ACCA Strategic Professional · Advanced Audit and Assurance (International)
Advertising, tendering, and obtaining professional work and fees: formula sheet
Key formulas
- Core test for marketing
- Acceptable = honest + truthful + not misleading + not damaging to the profession
- Apply this to every claim in a scenario. If one part fails, the marketing breaches the Code.
- Three prohibited behaviours
- No exaggerated claims | No disparaging references to others' work | No unsubstantiated comparisons
- Name the one that fits. Exaggerated claims cover services, qualifications and experience.
- Fundamental principles engaged
- Integrity + Professional behaviour
- Misleading marketing is dishonest (integrity) and harms the profession's reputation (professional behaviour).
- Claim test
- Can the firm prove it? Yes = factual. No = unsubstantiated
- Claims about rankings, market share or results need evidence on file.
- Fundamental principles
- Integrity, Objectivity, Professional competence and due care, Confidentiality, Professional behaviour
- Name the principle at risk in each issue you spot.
- Threat categories
- Self-interest, Self-review, Advocacy, Familiarity, Intimidation
- Low fees and the wish to win work are usually self-interest threats.
- Acceptance test
- Accept only if ethical requirements can be met and the firm has the competence, time and resources
- This follows the ISQM 1 approach to acceptance of client relationships.
- Clearance sequence
- Client permission → contact outgoing auditor → outgoing auditor replies (with client consent to disclose) → assess → decide
- No permission from the client means treat it as a red flag and normally decline.
- Low-balling safeguards
- Disclose fee basis to the client + assign enough time and competent staff + apply quality review
- Show that quality is not reduced by a low fee.
- Engagement letter
- Agree terms (ISA 210) before starting the audit
- Includes objective and scope, responsibilities, framework, expected report form and fee basis.
- Fee dependency percentage
- Fee dependency % = (Total fees from client and related entities ÷ Total fees of the firm) × 100
- Include audit and non-audit fees. For a PIE, the Code's trigger is more than 15% for two consecutive years.
- PIE fee dependency response
- Fees > 15% for 2 consecutive years → disclose the fact and extent to TCWG and arrange a review of the second year's audit by a professional accountant outside the firm
- Tell TCWG once fees first exceed 15%. The review is pre-issuance (before the opinion on the second year) or post-issuance (after it, before the next year's opinion). If fees stay above 15%, keep communicating and reviewing each year.
- Non-PIE fee dependency
- No fixed Code percentage; judge significance and apply safeguards
- Do not quote 15% as a rule for private companies. Say the Code sets no fixed percentage and a firm may use its own policy limits.
- Contingent fee on an audit
- Audit fee depending on a result or outcome = not permitted
- Self-interest threat is too significant for any safeguard to reduce it to an acceptable level.
- Low-balling test
- Fee must allow adequate time and appropriately skilled staff to meet professional standards
- A low fee is acceptable only if quality is not compromised. Disclosing the fee basis to the client is a common safeguard.
- Overdue fee test
- Size of debt × length of time overdue = significance of the threat
- Large, long-overdue fees can be seen as a loan to the client. Resolve them before issuing the report.
- Gifts and hospitality test
- Intent to improperly influence: do not offer or accept. No such intent: evaluate the threat. Clearly insignificant or inconsequential: threat acceptable. Otherwise: apply safeguards or decline
- Judge it as a reasonable and informed third party would, not by your own view.
- Threats created by gifts
- Self-interest, familiarity, intimidation
- Name the specific threat the facts create, and do not just say independence is threatened.
- Factors to weigh
- Value + frequency + intent + recipient's seniority + transparency
- Use these as a checklist for every gift or hospitality scenario.
- Referral fees and commissions
- Evaluate the self-interest threat, apply safeguards, or decline
- Typical safeguards are disclosure to the client, informed agreement, advice in the client's interest, and checking local law.
- Three-step response
- Identify the threat, evaluate its significance, address it or decline
- This is the conceptual framework approach and gives a clear exam structure.
Quick revision
- Threat categories: self-interest, self-review, advocacy, familiarity, intimidation.
- Method: identify the threat, evaluate significance, apply safeguards or decline.
- Marketing must be honest, not misleading and not disparage others.
- Do not make exaggerated claims about services or qualifications.
- Fees may be quoted at any level, but a very low fee creates a self-interest threat to quality.
- Safeguards for low fees: make the client aware of the scope, assign suitable staff and time.
- Fees depending on one client or overdue fees can threaten independence.
- Contingent fees for audit engagements are not permitted.
- Gifts and hospitality: acceptable only if value is clearly insignificant; otherwise decline.
- Referral fees and commissions create self-interest threats and need safeguards or refusal.
- Before bidding, check competence, resources, integrity and conflicts.
- Always apply to the scenario and end with a clear recommendation.
Common mistakes
- Saying audit firms are not allowed to advertise at all. Fix: State that advertising is allowed if it is honest and not misleading. The restriction is on how, not whether.
- Naming the wrong fundamental principle, such as objectivity or confidentiality. Fix: Link misleading marketing to integrity and professional behaviour. Use others only if the scenario clearly raises them.
- Saying low-balling is prohibited. Fix: Say it is permitted but creates a self-interest threat. Then show safeguards that protect quality.
- Contacting the outgoing auditor without saying client permission is needed. Fix: State that you must first ask the client for permission. Treat a refusal as a warning sign.
- Saying low-balling is unethical in itself. Fix: State that the fee level alone is not a breach. The threat is to competence and due care, so the firm must show it can still do a proper audit and tell the client the fee basis.
- Applying the 15% fee dependency test to every client. Fix: The 15% trigger is for PIEs and applies when it is exceeded for two consecutive years. For non-PIEs, say the Code sets no fixed percentage and the firm judges significance.
- Saying all gifts and hospitality must be refused. Fix: State that clearly insignificant or inconsequential items may be accepted, and explain how you judge that.
- Using your own view of value instead of the reasonable and informed third party test. Fix: Frame the conclusion as what an informed outsider would think, and consider value, frequency and intent.
Exam tips
- Always separate claims and judge each one. Marks go for showing which are acceptable and which are not.
- Quote the scenario's wording, then apply the test. Generic rule recitals score low on application.
- Name integrity and professional behaviour, and use the three prohibited behaviours as your checklist.
- Finish with practical recommendations. Professional skills marks reward clear, commercial advice.
- Watch for linked issues in the same scenario, such as fee quotes, gifts or referral payments, and deal with each under its own heading.
- Tendering questions usually come with pressure facts, such as a big client, a very low fee or a refusal to allow contact. Find the pressure and build your answer around it.
- Always show the client-permission step before contacting the outgoing auditor, and say that refusal is a red flag.
- Use the format asked, such as a briefing note or email to the partner. Professional skills marks reward clear structure, judgement and tone.