IntroductionThis survey is only applicable to respondents that have adopted or use or benefit from the Responding to Non-Compliance with Laws and Regulations (NOCLAR) provisions in the International Code of Ethics for Professional Accountants (including International Independence Standards) (the Code). Sections 5260 and 5360 as contained in the International Ethics Standards for Sustainability Assurance (including International Independence Standards) (IESSA), and conforming amendments to Sections 260 and 360 arising from the development of the IESSA, are outside the scope of this survey and only become effective in December 2026.
The International Ethics Standards Board for Accountants (IESBA) is conducting a post-implementation review (PIR) of the NOCLAR provisions in Sections 260 and 360 of the Code.
This survey seeks to obtain input from a broad range of stakeholders to enable the IESBA to determine:(a) Whether the NOCLAR provisions have achieved their intended purpose by identifying:
(i) Benefits from applying the provisions; and
(ii) Any practical challenges or questions regarding their implementation, including whether they are being consistently understood and applied; and
(b) What actions, if any, are needed by the IESBA to address identified matters.
The responses received will be analyzed for purposes of providing feedback to the IESBA and in developing recommendations for any actions.
Recognizing that some respondents may wish to discuss certain NOCLAR or NOCLAR-related matters on a confidential basis instead of documenting them in writing when responding to this survey, respondents are welcome to reach out to the IESBA Project Team (email jeanneviljoen@ethicsboard.org and kamleung@ethicsboard.org) to discuss such matters confidentially. In such circumstances, respondents are requested to discuss the matters on an anonymized basis.
The survey comment period starts on April 1 and ends on July 30.Survey Responses To Be Made PublicUnless confidentiality is specifically requested, respondents’ submissions will be considered a matter of public record and will be posted to the IESBA’s website. Where confidentiality is requested, respondents are nonetheless requested to provide any detailed input on an anonymized basis.
Some questions ask for details, examples or sharing of relevant reports or materials. Respondents are requested to provide such information on an anonymized basis.Survey InstructionsRespondents to the survey are asked to provide their responses only on the questions applicable to the stakeholder group to which they belong:
- Part A ― Demographic Information (All Respondents)
- Part B ― Jurisdictional Standard Setters (JSS)
- Part C ― Professional Accountancy Organizations (PAOs)
- Part D ― Regulators or Oversight Bodies
- Part E ― Accounting Firms or Individual Professional Accountants in Public Practice (PAPPs)
- Part F ― Professional Accountants in Business (PAIBs)
- Part G ― Other Users or Beneficiaries of the Code
Respondents may respond to all questions or only selected questions or matters. All responses to this survey, whether complete or partial, will be accepted and considered as input for the IESBA Project Team’s analysis.Overview and Key Intended Outcomes of the IESBA NOCLAR ProvisionsThe IESBA NOCLAR provisions establish a response framework to guide auditors, other PAPPs, and PAIBs in deciding how best to act in the public interest when they become aware of NOCLAR or suspected NOCLAR.
NOCLAR is any act of omission or commission, intentional or unintentional, committed by a client or employer, or by those charged with governance (TCWG), by management or by other individuals working for or under the direction of a client or employer which is contrary to the prevailing laws or regulations.
For a more detailed overview of the NOCLAR provisions of the Code, please access the following link here.
Key intended outcomes of the NOCLAR provisions in the public interest include:
- Ensuring that PAs respond in a timely way to identified or suspected NOCLAR.
- Rectifying, remediating, or mitigating the adverse consequences of identified or suspected NOCLAR to stakeholders and the general public.
- Deterring the commission of NOCLAR.
- Stimulating increased reporting of identified or suspected NOCLAR where required by law or regulation, or where determined appropriate under the Code in the public interest.