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Do You Need A Compilation Engagement Report?
Canadian Notice to Readers Standards Changed December 14th, 2021
Why You May Want A Compilation Engagement Report?Published December 2, 2024 | Updated December 3, 2024
by L. Kenway BComm CPB Retired
WHAT'S IN THIS ARTICLE
Introduction | Why New Compilation Engagement Standards Were Introduced | Who Can Perform Compilation Engagements | Disclaimer Notice on Tax Returns | T2 S141 Notes Checklist Guidance | Considerations Around Liability and Negligence | Required Content of CER | What are the Different Levels of Assurance? | Compilation Engagement Reports vs. Tax Basis Financial Information | Takeaway
Effective December 14th, 2021, CPA Canada introduced new compilation engagement standards for the first time in thirty some years.
Most small business owners would know compiled financial information as Notice to Reader (NTR) financial statements. A small business owner likely provides them on an annual basis to their banker, suppliers, or other third party that requires no assurances about the state of your business.
NTR statements were usually prepared by your accountant but also non-CPAs. NTR's new name is now Compilation Engagement Report (CER). CERs provide third parties confidence with the financial information due the CPA's assistance with ensuring that the financial information is complete, accurate, and in accordance with the applicable financial reporting framework.
As the new standard now includes compliance with ethical requirements, it makes it problematic for non-CPAs to now perform a compilation engagement.
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Let's chat about the compilation engagement standards revisions and how they might affect your business.
If you are a bookkeeper who supplied internal financial statements for the tax preparer, we'll discuss how this affects you as well.
Take a moment to get a cup of tea before we start. My favourite tea these days is olive leaf - stevia bark tea.
Okay here we go.
CPA Canada has written an excellent tax blog explaining how the new compilation engagement standards affect bookkeeping services and tax work. I will recap what the tax blog touched upon.
Why New Compilation Engagement Standards Were Introduced
In discussing the new Notice to Reader compilation engagement standards, CPA Canada starts out discussing how the intrinsic nature of engagements and tax compliance work in Canada has evolved and changed over time.
Clients used to hire CPA firms to perform an audit, review or compilation engagement which would include preparing their corporate tax return. More and more small business have switched to "tax-only engagements". This type of engagement often involves using financial statements provided by the client, or financial data from their client's systems if no formal financial statements were prepared.
It is important to note that nowadays the accountant may have been involved somehow with the business's day-to-day bookkeeping in some fashion. It could be all the bookkeeping was performed by the accountant or just a few year-end adjusting journal entries.
Tax-only engagements focus solely on tax return preparation and not on the financial statements themselves. The GIFI forms and the tax return may be passed onto a third party such as the business's bank.
This changing trend led CPA Canada to introduce new compilation engagement standards.
Who Can Perform Compilation Engagements?
Do you need a compilation engagement report?In Canada, only Chartered Professional Accountants (CPAs) in public practice are qualified to issue a Compilation Engagement Report (CER). Under the new compilation engagement standards, it is essential for your CPA to assess whether you actually need a compilation engagement.
CPA Canada provided the following guidelines:
1. Scope Exclusions: Your CPA will consider certain scope exclusions related to bookkeeping and tax work to determine if a compilation engagement is necessary. According to the new standards, a compilation engagement is NOT required if:
- The accountant assisted with some or all of the bookkeeping service work.
- The financial information is used solely for government-prescribed forms, such as corporate, trust, or personal tax returns.
2. Combined Exclusions: If both exclusions apply, it generally means that a compilation engagement is not necessary. This also applies if the business owner provides the information needed to prepare the corporate tax return.
3. Value to the Client: Despite the presence of these exclusions, a compilation engagement can still be performed if it provides value to the client. It is considered a best practice to clearly define the scope of services in a written engagement letter.
Disclaimer Notice on Tax Returns
As mentioned, banks will often request a copy of the GIFI forms and tax return instead of a set of financial statements. This practice led to a disclaimer placed on the tax return itself. The new compilation standards address this issue.
- Role of the Business Owner in a Tax-Only Engagement
In a tax-only engagement, it is important for the business owner to handle the distribution of tax return information to third parties, such as bankers or lenders, instead of the accountant. This practice ensures clarity regarding the accountant's limited role in the engagement. The accountant's responsibility is strictly confined to preparing and filing the tax return, without making any assertions about the accuracy or completeness of the underlying financial information. - New Compilation Engagement Standards
Under the recently updated compilation engagement standards, it is specified that disclaimers on tax forms or in footnotes should NOT be included with tax returns. This decision stems from the potential for such disclaimers to confuse or mislead readers concerning the accountant’s role and responsibilities.
Past Disclaimer Examples:
Example A: This tax return has been prepared based on the information provided by the client.
Example B: The preparer does not assume responsibility for verifying the accuracy or completeness of the provided data.
Example C: The preparer's role is limited to accurately compiling and filing the return as per the client's disclosures.
Example D: Users of this tax return should not rely on it for any purposes other than compliance with tax filing requirements.
Such disclaimers were intended to clarify the limited scope of the accountant's engagement in preparing the tax return, indicating that the information was not audited or reviewed for accuracy beyond the preparation of the return itself. However, under the new standards, these disclaimers should no longer be included directly on tax returns. Instead, a Compilation Engagement Report (CER) would accompany any financial statements prepared during a compilation engagement to communicate the scope and responsibility more clearly. - Proper Form of Communication
The updated standards emphasize that the appropriate method of communication should be a Compilation Engagement Report (CER) attached to the financial statements, when applicable. The CER clearly outlines the accountant's responsibilities and the nature and limitations of the engagement, ensuring that third parties receive complete and accurate information about how the financial statements were prepared. - Importance of Adhering to Standards
These standards are designed to improve transparency and reliability in financial reporting. By adhering to them, both accountants and business owners can reduce the risk of misinterpretation and maintain clear and consistent communication with all stakeholders involved.
By following these guidelines, business owners and accountants can ensure compliance with professional standards and foster trust with third parties.
T2 S141 Notes Checklist Guidance
In May 2022, the Canada Revenue Agency (CRA) issued a new version of T2 S141 Notes Checklist so that it aligns better with the current practices in tax engagements. Here's 2022 guidance from CPA Canada on how to complete these notes:
1. Client Provides Financial Statements:
- Answer "Yes" in box 111 - Can you identify the person specified in the heading of Part 1?.
- For box 95 - Does the accountant have a professional designation? and box 97 - Is the accountant connected with the corporation?, respond from the corporation's perspective.
- If box 95 is "Yes," complete "Other" in Part 2 box 305.
- If box 95 is "No," complete Part 4.
- In Part 5, check box 311 - The client provided the financial statements.
2. Client Provides Financial Information (e.g., trial balance) Only:
- Answer "No" in box 111 - Can you identify the person specified in the heading of Part 1?.
- In Part 5, check box 312 - The client provided a trial balance.
3. CPA Provides Bookkeeping and Prepares T2 (No Financial Statements):
- Answer "No" in box 111 - Can you identify the person specified in the heading of Part 1?.
- In Part 5, check box 314 - Other (please specify) and fill in CPA Provides Bookkeeping and Prepares T2 (No Financial Statements)
Considerations Around Liability and Negligence
What do you need to consider with regards liability and negligence when requesting non-CPA compilation engagement reports?In Canada, the preparation of financial statements, especially when accompanied by a Compilation Engagement Report (CER), is a task that requires specific skills and qualifications that Chartered Professional Accountants (CPAs) possess. Here’s a breakdown of the considerations around liability, negligence, and how CPAs are bound by professional standards compared to non-CPAs:
Liability and Negligence
1. Professional Standards: CPAs are subject to rigorous professional standards and ethical guidelines set by CPA Canada and its provincial bodies. These standards ensure that CPAs perform their duties with due diligence, competence, and integrity.
2. Liability for CPAs:
- CPAs have a fiduciary duty to act in the best interests of their clients. If a CPA prepares a CER, they are expected to follow the standards and provide a report that accurately reflects the compiled financial information.
- If a CPA fails to meet these standards and negligence can be proven (e.g., failing to identify and convey significant misstatements), they can be held liable for damages suffered by the client.
3. Non-CPAs and Liability:
- Lack of Certification: A non-CPA does not hold the same certification and is not bound by the CPA’s professional standards. This frequently means less rigorous training in accounting principles, ethics, and standards.
- Increased Risk: The risk of errors, omissions, or misinterpretations increases when someone unqualified prepares the CER. If a non-CPA were negligent, seeking recourse could be more challenging due to the absence of adherence to recognized professional standards.
Constraints and Protections of CPAs
- Professional Liability Insurance: Public practice CPAs are usually required to maintain professional liability insurance, which offers protection to clients for claims arising from errors or negligence by the CPA.
- Continuous Professional Development: All CPAs must engage in ongoing professional development. This ensures their knowledge is current, and they can provide competent services in preparing CERs and other financial reports.
- Peer Review and Oversight: CPAs may be subject to peer reviews and regulatory audits of their work, which helps maintain high standards and accountability.
- Regulatory Framework: CPAs are regulated by provincial bodies with codes of conduct and disciplinary processes. Clients have an avenue to file complaints against CPAs, which can lead to investigations and possible sanctions, offering another layer of protection.
- Ethical Guidelines: Adherence to a strict code of ethics ensures that a CPA's work is conducted with objectivity, confidentiality, and competence, minimizing the risk of negligent preparation of financial documents.
By engaging a CPA with the preparation of a CER, you are confident that the work is conducted according to the highest standards of the profession, thereby reducing your risk of financial inaccuracies and legal repercussions. Non-CPA preparers do not offer the same structured framework for recourse or reliability, which may introduce additional risk to your business operations.
The Bookkeeper's Tip
A Good Bookkeeping Practice
Have your bookkeeper provide you with your internal financial statements once a month. These statements provide you with a summary of your business activities. Familiarize yourself with the data and review them EVERY month. Let your bookkeeper know if you think something is "off" or not stated correctly. Don't wait until the end of the year to do this.
If you are NOT having an annual compilation engagement report prepared by your accountant, keeping tabs on your internal financial statements becomes even more important than before.
Having accurate internal financial statements will give you have a better understanding of your tax obligations and assist your tax preparer in providing you with an accurate income tax return; whether it is corporate or personal.
Let's Chat About ...
What the Compilation Engagement Report Includes
Here is a comparison of the old standard with the new standard for what a compilation engagement report must include.
|
ITEM Title Caution to Reader |
NEW REPORT Compilation Engagement Report Clarifies in more detail no procedures were performed to verify completeness or accuracy of information provided No change to level of assurance given |
OLD REPORT Notice to Reader |
Let's Chat About ...
What are the Different Levels of Assurance?
Accountants can provide three levels of assurances when their services are engaged. You need to discuss with your accountant what level of assurance is best suited to your circumstances. As discussed earlier, your circumstances may warrant none of these engagements. A tax-only engagement may be sufficient.
Compilation Engagements (CE) are the least expensive and offer "no assurance". The scope of the engagement is to prepare compiled financial statements based on information received from management. No expression of assurance is provided by the accountant. However, a CE ensures the financial information is complete, accurate, and in accordance with the applicable financial reporting framework. It signifies that a professional accountant has been involved in preparing the financial information.
Review Engagements cost more than a compilation engagement due to a broader scope. A "limited" assurance is provided by the accountant. To arrive at this conclusion, the accountant performs a review of the business's financial statements so as to form a conclusion on whether anything has caused the accountant to believe the financial statements have not been prepared in accordance with the applicable financial reporting framework.
Audit Engagements are the most expensive of the three options as it involves the most work. A "reasonable" assurance is provided by the accountant. The scope of the engagement is to perform an audit of the financial statements and form an opinion on whether the financial statements have been prepared, in all material respects, in accordance with the applicable financial reporting framework.
GAAP UPDATE
Statement of Cash Flow ... and ASPE
Have you wondered if the new Accounting Standards for Private Enterprise (ASPE) that came into effect on January 1, 2011 affected which financial statements need to be prepared?
BDO (www.bdo.ca), in their Private Enterprises: Decisions to Make on the Road to New Standards article, says statements of cash flow must always be presented under ASPE. It is NOT optional.
Compilation Engagement Reports vs. Tax Basis Financial Statements
Since December 14, 2021, there are new rules for compiling financial statements, known as CSRS 4200. If you need to show your financial statements to someone outside your business, you might have noticed the changes. These new standards replaced Section 9200 (the old NTR standards).
There's now a new report called a 'Compilation Engagement Report', which replaces the 'Notice to Reader'. You can and should include notes of the accounting policies used in the preparation of the financial information. These notes are important because they can explain any differences between your accounting methods and the standard methods (known as ASPE). This will help others understand your financial statements better as it unusual that the accounting basis in a compilation engagement will be ASPE.
It's generally good practice to disclose significant information such as contingent liabilities, going-concern considerations, and risks and uncertainties if these are material to the users of the financial statements. However, this level of detail might not always be required under a simple compilation engagement unless specifically requested by users or relevant to the financial information's understanding.
Please explain why I should have a CER if it provides no assurances? My online accounting software already gives me a set of financial statements. What exactly would the CPA be doing?
Please explain why I should have a CER if it provides no assurances? My online accounting software already gives me a set of financial statements. What exactly would the CPA be doing?
It's important to understand that a CPA providing a Compilation Engagement Report (CER) in Canada serves a different purpose than an assurance engagement. Here's why you might consider obtaining a CER, despite it not providing assurance:
- Professional Insight: A CPA brings professional experience and knowledge that goes beyond simply generating financial statements. S/he can help ensure that the financial information is complete, accurate, and in accordance with the applicable financial reporting framework.
- Stakeholder Confidence: While a CER does not provide assurance, it does signify that a professional accountant has been involved in preparing the financial information. This can provide greater confidence to external stakeholders such as banks, investors, or suppliers, compared to self-prepared financials.
- Detection of Errors or Misstatements: While the purpose of a CER isn't to identify errors or fraud, a CPAs involvement and professional expertise may identify unintentional errors or misstatements in your financial records. Let me explain further:
During a compilation engagement, CPAs rely primarily on the information provided by you. While they do not perform a detailed investigation or verification process like in audits or reviews, they are trained to notice obvious inconsistencies or errors while compiling the financial data. Some examples would be (i) They may notice if the financial data doesn't align with the industry norms or past performance; (ii) They might identify glaring accounting errors; or (iii) They ensure that the financial statements comply with the applicable accounting standards to the extent that is evident during the compilation process.
However, since this engagement doesn't include detailed testing, the CPA wouldn't catch errors that aren't apparent without deeper investigation. - Clarity and Consistency: A CPA help ensures your financial statements are clear, consistent, and understandable. This is important for making business decisions, planning, and analysis. It also ensures you're presenting your business in a professional manner to third parties.
- Compliance and Adjustments: CPAs can help ensure that your business is compliant with relevant financial reporting standards and regulations. S/he can also make any necessary adjustments that your accounting software might not be equipped to handle, such as reconciling complex transactions.
- Communication: A good CPA should communicate with you throughout the process. This includes discussing any key findings, concerns, or recommendations for improvements. If your past experiences with the old NTR engagement haven't included this, it might be beneficial to discuss your expectations upfront with your CPA.
If you're looking to get more out of your relationship with a CPA, explicitly discussing your desire for feedback on potential errors or suggestions for improvement is key. While the primary goal of a compilation is to compile and present financial data, a comprehensive dialogue about your business needs can ensure that you’re receiving practical insights tailored to helping you grow and manage your business effectively.
Ask your CPA to formally include in the scope of the CER suggestions on improving aspects of your bookkeeping as part of the compilation process such as correcting your chart of accounts. Request in the scope of the CER, that issues found during the engagement that may impact tax planning or management decisions be brought to your attention. - Value-Added Services: While a compilation itself does not normally include strategic advice, CPAs offer management consulting or advisory services as add-ons. Talk with your CPA about whether such services are included in the engagement and which services can be combined with or added to the engagement.
There are a few areas that are usually considered value-added services, depending on the extent to which they're carried out :
1. Detailed explanations of financial statement items or financial analysis.
2. Extensive advice on improving financial processes or systems.
3. In-depth tax planning or business advisory services.
These services might be offered alongside a CER but are typically not part of the standard CER process. It's prudent to have them clarified in the scope of the engagement to ensure your expectations are met.
In summary, while your accounting software generates financial statements, a CPA can add significant value through professional expertise, credibility, compliance, and possibly insights that can help you manage and grow your business effectively.
What does the standard scope of a Compilation Engagement Report (CER) include and is not considered an add-on service?
What does the standard scope of a Compilation Engagement Report (CER) include and is not considered an add-on service?
Here are the key points a standard scope of a Compilation Engagement Report (CER) includes and are generally not an add-on service:
- Preparing financial statements based on information provided by the client: This is part of the standard CER process.
- Not providing assurance on the accuracy or completeness of the information: This is a key aspect of a CER.
- Using professional expertise to compile financial information: This is part of the standard CER process.
- Noticing obvious errors or inconsistencies: While CPAs don't actively search for errors, noticing obvious issues is part of applying professional expertise during a standard CER.
- Asking questions about unusual items or discrepancies: This falls within the standard CER process as part of gathering information.
- Suggesting corrections to the chart of accounts: This could be considered part of the standard CER process if it's necessary for proper compilation of the financial statements. Ask for it to be included in the scope of the CER.
- Providing a compilation engagement report: This is the main deliverable of a CER.
- Discussing financial statement items with the client: Basic discussions to understand the information provided are part of a standard CER.
Here are a few areas that might be considered value-added services, depending on the extent to which they're carried out:
1. Detailed explanations of financial statement items or financial analysis.
2. Extensive advice on improving financial processes or systems.
3. In-depth tax planning or business advisory services.
These services might be offered alongside a CER but are typically not part of the standard CER process. The exact scope can vary slightly between firms, so it's always best to discuss the specific services included with your CPA. Ask for items / issues to be explicitly included in the scope of the engagement if that what your expectations are. This way you know if your expectation is an add-on service or included as part the of compilation engagement.
Is there an alternative to a CER engagement?
Is there an alternative to a CER engagement?
If a Compilation Engagement Report (CER) by a CPA is not required by your bank and such a service is cost prohibitive for your business at this stage, preparing a Management Information Report to accompany internally prepared financial statements can be a viable alternative. Here’s what you should consider:
Management Information Report
- Purpose: This report serves to provide management and any stakeholders with an understanding of the financial health of the business, geared towards internal decision-making rather than external reporting.
- Content: The report can include financial statements, summaries of key metrics, variance analyses, and commentary on significant changes in financial positions or operations.
- Frequency: It can be prepared monthly, quarterly, or annually, depending on your business needs.
- Benefits: Since it’s internally prepared, you save on costs associated with hiring external accountants. Also, because it’s tailored for internal use, you can focus on providing timely information quickly for management review.
- Customization: You can customize the report to include relevant information such as operational data and KPIs not necessarily required in external reports.
- Limitations: Unlike a CER, these internal reports do not provide any assurance level to third parties. Lenders or investors may require additional documentation. In addition, while cost-effective, prepare them with care, ensuring whoever prepares these reports has a reasonable understanding of accounting principles.
Moving Forward
As your business grows and if external validation becomes necessary, you might reconsider professional accounting services. Meanwhile, your focus should be on creating reliable and useful internal reports that support sound decision-making. If questions or complex issues arise, consulting with a CPA for specific concerns could still be beneficial without fully engaging them for a CER.
What are Tax-Basis Statements?
What are Tax-Basis Statements?
Under current complication engagement standards, you should find a reference to the note which describes the basis of accounting applied. One basis available is the tax-basis of accounting. If you're detailing financial information for tax compliance or planning purposes, using a tax-basis accounting method is quite common and suitable for many small businesses. Always ensure that any departures from accounting standards for private enterprises (ASPE) are transparently disclosed.
Tax-basis financial statements are prepared using the rules and formats used for tax purposes. They are focused primarily on reporting financial information according to tax requirements. It is aligned with the regulations for filing tax returns.
- They may include items such as non-taxable revenue and non-deductible expenses that may or may not appear on statements prepared under regular accounting standards. Normally, non-taxable items appear as separate line items or are disclosed in the notes.
- They follow tax laws which may allow or disallow certain items, and may align differently in timing and recognition. For example, tax laws may lead to temporary or permanent timing differences from ASPE reporting.
- While some notes still are necessary, tax basis statements may have different and simpler note requirements compared to ASPE financial statements.
How do Tax-Basis Statements differ from ASPE Statements?
How do Tax-Basis Statements differ from ASPE Statements?
ASPE (Accounting Standards for Private Enterprises) is a set of accounting principles used in Canada for private companies. Financial statements prepared under ASPE generally follow more formal accounting rules, requiring specific notes and disclosures.
Tax-basis statements are simpler and more focused on tax reporting, which can make them easier to prepare and understand. For example, tax basis financials do not require a cash flow statement like ASPE statements do.
This can lead to timing differences between the two reporting options. Temporary differences, such as depreciation vs. CCA, do not affect the total income or expense recognized over the life of the business, but they do affect the timing. Temporary differences will eventually be reconciled over time. Permanent differences, such as fines and penalties or grants received, arise from expenses or income that are recognized for accounting purposes but will never be recognized for tax purposes (or vice versa). These differences do not reverse over time.
Preparing statements on a tax basis can be simpler and cost-effective as well as be easier to understand. These statements provide a direct basis for preparing tax returns, minimizing reconciliation differences between financial reports and tax returns due to varying accounting treatments.
Be aware that tax-basis statements might not be suitable for all users, especially external stakeholders like investors or lenders who require detailed financial analysis and comparability with other enterprises.
Some lenders or financial analysts may prefer or require ASPE-compliant statements for comprehensiveness and thorough disclosure, potentially affecting negotiations or loan covenants.
Since tax-basis statements cater to tax rules rather than consistent accounting principles, comparability with other businesses might be reduced.
Takeaways
Whether to use ASPE or tax basis often depends on the needs of your business and its financial statement users. If your primary requirement is tax compliance and you don't have external stakeholders demanding detailed financial data, tax-basis statements might suffice. However, if you require external financing or have stakeholders who rely heavily on financial information, ASPE might better serve those objectives.
Understanding timing differences is helpful for effective tax planning and compliance. Recognizing how these differences affect both your financial statements and your tax liability can help you plan better and avoid surprises.
Why is Modifying Statements for Tax Basis Important?
Why is Modifying Statements for Tax Basis Important?
It's important to clearly label tax-basis financial statements to differentiate them from ASPE statements. Given the new CER requirements and who can prepare a CER, clear labelling of financial reports become even more important than before. In fact, disclosing the basis of accounting used is a compilation engagement standard.
For example, you can rename the Balance Sheet as 'Statement of Financial Position - Tax Basis (Unaudited)' and include a footnote saying 'Notice to Reader - Statement prepared on an income tax basis, not ASPE.'
Similarly, for the Income Statement, call it 'Statement of Operations - Tax Basis (Unaudited)' with a similar footnote.
Note: For financial statements that underwent a compilation engagement, each page of the financial statement should be marked “Unaudited—See Compilation Engagement Report.”
MORE >> Sample Financial Statements
What Are Some Considerations for Relations with Lenders?
What Are Some Considerations for Relations with Lenders?
If you have to submit statements to your banker or insurance agent on a regular basis, it would be prudent to ensure the switch to tax basis statements is acceptable. Be aware that the ASPE standards, in effect since January 1, 2011, are often tied your financial ratios and covenants tied to loans.
It is advised by experts like Doane Grant Thornton to maintain communications with your lenders and legal counsel to discuss any effects on your financial agreements especially if you are considering switching to tax-basis statements.
Takeaway - 2021 New Compilation Standards
Chat with the third party users of your financial statements to determine if they require no assurance compilation engagement statementsEffective for all fiscal periods ending on or after December 14, 2021, a new standard was introduced by the Audit and Assurance Standards Board for compilation engagements previously referred to as Notice to Reader engagements.
Small business owners will need to chat with the third party users of their financial statements to determine if they require compilation (no assurance) engagement statements or if internal financial statements with notes are adequate for their purpose. This is an important discussion to have as you are not required to have ASPE financial statements ... or it may mean you need to provide reviewed (limited assurance) or audited (reasonable assurance) statements.
The new compilation engagement statements may only be prepared by licensed public practice CPAs. The report must include additional information not previously disclosed in a Notice to Reader report; which includes management's responsibilities for the information provided, the CPA's responsibilities of what actions were or were not performed, along with the basis of accounting used.
An alternative for non-CPAs is to prepare a Management Information Letter to accompany internally prepared financial statements. They should be prepared with care and by a non-CPA who has a reasonable understanding of accounting principles.
For more information on these changes, please read Doane Grant Thornton's excellent overview titled "Canada's compilation engagement standard is changing: A summary for management" available online.