Professional Documents
Culture Documents
Prevod ENG
Prevod ENG
Contents
1 STARTING POINT AND DEFINITIONS............................................ ................................................ ..... 4 1.1 FRAMEWORK, SCOPE,
PURPOSE AND SCOPE................................... ................................................ .... 4 1.1.1
Framework............................................ ................................................ ........................................ 4 1.1.2
Scope..... ................................................ ................................................ ........................ 4 1.1.3 Purpose and
scope................... ................................................ ................................................ .. 4 1.2
DEFINITIONS ............................................. ................................................ .............................................. 5
1.2.1 Accounting .............................................. ................................................ ........................... 5 1.2.2 Accountant, accounting
practice and accounting company.............. ......................... 5 1.2.3 Client's
documentation................... ................................................ .............................. 5 1.2.4 Client's accounting
material .............. ................................................ ............................ 6 1.2.5 Assignment
documentation ................. ................................................ ........................................... 6 1.2.6 Invoicing
tasks ... ................................................ ................................................ ............. 6 1.2.7 Invoicing
basis................................ ................................................ .................................... 6 1.2.8 Salary
assignments........... ......... ................................................ ................................................ ....... 6 1.2.9 Salary
basis ....................................... ................................................ ....................................... 6 1.2.10 Pay slip, a-report and
compilation statement ( annual statement) salary ..................................... 6 1.2.11 Salary
documentation ..... ................................................ ................................................ ........ 6 1.2.12 Payment
order................................... ................................................ ................................ 7 1.2.13 Basis of
payment ............ ................................................ ................................................ ....... 7 1.2.14 Payment
proposal ....................................... ................................................ .................................... 7 1.2.15 Annual settlement
task ........... ....... ................................................ .............................................. 7
1.2.16 Pure reporting tasks ........................................... ................................................ ........ 7
5.7.1 Access rights and division of labor............................................. ............................................... 24 5.7.2 The client's internal
routines................................................... ................................................ 24 5.7.3 Basis of
payment ............................................. ................................................ ......................... 25 5.7.4 Reassuring
registration................... ................................................ ....................................... 25 5.7.5
Liquidity ...... ................................................ ................................................ ........................... 25
ATTACHMENT: RECOMMENDATION - ACCOUNTANT'S STATEMENT ON THE PREPARATION OF THE ANNUAL ACCOUNTS ..... 38
There are a number of regulations that regulate the material content of the professional practice that takes place. Which
regulations are relevant must be assessed concretely, based on the client's business. Good accounting practice does
not elaborate on the content of such additional regulations. References are given in footnotes to key provisions in other
regulations, including the bookkeeping and accounting rules. The text in the standard must be read in conjunction with
the provisions to which reference is made.
This standard provides guidelines for good accounting practice4 regarding general matters that apply to accountant
assignments, as well as in the assignment areas of invoicing, wages, payment, bookkeeping and annual accounts.
1.1.2 Scope
The standard applies to external accounting activities where the accountant in business undertakes to keep
accounts for others (accounting assignment)5 . The client's own responsibility for complying with duties given in or
pursuant to law rests fully on the client himself6 . The client cannot, by agreement, waive the duties incumbent on the
client, for example vis-à-vis third parties or public authorities. The services that the accounting firm offers to perform on
behalf of the client must be regulated in an assignment agreement7 . The accounting firm's responsibilities arise from
the assignment agreement and provisions given in or pursuant to law8 .
The standard applies to anyone who is authorized as an accountant in accordance with the Accountants Act, but is
limited to businesses that in business keep accounts for others (accountant assignment).
The accounting business must ensure that all accounting tasks are carried out in accordance with the
standard, including tasks that are not carried out by authorized accountants. The standard's content may also be
suitable as a quality standard for companies that carry out accounting internally.
In the standard, it is indicated in bold what are mandatory requirements, given that the respective requirements are
relevant for the tasks agreed to be carried out under the assignment agreement. The other content of the standard is
indicative. However, the entire standard must be considered as a whole, as the supplementary text, in addition to providing
concrete guidance, elaborates and explains the content of the actions that are necessary to fulfill the requirements for
conducting business in accordance with good accounting practice.
Solutions other than those of the standard may be acceptable, as long as they at least fulfill the purpose of the requirement and
ensures the same quality level of service delivery. The solutions cannot be in conflict with requirements given in or pursuant
to law. The accountant must be able to explain deviations from the standard's mandatory requirements (highlighted text), and
must therefore justify such deviations in the assignment documentation.
1.2 Definitions
1.2.1 Accounting
Accounting is defined as the performance of the client's duties according to accounting and
bookkeeping legislation, as well as the preparation of tasks and information for the client which the latter must provide in
accordance with law or regulations9 . The assignment can be expanded or restricted in the assignment agreement in relation
to this definition.
Accountant responsible for the assignment means an authorized accountant who, in accordance with the
assignment agreement, is designated as responsible for the accounting assignment11 .
Accountant means any person who performs tasks on the accountancy assignment, including the accountant responsible
for the assignment and employees.
Accountancy activities mean both sole proprietorships and companies that in business keep accounts for others12 .
Accounting company means a company as mentioned in the previous section13. The term does not include sole
proprietorships.
The documentation may have been received from external parties, or prepared by the client or the accounting firm.
1.2.10 Pay slip, a-report and compilation report (annual report) salary
Payslip means a written statement/receipt to the employee about the calculation method for salary, the
calculation basis for holiday pay and deductions that are made . 19
By a-melding is meant monthly reporting of salary and employment conditions to the Swedish Tax Agency,
NAV and Statistics Norway. A-message A01 is registered directly in Altinn, while a-message A02 is sent from a
payroll and personnel system. A-message feedback (A03) means feedback on submitted information after the a-
20
message has been delivered.
The statement of salary (annual statement) means an annual statement from the employer to
21
employee over reported information about benefits, withholding tax and holiday pay basis.
15 Cf. Bookkeeping Act § 13 first paragraph, the bookkeeping regulations and good bookkeeping practice.
16 Cf. the accountants regulations § 3-2.
17 Cf. the book-keeping regulations sub-chapters 5-1 and 5-2.
18 Cf. Bookkeeping Regulations § 5-2-7 and GBS 1 Issuance of credit notes.
19 Cf. the Working Environment Act § 14-15 fifth paragraph and the tax payment regulations § 5-10-20 first paragraph.
20 Cf. the a-information act of 22.06.12 no. 43 and the a-information regulations of 24.06.14 no. 857.
21 Cf. the tax administration act of 27.05.16 no. 14 § 7-12 third paragraph and the tax administration regulations of 23.11.16 no. 1360 § 7-12-2
(appendices/bookkeeping basis)22 .
The payment basis can be received from external parties or prepared by the client or the accounting firm.
The accounting business must establish sound internal control and communication routines that ensure fulfillment of
duties under the Money Laundering Act25 .
Accounting firms must have risk management and internal control that at least satisfy the requirements of the risk
management regulations26 .
22 Cf. the bookkeeping regulations § 5-6. For clients who are not obliged to keep books, the corresponding requirements for payroll accounts apply
according to the tax payment regulations of 21.12.07 no. 1766 § 5-11-2.
23 For example, tax return for wealth and income tax, company return for companies with participant determination or business statement only.
24 Cf. Bookkeeping Act § 3 and the Bookkeeping Regulations § 2-1.
25 Act on measures against money laundering and terrorist financing etc. of 06.03.09 No. 11.
26 Regulation on risk management and internal control of 22.09.08 no. 1080.
The accounting business should seek to have uniform routines for all clients. The number of employees, the
competence of the employees and the complexity of the assignments are factors that should be taken into account when
establishing and documenting internal routines and internal control. Even in accounting firms with few or no employees, it is
important that internal routines are documented, and they should therefore be set down in writing. This reduces, among other
things, the risk of vulnerability if the project manager
the accountant is disabled from participating in the work27 . In small accounting firms with few employees and simple
assignments and systems, the routine descriptions may be simpler and more concise than in larger accounting firms with
more employees and more complicated assignments and systems.
The risk management regulations only apply to accounting firms, but sole proprietorships should also carry out
risk management and internal control as described in § 6 and § 7 of the regulations.
The former accountant must, when the new accountant requests it, provide information to the new accountant about
circumstances that indicate that the new accountant should not undertake the assignment28 . In his statement, the
former accountant must, at a minimum, disclose matters relating to the execution of the assignment that involve a
breach of the assignment agreement or a breach of requirements given in or pursuant to law. The former accountant
must issue his opinion without undue delay, normally within 14 days of receiving the request from the new
accountant.
Both accountants must document such correspondence in the assignment documentation, either in the form of a
written statement or as notes from conversations.
A request for a statement from the former accountant can be waived if the new accountant has good knowledge
of the client and its accounting. The same applies to short-term assignments, as well as to assignments with a
limited scope, where a statement from a former accountant is not expected to have any impact on the execution of
the assignment. The assessments which result in a statement from the former accountant not being obtained must
be documented in the assignment documentation.
The statement can be given by a former accountant without being hindered by the duty of confidentiality29 . The content
of the statement from the former accountant can be passed on to the client.
The accounting business must continuously follow up existing customer relationships, and update them
27 See also point 2.5 on capacity-related vulnerability, including entering into an assistance agreement with another accountant.
28 Cf. the accountants' regulations § 3-1 second paragraph.
29 Cf. Accountants Act § 10 third paragraph.
30 Cf. Money Laundering Act § 2 No. 3
31 Cf. Section 5 of the Money Laundering Act.
2.4 Fees
The accounting firm shall, at the request of the client, provide an account of its fee calculation.
The report can be at an overall level, and does not need to show hours per employed per day. In the case of
fixed price agreements, it is not necessary to explain the fee calculation, as the fee follows directly from the assignment
agreement.
The number of authorized accountants in the business must be sufficient for it to be carried out
proper quality control in accordance with chapter 7.
The accounting business must assess its vulnerability in terms of capacity, and possibly take measures so that
clients and their own business suffer as little as possible in situations where capacity is lower than normal.
An example of measures against capacity-related vulnerability in accounting firms with few employees could be to
have an assistance agreement with another accounting firm.
2.6 Competence
The accounting firm must have sufficient competence to carry out its assignments in accordance with
assignment agreements and requirements given in or pursuant to law.
The accounting firm must only undertake advisory tasks if the firm has its own or hired expertise in the area in
question. Accountancy activities must not undertake tasks contrary to the Courts Act's provision on legal aid
activities33 .
Accountants should generally make themselves available to the client in matters related to the accounts and other matters
that naturally belong to the accountant's assignment, including, among other things, accounting analyses, calculations,
operational planning, budgeting, and tax and duty issues including complaints and change cases.
If the prerequisites for assisting the client are not present, the client should be advised to apply
competent assistance.
2.7 Confidentiality
33 Cf. Courts Act of 13.08.15 no. 5 § 218, cf. nevertheless the provision's fifth paragraph which reads: "Legal aid can be provided by anyone to the extent that legal aid is necessary to
provide good and complete help in other activities. Such legal aid can also be provided without connection to assignments within the main business."
The accounting firm must ensure that all employees submit a written non-disclosure agreement.
The same applies to others who have access to the client's accounting material at the accounting
firm and/or to the accounting firm's assignment documentation.
The duty of confidentiality is permanent. It therefore also applies after the assignment for the client has ended, and
after an employee in the accounting business has ended his employment. The term "employees" includes, in addition
to authorized accountants and employees who participate in the execution of the assignment (accounting employees),
also administrative staff, cleaners and others, including hired personnel.
If hired personnel who do not participate in the performance of the assignment have signed a non-disclosure agreement with
their employer, it may be omitted to draw up an additional non-disclosure agreement with the accounting firm.
Examples of this could be cleaners, security guards etc. However, this must be limited to those cases where the accounting
firm can document that such a non-disclosure agreement has been signed.
The duty of confidentiality does not apply where exceptions follow from the Accountants Act, special legislation, the
assignment agreement or with permission from the client, including in the following cases:
• An accountant who carries out an audit of another accountant's accounting assignment, may be given information and
documentation35 in connection with this audit .
• The former accountant is obliged to provide information to the new accountant about conditions that indicate that the new
accountant should not undertake the assignment if the new accountant asks about this36 .
• The accounting business is required to provide public control authorities with the necessary assistance to inspect the accounting
system and accounting material, as well as make equipment and software available for this37 .
This duty is nevertheless limited to the work that the accounting firm has carried out, as well as the material and
systems that the accounting firm has at its disposal. The assistance is provided free of charge from the supervisory
authorities.
• The accounting firm is required to assist the debt board and estate administrator free of charge with information about the
debtor's accounting and business conduct38 . This duty of assistance only applies to already completed tasks for the debtor
(principal). The duty to provide assistance is limited to providing factual information to the debt board and trustees about the
debtor's accounting and business management, without carrying out further assessments.
• Accountants can give evidence and submit documentation regarding accountant assignments or other services before the
court, or before the police when an investigation has been opened in a criminal case39 . • The accountant can notify the
police if, in connection with the accountant's assignment or other services, circumstances arise which give reason to suspect
that a criminal offense has been committed40 .
• If investigations do not disprove a suspicion that a transaction is connected to the proceeds of a criminal offense or terrorist
financing, the accounting firm must send information to Økokrim about the transaction in question and about the conditions
that have led to suspicion41 .
The assignment agreement must regulate who at the client is to be given information, cf. point 3.2.
The duty of confidentiality does not, however, prevent the accountant from giving information to persons who have personal
responsibility for the client's accounting. This applies, for example, to owners of sole proprietorships,
38 Cf. Bankruptcy Act of 08.06.84 No. 58 Section 18a and Section 101.
39 Cf. Accountants Act § 10 fourth paragraph.
40 Cf. Accountants Act § 10 fifth paragraph.
41 Cf. Money Laundering Act § 20 first paragraph, cf. § 18.
participants in responsible companies and the general manager and the board (the overall board, not
42 .
individual board members)
The purpose of the requirement for agreement regulation and access controls is to prevent unlawful additions, changes
or deletions in book-entry information, documentation etc. The regulation can take place in the assignment agreement,
as an attachment to it, through confirmations per e-mail or in other written form.
The accounting firm is not responsible for recorded information, documentation, etc. which is prepared by the
client within the agreed access. This should be stated in the agreement between the client and the accounting
firm.
In cases where the assignment is carried out in the client's accounting system, the client normally has full access
to all book-entry information, documentation etc. The client will therefore be responsible for ensuring that recorded
information, documentation, etc. which is prepared by the accounting firm is not changed or deleted unlawfully. This
should be stated in the agreement between the client and the accounting firm.
2.8.4 Maintenance
Software that the accounting firm uses during the execution of the assignment must be up-to-date, so that
requirements given in or pursuant to law can be complied with.
2.8.5 IT security
The accounting business must ensure satisfactory protection of software and hardware against
unauthorized access, change, deletion, loss and destruction of data. Measures must be implemented that provide
42 Cf. among others the Companies Act of 21.06.85 no. 83 § 2-24 and § 3-14, the Companies Act of 13.06.97 no. 44 § 6-12 third paragraph and § 6-14 fourth paragraph, and the Public Limited
Liability Companies Act of 13.06. 97 no. 45 section 6-12 third paragraph and section 6-14 fourth paragraph.
The accounting business must have an updated and tested contingency plan in order to be able to
handle significant operational interruptions related to software and hardware.
A contingency plan is a plan that describes notification routines, responsibilities and tasks if a situation arises
with significant operational interruptions in the IT systems. The contingency plan must be updated and tested to
ensure that the solutions work as intended in a situation with significant operational interruptions.
It must also be agreed that those who supervise the accounting activities are given access to information
from and supervision of the supplier where they deem it necessary as part of the supervision of the
accounting activities.
It must be stated in the agreement where the client's accounting material and the accounting firm's
assignment documentation are kept (where physical storage media are located).
The accounting firm must, where relevant, inform clients about where their accounting material
is kept45 .
Even if external suppliers are chosen for the operation of ICT, it is the accounting firm itself that has the formal
responsibility for information processing, documentation, storage and operation46 .
Business-critical ICT includes both hardware and software, for example accounting, invoicing, payroll and
annual settlement systems. The accounting firm's control right can be exercised by the accounting firm itself or
by hired assistance.
The agreement with the supplier must, among other things, comply with the requirement for a data processing agreement that regulates
47
processing of personal data, obligation to implement security measures, etc.
43 Cf., among other things, the Bookkeeping Act § 4 no. 9 and § 13 third paragraph, NBS 1 Safeguarding of accounting material, the Accountants Regulations § 3-2 third paragraph, the Risk Management
Regulations § 2 and § 7 second paragraph, as well as the Personal Information Act of 14.04.00 no. 31 § 13 and the personal data regulations of 15.12.00 no. 1265 chapter 2.
44 See, among other things, the Bookkeeping Act § 13 and the Bookkeeping Regulations Chapter 7, the Accountants Act § 10, the Accountants Regulations § 3-2, the Risk Management
Regulations § 5 and the Personal Data Act § 15.
45 Cf. § 13 of the Accounting Act, the accounting regulations § 7-4 and § 7-5, and regulations on the storage of accounting material in the EEA of 03.06.10 no. 759.
46 See, among other things, the risk management regulations § 5.
47 Cf. Section 15 of the Personal Data Act.
When working in the client's ICT systems, the above requirements do not apply to these systems, but the Norwegian Financial Supervisory
Authority still has the right to access the client's accounting data and accounting material48 . The same applies to others who carry out
quality control of their accounting activities in accordance with an agreement with the Norwegian Financial Supervisory Authority.
The accounting firm should arrange for agreements with software suppliers that ensure access to the client's
accounting material that must be kept and the accounting firm's assignment documentation for the entire retention
period53 .
2.9 Insurance
The accounting business must continuously assess its overall insurance needs.
Central to the assessment is the need to ensure that the accounting business does not directly or indirectly cause financial
damage to its clients. Professional liability insurance54 is an important tool in this respect. In the case of payment
assignments, the accounting firm should also consider extending the insurance cover with crime insurance55, as well as
informing the client whether the accounting firm has such insurance or not. Furthermore, reconstruction and interruption
insurance should be considered.
A group agreement can be entered into which can cover several subsidiaries57, provided that one exists
overview of the companies covered by the agreement. If the assignment agreement is not the same for everyone
the companies covered, it must be clearly stated in the agreement which conditions apply to the individual company.
For short-term individual assignments, it is acceptable to use, for example, an e-mail with a description of the assignment,
together with acceptance from the client. This must be assessed concretely based on the assignment
character and duration.
The assignment agreement must specify deadlines for the client's submission of documentation, as well as for
the accountant's assignment execution and reporting.
The assignment agreement must designate the authorized accountant who is the responsible accountant for the
assignment on behalf of the accounting company59 .
The assignment agreement must regulate how personal data must be processed, as well as state that security
measures must be implemented to ensure satisfactory information security60 .
The assignment agreement must regulate who at the client is to be given information.
The assignment agreement must not give the client the impression that the client's own responsibility is reduced through
the use of an accountant.
It is particularly important to provide a concrete indication of the accountant's duties in cases where parts of the accounting
work are carried out by others, for example the client himself or another accountant.
Written agreements should also be entered into for other assignments that are not carried out in combination with
accounting assignments.
In the case of a payment assignment, the assignment agreement or annex to this should contain a description of the routines for
carrying out the payment assignment, both at the client and the accounting firm, including routines for approval and payment.
Those who can bind the parties under ordinary contract and company law must sign the agreement.
In cases where the client has received a correct and comprehensive agreement signed by
accountant's activities, and a collaboration in line with the agreement has been initiated, it can be assumed in terms of contractual law that
the text of the agreement has been accepted by the client by conclusive conduct61 .
The accountancy business should nevertheless work to ensure that the assignment agreement is signed by the client, among other things to
prevent disputes over notice periods and other conditions that appear in the agreement. If the assignment agreement is not signed, the
accounting business risks that provisions on default and termination cannot be enforced against the client.
The assignment agreement is a living document, which often cannot remain unchanged throughout the lifetime of the assignment. In many
cases, it is not sufficient just to draw up an assignment agreement when establishing the assignment; the assignment agreement must be
kept up to date with changes in contractual parties, tasks, regulations, etc.
In the case of minor changes, it is not necessary to draw up a new assignment agreement. Endorsements can instead be made on
the existing assignment agreement, an addendum can be drawn up to this, or the change can be explained in a letter or an e-mail to the
client. An example of such a minor change is a change of the accountant responsible for the assignment. Documentation of the change is
kept together with the assignment agreement, as part of the assignment documentation.
Termination of the assignment agreement must take place by means of a written declaration (declaration of termination).
Both the accounting firm and the client can terminate the assignment agreement in the event of significant default.
Termination of the assignment agreement occurs regardless of the notice periods in the agreement.
Examples of significant default on the part of the accounting firm may be that
• the assignment has not been carried out to a significant extent in accordance with requirements given in or pursuant to law
• deadlines for reporting have not been met, and reporting has still not occurred after written notification
has been received from the client
For each assignment, there must be an overview of which powers the accounting business holds and which
natural persons the powers cover.
The accountancy business must ensure that powers of attorney are revoked upon termination of
assignments or employment, or when the power of attorney is to be transferred to others in the accountancy business.
It is not sufficient to delegate access, for example in banking and Altinn; there must be a separate written authorization
from the client.
All types of authorizations can be in the name of a natural person or in a function, provided that the function is held by a
specific person (for example, the general manager or the accountant responsible for the assignment). It may appear that the
holder of the authorization can delegate the authorization to others in the accounting business.
The accountant can, by authorisation, sign public duties65 on behalf of the client. In such a case, the power of attorney should
limit the accountant's responsibility to ensuring that the tasks are in accordance with the recorded information. In any case, the
authorized person has full responsibility towards the relevant authority for the correctness of the submitted information.
Authorization for electronic task delivery is also required when completing tasks, even if the accountant does not sign/submit.
A bank power of attorney should state the account number for the bank accounts covered by the power of attorney, as well
as any limitations in the power of attorney (for example, that it should only apply to certain types of payments).
Revocation of a power of attorney that refers to natural persons can be waived if the power of attorney states that it only
applies as long as the person is employed in the accounting business.
When a power of attorney is no longer valid, the accounting firm should ensure that access to, for example, the bank
and Altinn is removed.
4.1 Order
If the client's accounting material is not arranged upon receipt, the accounting material must be returned to
and arranged by the client or arranged by an accountant, in accordance with what follows from the assignment
agreement.
The requirement for order applies to both paper accounting material and electronic accounting material66 .
4.2 Storage
The accounting firm must ensure orderly and reliably secured storage67 of the client's accounting
material as long as the accounting firm is in possession of it.
When the client's accounting material is in the accounting firm's possession, the accounting
firm must ensure that requirements for control trails between documentation, bookkeeping/
specifications and mandatory accounting reporting are complied with throughout the retention period68 .
In the case of ongoing receipt of accounting material, the overview must at least state the time at which the
accountant closes the accounting period for bookkeeping as a basis for reporting.
The requirement for such an overview (log) applies to both accounting material on paper and accounting
material that the accountant receives and/or delivers electronically. The requirement does not apply where the
client only gives the accountant access to accounting material that is in the client's possession, for example in
the case of electronic storage solutions.
As an alternative to keeping a log of the receipt of accounting material as mentioned in the first paragraph, a log can be kept
of the cases where the receipt is delayed in relation to the deadlines set out in the assignment agreement.
The accounting firm should consider whether the overview should contain a signature from the recipient upon
delivery, as well as a note on what the delivery includes and how it is carried out.
The accounting firm cannot exercise a right of retention in accounting material that has been received from
the client, even if the fee for the work performed has not been paid. The same applies to accounting material
prepared by the accounting firm for which remuneration has been paid.
Booked information in the accounting system must be handed over electronically to the client in the same way
when the latter requests this, provided that remuneration has been provided for the bookkeeping.
If the client does not want the accounting material handed over, and the retention period has expired, the
accounting material must be shredded or deleted within one year after the end of the retention period.
The medium and format to be used for delivery should be agreed with the client in the assignment
agreement, as an attachment to this, per email or otherwise. Unless otherwise agreed, electronic disclosure of book-entry
information should take place in the accounting system's data format.
67 Cf. Bookkeeping Act § 4 No. 9 and § 13, Bookkeeping Regulations Chapter 7 and NBS 1 Securing accounting material, as well as Personal Data Act § 13 and Personal
Data Regulations Chapter 2.
68 Cf. Bookkeeping Act § 4 No. 7 and § 6, as well as NBS 2 Control Track.
69 Cf. the accountants regulations § 3-1 third paragraph.
The requirement to shred or delete accounting material ensures, among other things, that
requirements in the Personal Data Act are met. If the accounting firm does not wish to shred or delete all accounting material
after the end of the retention period, the accounting firm must as a minimum review the accounting material and shred or delete
the information that follows from requirements in the Personal Data Act70 .
The rules on right of retention in point 4.4 do not apply to public control authorities. If the accounting firm wishes to
assert its right of retention against the client, debt board or trustee, it should be agreed that the public control authority delivers
the accounting material back to the accounting firm.
The accounting profession is required to provide public control authorities with the necessary assistance to inspect the
accounting system and accounting material, as well as to make equipment and software available for this71 .
No remuneration can be demanded from the control authorities for such disclosure or assistance.
The rules on right of retention in section 4.4 apply in the same way here.
The accounting firm is also required to assist the debt board and estate administrator free of charge with information
about the debtor's accounting and business conduct73 . The obligation to provide and assist only applies to tasks already
performed for the debtor (principal). The duty to provide assistance is limited to providing factual information to the debt board
and trustees about the debtor's accounting and business management, without carrying out further assessments. In other words,
the accounting business is not obliged to carry out new tasks free of charge for the debt board or estate administrator.
The parties can agree in writing that the accounting firm will also provide services after termination of the assignment
74 Cf. Bookkeeping Act § 13b, Bookkeeping Regulations § 7-7 and NBS 3 Electronic availability for 3.5 years.
storage of the client's accounting material, and/or electronic access to recorded information, on behalf of the client. The formal
responsibility for storage nevertheless rests with the client.
If the accounting firm is unable to hand over the client's accounting material or accounting data as a result of the end of
operations at the client's, and it has not been agreed that the accounting firm shall ensure the storage, affected parties may be
given a reasonable period of time to request the accounting material be handed over. If no one shows interest within the deadline,
accounting material on paper can be shredded and electronic accounting material deleted from storage media75 . Affected parties are
normally considered owners with personal liability, board members, general manager, bankruptcy estate, local police authority, tax office,
the municipal tax collector and auditor. 30 days is normally considered a reasonable period. Any disclosure of the accounting material
must be based on concrete authority for disclosure, and assessed in relation to the accounting firm's duty of confidentiality76 .
The rules on right of retention, medium and format in section 4.4 apply in the same way here.
5 Assignment execution
5.1 General
The accountant must carry out his assignment in accordance with the assignment agreement and requirements given in or
pursuant to law, and also otherwise contribute to ensuring that the client's interests are safeguarded.
Based on an assessment of the assignment's risk, complexity, size, etc., the accountant must decide whether it is necessary to
carry out regular activities to follow up the client's internal routines, or whether it is sufficient to follow up changes that are
revealed through the execution of the assignment in general.
If the accountant chooses to regularly ask the client about changes in internal routines, this must happen at least annually.
The accountant must note the date for this in the assignment documentation. If the accountant instead chooses to update
the assessment if, in connection with the execution of the assignment, changes are otherwise discovered in the client's internal
routines, the accountant must at least annually note in the assignment documentation whether such changes have been
discovered or not.
If, in the performance of his assignment, the accountant discovers weaknesses in the client's internal routines, the
weaknesses must be raised with the client. In the case of significant weaknesses and repetitions, reporting to the client
must be done in writing.
The requirement to report violations of the law basically applies to violations of regulations related to
75 Cf. also the Personal Information Act § 28 first paragraph and the Personal Information Regulations § 2-11 fifth paragraph.
76 Cf. Section 10 of the Accountants Act.
the mission execution. Examples are bookkeeping, accounting, company, tax or levy rules.
The accountant should also raise with the client breaches of other regulations, if the accountant comes across such
breaches in the execution of the assignment. Examples are the working environment and privacy rules, as well as
provisions on creditor benefits77 .
If the accountant suspects that a transaction is connected to the proceeds of a criminal offense or terrorist
financing, further investigations must be carried out to confirm or disprove the suspicion. If investigations do not
disprove the suspicion, the accountant must send information to Økokrim about the transaction in question and
about the circumstances that have led to the suspicion79 .
The client is responsible for preparing the invoicing basis, unless otherwise stated in the assignment
agreement. As long as the invoicing basis is sufficiently specified, the accounting firm has no obligation to
verify the invoicing basis.
79 Cf. Chapter 3 of the Money Laundering Act and Chapter 3 of the Money Laundering Regulations.
80 Cf. in particular the Bookkeeping Act § 10 and the Bookkeeping Regulations § 5-1-1 to § 5-1-8.
81 Cf. the excise duty regulations of 11.12.01 no. 1451 § 5-8.
82 Cf. the bookkeeping regulations § 5-2-2 to § 5-2-8.
83 Cf. Section 13 of the Bookkeeping Act and Chapter 7 and Chapter 8 of the Bookkeeping Regulations.
84 Cf. in particular the Bookkeeping Act § 10 and the Bookkeeping Regulations § 5-1-1 to § 5-1-8.
The accountant must make payment reminders and interest invoicing in accordance with the frequency that follows
from the assignment agreement, and in accordance with requirements given in or pursuant to law89 .
If no rates have been agreed for dunning fee and interest on late payment, the accountant should contact the client
for information on whether to collect dunning fee and interest on late payment.
5.5.7.3 Collection
Where no other agreement has been made with the client, an overview of receivables ready for debt collection
must be approved by the client before being sent to the debt collection company. The accountant shall not carry out collection action
85 Cf. in particular the Bookkeeping Act § 10 and the Bookkeeping Regulations § 5-1-1 to § 5-1-8.
86 Cf. Bookkeeping Regulations § 5-2-7 and GBS 1 Issuance of credit notes.
87 For example invoice journal.
88 Cf. Bookkeeping Act § 7 second paragraph and the Bookkeeping Regulations § 4-1.
89 Cf. also the debt collection regulations of 14.07.89 no. 562 and the late payment interest act of 17.12.76 no. 100.
90 Cf. also the debt collection regulations and the Late Interest Act.
• fulfills requirements for a separate tax deduction account, including meeting the deadline for depositing
tax withholding funds on a tax withholding account, possibly holding a sufficient bank guarantee for withholding liability99
• has a satisfactory routine for follow-up of occupational injury insurance100 and compulsory occupational pension
(OTP)101
• has a reassuring routine for claiming and following up on any refunds, for example of sickness benefits102, parental
benefits, etc., as well as reporting withdrawals from such benefits
• follows up the accountant's reports and reports any errors or deficiencies
• fulfills retention obligations for accounting material, for example salary documentation, employment reports,
103
specification of benefits subject to salary information etc.
is prepared.
The client is responsible for preparing the salary basis, unless otherwise stated in the assignment agreement.
As long as salary etc. is satisfactorily documented, the accountant has no obligation to verify the salary basis.
91 Act of 13.05.88 no. 26 on debt collection activities and other recovery of overdue monetary claims.
92 Cf. the Working Environment Act of 17.06.05 No. 62 § 14-5.
93 Cf. the Information Act of 22.06.12 No. 43 § 3 and the National Insurance Act of 28.02.97 No. 19 § 25-1 (registration in the employer register and notification to the employee register).
94 Cf. the book-keeping regulations § 5-6 for those obliged to keep books and the tax payment regulations § 5-11-2 for those not obliged to keep books.
95 Cf. the tax payment regulations § 5-6-11.
96 Cf. the tax payment regulations § 5-6-12.
97 Cf. the tax payment regulations § 5-6-13.
98 Cf. the Working Environment Act § 14-15 fifth paragraph and the tax payment regulations § 5-10-20 first paragraph.
99 Cf. the Tax Payments Act of 17.06.05 No. 67 Section 5-12.
100 Cf. Occupational Injury Insurance Act of 16.06.89 No. 65 § 3.
101 Cf. OTP Act of 21.12.05 no. 124 § 2.
The accountant should continuously assess the need to ask the client whether personnel information reported in
the a-report has been updated.
In addition to complete and correct registration, accountants should pay particular attention to the use of the correct
description of salary benefits etc. in the a-report, rates for expense allowances etc., as well as calculation codes for
employer's tax.
Withdrawals and other deductions must be carried out in accordance with written documentation106. This
also applies to changes and termination of such features.
If the accountant does not have access to information from the tax card, the accountant should ask the client
whether such information can be obtained before payment of salary. If the information from the tax card cannot be
obtained, the Tax Payments Act107 applies .
By report is meant a written notification to the client in accordance with the assignment agreement, based on
registered salary bases in the period (for example salary statistics).
The accountant must prepare a basis for the payment of wages, tax deductions, expenditure deductions,
quotas, insurance deductions, etc.
If the payslip or compilation statement (annual statement) of salary is sent to the employee electronically
this must be done in a way that satisfies requirements for the protection of personal data.
105 Cf. Tax Payments Act § 5-4 and § 5-5, as well as the Tax Payment Regulations § 5-4 and § 5-5.
106 Cf. Working Environment Act § 14-15 second to fourth paragraph and Chapter 14 of the Tax Payments Act.
107 Cf. Tax Payment Act § 5-5 and Tax Payment Regulations § 5-5.
108 Cf. the bookkeeping regulations § 5-6 and the tax payment regulations § 5-11-1.
109 Cf. the tax payment regulations § 5-11-2.
110 Cf. the Working Environment Act § 14-15 fifth paragraph and the tax payment regulations § 5-10-20 first paragraph.
The employee must receive a pay slip when the salary is paid, or immediately after this.
Compilation statement (annual statement) salary can be included in the last payslip for the year.
Sending the national identification number must be secured so that it is not accessible to anyone other than the addressee111 .
Payslips and compilation statements (annual statements) salary may also contain special features that tell something
about a person's life situation, criminal convictions or other matters with high requirements for confidentiality112 .
5.6.9 Insurances
If, according to the assignment agreement, the accounting firm is to administer the client's
personnel insurance, the accounting firm must ensure that known changes in working conditions are also
reported to the insurance company.
Examples of personnel insurance are occupational injury insurance, compulsory service pension (OTP),
health insurance and group life insurance. Information about changes in working conditions can, for example, be found in
a-messages prepared by the accounting firm.
The accounting firm should introduce routines for division of labor, so that the same person cannot both register
and approve a payment114. The division of labor can take place internally in the accounting firm, or between the
accounting firm and the client.
The client is responsible for the basis of payment, unless otherwise follows from the assignment agreement. As long as the
content of the payment basis is sufficient to register payments in the payment solution and prepare documentation of payment
transactions, the accountant has no obligation to verify the payment basis. This applies as long as the accountant does not
understand that the payment basis is unreasonable
or unlikely, based on a reasonableness assessment. Payment bases that appear unreasonable or improbable should be
discussed with the client.
When paying abroad, the accountant must familiarize himself with the routines for foreign payments at the client's
bank connection, as well as any special requirements for such payments.
Registration of payment information should take place in sufficient time before the due date, so that payment can be made at the right time.
Necessary payment information can be information about the payee, KID number, account number, due date,
currency, IBAN (international bank account number) and BIC/SWIFT (bank identification).
5.7.5 Liquidity
The client is responsible for ensuring sufficient liquidity to carry out payments.
The accountant must not himself make a binding prioritization of claims against the client.
Accountants should normally recommend the following priorities for the client118:
1. salary or other remuneration to people other than owners, the board and general manager (including holiday pay), as well as
withholding tax (if not deposited into a separate tax withholding account)
2. wealth and income tax, value added tax and employer's tax
3. other requirements (for example, accounts payable and loan servicing)
4. payments to owners, the board and general manager
5. Claims that, by agreement or for other reasons, must stand behind other claims (for example, subordinated loans)
6. gifts
116 Cf. Section 13 of the Bookkeeping Act, Chapter 7 of the Bookkeeping Regulations and NBS 1 Safeguarding of accounting material.
117 Cf. Bookkeeping Act § 10, Bookkeeping Regulations § 5-11 and NBS 7 Documentation of payment transactions.
118 Cf. also the insurance coverage act of 08.06.84 no. 59 chapter 9.
The principal's approval of payments can take place at various stages in the payment process, such as
• prior approval of the basis of payment (purchase documents, etc.)
• attestation of the payment proposal from the accountant
• subsequent approval of the final payment in the payment solution
When recording transactions and other accounting dispositions, the accountant must within
119 Cf. Section 10 of the Bookkeeping Act, as well as Chapter 5 and Chapter 8 of the Bookkeeping Regulations.
120 Cf. Bookkeeping Act § 7, cf. Bookkeeping Regulations § 3-1.
121 Cf. Section 11 of the Bookkeeping Act, Chapter 6 of the Bookkeeping Regulations and NBS 5 Documentation of the balance sheet.
122 Cf. Bookkeeping Act § 7 third paragraph and the Bookkeeping Regulations subsections 5-3 and 5-4.
123 Cf. Section 13 of the Bookkeeping Act, Chapter 7 of the Bookkeeping Regulations and NBS 1 Safeguarding of accounting material.
124 Cf. Auditors Act of 15.01.99 No. 2 § 5-4, cf. § 5-2 fourth paragraph.
125 Cf. Tax Administration Act § 11-1 and § 14-1, Tax Payments Act § 5-13a and § 5-16 and the Customs Act of 21.12.07 No. 119 § 13-5 and § 16-16.
126 Cf. in particular § 10 of the Bookkeeping Act, as well as Chapter 5 and Chapter 8 of the Bookkeeping Regulations.
general framework decide on the use of bookkeeping accounts, balance sheet entry versus profit and loss entry
(activation/costing), as well as tax and duty-related treatment. Any discrepancies with the client must be clarified.
The starting point is that the accountant assesses all documentation of book-entry information. In cases where the documentation
is prepared by or on behalf of the client based on fixed routines, templates and systems, the duty to ensure that the documentation
meets the requirements can be complied with by the accountant assessing the routine, templates and systems, and then only
checking selected parts of the documentation
(random samples). An example of this could be the use of electronic invoicing.
Documentation of complicated and unusual transactions and dispositions has a greater risk of errors and omissions than
documentation of simple and routine transactions and dispositions, and should therefore be subject to a more comprehensive
assessment by an accountant.
When the accountant has to decide on the use of bookkeeping accounts, balance sheet versus profit and loss accounting and
tax treatment, this can be based on a discretionary assessment of the risk of error.
Routine and simple transactions and dispositions, where the processing follows ordinary regulations, and where the type of
transaction is known to both the client and the accountant, may require a small degree of assessment on the part of the
accountant. On the other hand, unusual and complex transactions and dispositions, where there may also be special rules for
processing, or where the type of transaction is not known to the client and/or accountant, may require a greater degree of
assessment on the part of the accountant.
As long as transactions and other accounting dispositions are satisfactorily documented, the accountant has no obligation to
verify the legitimacy of the recorded information. This applies as long as the accountant does not understand that the content of
the documentation is incorrect or improbable, based on a reasonableness assessment. Documentation that appears
unreasonable or improbable should be discussed with the client.
Documentation prepared by an accountant may be relevant, for example, for depreciation, corrections, loss entries,
personal withdrawals, estimates, tax calculations, annual settlement dispositions, etc.
The chart of accounts should, to the greatest extent possible, follow the Norwegian standard chart of accounts128 .
5.8.2.5 Traceability
The accountant must ensure a two-way audit trail between documentation, book-entry information and
mandatory accounting reporting.129
For each period of mandatory accounting reporting130 , at least the following accounts must be included in the balance sheet
be reconciled:
• accounts receivable and accounts payable
• cash and bank balances
• tax withholding and employer's contribution due
• VAT payable
Mandatory accounting reporting of wages etc. (submission of a notification) does not in itself entail an obligation to
agree. Due tax withholding and employer's contribution are reconciled for each period with other mandatory accounting
reporting.
An example of reconciling profit and loss items could be to carry out a gross profit analysis for goods sold, as a
reasonableness assessment of sales revenue and cost of goods.
If the client or a third party carries out reconciliations, the accountant should ensure that the reconciliations are
carried out and documented, and request that missing reconciliations be carried out.
129 Cf. Bookkeeping Act § 4 No. 7 and § 6, and NBS 2 Control Track
130 Cf. Bookkeeping Act § 3 and the Bookkeeping Regulations § 2-1.
Examples of external sources can be banks and other financial institutions, customers and suppliers.
5.8.3.4 Documentation
Reconciliations must be documented so that they can be verified. In addition to the reconciliation itself, the
documentation must contain underlying documentation and an explanation of any deviations.
5.8.4.1 Frequency
Periodic accounting reports to the client must be prepared with the frequency that follows from the
assignment agreement.
The need for and usefulness of periodic accounting reports, for example for management purposes, should be made
visible to the client. For joint-stock and public limited companies, the client should be made aware of the general
manager's reporting obligations to the board131 .
Furthermore, it is recommended to
• report with the degree of detail and in the manner considered appropriate for the client, preferably on the
basis of the Accounts Act's layout plans for profit and loss accounts and balance sheets132
• report age-distributed overviews of accounts receivable and accounts payable
• accrue significant income and costs, based on equal accrual principles from period to period
period
• inform the client if changes have been made to the reporting layout plan,
degree of detail etc., or changes have been made to accrual principles
If periodic reporting to the client is to be carried out in a language other than Norwegian, Swedish, Danish or English,
the reporting must be done in two languages where one of the languages is Norwegian, Swedish, Danish or English.
The accounting firm's name can appear, for example, in a cover letter or the e-mail in which the accountant sends the
accounting reporting or refers to where the reporting is ready for the client. It is not necessary for the accounting firm's
name to appear in each individual part of the overall reporting.
5.8.4.3 Comments
The following must be commented on in connection with periodic accounting reporting:
• assumptions on which the accounts are based, and as an accountant cannot expect the client to be aware of
or see the significance of • weaknesses in the client's internal routines that are recurring or that have not
been clarified, cf. point
5.2
131 Cf. Section 6-15 of the Companies Act and Section 6-15 of the Public Limited Liability Companies Act.
• the principal's significant or repeated breach of the assignment agreement or requirements given in or pursuant to
law, cf. point 5.3
• ambiguities and questions in general
The accountant must assess whether there is a need to link comments to negative developments in the client's
equity, liquidity and/or earnings.
The accountant must use the accounting principles and assessment rules135 that follow from the chosen
accounting standards. When choosing between several possible accounting principles or assessment rules, the
accountant must assess whether the client should be informed about the choice.
In the assessment of whether the client should be informed about a choice between several possible accounting standards,
accounting principles or assessment rules, account should be taken of the significance of the choice for the client's accounts,
reporting obligations, expenses for accounting etc.
The requirements apply in the same way to a client who voluntarily prepares a complete annual account in accordance with the
rules of the Accounting Act.
Income statement and balance sheet based on the Accounting Act's accounting principles and assessment rules138 can
be a better management tool than accounting based on tax values. At the same time, the utility for any other external
accounting users than the tax authority may be higher, for example credit institutions and other creditors. The
accountant should therefore consider informing the client about the various considerations of interest, so that the client can take
a stand on whether the profit and loss account and balance sheet should show accounting or tax values. At the same time, the
client should be informed that the realization principle is, in any case, used as a tax accrual principle139, which means that the
choice has no effect on taxable income and payable tax.
and/or economic task, unless they are insignificant140. Profit and loss accounts must be reconciled if this is
considered essential to ensure correct accounting.
The accountant must review the balance sheet and assess the documentation of significant amounts that appear to
be unreasonable or improbable.
Reconciliations in connection with the annual settlement should, among other things, include the following (in addition to what
follows from point 5.8.3.2):
• reconciliation of inventory against the inventory list141, possibly a summary of this
• assessment of the reasonableness of customer and supplier balances using age-distributed balance lists
(the assessments must be justified and documented), as well as reconciling any account statements received from customers
and suppliers against the book balance
• reconciliation of bank accounts against annual statements
• total reconciliation of salary information and benefits subject to employer's tax, tax deductions and
employer's tax against reported information142
• total reconciliation of value added tax in VAT declarations against the accounting basis for outgoing and incoming
VAT on an annual basis
If reconciliations and documentation are prepared by someone other than the accounting firm that prepares the annual accounts
and/or business statement, the accountant must ensure that the reporting basis is documented and reconciled, and ensure that
missing documentation and reconciliations are obtained or prepared.
The accountant must document the completion of these actions as part of the assignment
documentation.
140 Cf. also Section 11 of the Bookkeeping Act, Chapter 6 of the Bookkeeping Regulations and NBS 5 Documentation of the balance sheet.
141 Cf. the Bookkeeping Regulations § 6-1.
142 Cf. determination form RF-1022 Salary and pension costs. The reconciliation should normally be based on a-message reconciliation (A07) from Altinn.
143 Cf. Chapter 7 of the Accounting Act and good accounting practice.
144 Cf. Bookkeeping Act Section 4 No. 7 and Section 6, and NBS 2 Control Track.
145 Cf. Accounting Act § 3-5 and Tax Administration Act § 8-14.
146 Cf. Bookkeeping Act § 13 second paragraph, cf. first paragraph no. 1.
Useful information about the client's business can be found, among other things, in comments to periodic accounting reports,
auditor's numbered letters and other correspondence.
Examples of assessments and estimates can be obsolescence in inventory, provision for losses on receivables, write-down
of fixed assets, valuation of financial instruments, revenue recognition of construction contracts according to the current settlement
method, etc. Uncertainty can, for example, be linked to the assumption of continued operation.
For assignments that do not include ongoing bookkeeping, only assistance with the preparation of annual accounts and/or tax
assessment forms, the requirements in point 5.10 also apply.
The accountant must document the completion of these actions as part of the assignment
documentation.
In some cases, work is divided between several parties other than the client and the accountant who assists with the
preparation of financial reporting, for example another accountant who carries out ongoing bookkeeping. The key point is that
the assignment agreement delimits which tasks the accountant must perform, and which tasks are performed by the client
himself or others who have an accounting assignment for the client. In cases where work is divided between several
accountants, consideration should be given to asking the client to exempt the accountants from the duty of confidentiality147, so
that the accountants can obtain information directly from each other.
Common examples of mandatory accounting reporting are annual accounts, tax assessment forms, VAT notices and A-
notices.
The accountant should consider informing recipients of accounting reporting to public authorities that the accountant has only
148
assisted with the reporting, and has not carried out ongoing bookkeeping.
In the case of purely reporting assignments that include the preparation of annual accounts and/or tax assessment forms, the
requirements in point 5.9 also apply.
6 Assignment documentation
6.1 Purpose
The assignment documentation must contain essential information about the client and the accountant
assignment. The assignment documentation must also document the work that the accountant has carried out
for the client.
The assignment documentation should function as an appropriate tool in the ongoing work on the assignment.
6.2 Content
Clear documentation of the accountant's work must be prepared for each client149 .
The assignment documentation shall not contain the client's accounting material which is required
to be kept.
Work carried out by others, for example the client, auditor or another accountant, is not initially required to be kept as part
of the accountant's assignment documentation. This may, for example, apply to reconciliations and documentation of
balance sheet items which, according to the assignment agreement, do not
carried out by an accountant. Documentation of work carried out by others on behalf of the accountant, where the accountant is
responsible for the work according to the assignment agreement, is to be considered assignment documentation.
The assignment documentation is internal working documents for the accountant, and is the accountant's property.
If parts of the client's accounting material are also required as the accountant's assignment documentation, and the
accountant does not keep the accounting material on behalf of the client, each of the parties must keep their own
copies.
The progress report will, among other things, substantiate that the work has been carried out by the time that follows
the assignment agreement and requirements given in or pursuant to law.
150 Cf. also Section 22 of the Money Laundering Act and Section 17 of the Money Laundering Regulations.
151 Cf. also Section 22 of the Money Laundering Act and Section 17 of the Money Laundering Regulations.
In the case of annual settlement assignments that are purely reporting assignments (does not include ongoing bookkeeping),
the requirements for assignment documentation in point 6.2.7 also apply.
In the case of pure reporting assignments that include the preparation of annual accounts and/or tax assessment forms, the
requirements for assignment documentation in point 6.2.6 also apply.
6.3 Access
Assignment documentation must not be lent to the client, auditor or others without approval from the accountant
responsible for the assignment. In any case, the assignment documentation must not be lent out where there is a risk that
the contents may be lost.
Approval of lending can be given as a general routine in the accounting business, for example by the client's chosen auditor
being allowed to borrow the assignment documentation in return for acknowledging receipt.
The accountant's own copies of periodic accounting reports to clients, and reconciliation documentation
associated with the periodic accounting reports, can be kept for a shorter period of time if the accounting business and the
accountant responsible for the assignment consider this to be reasonable. Such assignment documentation must in any case be
kept for a minimum of two years after the end of the accounting year159 .
156 Cf. Tax Administration Act § 8-14 and Tax Administration Regulations § 8-2-3 to § 8-2-5.
158 Cf. the accountants regulations § 3-2 second and third paragraphs.
The assignment documentation can be stored electronically or on paper, or as a combination of electronic storage
and paper documentation. Electronic storage can take place in various system solutions, including so that parts of the
assignment documentation are stored, for example, in the accounting and annual settlement systems that are used.
Parts of the assignment documentation can be stored with the client, if it is ensured through agreement that the accounting firm
and external auditors are given access to the assignment documentation throughout the retention period. The accounting firm
is nevertheless responsible for keeping the assignment documentation in accordance with the law, regulations and good
accounting practice.
The accounting firm should therefore carry out a risk assessment relating to storage with the client.
160
If the assignment documentation is not kept together at the accounting firm, the order requirement means that the accounting
firm maintains an overview showing where the various parts of the assignment documentation are kept, and how access to
these is secured.
The requirements for orderly and reliably secured storage are otherwise understood in the same way as under the
Bookkeeping Act161 . There are no specific requirements for file formats, storage media etc. Storage of the assignment
documentation, for example in word processing or spreadsheet format, is accepted as long as the accounting firm overall
believes that the security is satisfactory. If parts of the assignment documentation coincide with accounting material kept on
behalf of the client, point 4.2 applies. This means, among other things, that storage in word processing or spreadsheet
format is usually not sufficient in such cases.
If the assignment documentation contains personal data, the requirements in the Personal Data Act to ensure
confidentiality also apply162 .
The requirement to shred or delete assignment documentation ensures, among other things, that requirements in the Money
Laundering Act and the Personal Data Act are met. If the accounting firm does not wish to shred or delete all assignment
documentation after the end of the retention period, the accounting firm must as a minimum review the assignment
documentation and shred or delete the information that follows from requirements in the Money Laundering Act and the
Personal Data Act163 .
7 Quality control
160 For accountancy firms, such an assessment is necessary to meet the requirements of the risk management regulations, see point 2.1.
161 Cf. Bookkeeping Act Section 4 No. 9 and Section 13, Bookkeeping Regulations Chapter 7 and NBS 1 Safeguarding of accounting material.
162 Cf. Section 13 of the Personal Data Act and Chapter 2 of the Personal Data Regulations.
163 Cf. Money Laundering Act § 22 third paragraph and Personal Data Act § 28 first paragraph.
• actions in connection with the annual settlement have been carried out, cf. point 5.9.4
• reporting is carried out in accordance with the assignment agreement and requirements given in or pursuant to law
• progress overview is up to date
• assignment documentation is up to date
The frequency and scope of the quality control may vary, based on a documented assessment of the
employee's competence, capacity and experience, as well as the client's routines and the complexity of the
assignment. Quality control must be carried out for each financial year, and at least in connection with the end of the financial
year. For bookkeeping assignments without the preparation of annual accounts and/or tax assessment forms, this means that
the quality control is carried out before the final balance sheet is sent to the person who is to prepare annual accounts and/or
tax assessment forms. For annual settlement assignments, this means that the quality control is carried out before submitting
the annual accounts and tax assessment forms. The control may consist of random samples.
The accounting business should assess quality controls aimed at work carried out by the accountant responsible for the
assignment. This is particularly relevant for assignments where there is no auditor who checks the accounts. If there are no
others in the accounting business who can carry out quality control of work carried out by the accountant responsible for the
assignment, it should be considered to use checklists. This is particularly relevant in connection with the annual settlement,
including when preparing annual accounts and/or determination forms
tax.
The routines for quality control should be recorded in writing. Checklists should be used when carrying out the quality
control, to ensure that all relevant and significant conditions are assessed.
ATTACHMENTS:
Recommendation of December 2012, updated June 2014, prepared by Regnskap Norge, the Norwegian Economic Association and
The Norwegian Association of Accountants
Contents
1 Purpose
Users of the annual accounts will benefit from confirmation that the accountant has followed the law, regulations
and good accounting practice when preparing the accounts. The statement confirms this. For the reader of the
statement, this means security for the quality of the preparation.
2 Responsibility
What is confirmed in the statement is that the accounting practice has followed the Accounting Act164 , the
Accounting Regulations165 and good accounting practice166 when preparing the annual accounts. The responsibility
for accountants should therefore initially not be greater than what already follows as a consequence of the Accountants
Act and good accounting practice. Nevertheless, the responsibility becomes more visible when the accountant confirms
through the statement that essential aspects of good accounting practice have been followed. In practice, this alone
could lead to increased responsibility for the accountant.
The last sentence in the statements, stating that these cannot be used in connection with claims against accountants
beyond the responsibility that follows from the general professional responsibility, is intended to limit the accountant's
responsibility to what follows from the general professional responsibility in any case. The section is voluntary, and can
be deleted if this is desired (cf. point 3). Professional responsibility means that the accountant's diligence and any
reprehensible conditions are assessed in relation to what an average competent and skilled accountant would have
done. It is emphasized for the record that the professional liability is a strict liability for negligence which, in line with
the accountants' increasing competence, also places ever greater demands on the accountant as a service provider.
3 Changes in text
The text of the statements must not be changed during use. Only the fields marked for change can and must be
changed (name, amount, year, etc.). The last sentence in the statements, that these cannot be used in connection with
claims against accountants beyond the responsibility that follows from general professional responsibility, can however
be deleted if this is desired.
There is no occasion to make your own reservations or other comments in the statements. See also point 9 on
errors, uncertainties and deficiencies in connection with the accounts.
It is the accounting firm that has assisted with the preparation of the client's annual accounts that can issue a statement.
An accounting firm cannot issue a statement in cases where another accounting firm has assisted with the preparation
of the annual accounts for the client.
Where the authorized accountant has a vested interest linked to the client, such a statement should not be issued.
Self-interest can, for example, be due to ownership shares, board membership, family connections or loan relationships.
An authorized accountant who is employed by the company to which the annual accounts relate cannot issue such a statement.
The accounting firm cannot hand over the statement to anyone other than the client (that company
the annual accounts apply), unless the client has released the accountant from the duty of confidentiality in writing172 .
Similarly, there is no obligation for the accountant to issue such a statement even if the client requests this.
The fact that the accounting business has performed other services for the client, for example payroll, invoicing, budgeting
or consulting services, does not mean that the accountant must issue a statement that includes ongoing bookkeeping services
in addition to assistance with the preparation of the annual accounts.
Both statements relate to the client's company accounts. No statement has been prepared for group accounts. The statements
can only be used for the annual accounts, and not for period accounts.
170 Cf., among other things, the Accounting Act of 17.07.98 no. 56 § 1-2.
171 Cf. Auditors' Act of 15.01.99 no. 2 § 2-1.
172 Cf. Section 10 of the Accountants Act.
• To avoid confusion between the accountant's opinion and an independent auditor's report173, it is specified in the opinion that the
accountant has not audited the annual accounts, and that the opinion must not be confused with an independent auditor's report. • It
is specified that the statement cannot be used in connection with claims against accountants beyond the responsibility that follows
from general professional responsibility. The sentence can be deleted if this is desired, cf. point 3.
• It is the accountant responsible for the assignment who must sign the accountant's report.
The accountant is obliged, among other things, to follow up on any uncertainties, assessments, estimates and other significant
questions relating to the annual accounts, and to assess the documentation of significant amounts that appear unreasonable or
improbable. These requirements must be seen in the context of the accountant's duty to withdraw from the assignment if the accountant
is unable to produce or provide a basis for agreed statutory reporting175 .
If, after this, the accountant believes that the annual accounts with note information are not in accordance with the law, regulations and
good accounting practice, the accountant cannot issue a statement. In that case, the accountant must report the deficiencies in writing to
the client.
We have assisted "Regnskapskunden AS" with the preparation of annual accounts in accordance with the Accounting
Act. The annual accounts consist of a profit and loss account, balance sheet and note information177. As can be seen from
the annual accounts, the annual result is NOK. XXX.XXX . The accounting equity amounts to NOK
XXX.XXX of the balance sheet sum of NOK. XXX.XXX .
For the accounting year, we have also carried out ongoing bookkeeping in accordance with the Bookkeeping Act. There is an
assignment agreement between the company and the accountant that regulates the scope of services and the division of labor in
more detail. The assignment agreement may include tasks other than ongoing bookkeeping and assistance with the preparation of
the annual accounts, for example consultancy services, which are not covered by this statement.
It is the board and general manager178 of the company who are responsible for ensuring that bookkeeping and the
preparation of the annual accounts are carried out in accordance with the law, regulations and good bookkeeping and
accounting practice. Our assignment is carried out on the condition that relevant, complete and correct information has been
received from the company.
We have carried out our assignment in accordance with the Accountants' Act with regulations and good
accounting practice. This means that within general frameworks we have:
• carried out the bookkeeping in accordance with the Bookkeeping Act with regulations and good bookkeeping practice,
including ensuring that documentation of bookkeeping information satisfies requirements given in or pursuant to law
and otherwise shows the legitimacy of the bookkeeping information, and ensured a control trail between
documentation, bookkeeping information and annual accounts
• taken a decision on the use of accounting accounts, balance sheet versus profit and loss, as well as tax and duty-related
treatment when accounting for transactions and other accounting dispositions
• discussed with the company any weaknesses in the company's internal routines regarding
bookkeeping and preparation of annual accounts, if we have discovered such in the performance of our assignment
We specify that we have not audited the annual accounts, and this accountant's opinion must therefore not be confused
with an independent auditor's report. Nor can the accountant's opinion be used in connection with claims against
accountants beyond the responsibility that follows from general professional responsibility179 .
"Ola Nordmann"
Assignment manager / authorized accountant
We have assisted "Regnskapskunden AS" with the preparation of annual accounts in accordance with the
Accounting Act. The annual accounts consist of a profit and loss account, balance sheet and note information180. As
can be seen from the annual accounts, the annual result is NOK. XXX.XXX . The accounting equity amounts to NOK
XXX.XXX of the balance sheet sum of NOK. XXX.XXX .
For the accounting year, we have not carried out ongoing bookkeeping in accordance with the Bookkeeping Act.
There is an assignment agreement between the company and the accountant that regulates the scope of services and the
division of labor in more detail. The assignment agreement may include tasks other than assistance with the preparation of
the annual accounts, for example consultancy services, which are not covered by this statement.
It is the board and general manager181 of the company who are responsible for the preparation of the annual
accounts in accordance with the law, regulations and good accounting practice. Our assignment is carried out on the
condition that relevant, complete and correct information has been received from the company.
We have carried out our assignment in accordance with the Accountants' Act with regulations and good
accounting practice. This means that within general frameworks we have:
179
The sentence can be deleted if this is desired.
180 If the annual accounts also contain a cash flow statement, this must be included in the text: "The annual accounts consist of an income statement, balance sheet, cash flow statement and note
information."
181 For enterprises with a board and general manager: "the board and general manager of"
For companies with a board, but without a general manager: "the board of"
For responsible companies without a board "participants in"
For sole proprietorships: "owner of"
• discussed with the company any weaknesses in the company's internal routines regarding
bookkeeping and preparation of annual accounts, if we have discovered such in the performance of our
assignment
• based the annual accounts on a reconciled and documented balance sheet •
discussed any uncertainties, assessments, estimates and other significant issues related to
the annual accounts with the client
• assessed the documentation of any significant amounts that have appeared to be unreasonable or
unlikely
• assisted with the preparation of the annual accounts in accordance with the law, regulations and good accounting practice
We specify that we have not audited the annual accounts, and this accountant's opinion must therefore not be
confused with an independent auditor's report. Nor can the accountant's opinion be used in connection with claims
against the accountant beyond the responsibility that follows from general professional responsibility182 .
"Ola Nordmann"
Assignment manager / authorized accountant
182
The sentence can be deleted if this is desired.