Nick Pollard: Broadening auditor choice in the Scottish housing sector
Social Housing Magazine has produced an interesting article on audit provision in Scotland. Using the 2021-22 audited financial statements (AFS) returns compared to the 2017-18 AFS returns from the Scottish Housing Regulator, it presents some interesting data and perhaps enables some thoughts on how to resolve the problems.
Of the 146 RSLs in 2021-22, 142 or 97% have a financial year end of March each year. In 2017-18 that number was consistent at 97% with 154 of the 158 RSLs having a March year end so this is nothing new.
Perhaps if some of the RSLs shifted their year ends across the calendar year there would be a more even distribution of audit resources across the sector throughout the year and perhaps a reduction in cost? Although I am sure auditors will likely have a different view and comparative analysis may be a concern, it would help alleviate the massive pressure to deliver within a six-month window of March to September each year.
There is a perception that there has been a diminishing resource from the perspective of the number of audit firms in the market through M&A in the audit sector in recent years but the evidence suggests this is not the case with there being 14 firms acting in 2021-22 compared to 13 in 2017-18, more now than previously.
The lion’s share of audits in 2021-22 were performed by Alexander Sloan, RSM, Azets (formerly Scott Moncrieff) and Chiene & Tait, with almost 73% of audits being performed by these four firms.
Whereas in 2017-18 it was spread across three audit firms, Alexander Sloan, RSM and Scott Moncrieff amounting to 61% of market share. It is noticeable that KPMG and French Duncan’s market share has declined during that period. Can we tempt some firms back into the market but in so doing we and our boards have to accept the cost is a commercial cost?
The issue of two firms acting for external and internal audit remains a perceived problem, however, the reality is that most internal audit firms are completely different to external audit firms suggesting that there are in fact specialisms in the external and internal arena rather than too few firms.
The legislation also seems to be a barrier with the Housing (Scotland) Act 2010 requiring RSLs to submit accounts to the SHR within six months of the period end to which they relate however the Financial Conduct Authority (FCA) requires a seven-month period and Companies House and HMRC require a nine-month period.
If the Housing (Scotland) Bill 2023, which is to be consulted on, was to amend that date for the SHR to the FCA date then that would add a further four weeks in which to complete additional audits and firms could stagger them a little more which would help.
If the FCA could move their date to the Companies House and HMRC date of nine months and the Housing (Scotland) Bill 2023 do likewise in the Act then that could be a massive help all round.
So whilst we perhaps hold our hands up to say there isn’t much we can do in the sector maybe it is indeed in our own hands to find solutions!
Nick Pollard is group finance director at Link Group but writes here in a personal capacity