Audit committees of Nigerian clients and the FRC

What the FRC's Rules ask of a Nigerian client's audit committee and its chairman, and how the auditor records what it checked on the engagement file.

By Achekam · 11 October 2026 · 5 min read · For Accountants & audit firms in Nigeria

An auditor in Nigeria spends a good deal of time with the client's audit committee: presenting the plan, discussing findings, answering questions on the draft report. Less often does the auditor stop to ask whether the committee itself meets the Financial Reporting Council's expectations. Yet the FRC's Rules reach the committee directly, and some of what they require ends up in the confirmation the auditor sends before signing.

This article gathers what the FRC's Rules and registration guidelines say about a client's audit committee and its members, and how an audit team can record its checks so that the file shows them.

Rule 10 and the statutory audit committee

In a public notice to statutory auditors dated 24 June 2025, the FRC said strict compliance with its Rules 9 to 14 is mandatory. The notice lists those Rules by subject: Rule 9 on key audit matters in line with ISA 701, Rule 10 on the statutory audit committee, Rule 11 restricting the auditor's logo, brand and identity in clients' annual financial reports, Rule 12 on the audit transparency report, Rule 13 on non-resident companies' financial statements and Rule 14 on non-compliance with laws and regulations.

So Rule 10 is one of the mandatory Rules, and its subject is the statutory audit committee. Its wording is not reproduced here; read it in the FRC's compilation of its Rules 1 to 14 and note on the planning file which of its requirements apply to the client and how the team will test them. Because the notice addresses statutory auditors, a team that has not considered Rule 10 on a client with a statutory audit committee has a gap an FRC reviewer may notice.

Members registering in the Governance category

The FRC's registration guidelines for individual professionals provide for audit committee members to register with the FRC under the Governance category. They do so by uploading the minutes of the meeting where they were appointed, or a letter of introduction from the entity.

For the auditor this gives a concrete question to ask at planning: which committee members hold FRC registration numbers, and under which category? The minutes that appointed them are also the document the member needed to register, so a client that cannot find them has two problems, not one.

The guidelines add that professionals whose bodies are not listed may apply in writing to the FRC's registration address with their certificate and the body's enabling law. A committee member from such a profession is not automatically excluded, but the route is different and slower.

The chairman's professional membership

Rule 2 of the FRC's Rules carries a specific requirement for the committee's chairman. Under Rule 2(c), an audit committee chairman who attests must be a professional member of an accounting body established by Act of the National Assembly.

Rule 2 also governs a note in the statements. Under Rule 2(b), a reporting entity must disclose in a note to its financial statements the name, firm and FRC registration numbers of every professional who provided any form of assurance service on its accounts, with a summary of the services rendered. The note will name the auditor itself, so the team should check it against the services the firm actually provided and the FRC numbers it actually holds.

Why the auditor cares: the confirmation before signing

Under FRC Rule 14, effective 1 January 2025, the auditor must confirm by e-mail to the FRC, before signing an audit opinion, that the reporting entity and all signatories to the financial statements have met their obligations under FRC Rules 1 and 2 and the listed sections of the FRC Act. Since the chairman's attestation falls under Rule 2, the auditor cannot give that confirmation honestly without having checked it. The full sequence is covered in Rule 14 confirmations and Rule 9 key audit matters.

A short list of what to establish with the client's company secretary:

1. Whether the client has a statutory audit committee, and the Rule 10 requirements that apply to it.
2. Each member's FRC registration number and category.
3. The minutes of the meeting that appointed each member.
4. The chairman's professional body and membership evidence, for Rule 2(c).
5. The draft Rule 2(b) note listing assurance providers and their FRC numbers.

Recording governance matters in Achekam

Achekam's TCWG & Governance Pack Centre saves its work on the server for the chosen engagement, alongside the Engagement Control Tower and the other fieldwork tools. That is the natural home for the team's communications with the committee and its record of the committee's composition and registrations. The ISA numbers shown on these screens' badges are labels, not evidence of compliance; the evidence is what the team records.

On a Nigerian engagement, the engagement page also shows an Audit Control Tower covering entity classification, whether company law requires an audit, the ISA for LCE, an acceptance checklist, regulatory confirmations and sector checklists. The regulatory confirmations are where the auditor's Rule 14 work is recorded; the committee checks above feed directly into it. More on how the Tower is laid out is in the audit control tower for Nigerian and Kenyan engagements.

Where the team has to make a judgement, for example on whether a chairman's membership meets Rule 2(c), the firm's quality registers can hold it. Professional judgements are kept on the server with every version and who changed it. Sign-off roles on those judgements are checked only by the screen, not by the server, so the firm should still confirm who signed off.

Regulatory confirmations on the engagement

The audit committee is usually the auditor's strongest ally in a difficult year. Checking its standing early, and politely, keeps it that way, and spares everyone an awkward conversation at the signing meeting.

General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.