23 July 2026

Minerva Analytics has moved to help shape the UK’s latest audit reforms, setting out its position in response to the Financial Reporting Council’s (FRC) consultation on revisions to two auditing and assurance standards and urging clearer guidance to ensure consistent, high-quality assurance.
Minerva broadly supports the amendments. Its consultation response argues that tightening ethical standards around the use of external experts is necessary though insufficient without clearer guidance, positioning investors’ need for consistency and accountability at the centre of audit reform.
We responded to the consultation to offer an investor and stewardship perspective given Minerva’s more than 30-year mission to provide objective and expert sustainable stewardship support services to professional investors.
Minerva’s consultation response addressed areas including the integration of ethical requirements, objectivity and independence, transparency for Investors and the timeline for the revised standards. The two standards in question are ISA (UK) 620 Using the Work of an Auditor's Expert and ISAE (UK) 3000 Assurance Engagements Other than Audits or Reviews of Historical Financial Information.
“From an investor and stewardship perspective, we broadly support the proposed amendments,” wrote Sarah Wilson, CEO of Minerva Analytics. She welcomed the stronger integration of ethical considerations into the evaluation of experts, enhanced focus on competence, capabilities and objectivity and the introduction of an explicit prohibition on using an expert where those requirements are not met.
“The proposed changes should contribute positively to audit and assurance quality; however, we encourage the FRC to provide practical guidance, examples and clarifications to support consistent application,” added Wilson. The response also stated that subject to Minerva Analytics’ observations, we support the proposed amendments and “believe they represent a positive enhancement to the UK audit and assurance framework”.
The ISA 620 standard sets out an auditor’s responsibilities when using the work of an expert outside accounting or auditing. Meanwhile, the ISAE 3000 standard sets a framework for assurance engagements where an independent practitioner provides assurance over non financial information.
The consultation on narrow scope amendments to the pair of standards is being undertaken in response to tweaks made to the equivalent international standards by the International Audit and Assurance Standards Board (IAASB). These amendments respond to the International Ethics Standards Board for Accountants’ (IESBA) recently approved revisions to its International Code of Ethics for Professional Accountants. This introduced provisions including explicit ethical requirements for using the work of external experts in audit, assurance and non-assurance engagements.
Minerva’s response stated that the proposals “appear to be a sensible response to the IESBA and IAASB revisions, helping to reinforce ethical considerations when using the work of external experts”. It also noted the addition of a “clear prohibition” on using the work of an expert where the necessary criteria are not met, which could help support audit and assurance quality and strengthen confidence in both financial and non-financial reporting.
The FRC has proposed an effective date for audits of financial statements for periods beginning on or after 15 December 2026 for all the amended standards within the scope of its recent consultation, which closed on 10 July 2026.
One of central concerns highlighted by Minerva in its consultation response was the need for there to be consistency between the two standards to help ensure that the “same rigour and quality assurance” can be found in both financial and non-financial data provided. Namely, the ISA 620 offers examples of situations that can impact objectivity, such as self-interest threats, advocacy threats and intimidation threats. However, ISAE 3000 lacks such examples, with Minerva suggesting that their addition could prove helpful to avoid leaving these at the discretion of the auditor or the external expert.
Minerva urged the FRC to provide practical guidance, examples and clarifications to support consistent application before its effective date in December. While Minerva suggested that the date would be reasonable with those provisions, additional guidance from the Council is needed to assess an expert’s competence, capabilities, and objectivity.
The consultation response also encouraged the FRC to consider the practical implications for smaller expert organisations to “ensure the proposed changes remain proportionate in practice”, including the potential cost and administrative burden associated with enhanced documentation requirements.
“As investors increasingly rely on assurance over both financial and non-financial information, it's important they can have confidence in the independence, competence and objectivity of the experts involved in the audit process,” said Darren Ball, Research Team Leader at Minerva Analytics. “We welcome the FRC's proposed amendments as a positive step forward, but clearer practical guidance will be key to ensuring they are applied consistently across the market”.
As audit and assurance expand into non-financial reporting, consistency in how expert input is assessed will be critical. Without clearer guidance, the risk is a fragmented assurance landscape. Minerva’s response positions this not as a technical detail, but as central to investor confidence in reported outcomes.