Action Plan Developed by Ordre des Experts Comptables et Financiers de Madagascar (OECFM) BACKGROUND NOTE ON ACTION PLANS

Transcription

1 Ordre des Experts Comptables et Financiers de Madagascar () BACKGROUND NOTE ON ACTION PLANS Action Plans are developed by IFAC members and associates and address policy matters as identified through responses to Compliance Self-Assessment Questionnaires. They form part of a continuous process under the IFAC Member Body Compliance Program to support ongoing development and improvement of the accountancy profession. Action Plans are drafted by IFAC members and associates for their own use. They reflect national frameworks, priorities, processes and challenges specific to each jurisdiction and will be subject to periodic updates. Action Plans will vary in objectives, content and level of detail due to different national environments and stages of development. Refer to responses to the Part 1 Assessment of the Regulatory and Standard-Setting Framework Questionnaire and Part 2 SMO Self-Assessment Questionnaire for background information on each member and associate their environment and existing processes. The responses may be viewed at: Use of Information Please refer to the Disclaimer published on the Compliance Program website. ACTION PLAN IFAC Member: Ordre des Experts Comptables et Financiers de Madagascar () Approved by Governing Body: Original Publish : May 2011 Last Updated: December 2015 Next Update: December 2017 Status as of of Publication Page 1 of 25

2 Ordre des Experts Comptables et Financiers de Madagascar () GLOSSARY CPD Continuing Professional Development CSC Higher Council of the Accounts Department FIDEF Fédération International des Experts-Comptables Francophones FTS French Translated Standards I&D Investigation and Disciplinary IAASB International Auditing and Assurance Standards Board IASs International Accounting Standards IASB International Accounting Standards Board IESs International Education Standards IESBAs International Ethics Standards Board for Accountants IFAC International Federation of Accountants IFRSs International Financial Reporting Standards IPSASs International Public Sector Accounting Standards IPSASB International Public Sector Accounting Standards Board ISA International Standard on Auditing ISQC 1 International Standard on Quality Control 1 Ordre des Experts Comptables et Financiers de Madagascar PCG Plan Comptable Général QA Quality Assurance ROSCs Report on the Observance of Standards and Codes SMOs Statement of Membership Obligations SMPs Small and Medium Practices XBRL Extended Reporting Business Language Status as of of Publication Page 2 of 25

3 Ordre des Experts Comptables et Financiers de Madagascar () General Actions Background: The Action Plan of the was designed in 2008 with the prospect at the time of funding for its implementation by the World Bank, as a logical continuation of the 2008 ROSC Accountancy & Audit assessment. According to the predictions of that time, non-permanent actions of the Plan should be completed in Unfortunately, though the first Action Plan was submitted in early 2009 to the World Bank as part of the study to fund the broader "ROSC Country Action Plan", a political crisis led this Institution to apply the provisions of its Operational Policy OP 7.30 ("Relations with government in fact") in March 2009, which restricts the borrowing opportunities for the country. Unlike previous political crises which could be solved in a few months, the 2009 crisis lasted almost 5 years and has had much more serious effects causing persistence until now of the political instability and economic stagnation. Thus, the lack of financial resources continues to last and the actions continues to be performed through volunteering, requiring significant individual commitment while fellow volunteers working on the matter have to constantly face a harsher business environment in their own firms. This situation, as well as the increasing of internal debates on concepts and approaches inherent to the entry of new members into the Council and the Working s, has considerably slowed the work, leading to delays in implementing certain actions. However, some significant events have occurred since the previous update of the Action Plan in 2013: with the holding of three DEX final exams membership in practice has increased significantly from 104 to 120 ; the Executive Secretary, a key element for the continuity of actions, is now operational; the principle of separation between actions implementation and actions monitoring was adopted; a conceptual framework of QA system has been defined; the voluntary firms for QA test have been identified; the web site was set up; the Body was admitted as a member of PAFA in May The future will be marked by the election on September 2015 of a new Council for a term of 2 years; the achievement of punctual actions and their transformation into continuous actions; start of the project of mutual which will discharge the Council from social tasks that hinder it in its tasks of regulating the profession. Steering Committee, Partnership, Common Matters 1. Continuing Ensure permanent coordination of actions and monitoring their implementation. Continuing Comité de Pilotage 1,1. 01/02/15 Clarify and validate the Order missions as "Profession to Serve the Economy." 02/09/15 Council 1,2. 06/09/15 Create an organism of cooperation, mutuality and of retirement for the benefit of members and their families. 05/09/17 Council / Commission Juridique et Fiscale / Commission Communication 2. Continuing Maintain a relationship / sponsorship with FIDEF and / or a Frenchspeaking professional body of international renown to strengthen the accounting profession () and enable it to exercise its functions effectively. Continuing Council Status as of of Publication Page 3 of 25

4 Ordre des Experts Comptables et Financiers de Madagascar () 2,1. 06/09/15 Undertake best endeavor to the success of activities that FIDEF would like to do on the sidelines of the Francophonie Summit in November 2016 in Madagascar. 06/11/16 Commission Communication 3. 01/08/12 Identify, prepare and accomplish steps for the rapid publication of legislation implementing the Ordinance on the profession. 30/06/16 Commission Juridique et Fiscale 3,1. 01/08/14 Identify and analyze continuously the texts and laws involving accounting and Financial Experts. Commission Juridique & Fiscale 3,2. 01/01/14 Define with more accuracy the exclusive missions of the Expert Comptable et Financier. 31/12/15 4. Ensure a continuous updating of the website /09/11 Annually update the "Tableau de l'ordre" (The Body Chart) /07/15 Update the By-Laws ("Règlements internes"). 30/06/ /08/12 Improve the visibility of the Body to the public. 8. Maintain the involvement of the Body in the field of taxation. Commission Juridique & Fiscale Commission Communication Commission Tableaux et Professions SMO 6 Working Commission Juridique & Fiscale Commission Communication Commission Juridique & Fiscale 9. 01/07/13 Reactivate the involvement of the Body in the field of reform of business law. 30/09/16 Commission Juridique & Fiscale 9,1. 01/08/14 Establish an annual day of business law. 30/09/16 9,2. 01/11/13 Establish a legal advice consultation. 30/09/16 Commission Juridique & Fiscale Commission Juridique & Fiscale Commission Tableau et Discipline Status as of of Publication Page 4 of 25

5 Ordre des Experts Comptables et Financiers de Madagascar () 10. Maintain the fight against the illegal practice of the profession. Launch and follow-up the media actions as well as procedures in Court of pursuits against people in illegal practice of the Profession. Ongoing Commission Tableaux et Professions SMO 6 Working Commission Juridique & Fiscale /08/14 Identify, establish and take steps for the notification of the Body decisions. 31/12/15 Commission Juridique & Fiscale Commission Tableau et Professions SMO 6 Working Status as of of Publication Page 5 of 25

6 Ordre des Experts Comptables et Financiers de Madagascar () Action Plan Subject: Action Plan Objective: SMO 1 Quality Assurance Develop and implement a quality assurance review program on the basis of the requirements set out in SMO 1 and set requirement for firms to establish and maintain quality control in accordance with ISQC 1 requirements Background: According to Article 70 of the Ordinance on the Profession, the application of standards on auditing will be the object of a Quality Assurance (QA) review implemented under the leadership of the "Conseil de l'ordre". The QA system conceptual framework has been defined. However, the keep on to place among its highest priorities the establishment of a sound QA review system program in-line with IFAC SMO 1. The ISQC1 standards are adopted by the since the adoption of ISAs in Our current plan is to control its application by each member. As noted below, the schedule for the operationalization of the quality assurance system is as follows: - Establish a working group "SMO 1 - Quality Control", completion date 12/31/15, - Finalize and test, with the 10 volunteer cabinets, a draft system of QA according to SMO 1 requirements "a-g" based on the results of action #5 above, completion date 06/30/16, - Render mandatory to all members, the compliant SMO 1 "a-g" QA system, completion date 09/30/17, - Finalize and make the Public Oversight (SMO 1 "h") mandatory to all members, completion date 09/30/19. Implementation of ISQC /08/13 Establish a working group "SMO 1 - Quality Control." 31/12/15 Technical Vice Commission Normes 2. Raise members' awareness of the external Quality Control (seminar animated by a specialized trainer, circular). SMO 1 - Working 3. Disseminate among members a " toolbox" CD ROM with synopsis and summary containing at least (i) the French translation of ISQC 1 downloaded from the Web site of FIDEF; (ii) the Model-type; (iii) the whole of the French translations of IFAC standards. SMO 1 - Working 4. Maintain a "Cellule de Veille" monitoring group with the tasks of (i) collecting feedback on the difficulties encountered by members in the practical application of ISQC1 in their practice, (ii) issuing advice notices, (iii) initiating training seminars on. Conseil de l'ordre et SMO 1 - Working Status as of of Publication Page 6 of 25

7 Ordre des Experts Comptables et Financiers de Madagascar () Implementation of a System of Quality Assurance 5. 01/11/13 Call volunteers to pilot test the draft QA system (including QA guidance) with the assistance of audit firms accustomed to this type of review (each volunteer playing in turn the function of controller and of controlee but the controller of a practice having to be controlled only by another practice of the panel it does not control). Training of the volunteers conducting the External Quality Control will be given beforehand. Terminé Technical Vice SMO 1 - Working 6. 01/08/14 Finalize and test, with the 10 volunteer cabinets, a draft system of QA according to SMO 1 requirements "a-g" based on the results of action #5 above. This system (System of External Quality Control) will include a procedure of nomination of reviewers and a procedure of updating. Any External Quality Control mission will be gradual: AUP in the early years and then limited exam and, at last, assurance engagement. Criteria of shifting from one type of control to another will be determined by the Body. Controls standards will be those of IFAC (ISRSs, ISAEs). Limited review and Assurance Reports will be publishable. A draft guide for performing internal and external quality control will be available before December The quality control tests of the volunteer cabinets should be completed by the end of June /06/16 SMO 1 - Working 6,1. 01/01/17 Render mandatory to all members, the compliant SMO 1 "a-g" QA system. 30/09/17 SMO 1 - Working & Commission Juridique & Fiscale 6,2. 30/09/17 Finalize and make the Public Oversight (SMO 1 "h") mandatory to all members. 30/09/19 SMO 1 - Working & Commission Juridique & Fiscale 7. Regularly raise the members' awareness of the positive effect of the System of External Quality control through information meetings that will include testimony from those who experienced this system. The goal is to lead them to name the firms that would ensure their fellow External Quality Controller. SMO 1 - Working & SMO 2 - Working Status as of of Publication Page 7 of 25

8 Ordre des Experts Comptables et Financiers de Madagascar () Maintaining Ongoing Processes 8. to establish and maintain Action Plans to ensure the System of External Quality Control incorporates all the requirements of SMO 1. This includes review of the implementation of the Action Plan to date and preparation of the Action Plan for future. Council Review of 's Compliance Information 9. Perform periodic review of 's response to the IFAC Compliance Self-Assessment questionnaires and update sections relevant to SMO 1 as necessary. Once updated inform IFAC Compliance staff about the updates in order for the Compliance staff to re-public. Council Status as of of Publication Page 8 of 25

9 Ordre des Experts Comptables et Financiers de Madagascar () Action Plan Subject: Action Plan Objective: SMO 2 International Education Standards for Professional Accountants and Other Pronouncements issued by the IAESB Ensure that s professional accountancy education program is regularly reviewed and updated to include courses on new and revised international standards and that it incorporates all elements required by the International Education Standards Background: The basic text relating to training and quality assurance is Article 70 of Ordinance No This basic text is supplemented subsequently by: - Decree Article 24 on the access to the profession curriculum. The update of this curriculum to make it compliant with the standards IESS is in draft texts awaiting publication by the public authority. - Training rule - The Code of Ethics. members take an oath before the Court of Appeal to protect the public interest. The Diploma of "Expert-Comptable et Financier" (DEX) was established by a Governmental Decree in 1992: to become a professional accountant in Madagascar, a candidate must complete at least 7 years of training after the Baccalauréat (high school diploma): (i) the candidate must obtain a diploma of higher education (DESCF (Diploma of Higher Education Accounting and Finance)) degree or, the DESCA (Diploma of Advanced Studies In Science Accounting) obtained through training into the INSCAE (National Institute of Accounting Sciences and Business Administration) which is a semi-private institute founded by the World Bank (Baccalauréat +5 level), (ii) and then pass an entrance examination for admission to the controlled practice training of 3 years within one member of (iii) at the end of the practice training, candidates must pass a final exam to obtain the DEX (Diploma of "Expert-Comptable et Financier") which allows them to register as members of. A revised draft of this curriculum was adopted in 2008 by the. To better ensure a timely response to the changing requirements of International Education Standards (IES), International Standards on Auditing (ISA) and International Financial Reporting Standards (IFRS), this draft gave the responsibility to set the training program and to organize the entry and final examination - However, due to the 2009 crisis in Madagascar, the adoption of this text by the government has not yet been obtained at this stage. The organizes professional training seminars for its members. The Continuing Professional Development (CPD) is required by law and the Code of Ethics. Professional accountants are required to maintain their technical skills and to keep the level of current practices to maintain the quality of their services. However, the Code of Ethics does not specify the number of hours and does not institute the monitoring of CPD. Only few members are proficient in spoken and written English, while texts, guides and tools of IFAC and those of the IFRS Foundation are entirely in English, in perpetual evolution and French translations concern only few of them and are published only belatedly. Status as of of Publication Page 9 of 25

10 Ordre des Experts Comptables et Financiers de Madagascar () Implementation of Mandatory Continuing Professional Development (CPD) Requirements /08/13 Reinforce the working group "SMO 2 - Training Commission continued professional framed by the partner / sponsor for the development of a "CPD system and annual CPD programming processes" in accordance with SMO 2 and the requirements of IES 2 and 4. Will be establish a working group Strengthen the "SMO 2 - Committee of Professional Training" framed "partner / sponsor" for the development of a "system of continuing education and annual programming of the continuing education of professionals" SMO 2 and conform to the requirements of IES 2 and 4. Will be considered internal training to the Order (by the technical assistant, the local big 4, members with sufficient knowledge), external formations (local seminars where abroad, the training provided by accredited universities and other trainers origin ex. Judicial), activities similar to training (as does teach or conduct training or activities in groups technical work). 31/12/15 Training Commission /08/15 Mandating minimum training time received or equivalent (minimum time that is currently 120 hours in three years with at least 20 hours per year and 60 hours verifiable by IES 7). 31/12/15 Organize training planned by other working groups on Quality Control (SMO 1), the statements of the IAASB (SMO 3), and the Code of Ethics (SMO 4) /12/13 - December 2013: Day of the profession on quality control, marketing and the setting of audit fee, - July 2015: Seminar on marketing and the setting of audit fee. / Autres es de Travail The December 11, 2015, the organize another day to its members relating to training, extension of ISAs and Malagasy legislation /12/13 Develop, establish and bring to the Council approval the CPD program /01/16 Submit to the Council approval a first draft of the "CPD system and annual CPD programming processes. 30/09/16 Status as of of Publication Page 10 of 25

11 Ordre des Experts Comptables et Financiers de Madagascar () /01/ /01/16 Strengthening for 3 years the material and technical resources and financial standing of the permanent training structure that will be in charge of implementing the measures relating to the training of professionals (before achieving financial independence. Strengthen the capacity of the SMO 2 working group members which are ready to devote themselves entirely to the activity of training of professionals. They must be able to maintain and update the system and training program and provide trainings. 01/01/ /01/16 Update professional library /01/16 Update the training program and organize training /01/16 Establish a permanent training in English with the primary goal of enhancing the understanding of oral and written English. Texts and tools in English of IFAC and IFRS-Foundation shall be used whenever possible during training. & Commission Finance Developing the Academic Training Program and System /05/10 Obtain approval/ratification by the Government of the texts about the access procedure to the "Expert-Comptable et Financier" Diploma (DEX) revised in /01/ /01/16 Monitor the proper implementation of the new texts. According to these new texts, from July 2012, a new academic program 4 / 5 years will be applied for accounting students before their entry into the practicum. The new program will limit the practical experience (prior to entry into teaching practice) to a minimum of 1 month, more experience is not required. There will be no more opportunity to become an "Expert- Comptable et Financier" in Madagascar with only practical experience, academic training is now mandatory. 23. Support Superior Education Institutions to set up a referral program of at least four years from the Bachelor degree, leading to accounting profession or forming high-level executives in Accounting and Finance. Status as of of Publication Page 11 of 25

12 Ordre des Experts Comptables et Financiers de Madagascar () /07/09 Improve the quality of training of Superior Education Institutions specialized in accounting and auditing /01/16 Improve the quality of training of Superior Education Institutions specialized on accounting and auditing /01/16 Organize annually the entrance competition to the Expert Comptable Practice Training /08/12 Revise the regulation of controlled practical training of the trainees. 31/12/ /02/17 Organize the annual examination for the admission of new Experts Comptables et Financiers /02/14 Monitor the three-year controlled practical training of Trainee Experts Comptables. The monitored training period shall be done over 3 years in firm s member of the Body. The firm is the training supervisor. Trainees will be required to prepare an annual training record and half-yearly training report from the second year. They must also participate in mandatory training sessions organized by the Body and prepare a dissertation to be presented at the examination of DEX. et Cabinets Membres de l'ordre 30. Maintain the Commission treating equivalence between Malagasy and foreign diplomas. Maintaining Ongoing Processes Monitor comply with CPD requirements, ask every member each year about his CPD choices and actions. to monitor the new and amended standards issued by the IAESB to ensure they are incorporated in education requirements. to establish and maintain Action Plans to support ongoing convergence with IES. This includes review of the implementation of the Action Plan to date and preparation of the Action Plan for future activities as necessary. Council Council Council Status as of of Publication Page 12 of 25

13 Ordre des Experts Comptables et Financiers de Madagascar () Review of 's Compliance Information 34. Perform periodic review of 's response to the IFAC Compliance Self- Assessment questionnaires and update sections relevant to SMO 2 as necessary. Once updated inform IFAC Compliance staff about the updates in order for the Compliance staff to republish. Council Status as of of Publication Page 13 of 25

14 Ordre des Experts Comptables et Financiers de Madagascar () Action Plan Subject: Action Plan Objective: SMO 3 International Standards and Other Pronouncements Issued by the IAASB Ensuring that there is an ongoing convergence process with IAASB pronouncements and supporting implementation of the auditing standards Background: Unlimited companies and Limited Liability Companies (under certain conditions) are required to be audited according to the law of January 30, 2004 on commercial companies. Banks and insurance companies are required to have a co-auditor, whatever their legal form. According to Article 70 of the Ordinance No of November 5, 1992, the standards on auditing are defined by the Conseil de l'ordre. Clarified International Standards On Auditing (ISAs) were adopted by the Council in 2009 and a draft in French was distributed to members. However, ISAs are constantly evolving and IFAC publishes very useful guides but the French versions are yet to be published. Moreover, in addition to ISAs, other standards and pronouncements are in force but only in English (International Auditing Practices Statements (IAPSs), International Standards on Assurance Engagements (ISAEs), International Standards on Related Services (ISRSs)). The French translation of the ISAE, ISRS and ISRE standards was completed in July 2013 and adopts the standards on an ongoing basis. Ongoing Adoption of IAASB Pronouncement 35. Ongoing Implement measures strengthening relationships with IFAC and audit international organizations. Ongoing Conseil de l'ordre & All the Working s /08/13 Reinforce the working group "SMO 3 - IAASB Convergence." 31/12/ Bring the to adopt translated IAASB pronouncements. 38. Prepare manuals for specific aspects of legal engagements. 39. Disseminate translated clarified ISAs among members. Ongoing Translation Activities of New Drafts and Standards Not yet Translated in French /08/13 Establish the working group "SMO 3 - IAASB Translation." 31/12/15 SMO 3 - Working SMO 3 - Working SMO 3 - Working SMO 3 - Working SMO 3 - Working / Professional Translator Status as of of Publication Page 14 of 25

15 Ordre des Experts Comptables et Financiers de Madagascar () 41. Ongoing Assure the continuing translation of new drafts and standards not yet translated into French (NDNETF), complying with the IFAC Translation Policy. Ongoing 42. Ongoing Conduct a review of existing French translations. Ongoing Education and Promotion Activities SMO 3 - Working SMO 3 - Working /08/14 Establish an intranet working platform that helps members (particularly Small and Medium Practices) to improve the quality of audits and related missions (including practicing IFAC standards through questionnaires and basic tools models), the exchange and sharing of "best practices" and problems of standards practicing, sources of knowledge, quality control and statistical monitoring of etc.). 31/08/18 External Consultant /12/16 Organize an IFAC meeting in Madagascar. 31/12/22 Maintaining Ongoing Processes Council Commission Communication; Tous les es de Travail 45. Establish and maintain Action Plans to support ongoing convergence with IAASB pronouncements. This includes review of the implementation of the Action Plan to date and preparation of the Action Plan for future activities as necessary. Council Review of 's Compliance Information 46. Perform periodic review of 's response to the IFAC Compliance Self-Assessment questionnaires and update sections relevant to SMO 3 as necessary. Once updated inform IFAC Compliance staff about the updates in order for the Compliance staff to republish. Council Status as of of Publication Page 15 of 25

16 Ordre des Experts Comptables et Financiers de Madagascar () Action Plan Subject: Action Plan Objective: SMO 4 IESBA Code of Ethics for Professional Accountants Ensuring that s revised code of Ethics is in line with the requirements of the new IESBA Code of Ethics and ensure that appropriate implementation actions have been taken to ensure s members are properly educated about the new concepts in the ethical requirements Background: The sets the ethical standards for its members in accordance with Ordinance No , article 70. The had issued its own code of ethics with 45 items, before adopting the 2004 Code of Ethics translated by IFAC and the Conseil Superieur de l Ordre des Experts Comptables (CSOEC) a French professional body. members are required to apply both the IESBA Code and code which is in compliance with IESBA Code but contains more restrictive requirements. The International Ethic Standards Board for Accountants (IESBA) Code of Ethics revised in July 2009 was adopted by the "Conseil de l'ordre" in May 2011 and the 2010 French translation of the Code was presented at the Annual General Meeting on July 15, In , received the French translations of the IESBA Code of Ethics as well as the 2013 edition of the IESBA Handbook. The 2013 version of the IESBA Code is adopted. Its application should be confirmed by quality assurance being implemented. The rules about audit fees dating back to 1999 were revised in early 2015 and draft guides on these rules and on marketing were submitted for approval to the Council in July Implementation of the IESBA Code of Ethics /07/09 Create the working group "SMO 4 - IESBA Code of Ethics." Completed /07/09 Obtain adoption of IESBA Code of Ethics. Completed Technical Vice Technical Vice Volunteer Members SMO 4 - Working 49. Train members on the IESBA Code. The IESBA Code is included in mandatory training for trainees and Member. SMO 4 - Working & 50. Establish and adopt additional requirements to the IESBA Code. SMO 4 - Working Status as of of Publication Page 16 of 25

17 Ordre des Experts Comptables et Financiers de Madagascar () Maintaining Ongoing Processes 51. Obtain subsequent French translations of new and amended pronouncements from the International Ethics Standards Board for Accountants (IESBA) and incorporate them into Ethical Code. Council 52. to establish and maintain Action Plans to support ongoing convergence with IESBA pronouncements. This includes review of the implementation of the Action Plan to date and preparation of the Action Plan for future activities as necessary. Council Review of 's Compliance Information 53. Perform periodic review of 's response to the IFAC Compliance Self-Assessment questionnaires and update sections relevant to SMO 4 as necessary. Once updated inform IFAC Compliance staff about the updates in order for the Compliance staff to republish. Council Status as of of Publication Page 17 of 25

18 Ordre des Experts Comptables et Financiers de Madagascar () Action Plan Subject: Action Plan Objective: SMO 5 International Public Sector Accounting Standards and Other Pronouncements Issued by the IPSASB Use best endeavors to assist in the adoption and implementation of IPSASs in Madagascar Background: The Higher Council of Accounting (CSC) a structure of the Ministry of Finance has responsibility for setting accounting standards in the public sector. The of the CSC is no longer a member of the since August IPSAS were adopted by the CSC with modifications in A member of the headed at this time the working group of the adoption of IPSAS. In 2006 was published a "Plan Comptable des Opérations Publiques" (POCP) which keeps the conceptual framework as well as the conventions, rules and principles of the "PCG 2005 cohérent IAS / IFRS" (see below SMO7 background) but with consideration of IPSAS 2004 provisions where they differ from IAS / IFRS. However, there has been no publicly available information on IPSAS that have been implemented and due to lack of resources had difficulties to support the implementation of IPSAS. Nevertheless, will continue to use its best endeavors to raise the awareness of government to the benefits of IPSAS and the need for its adoption. Contribution to the Development of IPSAS in Madagascar /07/09 Constitute the working group "SMO 5 IPSAS." Completed Technical Vice Volunteer Members /08/15 Set up a task force with the Governmental accounting department responsible for local and national public sector accounting and a special committee to undertake an overall review of public sector accounting standards applied in Madagascar, comparing them to full accrual IPSASs. 31/07/16 Technical Vice SMO 5 - Working /02/16 Build capacity for implementation of IPSAS /02/ /01/16 Strengthening technical and material support of the department in charge of national public agencies (EPN) and the public administrative institutions (EPA). Establish arrangements for compliance with current legislation by all EPN. 31/01/16 31/01/17 SMO 5 - Working SMO 5 - Working SMO 5 - Working /08/15 Educate / train state officials and local government accounting on IPSASs. SMO 5 - Working Status as of of Publication Page 18 of 25

19 Ordre des Experts Comptables et Financiers de Madagascar () /08/15 Facilitating access to translations of the latest IPSASs. Maintaining Ongoing Processes SMO 5 - Working 61. to identify opportunities to further assist in implementation of ISPASs. Council 62. to use best endeavors by identifying opportunities to further assist in the adoption of the IPSAS. This includes review of the existing activities and updating action plans for the future activities where necessary. Council Review of 's Compliance Information 63. Perform periodic review of 's response to the IFAC Compliance Self-Assessment questionnaires and update sections relevant to SMO 5 as necessary. Once updated inform IFAC Compliance staff about the updates in order for the Compliance staff to republish. Council Status as of of Publication Page 19 of 25

20 Ordre des Experts Comptables et Financiers de Madagascar () Action Plan Subject: SMO 6 Investigation and Discipline Action Plan Objective: Ensure that s disciplinary mechanisms are designed to incorporate all requirements set out in SMO 6 Background: The I&D system is based on Articles of the Ordinance The detailed procedures are presented in the Rules of Procedure. The implementation of this system is ensured by the disciplinary committee. The procedures for investigations and discipline may involve, in addition to the disciplinary committee, the prosecutor and the Supreme Court. The "Conseil de l'ordre" is responsible for the investigation and discipline (I&D) of its members through a Board of Discipline constituted by Council members and meeting under the observation of the Government Commissioner. A "Rapporteur" appointed by the Speaker of the Chamber of Discipline makes the investigation. His report is delivered to the Chamber of Discipline. The case file including the rapporteur's report is made available to the involved member and his Council or his Secretary, three days before the hearing date. The Disciplinary Board shall deliver its verdict after hearing the involved member. If convicted, the penalty can range from a simple reprimand to exclusion for a maximum of five years and the most severe sanction is expulsion from. The decisions of the Chamber of Discipline may be appealed to the Supreme Court by either the involved member or the Commissioner of the Government. However, the House of Discipline has never issued any sanctions against a member of the. The weaknesses identified after using the self-assessment (by using appendix III of Dashboard Report) is presented at the end of this document. Review of the Investigation and Disciplinary (I&D) System /07/09 Create the working group "SMO 6 - Investigation and Discipline." Terminé Volunteer Members /08/15 Establish a system (structure, procedures) on Investigation and Discipline complying with SMO 6 and the recommendations of World Bank ROSC study. 31/07/16 SMO 6 - Working /08/15 Prepare draft amendments of texts on the profession and Bylaws in alignment with the new system. 31/07/16 SMO 6 - Working & Commission Juridique et Fiscale /08/16 Ensure continuous training of members on SMO 6 / Investigation and Discipline System and the final revised Bylaws and amendments to the revised texts on the Profession. SMO 6 - Working & SMO 2 Working /08/16 Undertake accompaniment survey of the implementation. will undertake this survey to ensure the revised I&D system is properly implemented and functions as intended. SMO 6 - Working Status as of of Publication Page 20 of 25

21 Ordre des Experts Comptables et Financiers de Madagascar () /08/16 Undertake survey on members' and the public's knowledge of the revised I&D rules. SMO 6 - Working Maintaining Ongoing Processes 70. to maintain Action Plans to incorporate the new requirements of SMO 6 in Investigation & Discipline system. This includes review of the implementation of the Action Plan to date and preparation of the Action Plan for future activities as necessary. Council Review of 's Compliance Information 71. Perform periodic review of 's response to the IFAC Compliance Self-Assessment questionnaires and update sections relevant to SMO 6 as necessary. Once updated inform IFAC Compliance staff about the modifications in order for the Compliance staff to republish. Council Status as of of Publication Page 21 of 25

22 Ordre des Experts Comptables et Financiers de Madagascar () Action Plan Subject: Action Plan Objective: SMO 7 International Financial Reporting Standards and Other Pronouncements issued by the IASB Use best endeavors to continue assisting CSC with the implementation of IFRS and promoting ongoing convergence with IFRS Background: According to Decree No of 18 February 2004 establishing the current general accounting principles in Madagascar, Article the following companies are required to maintain bookkeeping: - Companies subject to the Code of Commerce; - Public enterprises, parastatal or mixed economy; - Cooperatives, associations, non-governmental organizations (NGOs); - And more generally the entities producing goods or commercial services or non-market, insofar as they engage in economic activities that are based on repetitive actions. Entities in specific sectors such as banks and insurance have the same bookkeeping obligations. Given their specificity, they have to follow specific accounting principles. The Higher Council of Accounting (CSC) structure of the Ministry of Finance is the body responsible for the adoption and implementation of International Accounting standards (IAS) and IFRS. According to its structure one of its six Vice-President s is necessarily the of the and among its 17 members (from the public sector, private sector and financial market, education etc.) four are members of the. The Presidency of the CSC is no longer a member of the since August In 2005, as part of a project that began in 1999, the CSC has incorporated key reference treatments and exposure drafts of IFRS 2004, with adaptations, in the National Accounting Plan ("PCG cohérent IAS/IFRS"). A study by the World Bank, confirmed by a national survey conducted in 2008 (funded by the European Community) showed that the vast majority of entities mistakenly believe that they understand the PCG 2005 while they establish financial statements that are far short of the PCG 2005, particularly in terms of accounting for certain transactions and of disclosures. Another study commissioned by the CSC in 2010 highlighted that meanwhile the IAS / IFRS have evolved incessantly and largely in comparison with the PCG Thus, the should redouble its efforts in assisting the CSC to make applicable to Madagascar without modifications all the texts of the IFRS Foundation (IFRS and IFRS-SME). Promoting Ongoing Convergence of Accounting Standards with IFRS and IFRS SME /07/09 Create a working group "SMO 7 - Promoting the continuing convergence with IAS / IFRS" composed of local experts. Completed Technical Vice Volunteer Members /08/15 Contribute to the creation within the Ministry of a system which control application of existing accounting standards. 31/07/2017 SMO 7 - Working Status as of of Publication Page 22 of 25

23 Ordre des Experts Comptables et Financiers de Madagascar () 74. Provide technical assistance to CSC in its efforts towards convergence with IFRSs standards, IFRS -SME, IFRS Taxonomy (XBRL). SMO 7 - Working /01/14 Contribute in the creation and implementation of the CSC "Cellule de veille" (Monitoring Unit) as well as the reorganization of the CSC. 31/07/17 SMO 7 - Working /01/13 Encourage members to subscribe to the IFRS-F website. A free subscription is available on the IFRS-F website for downloading certain documents including the French version of the IFRS-SME. sent a letter to their members to encourage them to subscribe to the website in February 2013, but few have responded. This action is thus to repeat continuously from September SMO 7 - Working /08/15 Ensure the participation of / CSC representatives in the meetings and seminars organized by the IASB and in the public dissemination of reports and records relating to these seminars. SMO 7 - Working /08/12 Monitor the implementation within the CSC of a system which monitor the risk on not achieving the goal of applicability of IFRS and IFRS-SME, brought by CGAs /08/15 Promote strengthening relation between CSC, IFAC and other international agencies working in the field of accounting and audit /08/15 Contribute to the reform actions of the Register of Commerce and Companies to improve the structure and system of receiving, detecting failure of declaration, archiving and easy availability of financial information. SMO 7 - Working /01/15 Contribution in training and informing of preparers and users of financial information about the General Accounting Plan and / or IFRS and IFRS SME. SMO 7 - Working /01/17 Contribution to the actions of "rebranding" the PCG 2005 and / or of studying name to give the full IFRSs and IFRS SME applied in Madagascar to highlight the ongoing convergence with international standards. 31/07/18 SMO 7 - Working Status as of of Publication Page 23 of 25

24 Ordre des Experts Comptables et Financiers de Madagascar () /01/13 Contribute to the development of incentives to reward companies more transparency. 31/07/14 SMO 7 - Working Maintaining Ongoing Processes 84. to use best endeavors by identifying opportunities to further assist in the implementation of IFRS. This includes review of the existing activities and updating the Action Plan for future activities as necessary. Council Review of 's Compliance Information 85. Perform periodic review of 's response to the IFAC Compliance Self-Assessment questionnaires and update sections relevant to SMO 7 as necessary. Once updated inform IFAC Compliance staff about the updates in order for the Compliance staff to republish. Council Status as of of Publication Page 24 of 25

25 Ordre des Experts Comptables et Financiers de Madagascar () SMO 6 Requirements Not Yet Met Requirements Y N Partially Comments 1. Link with the results of QA reviews has been established. X Rights of representation and appeal 2. A third appeals body exists which is separate from both the disciplinary committee and investigative committee. X The decisions of the Chamber of Discipline may be appealed to the Supreme Court by either the involved member or the Commissioner of the Government. Administrative Processes 3. Timeframe targets for disposal of all cases are set. X 4. Tracking mechanisms to monitor progress in investigation and discipline and related procedures are established. X Public Interest Considerations 5. Activities are supported to ensure that the public is aware that an investigative and disciplinary system exists in the jurisdiction. X 6. A process for the independent review of complaints on which there was no follow-up is established. X Regular review of implementation and effectiveness 7. Regular review of implementation and effectiveness of the system are performed and corrective actions are implemented. X Status as of of Publication Page 25 of 25