Closed for Christmas

The office will close 20th December 2019 at 3pm.  It will reopen on Thursday 2nd January 2020. 

Thank you to all our clients and suppliers for a wonderful 2019 and here’s to continued success in 2020!

Governance Seminar 2020

We are delighted to confirm the renewal of our annual Not for Profit Governance Seminar for 2020.

Date for your diary: 27th February 2020

Time: 9:30 – 13:00



  hours  minutes  seconds


Governance 2020

Location: Crowne Plaza, Santry, Dublin 9

Themes and topics to be confirmed in the new year. If you wish to register your interest in attending please email

2019 CGT Deadline

If you sold, gifted or transferred an asset between 1 January and 30 November 2019, or received capital payments from such assets, the deadline for payment of any Capital Gains Tax due is  15 December 2019.

If you have made a disposal and need assistance in making the correct returns or need advice on preparing your liability please get in touch.


For disposals between 1 December and 31 December 2019, the payment deadline is 31 January 2020.

These arrangements apply to all taxpayers, including PAYE and self-employed.

Registration of Beneficial Owners

*Not Spam – Company Compliance Obligation!!

If you are a Director or a Secretary of a company and are unaware of the requirements then you are not alone as we have had a number of clients email us to query whether these emails are spam. This is a new anti-money laundering compliance requirement whereby all companies in Ireland are obliged to upload the details of all beneficial owners of the company.

If you are the Secretary of a Company in Ireland you will have received an email from the CRO in relation to the company’s duties to file a return to the


The Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2018 transposes the majority of the Fourth EU Money Laundering Directive (4MLD) into National Law. Statutory Instrument Number 110 of 2019 transposes the elements of 4AMLD & 5AMLD that require companies and industrial and provident societies to maintain an internal register of their beneficial owners and to file this information with a central register.

The Regulations came into effect on the 22nd March 2019, with immediate effect for companies/societies to create and maintain their own internal register.

Any company/society who has not filed on or before the 22nd November 2019, will be deemed to be late and be subject to sanctions as prescribed in the Regulations including significant fines

The central Register of Beneficial Ownership of Companies and Industrial and Provident Societies (RBO) is a standalone Register which is being established under anti-money laundering legislation, not company law.

The filing of beneficial ownership data must be done through the on-line portal on the RBO website and is therefore a process separate to the registration of information/forms under the Companies Acts etc. If we act as your professional advisers then we are authorised to present this information on your behalf as Presenters and can provide you with the assurance that this will be complete in advance of the filling deadline and not leave you exposed to potential non-compliance sanctions and fines. We will be in contact shortly to confirm your company details before completing the submission.

RBO – Information Requirement

The requirement for corporate and legal entities (“companies/societies”) to hold their own beneficial ownership register was transposed into Irish law by Statutory Instrument No 110 of 2019. The following information is required for each Beneficial Owner:

  • Company / Society Name:
  • Company / Society Number:
  • Surname:
  • Forename(s):
  • Date of Birth:
  • PPS Number
  • Nationality
  • Country of Residence:
  • Statement of the nature & extent of interest held:
  • Statement of the nature & extent of control exercised:
  • Residential Address:
  • Eircode (optional):
  • Date of entry as beneficial owner:
  • Date of cessation as beneficial owner:
  • If either,
    • after having exhausted all possible means and provided there are no grounds for suspicion, no natural person is identified, or
    • if there is any doubt that any natural person so identified is a beneficial owner of the relevant entity, there shall be entered in the company/society’s internal register as its beneficial owners, the names and details of the one or more natural person(s) who hold the position(s) of senior managing official(s)(SMO) of the company/ society.

All the same details must be entered in the internal register and in the RBO for an SMO as for any other beneficial owner. Relevant entities shall keep records of the actions taken to identify their beneficial owners. (Regulations 5(4) & (5) of S1 110/2019 refer).

  • Presenter Details:
  • Name of presenter:
  • Address of presenter:
  • Phone number of presenter:
  • e-Mail address of presenter:
  • Capacity in which the presenter is acting: (eg officer/employee of company/ society, person acting on behalf of the company/society etc).
  • If the presenter is not a natural person, please enter the name, address, phone number and e-mail address of a natural person for correspondence purposes.

Companies/societies should familiarise themselves with their responsibilities as set out in Regulation 21 of Statutory Instrument No 110/2019

  1. to maintain an internal register of beneficial owners, and
  2. to file data with the Central Register (RBO).

Companies/societies and their agents should also be aware of their responsibilities under GDPR for safeguarding any personal data they hold in respect of its beneficial owners.

Entities should seek their own legal advice/opinion to ensure compliance in this regard.

* The forename & surname entered in the RBO Portal must match the legally registered name of the natural person, i.e. the name as registered on your PPSN with the Department of Employment Affairs and Social Protection.

The Registrar reserves the right to reject any submission where the name entered on the RBO Register does not match the name as registered on your PPSN with the Department of Employment Affairs and Social Protection.

Credit Union – Business Model Strategy

Your Strategic Planning Document is a living breathing document. It underpins your every decision and you report on the key performance indicators and goal achievement on a monthly and quarterly basis…. or is your strategic plan gathering dust on a shelf?

The strategic vision of the Registrar is “Strong Credit Unions in Safe Hands”. The foundation on which this strategy is built is on the belief that strong, well-governed Credit Unions, led by volunteers and retaining their local identity should remain an important part of the financial landscape of Ireland.

In February 2019 The Central Bank issued it’s guidance report on the Business Model Strategy for the sector. Downloadable directly the below link:

BM Guidance—guidance-for-credit-unions.pdf

Detailed within the report are the ten interrelated components to be considered when you are completing any business model risk assessment. We are now using these headers to assess all Strategic Plans. Does your strategic plan adequately assess challenge all of the below items?

  1. Common Bond: the differentiated groups of members to whom the business model is to deliver value.
  2. Member Relationships: the ongoing relationship (physical and virtual interaction) established with members.
  3. Delivery Channels: the routes for reaching new and existing members, for sales and ongoing relationships.
  4. Value Propositions, Products and Services: the value delivered in terms of products/services and other attributes.
  5. Revenue Streams: the new and recurring value being paid for products/services and other attributes.
  6. Key Activities and Key Resources: Key Activities are the activities needed to deliver on value propositions, while key resources are the resources (physical, financial, staff, know-how, software etc.) needed to deliver on value propositions.
  7. Key Partners, Outsourcing and Shared Services are the business partners, suppliers, collaborating entities in formal partnerships that are involved in the supply of products and/or services.
  8. Cost Analysis: the costs of delivering value propositions.
  9. Financial planning: the effect of business model change on financial performance.
  10. Balance sheet considerations: the effect of business model change on the balance sheet.

If your credit union has not completed a detailed review of it’s business model and strategic plan then you may benefit from a third party assessment. We can also assist management teams and Boards to effectively collect their strategies and goals into a fit for purpose reporting format. 

Should you require additional information or a consultation please contact us directly.

Small & Micro Companies

Small & Micro Companies – The New Reporting Requirements

Companies Act 2017 (CA2017) introduced new, simplified accounting requirements for small and micro companies coming from the Small Companies Regime (SCR) and Micro Companies’ Regime (MCR) which derive from the provisions of the 2013 EU Accounting Directive. This reduces administrative burden on small and micro companies. They can adopt simpler requirements in respect of financial statements and reports for a FY.

Qualification to use the SCR and MCR

A company must qualify in order to apply the SCR or MCR in the final preparation of accounts. Some companies are dis-applied from the regimes as ‘ineligible entities’, even if they meet the size criteria. Included here-under are some company types that would be regarded as ineligible:

Scenario 1 – a company that meets the micro size thresholds but is part of a group and included in the consolidated financial statements cannot qualify for the MCR – subsidiary cannot qualify as a micro company.  
Scenario 2 – Holding company meets micro size thresholds but prepares group financial statements, cannot be a micro company.  
Scenario 3 – a subsidiary that meets the small size thresholds itself but is part of a larger group that does not meet the small thresholds can qualify for SCR in preparing its individual financial statements, but not the audit exemption.  
Scenario 4 – a holding company that meets the small size thresholds but is the holding company of a group containing an ineligible entity cannot qualify for the SCR., as to qualify as a holding company, no member of the group can be an ineligible entity.      
  Small Company Small Group Micro company
CA 2014 section280A 280B 280D
Turnover not exceeding€12M (increased from €8.8M)€12M net or €14.4M gross €700,000
Balance sheet total not exceeding€6m (increased from €4.4M) €6m net or €7.m gross €350,000
Average number of employees not exceeding 50 50 10

Can all company types qualify for the SCR or MCR?

Eligible    Excluded
Company limited by shares Public limited companies (PLCs)
Company limited by guarantee (CLG) public unlimited companies (PUCs)
Designated activity company (DAC) public unlimited companies with no share capital (PULCs)
Unlimited company (ULC)  

What accounting standards do companies use when applying the SCR and the MCR?

Small Companies      Micro Companies
FRS 102 section 1A FRS 105

Both applicable standards have been amended to reflect the Irish company law disclosure requirements.

  • SCR and MCR mean fewer disclosures are required in the statutory financial statements of companies

The information required to be provided in the notes to the financial statements of companies adopting the SCR or MCR is driven by CA 2014, FRS 102, section 1A and FRS 105. One of the main advantages of adopting SCR or MCR is the reduction in number of notes to be provided with financial statements. CA 2017 provides exemptions for certain part 6 disclosures, however, this also included new note disclosure requirements. An example being section 321, which requires the reason for an accounting policy change and the impact of the change on the financial statements for current and preceding financial years. Also, notes must be presented in the order in which the items to which they relate to are presented in the balance sheet and profit and loss account.

Details of the disclosures required under the SCR and MCR?

Details of the disclosures required are found in CA 2014 (primarily part 6), the relevant Schedule to CA 2014 and the applicable accounting standards.             

The inclusion of the Irish legal disclosures of the SCR and MCR into FRS 102 and FRS 105 respectively is positive for preparers of financial statements as it creates a ‘one stop shop’ of accounting standard and company law requirements for the financial statements of companies applying the regimes.

  • Disclosing directors’ remuneration in a small and micro company financial statements

Disclosures are required in the financial statements of a company adopting SCR, under FRS 102, including payments to third parties for services of directors.

Companies preparing accounts under FRS 105 1A, MCR, are exempt from these requirements to disclose director’s remuneration.

  • SCR and statement of cash flows

Section 7 of FRS 102 contains a requirement to present statement of cashflows. A small entity does not have to comply with this, although it must qualify as a small entity under FRS 102.

Audit Exemption

Non-group company – May avail of the audit exemption provided that it qualifies as a small company and meets the other requirements of CA 2014.
Group company – Definition of group wider for audit exemption
– To qualify it must head up a group which also meets the small criteria (sub group)
– Small company, part of a group – assess whether largest group to which company belongs qualifies as small.
– Main group qualifies as small, then small company within the sub group may avail of audit exemption.
– If main group does not qualify, precludes all members
– Presence of a securitisation company (s.110 company) in main group precludes all other members  

Do the changes introduced by CA 2017 require more information to be included in financial statements that are abridged for filing purposes?

Possibly, depending on the circumstances. While overall disclosures for SCR and MCR companies have been reduced, all notes to the statutory financial statements are now required to be included in the abridged financial statements. Previously it was just certain notes to be included.

Other considerations when filing include that it is no longer a requirement when filing an annual return with abridged financial statements to include separate statement with director’s interests in shares and debentures.

Small and micro companies are exempt from filing a director’s report.

In conclusion, the simpler requirements of the SCR and MCR are designed to reduce the administrative burdens.

For further information on the Micro-Companies Regime and to see if your company qualifies please do not hesitate to contact us.

Veterinary Practice Valuations

As reported by the tough working conditions, burnout and hard earned income is pushing veterinary practitioners to the brink.

The 2018 Veterinary Practice Survey Report, conducted by HLB Sheehan Quinn, showed that almost half of vets said they would be willing to sell their practice to a corporation, with exhaustion cited as reason for wanting to sell.

The Veterinary Sector has seen a significant increase in the market share of large operators like Independent Vetcare (IVC) and CVS Group Ltd. The growth of  these Corporate operators has been aided by aggressive acquisition strategies by both companies in Ireland and the UK. Struggling practitioners in a lot of cases simply cannot risk turning down the offers tabled.

WDA have been providing accounting and advisory services to Veterinary Practices for a number of years and have built up significant expertise in the sector. If you are currently considering an offer or would like to establish a valuation for your practice please get in touch and we will be able to talk you through your options.

Internal Audit Quality Self-Assessment

As Internal Auditors in the Credit Union Sector WDA were invited to attend a workshop in the Central Bank on 18 July 2018. The subsequent report issued by Central Bank detailed its observations and highlighted Expectations for Internal Audit in the Sector.

WDA completed a detailed self-assessment of its own performance in line with the Central Bank’s Report issued on 18th July 2018 and it is our opinion that the Internal Audit services provided by WDA meets the highest standards expected by the Central Bank.


Supervisory Expectations on the Internal Audit Function.

CBI Findings WDA Response Compliant
Activities that are determined to be higher risk in a credit union should be audited in more depth and more frequently than activities that are determined to be lower risk –risk based approach.

WDA base all internal work plans and audit testing on a risk based approach. WDA have over 25 years of experience providing services to the Credit Union sector including Audit, Internal Audit, Risk and Compliance. WDA IAF staff have experience in conducting risk assessment of industrial and community credit unions ranging from €15m to €350m assets.

The IA Function should establish and maintain a system to monitor the implementation of actions agreed by the board of directors which should include a follow up process to ensure that agreed actions have been effectively implemented.


All quarterly reports issued to the board are accompanied by a response document. These formally capture the board’s consideration of the findings and response to all findings. WDA review all responses received and follow up on all material/ significant mitigation plans.



CBI Findings WDA Response Compliant
IA reports should provide objective assurance on the effectiveness of the credit union’s risk management, internal control and governance processes. It should be accurate, objective, clear, concise, constructive, and complete and timely -to support boards understanding of weaknesses identified.

WDA IAF reports maintain a formal assessment of the effectiveness of the credit union’s risk management, internal control and governance processes.

Reports should cover at a minimum:

o   objectives, scope and work undertaken;

o   An opinion on the effectiveness of the credit union’s risk management, internal control and governance processes;

o   Internal audit findings;

o   Recommendations, ranked by priority, with timelines for implementation, and progress on previously agreed action plans.

WDA have developed and tailored the reporting framework to adhere with all legislative requirements whilst maintaining concise and effective communication style. The reports are all issued in an RMP style and are regarded as being user-friendly and highly effective.


The WDA internal audit reporting framework has historically been well-received during CBI PRISM inspections. 



Engagement with Board    
CBI Findings WDA Response Compliant
Effective engagement with IA should be evident:

o   Boards should have an awareness and understanding of issues identified by IA.

o   Evidence of board discussion and challenge in relation to IA issues raised.

The IA function should make recommendations to boards on improving the effectiveness of the risk management, internal controls and governance processes

All reports issued to Board are accompanied by a response document that formalises the Board’s responses and requires direct engagement with the Board.



Priority Areas    
CBI Findings WDA Response Compliant
Appropriate and effective systems of control are at the core of mitigating operational risk. These include regular verification and reconciliation of transactions and accounts, as well as appropriate segregations of duties, including procedures to deal with key person risk.

WDA have designed a suite of verification tests to gain sufficient assurance with the internal control environment.


Once WDA determined that the risk of internal control failure is sufficiently low the process of implementation of a thematic review cycle can commence.

‘IT’ is a major enabler of strategy and business development for credit unions. The operational risks associated with this area need to be appropriately managed, monitored and reviewed given the reliance on and the pace of change in this area.

WDA have designed and executed a detailed Internal Audit review of IT Infrastructure and Environment in credit unions. 

AML/CFT framework should be included in the risk assessment undertaken by IA–the board should consider, on at least an annual basis, whether the AML/CFT framework should be tested by IA.

WDA have designed and executed a detailed Internal Audit review of AML/CTF in credit unions.


Supervisory Observations on the Internal Audit Function                                                                                                    

CBI Findings WDA Response Compliant
Ineffective engagement with the IA function, including a lack of written responses or challenge to reports from the IA function by the board.

The WDA reporting framework includes a ‘Response Document’ which requires the Board to formally respond on all IAF findings and recommendations.

Failure of boards to adequately monitor the quality of the IA function.

WDA have reported to Boards the requirement to document a formal appraisal of the IAF on an annual basis. WDA have received feedback resulting from these reviews in the past and incorporated improvements/ amendments to the process as a result.

Plans lacking in detail and not demonstrating comprehensive work plans in place.

Annual audit plan designed and discussed with management team including plans for each quarter’s theme. Themes selected on a risk based approach. WDA identify areas with potential control weaknesses and outline areas to be reviewed therein. Comprehensive work plan not reflected in the audit plan as the audit plan is initially set in Q4 of the preceding year and the detailed plan of works is considered when the lead auditor is scoping the areas of weakness in the upcoming quarter.

Lack of formal remediation plans to address findings in previous IA reports.


All findings in IAF report include details recommendations and expected timelines for remediation.

Lack of IA testing in key risk areas e.g. bank reconciliations, IT controls, credit underwriting and risk and compliance functions.

WDA have designed and implemented detailed thematic reviews of ‘IT’ Controls, Credit Underwriting and Credit Environment and Risk and Compliance functions. On all new IAF engagements WDA complete quarterly reviews of the bank and cash reconciliations until sufficient assurances have been sought regarding internal controls and the internal control environment. IAF will maintain testing on the bank and cash to ensure sufficient internal controls and financial controls are in place to mitigate the potential risk to error or fraud in the bank and cash reconciliations.

Examples of weaknesses concerning testing of branch locations (where applicable), including lack of evidence of testing by IA function in branches.

WDA have internal audit clients with multiple branch locations. Within the annual audit plan WDA included branch reviews and testing. The review included; visits on site in each branch location; testing of process and controls and interviews with branch staff.

No consideration given by IA to external audit management letters or third party external review reports.


WDA IAF maintain a review of all external reports and have reviewed the audit management letter in detail on an annual basis. These reviews are incorporated into the document review process in each quarter regardless of the theme.

o   Issues not identified in reports

o   Issues not appropriately ranked/prioritised

o   Lack of awareness at board level of issues identified by IA

o   Lack of review/response by the board of directors Lack of tracking of issues raised in IA Reports by boards and/or IA

WDA have modified and expanded the IAF reporting structure to ensure that all findings are laid out in the established ‘RMP’ format. This provides clarity on the issues/ expectations/ remediation and facilitates the Boards response to the findings. IAF are content that the reporting framework has been sufficiently developed to an acceptable standard and has repeatedly been positively appraised by PRISM inspectors.


If you wish to discuss internal audit services or want us to provide a quotation for services please do not hesitate to contact us:

Winners – Irish Accountancy Awards 2018

At the recent Irish Accountancy Awards event we were delighted to receive the honour of winning the Best Use of Technology in Accounting & Finance 2018 for recognition of the firm’s utilisation of RedFlare. We utilise RedFlare internally to assist with practice manager. We also utilise RedFlare to add value to an integrated Governance, Risk, Compliance and Data Protection consultancy service to our clients. for more information on RedFlare see

We were also nominated for Medium Practice of the Year. The category contained a number of incredible firms and it was an honour to be recognised in their company.

Thank you to the Irish Accountancy Award for the recognition and also for organising a great event.


Copy of Winner

GDPR and Adding Value

GDPR compliance has for some become a big headache and for others big business but both sides should see the upcoming Regulations as an enormous opportunity.

Operational Level

Companies are being forced by the Regulations to review, revise and rethink all its core processing functions. The two initial questions all CEOs/DPOs had to ask themselves were: What do we process? and; Why do we process it? The value-added role in this process was to ask the third question: how can we do it better? Most established businesses will over time have accrued additional processes; captured extra data and inadvertently over exposed themselves in the new world of data protection. This journey to compliance will force them to revise their core functions and find efficiencies in their data capture, data storage and date processing functions. This is an area where resources have not traditionally been allocated but the threat of monetary or reputational penalty has focussed companies on reviewing and refining these processes.

Strategic Level

–        Marketing & Sales

Whether you have been marketing to your customers or intend to market to your customers you must be able to stand over your consent collection and consent recording processes. The regulations are very clear on the requirement for consent to be collected in a clear and transparent way and that the consent has been documented. This is cause for a lot of organisations to worry about data bases they have generated internally over a number of years without consent; marketing lists, email data bases and potential sales lists. Whilst this, for many businesses, is being viewed as a negative outcome of GDPR for many others it is an opportunity to purge your databases of disinterested and disengaged customers and non-customers. A focused campaign of consent collection will allow a sales team/ sales manager to identify a more focussed, narrowed list of truly engaged customers and potential customers. This process should have the potential to reshape the marketing campaigns around a focussed group of purchasers/ service users who want your product and service and want to engage with your company. We have clients that have been ‘selling’ for over 40 years trying sales strategies that they have never previously considered and to great benefit.

–        Service Level Operators

Differentiating your company in the market place as a Professional Services provider, a company operating on a SAAS model or as an Outsourced Service Provider or data processor is a difficult job however, as customers and contracting organisations begin to wake up to GDPR and their own responsibility therein early adopters of GDPR best practice will afford themselves an opportunity to gain an advantage over competing providers and vendors when it comes down to the tendering process. Be a market leader and a standard bearer in your sector. Present your relevant compliance with the Regulations and provide your customers and suppliers with the assurances they will require to continue with your services or chose you over your competitors.

–        Governance Level

No organisation wants to be ‘the one’. The time to start your compliance journey is now, it’s still not too late. Every organisation must allocate commensurate resources to ensure that their organisation can demonstrate compliance with the Regulations or a clear plan to achieve compliance in a reasonable time frame. No organisation will be compliant on 25 May 2018 but the Regulators will expect that all organisations will be able to demonstrate their own responsibility to the protection of their data and their data subjects rights. The decision now is how to add value in that process.

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