14086693619_1d5641df7d_b

Analysis: How well does regional harmonization function when the member states are given a range for implementation? Statutory audit is the test object here.

According to European Union (EU) regulations statutory audit is not required for small undertakings. The question is, however, to which extent the member states have implemented this possibility.

The contents of this analysis is as follows:

  1. The Sources
  2. Small Undertakings
  3. Summary
    1. Balance Sheet Total Thresholds
    2. Net Turnover Thresholds
    3. Net Turnover/Balance Sheet Total Ratio
    4. Number of Employees
    5. Increased or Decreased Thresholds
    6. Patterns of Thresholds
  4. Specified overviews
    1. Balance Sheet Total and GDP
    2. Net Turnover
    3. Number of Employees
  5. Conclusions

1. The Sources

Federation of European Accountants (FEE) have produced an overview of the situation as of April 2016. The overview includes all the 28 EU member states as well as Iceland, Norway and Switzerland, totally 31 states: Audit exemption thresholds in Europe.

Despite the recent vote for leaving EU the United Kingdom is still a part of EU and is therefore included in the overview.

Information about the Gross Domestic Products (GDP) is taken from The International Monetary Fund (IMF) World Economic Outlook Database as of April 2016 and relates to the position 2015.

2. Small Undertakings

The EU Accounting Directive requires audit for public-interest entities, large and medium-sized undertakings. The member states are, however, not obliged to require audit for small undertakings.

What is a small undertaking then? According to the EU Accounting Directive a small undertaking is one that for the last two balance sheet dates is below at least two of the three following limits.

  • Balance sheet total: EUR 6,000,000
  • Net turnover: EUR 12,000,000
  • Average number of employees during each financial year: 50

All the 28 EU member states, as well as Iceland, Norway and Switzerland, have implemented some kind of exemption, but in very different ways as we will see.

3. Summary

One state is standing out on the large side of the scale: Switzerland, which has thresholds three times larger than the EU maximum for both the balance sheet total and net turnover and a threshold five times larger for the number of employees.

However, Switzerland is not an EU member state although it’s included as an European state. This also goes for Iceland and Norway.

If wee stick to the EU member states there are still some interesting patterns.

3.1 Balance Sheet Total Thresholds

Thresholds for the balance sheet total range from the EU maximum of EUR 6,000,000 for 3 member states (Germany, Netherlands and United Kingdom), all the way down to less then EUR 1,000,000 for 4 member states (Latvia EUR 800,000, Sweden EUR 150,000, Finland EUR 100,000 and Malta EUR 46,600). This means that the top states have a threshold of 129 times the bottom state!

Hungary does not have a balance sheet total threshold, only thresholds for net turnover and number of employees.

The non-member states Iceland and Norway have the thresholds of EUR 1,400,000 and EUR 2,500,000 respectively, well within the levels of the member states.

3.2 Net Turnover Thresholds

Thresholds for the net turnover range from the EU maximum of EUR 12,000,000 for the same 3 member states as above (Germany, Netherlands and United Kingdom), all the way down to less then EUR 1,000,000 for 4 member states (Hungary EUR 965,000, Sweden EUR 300,000, Finland EUR 200,000 and Malta EUR 93,000).

The non-member states Iceland and Norway have the thresholds of EUR 2,800,000 and EUR 625,000 respectively.

3.3 Net Turnover/Balance Sheet Total Ratio

The EU thresholds of  EUR 12,000,000 and EUR 6,000,000 respectively means a ratio of 2 to 1; the net turnover threshold is 2 times the balance sheet total threshold.

This pattern is implemented by 27 of the 28 EU member states, if we include slighter round off differences for Cyprus, Denmark, Lithuania and Malta. Hungary is the member state which breaks the pattern, by not having any balance sheet total threshold at all.

Of the non-member states Iceland follows the pattern, as well as Switzerland if accepting a round off difference. Norway, however, has a ratio of 0,25 instead of 2 because the threshold for net turnover of EUR 625,000 is lower than the threshold for balance sheet turnover of 2,500,000!

3.4 Number of Employees

Thresholds for the number of employees range from the EU maximum of 50 persons for the majority, 24 of the member states, all the way down to below 10 persons for 3 member states (Finland and Sweden, 3 persons, and Malta, 2 persons).

The non-member states Iceland and Norway have the thresholds of 50 persons (the EU maximum) and 10 persons respectively.

3.5 Increased or Decreased Thresholds

Today’s thresholds were to be implemented by the member states no later than July 20, 2015, to be effective for financial years beginning from January 1, 2016.

9 member states increased their thresholds with a range between 3 % (Austria) and 100 % (Estonia). The other 7 member states were Belgium, Bulgaria, Germany, Greece, Latvia, Netherlands and United Kingdom.

1 member state decreased it’s threshold: Slovenia by 9 %.

The remaining 19 member states, as well as the non-member states Iceland, Norway and Switzerland, kept their thresholds unchanged.

3.6 Patterns of Thresholds

So are there any patterns in the levels of the thresholds or the changes?

I can’t really see that. In the high-end of the thresholds we find large and small economies as well as eastern and western European states.

The top 3 member states, which utilized the maximum thresholds for the balance sheet total and the net turnover, have highly similar GDP per capita ranging from USD 41 K to USD 44 K. The national economies shows a greater variety, ranging from USD 738 B (Netherlands) all the way up to 2,849 B (United Kingdom) and USD 3,358 B (Germany).

Further down the list we can, however, find a mix of big and small economies as well as high and low incomes per capita, without any real linkage to the levels of thresholds.

The bottom 3 member states have quite different GDP per capita, ranging from USD 23 K (Malta) to USD 42 K (Finland) and USD 50 K (Sweden), which places the two later states well in comparison with other member states. The same pattern goes for the national economies, beginning with a relatively small figure of USD 10 B (Malta) but then more average figures follows of USD 230 B (Finland) and USD 492 (Sweden). So at least for Finland and Sweden there´s no explanation in the size of the individual or the national economies to why the thresholds are so low.

4. Specified Overviews

The following are simplified overviews of mine. For more details follow the link above to FEE’s overview which contains important information of the national implementations.

4.1 Balance Sheet Total and GDP

The Gross Domestic Product (GDP) is mentioned in parenthesis after each state in the format (Total GDP for the state in USD billions – B/GDP per capita in USD thousands – K), and relates to the position for 2015.

1 non-member state have implemented higher limits than in the EU Accounting Directive:

  • EUR 18,203,000 Switzerland (USD 665 B/USD 81 K)

3 member states have utilized the maximum limit, EUR 6,000,000:

  • Germany (USD 3,358 B/USD 41 K), Netherlands (USD 738 B/USD 44 K), United Kingdom (rounded off to EUR 6,541,000) (USD 2,849 B/USD 44 K)

21 states have implemented limits of EUR 1,000,000 – 5,000,000:

  • EUR 5,000,000 Austria (USD 374 B/USD 43 K)
  • EUR 4,837,000 Denmark (USD 295 B/USD 52 K)
  • EUR 4,500,000 Belgium (USD 455 B/USD 40 K)
  • EUR 4,400,000 Ireland (USD 238 B/USD 51 K), Italy (USD 1,816 B/USD 30 K), Luxembourg (USD 57 B/USD 102 K)
  • EUR 4,000,000 Greece (USD 195 B/USD 18 K), Slovenia (USD 43 B/USD 21 K)
  • EUR 3,650,000 Romania (USD 177 B/USD 9 K)
  • EUR 3,400,000 Cyprus (USD 19 B/USD 23 K)
  • EUR 2,850,000 Spain (USD 1,199 B/USD 26 K)
  • EUR 2,500,000 Norway (USD 389 B/USD 75 K), Poland (USD 475 B/USD 12 K)
  • EUR 2,000,000 Croatia (USD 49 B/USD 12 K), Estonia (USD 23 B/USD 17 K)
  • EUR 1,800,000 Lithuania (USD 41 B/USD 14 K)
  • EUR 1,550,000 France (SARL and SNC) (USD 2,422 B/USD 38 K)
  • EUR 1,500,000 Czech Republic (USD 182 B/USD 17 K), Portugal (USD 199 B/USD 19 K)
  • EUR 1,400,000 Iceland (USD 17 B/USD 51 K)
  • EUR 1,000,000 Bulgaria (USD 49 B/USD 7 K), Slovakia (USD 87 B/USD 16 K), France (SAS)

4 member states have implemented limits below EUR 1,000,000:

  • EUR 800,000 Latvia (USD 27 B/USD 14 K)
  • EUR 150,000 Sweden (USD 492 B/USD 50 K)
  • EUR 100,000 Finland (USD 230 B/USD 42 K)
  • EUR 46,600 Malta (USD 10 B/USD 23 K)

1 member state have no limit for the balance sheet total:

  • Hungary (USD 121 B/USD 12 K)

4.2 Net Turnover

1 non-member state have implemented higher limits than in the EU Accounting Directive:

  • 36,405,000 Switzerland

3 member states have utilized the maximum limit, EUR 12,000,000:

  • Germany, Netherlands, United Kingdom (rounded off to EUR 13,082,000)

22 states have implemented limits of EUR 1,000,000 – 11,000,000:

  • EUR 10,000,000 Austria
  • EUR 9,674,000 Denmark
  • EUR 9,000,000 Belgium
  • EUR 8,800,000 Ireland, Italy, Luxembourg
  • EUR 8,000,000 Greece, Slovenia
  • EUR 7,300,000 Romania
  • EUR 7,000,000 Cyprus
  • EUR 5,700,000 Spain
  • EUR 5,000,000 Poland
  • EUR 4,000,000 Croatia, Estonia
  • EUR 3,500,000 Lithuania
  • EUR 3,100,000 France (SARL, SNC)
  • EUR 3,000,000 Czech Republic, Portugal
  • EUR 2,800,000 Iceland
  • EUR 2,000,000 Bulgaria, France (SAS), Slovakia
  • EUR 1,600,000 Latvia

5 states have implemented limits below EUR 1,000,000:

  • EUR 965,000 Hungary
  • EUR 625,000 Norway
  • EUR 300,000 Sweden
  • EUR 200,000 Finland
  • EUR 93,000 Malta

4.3 Number of Employees

1 non-member state have implemented higher limits than in the EU Accounting Directive:

  • 250 Switzerland

24 states have utilized the maximum limit, 50 employees:

  • Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Denmark, Estonia, France (SARL, SNC), Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Netherlands, Poland, Portugal, Romania, Slovenia, Spain, United Kingdom

6 states (excluding France which is already accounted for in the previous paragraph) have utilized limits below 50 employees:

  • 30 Slovakia
  • 25 Croatia
  • 20 France (SAS)
  • 10 Norway
  • 3 Finland, Sweden
  • 2 Malta

5. Conclusions

The EU Accounting Directive seems to have succeeded in one way, to allow small undertakings in every member state exemption from statutory audit. But in every other way my conclusion is that as a harmonization it has failed.

The significant differences in national implementations, and the complexity of some of them, does not support cross-border establishments for small undertakings. There’s still a need for small undertakings to examine the regulations of each other EU member state in which an established is planned. What is allowed in one member state is forbidden in another.

Small undertakings are to a high extent owner managed. My personal belief is that the conditions for owner managed businesses are so different from larger and listed companies that it’s well motivated to exempt them from statutory audit – even if nobody of course should be prevented from optional audit.

This exempt should however be far more harmonized. As it is now the fragmented implementation of this part of the EU Accounting Directive is a remaining barrier to the EU’s single market goal of “One market without borders”.


Comment and follow

Do you have opinions on this post?

You’re welcome to comment my blog,
and please feel free to sign up as follower