FRC Rule 14 confirmations and Rule 9 key audit matters
What FRC Rules 14 and 9 ask of a Nigerian auditor before an opinion is signed, and how Achekam holds the report until the team records each step.
By Achekam · · 4 min read · For Accountants & audit firms in Nigeria
Two of the Financial Reporting Council's rules land in the final days of a Nigerian audit, when the team is busiest and the client is impatient for its report. Rule 14 asks for an e-mail to the FRC before the opinion is signed. Rule 9 decides whether the report must carry key audit matters and, where it carries none, asks the auditor to tell the FRC in writing.
Neither step is complicated. Both are easy to forget, and both are the kind of omission an inspection finds months later. Achekam's Nigerian pack does not send anything on the firm's behalf, but it will not let the report through until the team has recorded that each step was done, with evidence.
Rule 14: the confirmation before signing
Under FRC Rule 14, from 1 January 2025, a Nigerian auditor must confirm by e-mail to rule14@frcnigeria.gov.ng, before signing an opinion, that the client and its signatories complied with FRC requirements. The FRC declared Rules 1 to 14 mandatory by a public notice to statutory auditors of 24 June 2025. The FRC Rules themselves are the place to read the exact wording.
The order matters. The e-mail comes before the signature, so it belongs on the completion checklist, not in the post-signing administration.
Rule 9: which reports carry key audit matters
FRC Rule 9 requires key audit matters, reported in the way ISA 701 describes, in auditor's reports on these Nigerian entities:
- listed entities;
- public companies;
- banks, other than microfinance banks;
- insurers, other than HMOs;
- mutual funds;
- pension funds;
- private holding companies of any of the above.
The rule was issued on 15 November 2016 and reaffirmed on 24 June 2025. The list reaches further than listed entities, so a private holding company sitting above an insurer, for instance, falls inside it.
Notifying the FRC when none is communicated
Sometimes an audit in a Rule 9 category ends with no key audit matter to communicate. In that case the auditor notifies the FRC in writing before the audit concludes. This is a separate step from Rule 14 and easy to miss, because a report with no key audit matters looks finished. Keep the reasoning behind the conclusion on the file as well: the notice tells the FRC what was decided, and the working papers should show why.
How Achekam holds the report
On a Nigerian engagement, the engagement page shows an Audit Control Tower. It covers entity classification, whether company law requires an audit, the ISA for LCE decision, an acceptance checklist, regulatory confirmations and sector checklists. Achekam also works out whether key audit matters are required, using the Rule 9 categories.
The confirmations sit under Engagement > Audit Control Tower > Confirmations. On a Nigerian audit, the report stays blocked until the team records, with evidence, that the Rule 14 confirmation was sent and, where needed, that the FRC was notified under Rule 9. In particular:
- Achekam does not send the Rule 14 e-mail. The auditor sends it and records it with evidence in Achekam, and signing stays blocked until it is recorded.
- For an audit in a Rule 9 category that communicates no key audit matter, Achekam requires the written notice to the FRC to be recorded with evidence before signing.
The report itself is drafted on standard ISA 700, 705, 706 and 701 wording, and for a Nigerian engagement the draft uses Nigerian legal wording that cites CAMA 2020 and the FRC Act. The partner owns the final text, and only the engagement partner approves it. The acceptance checklist in the Control Tower must also be approved by a partner other than its preparer before the report can be approved.
The sequence on one engagement
Take an audit of a private holding company whose subsidiary is an insurer. In the Control Tower, the entity is classified and Achekam shows that key audit matters are required. Late in the audit, the team concludes that there is no matter to communicate. The manager drafts the written notice to the FRC, the partner sends it, and the team records it with the sent copy as evidence. Separately, the partner sends the Rule 14 confirmation e-mail and the team records that too. Only then does the report move to approval and signing.
| Step | Sent by | Recorded in Achekam | Blocks signing until recorded |
|---|---|---|---|
| Rule 14 confirmation e-mail | The auditor | Yes, with evidence | Yes |
| Rule 9 notice where no key audit matter | The auditor | Yes, with evidence | Yes, for Rule 9 categories |
| Key audit matters in the report | The engagement team | In the report draft | Required for Rule 9 categories |
A completion checklist for Nigerian audits
- Confirm the entity's classification and whether Rule 9 applies.
- If it applies, decide the key audit matters, or prepare the written notice if there are none.
- Send the Rule 14 confirmation before the opinion is signed.
- Keep the sent e-mails as evidence: the full message with date and recipient.
- Record each step in the Control Tower's Confirmations.
- Have the acceptance checklist approved by a second partner.
Keeping the sending with the auditor
Achekam records but does not send, so the habit to build is simple: the sent message comes first, the record follows straight away with the evidence attached. Make that part of the partner's pre-signing routine on every Nigerian file. The other gate on the same report is the firm's FRC listing, explained in the FRC firms register and signing a Nigerian audit; for comparison, the South African position on registrations is in who checks the signing partner's IRBA registration.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
