Readers of today's FT will have seen that we have published independent research carried out by the London School of Economics which shows that the dominance of the Big Four firms has directly led to an increase in audit fees. This is clear evidence to support our long standing contention that the market place is not operating as it should and, alongside other evidence and concerns over undue concentration, will hopefully prompt a change in mindset and behaviour amongst UK plc. It is now clear, as if further evidence was needed, that a further reduction (from a Big 4 to a Big 3) would be a major concern and the best way to mitigate against such an eventuality is to widen the choice in the marketplace now, before it is too late.
So what do I hope might happen as a result of us publishing this research? Well first, and as noted above, I hope it provides further evidence of the need for a change in attitude and approach by UK plc towards the choice of auditors. But I think it also adds weight to the need for perhaps a sharper approach to addressing the issue of competition and choice.
When I first publicly set out my views on this issue some years ago I said there were three things that were needed as a matter of priority. First, we needed research to show the effect of concentration in the marketplace which I hoped would help people recognise the extent of the issue. I hope this research, added to previous reports published by the FRC and others, makes it clear that there is potential distortion in the market and that something needs to be done. Second, I urged the publication of AIU inspection reports to (hopefully) help dispel the myth that only the largest firms are capable of delivering a quality audit. This is due to happen later this year - not as speedily as I had hoped but very welcome. The style and format of these public reports is not yet known but I am sure the FRC is aware of their importance and will ensure they address the need to give a better understanding of audit quality at all the leading firms. Third, I suggested that "Big 4 only" clauses in banking and other agreements should be banned. Progress here has been more modest - and even slower. The FRC has agreed that details of such clauses should now be published in he annual reports of companies and I understand they hope that over time this will lead to such clauses no longer being a regular feature of bank facility agreements. Personally, I think this is too little.
One of the arguments I have heard for not banning such clauses is that they are an outcome of a free market and it would be inappropriate to restrict the free operation of the market. I believe that teh LSE research has dispelled this assumption ion that it shows that the market is distorted and thus we need to be aware of anything that might be a result of that distortion or that might encourage that distortion. I believe that "Big 4 only" clauses fall firmly into that description - and this should be banned. As well as removing a potential market distortion it would also send out a strong message about the need to broaden choice.
Although the research only considered the audit market I believe it is implicit that there will be a similar position in other parts of the market which are highly concentrated and thus equally an issue in respect of non audit work. "Big 4 only" clauses serve to restrict our ability, and that of other firms, to provide non audit services as well regardless of our capabilities.
We have published this research as part of a genuine desire to stimulate discussion and debate - and we look forward to responses from other interested parties.