1. Characteristics of accounting supervision in Western countries

(1) Characteristics of accounting supervision in the United States

In countries with common law systems, accounting supervision of listed companies is generally based on The government's procedural supervision is the leading role. Regulators only supervise whether the financial reports of listed companies comply with the procedural requirements of relevant rules. At the same time, they focus on the role of self-regulation and independent supervision. The accounting supervision of listed companies in the United States basically follows this supervision concept, and its characteristics are mainly reflected in the following aspects:

1. An accounting supervision model dominated by a quasi-governmental supervision model.

The Sarbanes-Oxley Act requires the establishment of a new independent "Public Company Accounting Oversight Board" to replace the original Public Company Accounting Oversight Board affiliated with the American Institute of Certified Public Accountants. As a quasi-governmental agency for accounting supervision, it accepts the SEC It is fully responsible for the supervision of the accounting profession and enjoys the power of supervision, investigation and punishment. This marks the transformation of the US accounting supervision model from industry self-regulation to a quasi-governmental supervision model, and strengthens the involvement of government departments in industry supervision.

2. Strengthen the accounting accountability system.

The Sarbanes-Oxley Act stipulates that the chief executive officer (CEO) and financial director (CFO) of U.S. listed companies must sign and certify their annual and interim financial statements, requiring the CEO and CFO to verify the financial statements submitted to the SEC. The financial reports are guaranteed to "fully comply with the Securities and Exchange Act and fairly reflect, in all material respects, the financial condition and results of operations." Financial reports are not allowed to contain any major errors or omissions that cause the financial statements to mislead the public. Senior financial personnel of the company are required to follow professional ethics rules. If problems are found in the future, the CEO or CFO will personally bear serious civil or even criminal liability for the company's financial statements. . For the first time, the Sarbanes-Oxley Act clearly defined the legal responsibilities of company executives and accounting practitioners in statutory law, indicating that US accounting supervision has entered the era of legal supervision.

3. Evaluate the effectiveness of internal controls.

The Sarbanes-Oxley Act requires company management and external auditors to separately evaluate and report on the effectiveness of the company's internal controls over financial reporting in the annual report. It also requires external auditors to evaluate the company's management evaluation process. and internal control systems to conduct corresponding inspections and issue formal opinions. Independent auditors need to plan the audit work, understand the company's internal controls, evaluate the design effectiveness and execution effectiveness of the controls, and then issue audit opinions.

(2) Characteristics of accounting supervision in other Western countries

1. Characteristics of accounting supervision in the UK.

British accounting supervision emphasizes that company financial reports should give true and fair reflections, focusing on private audits to protect the interests of investors. With the development of economic globalization and accounting internationalization, the limitations of the British accounting supervision model, which focuses on industry self-discipline, have gradually been exposed. Due to the lack of a strong set of accounting regulations, the degree of accounting supervision is not completely consistent across the UK, which has greatly affected the level of accounting supervision in the UK securities market. Therefore, the United Kingdom has gradually moved away from the model of relying solely on industry self-regulatory organizations for supervision, and implemented government supervision as the leading role. It also plays the role of self-regulation and independent supervision to usefully supplement and improve the existing accounting supervision model. The Institute of Accountants in England and Wales, together with other UK accountancy bodies' advisory committees, has established a new Accounting Investigations and Disciplinary Committee, which together with the new Financial Reporting Council investigate important matters affecting the public interest, while the Professional Standards Board also conducts a review of the new audit The investigation agency is responsible, and the SBA still has the power to investigate and monitor other audit matters. In addition, the UK has also strengthened the supervision of audit firms and implemented a new professional follow-up education system.

2. Characteristics of French accounting supervision.

Obviously different from other Western industrialized countries, the French government attaches great importance to national economic planning and macro-control. France emphasizes the unity of accounting standards and emphasizes that accounting obeys the requirements of tax law and is consistent with the provisions of tax law. The government's finance and taxation department occupies a dominant position in accounting supervision. Therefore, France's accounting supervision is government-driven and tax-led. The government has established a national accounting supervision committee to be responsible for the implementation of the overall accounting plan, and is more inclined to safeguard the country's rights and interests to meet the needs of the country. The needs of state-owned investors, government taxation and macroeconomic control.

3. Characteristics of German accounting supervision.

In civil law countries, accounting supervision of listed companies is mainly based on substantive government supervision. Regulators must review the physical content of listed companies’ financial reports, and even need to determine whether certain financial report data conforms to Make judgments based on specified standards and take appropriate measures. Compared with France, Germany’s accounting rules formulated in the form of laws are more mandatory and emphasize the unity of accounting standards and tax laws. Tax laws determine accounting to a large extent, and they deal with the country’s owner’s equity and the company’s It has a direct impact on the owner's equity relationship. German accounting is company-interest-oriented and protects the company's interests. It is extremely conservative and does not require full disclosure, allowing companies to have greater flexibility in the choice of accounting policies. Accounting supervision emphasizes protecting company interests and trying to meet the needs of banks and tax agencies in accounting information disclosure.

4. Characteristics of Japanese accounting supervision.

Japan implements an accounting supervision model based on law and centralized government supervision. The main body of accounting supervision is directly led by the Minister of Finance, with the Securities and Exchange Supervisory Commission as the specialized government regulatory agency, and the regional financial director appointed by the Minister of Finance as the local securities supervisory supervisor. When performing supervisory tasks on the basis of law, the Securities and Exchange Supervisory Commission and self-regulatory institutions shall be organically combined.

2. Problems in my country’s accounting supervision

(1) Relevant laws and regulations are not sound and complete enough.

At present, my country has initially formed an all-round and multi-level accounting regulatory system with the Accounting Law as the main body and supplemented by relevant administrative regulations, rules and other normative documents. However, there are still some problems in the laws and regulations of accounting supervision in my country: the accounting information quality control system is not systematic; the legal liability system is not perfect, and there is a lack of civil compensation for investors who have suffered damage; there are coordination problems between accounting regulations, Relevant measures lack detailed rules, there are omissions and conflicts, and there is no standardized system.

(2) Government supervision is scattered and responsibilities are unclear.

my country's accounting supervision is a government supervision model, with the main purpose of meeting national taxation and macroeconomic policies. The government takes the lead in formulating a national unified accounting system and accounting standards, and relevant government departments perform accounting supervision responsibilities. At present, the government accounting supervision departments in our country include the Ministry of Finance, the Audit Office, the Taxation, the Industry and Commerce, the Securities Regulatory Commission, etc. The numerous regulatory departments have resulted in too many regulatory entities and unclear regulatory responsibilities. In actual work, there is no regulatory synergy, resulting in solve the problem of fragmented and chaotic supervision. At the same time, this regulatory structure can easily lead to the inability of various departments to share information, push each other's responsibilities, and lead to low regulatory efficiency.

(3) Social supervision is weak.

The main body of social supervision refers to the professional team of certified public accountants, the general public and investors. At present, the services provided by my country's certified public accountants are in a buyer's market. They are easily influenced by management authorities in the process of supervising corporate management authorities, thereby losing the independence of auditing, resulting in a decline in audit quality, and failing to fully exert their "economic police" role. At the same time, regarding the re-regulation of CPAs, the effects of laws and regulations, government supervision and industry self-discipline are not ideal. In addition, the general public and investors do not have strong awareness of supervision, lack opportunities to participate in accounting supervision, and find it difficult to play a role in accounting supervision.

(4) Internal accounting supervision of enterprises is weak.

Internal accounting supervision is the supervision and control of the company's economic activities and the quality of accounting information by the unit's accountants and auditors. Because enterprises do not pay attention to the establishment of internal control systems, the professional quality of internal supervisors is low, and the financial relationships of supervisors are restricted by their own units, internal supervision does not fully play its basic role in accounting supervision, and is even related to management. The authorities committed cheating, which resulted in the internal accounting regulatory agencies being less independent and unable to perform their supervisory functions.

3. Suggestions for improving accounting supervision in my country

By comparing accounting supervision between China and the West, my country can learn from the experience and lessons of accounting supervision in Western countries and establish a series of perfect system to achieve a long-term mechanism for accounting supervision and improve the effectiveness and efficiency of accounting supervision.

(1) Improve the legal system of accounting supervision and strengthen the responsibilities of senior managers.

Although the "Securities Law" stipulates the principle of priority in civil liability for compensation, in judicial practice due to the lack of appropriate litigation mechanisms in existing laws, investors' losses are actually not compensated. The United States has relatively practical laws related to civil compensation. To this end, we can learn from the practice of the United States. While strengthening the penalties for criminal liability and administrative liability, we also stipulate the civil compensation liability for investors and increase the liability for those directly responsible. Personal legal liability, strengthen the behavioral constraints and accountability of senior managers, and truly place senior managers under the constraints of civil liability.

(2) Focus on government supervision and strengthen industry self-discipline.

Cases such as Enron have exposed serious flaws and loopholes in the U.S. self-regulatory system. It is not enough to rely solely on the industry self-discipline of certified public accountants for accounting supervision. Therefore, combined with my country's economic, political and social cultural characteristics, our country should establish an accounting supervision model dominated by government supervision and supplemented by industry self-discipline. Industry self-discipline actively cooperates with government supervision to make up for the deficiencies in government supervision in terms of information feedback and knowledge stock. Government regulatory authorities must also support and guide industry self-discipline work, actively promote the construction of industry self-discipline management systems, and strengthen technical assistance from self-regulatory organizations. function and improve the re-supervision system of the CPA industry. At the same time, adjustments will be made in accordance with the relevant provisions of the Accounting Law to clarify the respective powers and responsibilities of the financial department, audit department, China Securities Regulatory Commission and Institute of Certified Public Accountants, and enhance the independence of the Institute of Certified Public Accountants.

(3) Establish systematic internal control standards and strengthen the supervision of the company’s internal controls.

my country’s research on internal control standards is not enough. There are only guidelines on internal control standards for financial companies such as securities companies, insurance companies, and commercial banks formulated by industry regulatory agencies. Internal control standards for listed company systems have not yet been released. .

To this end, our country should refer to the COSO framework released by the United States in 2004 and establish a complete set of recognized internal control standards as soon as possible so that internal control evaluation can be followed. In addition, my country has not yet put forward mandatory regulations on the effectiveness evaluation of internal control over financial reporting. The internal control review business of independent auditors is not clearly distinguished from the internal control evaluation in financial reporting audits. Therefore, my country should focus on the design, implementation and operating performance of internal control. Standardize the inspection standards for internal control effectiveness evaluation. At the same time, listed companies should improve the independent director system, give full play to the role of independent directors and audit committees, and strengthen the supervision of internal controls.

(4) Enhance the independence of certified public accountants and play the role of "economic police".

The provision of non-audit services by accounting firms not only brings additional income to the firm, but also weakens the objectivity and independence of the certified public accountants who perform audit services. Our country should formulate relevant policies as soon as possible to clearly stipulate that accounting firms cannot provide or restrict the provision of non-auditing services while providing audit services to the same client, strengthen the supervision of CPAs engaged in consulting business, and increase the supervision of CPAs and accounting firms. The severity of penalties for violations of laws and regulations will ensure the independence of CPA audits from a institutional perspective, improve the quality of audits, and give full play to their role as "economic police".

(Author’s unit: School of Accountancy, Shandong University of Economics)