Independence declarations: what is recorded today
What Achekam records about staff independence, the approval and assignment checks it does not perform, and what an audit firm must still do outside it.
By Achekam · · 4 min read · For Accountants & audit firms in South Africa, Nigeria, Kenya
A first-year trainee is put on the audit of a family company. Nobody asks, and the trainee does not think to mention, that an aunt is the client's financial director. The annual declaration the trainee signed in January said "no relationships to declare", because at the time the trainee had not been assigned to that client and did not know the firm audited it.
Independence failures rarely come from bad faith. They come from timing: a declaration made once a year, an assignment made on a Tuesday afternoon, and no step that connects the two. This article sets out what Achekam records about independence today, the two checks it does not perform, and the work a firm needs to keep doing itself.
What staff can record
Under Quality & Governance, Independence & Conflicts, staff record their annual independence declarations. They also record any interest, relationship or gift involving a client as it arises, rather than waiting for the next annual cycle.
Anyone can check whether a person has an active independence exception for a client. That check is the most useful part day to day: before a manager adds someone to a team, they can look the person up against that client and see whether something is on record.
Two checks that do not happen
Achekam has no way to approve an independence declaration. Every declaration stays "awaiting the quality partner", however long ago it was submitted. If your firm's policy requires the quality or ethics partner to review declarations and evaluate any threats, that review and its outcome must be recorded outside Achekam.
Assigning a person to an engagement also does not check the independence register. A manager can put someone on a team with an active exception for that client, and nothing will warn them. The check described above is available, but it has to be done by a person.
Both limits are worth stating plainly to your quality partner and to staff, so that nobody assumes the system is doing work it is not.
At signing, the partner confirms outside Achekam
When a partner signs the firm's financial statements in the Partner Signing Cockpit, the signature is bound to that version's content hash. The cockpit also asks the partner to confirm acceptance and independence outside Achekam.
Read that prompt literally. It is a reminder that the evidence of independence for this engagement sits wherever your firm keeps it: a signed engagement-level confirmation from each team member, the quality partner's evaluation of any threats, and the safeguards applied. The partner should have seen that evidence before clicking.
Restricting a client to named people
Where a threat is identified, or where a client is simply sensitive, partners and administrators can restrict a client, or a single engagement, to named people, with a reason. A restriction is later lifted rather than deleted, and who did what and when is recorded. The account manager and the engagement's partner and manager can always open a restricted client.
The restriction reaches beyond the client file. A meeting about a restricted client shows only as "busy" to people who are not on that client's access list, so a colleague browsing the calendar does not learn who the firm is meeting about what.
Restriction is a safeguard, not an independence evaluation. It keeps people with a conflict away from the file; it does not record why that person is conflicted or what the quality partner concluded. Keep both.
Who does what today
| Task | In Achekam | Outside Achekam |
|---|---|---|
| Annual declaration by each person | Recorded | Policy on timing and follow-up |
| Interests, relationships and gifts | Recorded as they arise | Evaluation of the threat |
| Approving or reviewing a declaration | Not possible; stays awaiting | Quality partner's review and conclusion |
| Checking a person before assignment | Available as a look-up | Making the look-up a required step |
| Keeping a conflicted person off a client | Client or engagement restriction | Recording why |
| Partner's confirmation at signing | Prompted in the cockpit | The evidence the partner relies on |
The law adds to the professional code
Independence is in the professional codes every firm already applies, and in some places in company law as well. In Kenya, for example, the Companies Act 2015 bars an ineligible auditor at s.773 and covers independence at s.774; the text is on Kenya Law. Whatever the source of the rule in your country, the record that shows you met it is the firm's to keep.
A practical routine until approval exists
- Ask every person to submit the annual declaration in Achekam, and to record interests, relationships and gifts during the year as they arise.
- Have the quality partner review declarations on a fixed date and keep a signed list of what was reviewed and concluded, outside Achekam.
- Make "check for an active exception" a written step in your team-assignment procedure, done by the manager who assigns.
- Restrict any client where a threat has been identified, with the reason stated.
- Before signing, the partner confirms the engagement-level independence confirmations are complete, then answers the cockpit's prompt.
This sits alongside the acceptance and conflict check at the start of a relationship, covered in client acceptance and the conflict check, and alongside the other quality records described in quality registers and consultations.
What to change this month
Take your team-assignment procedure and add one line: the person assigning checks the independence register for that client first. It is a small step for each assignment, and it covers the one connection Achekam does not make for you.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
