An IESBA consultation paper Collective Investment Vehicles and Pension Funds - Auditor Independence is seeking views on whether revisions to the International Code of Ethics for Professional Accountants (including International Independence Standards) (the Code) are necessary to address the independence of auditors when they audit collective investment vehicles (CIVs) and pension funds (investment schemes).

In our submission to the IESBA we express our view that the Code remains fit for purpose in addressing auditor independence for investment schemes and revisions are not required. This includes the introduction of a new defined term “Connected Parties” comprising the suggested criteria. We also raised concerns about potential unintended consequences from bringing in ‘other service providers’, because it is not just investment schemes that use service organisations.

We believe any specific concerns would be better addressed by jurisdiction-specific legislation/regulation, and possibly IESBA non-authoritative materials. This is primarily due to the differing ways that investment schemes are structured and regulated globally, which gives rise to added complexity if attempting a standard setting response.