• Representing our clients’ interests
    to Government and regulators

Consultation Responses

Representing our clients to Government and regulators

BDO works with over 25,000 UK-based clients every year. We advise individuals, start-ups, small and mid-market business as well as large, publicly listed corporates. Our services include audit and assurance, tax, advisory and business outsourcing. We are committed to helping our clients achieve success and realise their ambitions.

As a responsible corporate citizen and in order to represent the interests of our clients, we respond to consultations that may alter the environment our clients do business in. We also want to help the Government ensure that there is no more regulation than is absolutely necessary and that all regulation is as effective as possible.

Below you will find information on BDO’s responses to consultations issued by Government departments and regulators. In each case, we provide an overview of the BDO position as well as a copy of our official response, where appropriate. If you or your business is affected by any of the issues raised in these consultation responses, please get in touch. We will happily discuss how we can help.

Recent consultation responses

Government consultations

CIPFA – Research Exercise on Charities SORP (FRS 102) – December 2016

BDO LLP is supportive of research relating to the Charities SORP and how the SORP could evolve. We welcome the attention given to ensuring the financial reporting framework applicable to charities remains fit for purpose.

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BEIS Green paper on Corporate Governance Reform – November 2016

BDO LLP welcomes any effort to improve corporate governance for private companies. Our concern is that proposed changes must be appropriate and proportionate. What is required is a mechanism that will improve the unacceptable behaviour of the minority while not overburdening the majority. In the absence of independent shareholders, any code for private companies would also need a mechanism to encourage accountability against or enforcement of the strengthened framework.

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BIS Implementation of non-financial reporting directive – February 2016

BDO LLP is strongly in favour of the deregulatory approach set out in Option 2 of the consultation.

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FRC consultations

Audit of Charities in the UK – May 2017

BDO LLP is supportive of steps taken by the FRC to simplify the Practice Note and enhance the level of practical guidance it contains.

In our submission, we welcome the changes that have led to a reduction in the amount of not superfluous and not charity specific information as well as the increased use of practical and example based guidance as this encourages consistency and high standards in charity auditing. 

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Minor revisions to ISA (UK) 330 – April 2017

BDO LLP agrees with the proposals to amend ISA (UK) 330 and ISA (UK) 505 and agrees that PN 16 is now redundant and should be withdrawn.

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Draft amendments to FRS 102 – March 2017

BDO LLP is generally supportive of the amendments proposed in the Exposure Draft. We welcome the decision not to introduce concepts and requirements drawn from IFRSs . We are also supportive of attempts to ensure the standard is proportionate.

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Proposal to adopt (in the UK) ISA 800 (Revised) and ISA 805 (Revised) – December 2016

BDO LLP agrees with the proposed adoption of ISA 800 (Revised) and ISA 505 (Revised) as these provide high level standards and application material that meet various audit needs.

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FRED 66 Draft amendments to FRS 101 ‘Reduced Disclosure Framework’ – December 2016

BDO LLP agrees with the proposed amendments to FRS 101. This would result in a Qualifying Entity being subject to substantially all of IFRS 16’s lessee disclosure requirements.  We would highlight however that these proposals might result in different levels of information being required in respect of economically similar arrangements.

We would question whether it is necessary to subject a Qualifying Entity to all of IFRS 16’s lessor disclosure requirements given the substantial exemptions from disclosure requirements in IFRS 15.

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Revised Operating Procedures – October 2016

BDO LLP supports the Conduct Committee’s desire to improve the transparency of its activities and is of the view that the changes proposed in the revised Operating Procedures will help achieve this aim. We also support the introduction of a better staffing or operating model providing that is maintains the quality and cost effectiveness of the CRRT’s output.

We have some concerns about the clarity and transparency of the proposals that relate to the “closed case list” and the expectation placed on companies that do not adopt the UK Corporate Governance Code.

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Triennial Review of UK and Ireland Accounting Standard – Approach to changes in IFRS – September 2016

BDO LLP has some concerns that there is as yet, not sufficient practical implementation evidence to guide how the principles embodied in IFRSs should be brought into FRS 102. BDO believes the FRC should apply the same approach as for IFRS 9 and IFRS 16, namely to wait until implementation of the IFRS provides sufficient compelling evidence for any changes to FRS 102. 

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FRED 65; Draft amendments to FRS101 Reduced Disclosure Framework – Notification of Shareholders – July 2016

BDO LLP agrees with the proposal to remove the requirement for a qualifying entity to notify its shareholders about the proposed use of the disclosure exemptions set out in FRS 101 Reduced Disclosure Framework and the similar consequential amendments to FRS 102.

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