Certified Public Accountants and Auditing Oversight Board (CPAAOB / 公認会計士・監査審査会)
On this page
Wiki route
This entry sits under financial-regulators INDEX. Read it alongside FSA Supervision Bureau and Fsa Inspection Bureau for the supervisory boundary, and against Strategy Development and Management Bureau (FSA Strategy Development and Management Bureau) / FSA Planning and Coordination Bureau for the rule-making and policy interfaces. For the audit-firm side, anchor through Ey Shinnihon · Deloitte Touche Tohmatsu LLC (Deloitte Touche Tohmatsu) · Kpmg Azsa · PwC Japan LLC (formerly PwC Arata) (Big 4) and Taiyo Grant Thornton · BDO Sanyu Audit Corporation (BDO Sanyu) (mid-tier). License perimeter via Financial licenses.
1. Legal positioning
- Governing law: Certified Public Accountants Act, Article 35 (establishment of the Board), and the Act for Establishment of the Financial Services Agency
- Affiliation: an attached organization of the Financial Services Agency (an external bureau of the Cabinet Office) — positioned not in parallel with the Supervision Bureau, the Strategy and Policy Bureau, or the Planning and Coordination Bureau, but as an independent oversight board
- Headquarters location: Kasumigaseki, Chiyoda-ku, Tokyo (within the FSA main building)
- Board composition: a chairperson 1 名 + up to 9 名 members, appointed by the Prime Minister with the consent of both Houses — composed of certified public accountants, legal practitioners, corporate-accounting practitioners, and persons of academic experience
2.1 CPA Examination
- Conducting the short-answer examination (2 times a year) + the essay examination (1 times a year)
- Appointment of examiners, preparation of examination questions, and pass/fail determination — exclusively operating the entry-point gate of Japan’s accounting profession
2.2 Audit Firm Inspection
- Subjects of inspection:
- Major audit firms (Big 4: Ey Shinnihon · Deloitte Touche Tohmatsu LLC (Deloitte Touche Tohmatsu) · Kpmg Azsa · PwC Japan LLC (formerly PwC Arata)) — in principle periodic inspection every 3 years
- Scope of inspection: quality-control systems, individual audit engagements, independence, fraud response, IT controls
- Publication of inspection results: annual publication of the “Case Examples of Audit Firm Inspection Results” and “Case Examples of CPA Audit Inspection Results”
2.3 Quality Control Review
- A two-tier structure in which the CPAAOB additionally conducts monitoring of the results of JICPA’s quality control review (peer review)
2.4 International cooperation
- A member of IFIAR (International Forum of Independent Audit Regulators) — a network of global audit-oversight authorities
3. Linkage of inspection results with disciplinary action
In the flow of CPAAOB inspection / recommendation → the FSA Commissioner’s disciplinary decision, major disciplinary cases include the following (for details of each case, see the individual audit-firm pages):
- ChuoAoyama Audit Corporation (following the Kanebo window-dressing case, a 2 -month suspension of operations from 2006-07-01〜08-31 → renamed Misuzu Audit Corporation in 09-01 the same year, dissolved 2007-07 . PwC established Aarata Audit Corporation as the receiving body in 2006-06 ) — a symbolic case right after the CPAAOB’s launch
- Disciplinary action related to the Toshiba case against Ernst & Young ShinNihon LLC (now Ey Shinnihon) (2015-12-22, a 3 -month suspension of new-contract-conclusion operations [2016-01-01〜03-31] + a business improvement order + a surcharge of approx. 21 億円 — the first surcharge against an audit firm)
- Numerous improvement orders for deficiencies in the quality-control systems of mid-tier and small/medium audit firms
4. Division of roles with JICPA
| Function | CPAAOB | JICPA (Japanese Institute of Certified Public Accountants) |
|---|---|---|
| CPA examination | Administration & pass/fail determination | Recommendation of examiners |
| Registration | Supervision | Registration affairs |
| Quality control review | Monitoring (secondary) | Peer review (primary) |
| Ethics / self-regulation | Supervision | Discipline (self-regulation) |
| Inspection | Holds the authority | Disciplinary investigation |
| International cooperation | IFIAR | IFAC |
5. Position in governance
- Differs in subject from the bank / securities / insurance inspection of the FSA Supervision Bureau (FSA Supervision Bureau) — the CPAAOB covers audit quality, the Supervision Bureau covers the financial institutions themselves
- The FSA Inspection Bureau (Fsa Inspection Bureau) was merged into the Supervision Bureau in 2018 年, but the CPAAOB was not subject to that merger — it maintains its status as an independent oversight board
- Relationship with the Business Accounting Council (a separate council of the Cabinet Office) — a division of labor in which the Business Accounting Council sets auditing standards and the CPAAOB inspects audit quality
Related
- financial-regulators INDEX — parent INDEX
- FSA Supervision Bureau — supervision of the bank / securities / insurance entities themselves
- Fsa Inspection Bureau — the inspection function before the 2018 年 merger
- Strategy Development and Management Bureau (FSA Strategy Development and Management Bureau) — accounting-audit policy cooperation
- FSA Planning and Coordination Bureau — rule-making for the CPA Act / audit system
- Ey Shinnihon · Deloitte Touche Tohmatsu LLC (Deloitte Touche Tohmatsu) · Kpmg Azsa · PwC Japan LLC (formerly PwC Arata) — Big 4 inspection subjects
- Taiyo Grant Thornton · BDO Sanyu Audit Corporation (BDO Sanyu) — mid-tier inspection subjects
- Financial licenses — the regulatory boundary of the CPA Act / audit quality control
Sources
- CPAAOB official — https://www.fsa.go.jp/cpaaob/
- FSA “On disciplinary action, etc., against audit firms and certified public accountants,” Ernst & Young ShinNihon LLC (2015-12-22 administrative action: 3 -month suspension of new-contract-conclusion operations + business improvement order) — https://www.fsa.go.jp/news/27/sonota/20151222-4.html
- FSA “On the decision of a surcharge payment order against Ernst & Young ShinNihon LLC for false certification of financial documents” (surcharge of approx. 21 億 1,100 万円, the first surcharge against an audit firm) — https://www.fsa.go.jp/news/27/syouken/20160122-4.html
- ChuoAoyama Audit Corporation / Misuzu Audit Corporation (Kanebo window-dressing case, 2006-07-01〜08-31 suspension of operations, 2006-09-01 renaming to Misuzu, 2007-07 dissolution, PwC Aarata established 2006-06 ) — https://ja.wikipedia.org/wiki/みすず監査法人