC – Consiliul de Supraveghere în Interes Public a Profesiei

Contabile (in Romania) (Council for the Public Interest

Oversight of the Accountancy Profession)

CSPAAS - Consiliul pentru Supravegherea Publică a Activităţii de Audit

Statutar (Council for Public Supervision of the Statutory

Audit Activity) (in Romania, transformed in CSIPPC)

DCG - diploma in accounting and management obtained in FRance

DEC - chartered accountant diploma obtained in France after DSCG

DG – General Directorate

DSCG - higher diploma in accounting and management obtained after

DCG in France

EFP – professional education and training

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FEE – Fédération des Experts-comptables Européens/ Federation of

European Accountants

FPC – continuing professional training

FRC – Financial Reporting Council

GBH - Gewerblicher Buchhalter (Accounting technician, profession

existing in Austria before January 1, 2013)

IAESB – International Accounting Education Standards Board

IAS - International Accounting Standards

IASB - International Accounting Standards Board

ICAEW - Institute of Chartered Accountants in England and Wales

ICAS - Institute of Chartered Accountants of Scotland

IESs – International Education Standards (developed by IAESB)

IESBA - The International Ethics Standards Board for

IFAC – International Federation of Accountants

IFRS – International Financial Reporting Standards

IMI – Internal Market Information system (information system of the

Single Market in the EU)

IPS - Institutul pentru Politici Sociale (in Romania) (Social Policies

Institute)

JO – Official Journal of EU

KWT - Kammer der Wirtschaftstreuhänder (Chamber of Public

Accountants in Austria)

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MEN – Ministerul Educaţiei Naţionale (in Romania) (Ministry of

National Education)

MO – Monitorul Oficial (in Romania) (Official Journal)

OG - Ordonanţa Guvernului (in Romania) (Government Ordinance)

OUG - Ordonanţă de Urgenţă a Guvernului (in Romania) (Emergency

Government Ordinance)

PK - Paritätischen Kommission Bilanzbuchhaltungsberufe (Parity

Commission for Management Accountancy Professions in

Austria)

PNDPC - Programul Naţional de Dezvoltare Profesională Continuă al

CECCAR (National Programme for Continuing Professional

Development of CECCAR)

POB - Professional Oversight Board

PV - Personalverrechner (Payroll Accountant, profession registered in

Austria on January 1, 2013)

SBH - Selbständige Buchhalter (independent accounting technician,

profession existing in Austria before January 1, 2013)

SEE – Spaţiul Economic European (European Economic Area, all the

MS of EU + Iceland, Liechtenstein, Norway)

SICIFRIC - related interpretations of the International Financial

Reporting Standards

SM – Member State (of the European Union)

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UBIT - Unternehmensberater, Informationstechnologen und Buchhalter

(Economic sector of information technology, consultancy and

accounting of the Austrian Economic Chambers – WKO)

UE – European Union

WKO - Wirtschaftskammer Österreich (Austrian Economic Chambers)

WT-Arl – Directive on the practice of accounting professions public in

Austria

WTBG - Wirtschaftstreuhandberufsgesetz (Public Accountants’ Statute

of Professional Practice)

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Useful Links

CE Regulations for the international accounting standards –

http://ec.europa.eu/internal_market/accounting/legal_framework/

regulations_adopting_ias/original_text_en.htm

List of national bodies for public interest supervision -

http://ec.europa.eu/internal_market/auditing/links/index_en.htm

EC database with regulated professions in the MS –

http://ec.europa.eu/internal_market/qualifications/regprof/index.

cfm?newlang=en

National Contact Points for the recognition of qualifications in

the MS –

http://ec.europa.eu/internal_market/qualifications/contact/nationa

l_contact_points_en.htm

SOLVIT centers in the MS - http://ec.europa.eu/solvit

PK Austria –

http://www.bilanzbuchhaltung.or.at/de/desktopdefault.aspx

CECCAR - http://ceccar.ro/ro

CNDCEC - http://www.cndcec.it/Portal/Default.aspx

http://ec.europa.eu/internal_market/accounting/legal_framework/regulations_adopting_ias/original_text_en.htm

http://ec.europa.eu/internal_market/accounting/legal_framework/regulations_adopting_ias/original_text_en.htm

http://ec.europa.eu/internal_market/auditing/links/index_en.htm





http://ec.europa.eu/solvit

http://www.bilanzbuchhaltung.or.at/de/desktopdefault.aspx

http://ceccar.ro/ro

http://www.cndcec.it/Portal/Default.aspx

Professions in the field of accounting

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