Better Regulation principles must be followed.

A comprehensive impact assessment for the package of measures

is needed, including Sir Donald Brydon's independent audit review and the CMA market analysis. The
government's Better Regulation Framework recommends doing this. The package's total cost to businesses is
going to be high, therefore it's important to identify the projected advantages. To ensure that the final package of
reforms is successful and achieves what is intended, it is vital to interact with stakeholders after determining the
details of the measures and the findings of impact assessments. Audit concerns we've seen are often behavior or
quality faults. They need a simple but powerful response that concentrates on governance, reporting, and audit
and avoids peripheral impact measures. Auditor and director regulation must be strengthened. The complexity
of the proposed improvements and the labor needed to formulate and analyze them requires a careful upfront
evaluation of priorities. Without it, politicians and regulators won't be able to perform their jobs and the public
won't see substantial change. We advise the following objectives for improving auditor and director regulation:
ICAEW thinks the existing system could be enhanced with a renewed emphasis on preventing disorderly
collapse, fresh thinking on fraud, better audit reporting, and advocating proportionality (ICAEW representation
64/19). ICAEW thinks the new regulator might be granted authority to enhance directors' accountability and
obligations under the Companies Act. The Companies Act requires directors to keep proper accounting records
(section 386). REP 64/19 suggests this might be the foundation for a new UK framework enhancing directors'
and auditors' internal control obligations. We also favor a stronger focus on Section 501 of the Companies Act,
which renders deceiving auditors a crime. Greater attention on this would underline the responsibility of
executives and directors to give auditors with all the information they require. The Court of Appeal ruled that
this law doesn't apply to firms as written. Change the law to empower ARGA to prosecute firms.