The Executive Counsel of the FRC has fined PwC £1.75 million over the failure of its audit of BT Group plc. On top of the fine the FRC issued a severe reprimand and said the Audit Report ‘did not satisfy the Relevant Requirements’.
Richard Hughes the audit engagement partner received a financial sanction of £42,000 and the same non-financial sanctions as the firm.
PwC and Hughes each admitted breaches of Relevant Requirements in relation to the audit of adjustments between the current and prior years disclosed by BT in its financial statements for the financial year ended 31 March 2017 (FY17 Financial Statements) which were made following the identification of a fraud in its Italian operations in 2016.
The scale of the BT Italy fraud was such that in the FY17 Financial Statements BT disclosed adjustments of approximately £513m. These adjustments were made up of (i) corrections of prior period errors of £268m and (ii) changes in accounting estimates of £245m (the BT Italy Adjustments). The prior-period errors were corrected by restating the prior-period comparatives in the FY17 Financial Statements.
One element of the changes in accounting estimates was the receivables balance which comprised two adjustments totalling £72m (the Debt Adjustments). The Respondents did not approach the audit of BT’s treatment of the Debt Adjustments with the necessary professional scepticism and they failed to adequately document their audit work across the entirety of the BT Italy Adjustments.
The breaches
PwC had identified the accounting treatment and related disclosures in respect of the impact of the fraud as a significant risk. There was a need for heightened professional scepticism in relation to BT’s treatment of the BT Italy Adjustments and in particular the relative amounts attributed to the correction of prior-period errors and changes in accounting estimates given: (i) the particular requirements of the applicable accounting standard, IAS 8; (ii) queries raised by PwC USA’s regulatory advisory team as to the ratio of the adjustments and whether they were fully supported by evidence; and (iii) if the errors were material in any prior period a “restatement” would be required for US reporting purposes and BT had stated the value of the errors to fall short of the materiality thresholds in all relevant years (2012 to 2016), and only just short (by approximately £1 million) of the materiality threshold in 2016.
Despite this, in relation to the Debt Adjustments, the Respondents: (i) failed to act with the requisite professional scepticism; (ii) did not obtain sufficient appropriate audit evidence; and
(iii) did not properly determine whether the changes in accounting estimates were appropriate. In relation to the total sum of the BT Italy Adjustments the Respondents also failed to prepare audit documentation that was sufficient to enable an experienced auditor, having no previous connection with the audit, to understand the nature, timing and extent of the audit procedures performed.
For the avoidance of doubt, the Executive Counsel has not made a finding that the 2017 Financial Statements were misstated, that the total sum of the BT Italy Adjustments was wrong, or that the breaches were intentional, dishonest or reckless. The stage at which admissions were made has been reflected in the 30% discount applied to the financial sanctions.
These breaches concern the audit of BT for the financial year ended 31 March 2017 which formed part of a wider investigation which included within its scope PwC’s audits of BT’s financial statements for the years ending 2015 and 2016. The investigation in relation to those earlier years was closed without enforcement action. (link to original press notice – https://www.frc.org.uk/news/june-2017/investigation-opened-into-the-audit-of-the-financi)
