The narrative that management and auditor assessment of internal controls of financial reporting is too expensive is a very common, but undemonstrated, narrative regarding virtually every accounting, disclosure, and audit reform. Investors view the benefits of ICFR audits as exceeding the costs.
Our key takeaway from the Consultation is that the UK government’s most significant instrument of reform is an empowered audit regulator, replacing the Financial Reporting Council (FRC) with the new Audit Reporting and Governance Authority (ARGA).