Transatlantic Audit Accord in Limbo: Implications for Global Accounting Mobility

In today’s increasingly interconnected financial landscape, the free movement of audit professionals between major markets is more than a convenience—it’s a necessity. Yet, recent developments have highlighted the challenges in achieving mutual recognition of accounting qualifications between the United States and the United Kingdom. Talks that once promised to break down barriers for US and UK accountants have now stalled, leaving audit leaders and global firms navigating uncertain regulatory terrain.

At the heart of these discussions lies a critical ambition: to facilitate cross-border mobility for auditors, especially those working with multinational clients, dual-listed companies, and complex financial institutions. Since the pilot program launched in 2018 between the American Institute of Certified Public Accountants (AICPA) and the Institute of Chartered Accountants of Scotland (ICAS), there was optimism that broader mutual recognition agreements would soon follow. These agreements were expected to streamline professional transitions and widen talent pipelines across both jurisdictions.

However, as of late, negotiations have faltered. The original pilot program—quietly discontinued after multiple extensions—never expanded to include professionals qualified in England and Wales or to permit US-qualified accountants to undertake audit work in the UK. One major sticking point has been the lack of alignment over audit training standards and oversight systems. While both sides agree in principle that audit experience gained in the US could be relevant in the UK, the two parties have been unable to agree on a unified framework to evaluate this experience consistently.

Additionally, the UK’s regulatory framework requires more specific and structured experience before granting audit signing authority. The divergence in qualification pathways—such as the more defined audit experience required in the UK compared to the broader approach in the US—has made harmonization difficult.

Another complicating factor has been the limited scope of negotiations. The AICPA has only been engaging with ICAS and the Institute of Chartered Accountants in England and Wales (ICAEW), excluding the Association of Chartered Certified Accountants (ACCA), which represents a substantial portion of UK accounting professionals. While the Financial Reporting Council (FRC) has emphasized that any final agreement would be applied equally across UK professional bodies, the exclusion raises concerns about inclusivity and representativeness.

Despite these challenges, there remains cautious optimism. Leaders in the accounting profession continue to emphasize the benefits of a mutual recognition agreement, not just for mobility, but for strengthening audit quality and supporting global financial stability. As Bruce Cartwright, CEO of ICAS, stated, “We shouldn’t underestimate the complexity of these big financial institutions.” Access to top-tier talent across jurisdictions would enhance the robustness of audits, particularly where dual listings and transnational operations are involved.

From a policy standpoint, the UK government has signaled interest in reform, proposing amendments to the Companies Act to recognize foreign audit experience—an initiative that could pave the way for future progress. The Big Four accounting firms have also lent their support, citing operational efficiencies and global competitiveness.

Dawgen Global’s Perspective

At Dawgen Global, we recognize that mutual recognition of professional qualifications is essential to building a more agile and effective audit environment, particularly in the Caribbean where cross-border commerce is frequent and often aligned with US and UK frameworks. The current impasse in US-UK negotiations should prompt broader discussions within regional and international accounting communities. There is a growing need to establish globally consistent pathways for qualification recognition that do not compromise professional standards but rather elevate them through shared oversight and quality assurance.

As the demand for global audit services increases, especially in regulated industries like banking, insurance, and publicly listed entities, the audit profession must evolve. Collaboration, transparency, and regulatory innovation will be key to ensuring talent mobility while maintaining trust in financial reporting.

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