However, the Commission first visited the idea of harmonizing the audit profes-
sion with the Eighth Directive (84/253/EEC) issued in April 1984. This dealt with the
professional qualifications of auditors, insisting that they had at least three years’ ex-
perience before qualifying and that the professional qualification should be equiva-
lent to a university degree. The degree of professionalization throughout the EU was
very varied, not least because the role of the auditor had developed historically in dif-
ferent ways in different states. Countries like Spain, Italy, and Greece had to under-
take fairly radical restructuring of their different forms of the profession, leading to
the establishment of official government registers of auditors.
The organization of the profession remains, however, extremely diverse through-
out Europe. For example, the United Kingdom has six accounting bodies, members
of four of which have ministerial approval to be statutory auditors, subject to having
obtained the necessary training certificates. France has two bodies, but one is exclu-
sively for auditors, and the other for those who provide accounting, tax, law and other
services. Both bodies are subject to the control of ministries, but not the same one,
and recognition as a statutory auditor goes automatically with membership of the
audit body.
In Germany, however, there are three private-sector professional bodies in the
same area of auditing, accounting, and tax. However, auditors have to be registered
with a government agency, the Wirtschaftsprüferkammer(WPK—chamber of audi-
tors), which awards a license to practice, and can withdraw this. Membership of the
private sector Institut der Wirtschaftsprüfer(IdW—auditors institute) is optional, al-
though the IdW issues audit standards and ethical codes. Equally, the IdW is a mem-
ber of Federation des Experts-comptables Européens (FEE), the regional association,
but the WPK is not, and is regularly opposed by the IdW when it applies for mem-
bership. There is an entirely separate body known as Steuerberaterwho provide ac-
counting and tax advice to clients. These are regarded as “second tier,” by the
Wirtschaftprüfer, although they have been given access to audit through the new sta-
tus of Vereidigte Buchprüfer. Steuerberater may take a supplementary exam and then
register with the Wirtschaftsprüferkammer as auditors of medium-sized companies.
This very diverse range of structures is not about to change—accountants are very
conservative people, at least at an institutional level. However, it makes common
agreement on anything in the audit area quite difficult. However, FEE, the regional
organization for the profession, maintains that, despite the different structures, the
quality of audit is high and in most countries is carried out to worldwide standards.
In 2002, it published a discussion paper which suggested that the European profes-
sion should systematically adopt International Standards of Auditing. A number of
national bodies have also set up a working party to harmonize the content of profes-
sional examinations.
The Commission signaled a renewed interest in auditing matters in 1996, when it
published a green paper on the role, position, and liability of the statutory auditor
within the EU. This was followed by wide consultation, a conference, and then pub-
lication on May 7, 1998, of a “Communication” on the future of statutory auditing in
the EU. The Communication announced the setting up of a Committee on Auditing
whose role is to examine the comparability of auditing standards and to audit quality
control systems and rules on auditor independence. The Commission said it hoped
that harmonization could be achieved without legislation, but would not hesitate to
introduce this if necessary.
The Commission’s rationale for this initiative was that reliable financial state-
17 • 12 EUROPEAN HARMONIZATION