summary, a large group of up to 30 countries will have to comply with IAS and prob-
ably ISA by 2005 or soon thereafter. But the infrastructure and regulation problems
are yet to be resolved. Even within the current 15 EU members, there are large dif-
ferences in infrastructure, particularly regulation, as well as differences in education
and professional structure.”^5
Other regional organizations of accountants are not as active in setting interna-
tional auditing standards.
15.3 THE AUDITOR. A fundamental consideration in comparing auditing standards
among countries is the definition of who may be an auditor with power to attest to fi-
nancial statements. Among the countries in this survey, there is wide variation in
defining the auditor’s identity and qualifications. Exhibit 15.1 summarizes essential
information related to the auditor in five areas: title of auditor, source of authority, li-
censing procedures, training, and foreign reciprocity. The paragraphs below discuss
broad conclusions that may be reached on the basis of Exhibit 15.1. They are not in-
tended to repeat detailed information supplied by the exhibit. (This statement is also
applicable to subsequent exhibits in this chapter.)
(a) Title of Auditor and Source of Authority. There are two basic types of auditors
who may perform the attest function: statutory accountants and public accountants.
Because statutory accountants are defined in the law, they are, in a sense, an exten-
sion of the legal system. Auditing standards in these cases are usually part of the legal
system. Examples of countries with statutory auditors are France, Italy, and Mexico.
Public accountants, while also authorized in the law, are defined through their mem-
bership in independent professional associations of accountants. Examples are pub-
lic accountants in Argentina, certified public accountants in the United States, regis-
tered accountants in the Netherlands, and chartered accountants in the United
Kingdom. The source of authority for the attest function in most countries comes
from national laws and commercial or companies’ laws, but, in some cases, such as
the United States and Canada, the individual states or provinces have considerable
control over who the auditor is and the qualifications for becoming one. In Canada,
three groups of professional accountants have evolved, while, in the United States,
the American Institute of Certified Public Accountants (AICPA) is the main deter-
miner of auditing standards. Most countries have strong organizations of professional
accountants that establish auditing standards and may also influence who may be-
come an auditor. However, the fact that auditing and auditors are deeply rooted in the
laws of most countries is a principal impediment to the international harmonization
of auditing standards.
(b) Licensing Procedures and Training. In most countries, the auditor is trained in an
academic program and must meet certain licensing requirements. Licensing proce-
dures may cover areas such as personal characteristics, education, examinations, and
experience. Most countries have a minimum age requirement that ranges from 21 to
25 years of age, as well as a citizenship requirement. Although most countries require
the equivalent of a university degree, not all do. For instance, Korea and Kenya do not
require university degrees, and in Canada certified general accountants and members
15.3 THE AUDITOR 15 • 5(^5) Smith, 2002.