The Financial Reporting Council and the Architecture of Economic Trust
How stronger accounting discipline can support transparent business fair revenue collection and sustainable development in Bangladesh
Sayeed Ahmed FCA
Published: 18 Sep 2026, 10:40 AM
Sayeed Ahmed FCA. Photo: Collected
Reliable accounts are not merely a concern of accountants. They influence the price of credit, the confidence of investors, the protection of depositors, the fairness of taxation and the quality of economic decisions. Bangladesh created the Financial Reporting Council under the Financial Reporting Act 2015 to place financial reporting and audit of public interest entities within an independent system of standard setting, monitoring and oversight. The next stage is to make that mandate visible in the behaviour of businesses and in the quality of information used across the economy.
Financial reporting
as public infrastructure
Roads, ports and power networks are recognised as economic
infrastructure because many users depend on them. Trustworthy financial
reporting performs a similar, less visible function. A lender decides whether a
business can repay. An investor judges whether profits are sustainable. A
supplier considers whether to offer credit. A board evaluates management. A
revenue authority examines the tax base. Employees and pension funds assess the
strength of an organisation on which their future may depend. Each decision is
weakened when the underlying accounts are incomplete, inconsistent or difficult
to compare.
The benefit of reliable reporting therefore extends beyond a
company's owners. A material error in one set of accounts may influence bank
lending, market prices, tax assessment and business contracts. Where weak
reporting becomes common, the wider cost appears as a higher risk premium,
cautious investment, misdirected credit and loss of public confidence. This is
why the Financial Reporting Act focuses on public interest entities: their
size, use of public funds, market presence or systemic importance gives their
reporting a consequence beyond the private affairs of their owners.
The FRC's role should be understood within this wider
setting. It is not a substitute for company directors, auditors, professional
bodies, sector regulators, stock exchanges or revenue authorities. Directors
remain responsible for preparing true and fair financial statements. Auditors
provide independent assurance. Professional bodies educate and regulate their
members. Sector regulators supervise their respective industries. Revenue
authorities administer tax, value added tax and customs duties. The FRC adds a
missing layer: independent oversight of whether reporting and audit standards
are properly applied where the public interest is significant.
What accounting
discipline should mean
Discipline in accounting should not mean fear, excessive
formality or punishment for every honest error. It should mean that similar
transactions are reported in similar ways; estimates have evidence; related
parties are disclosed; assets are not overstated; obligations are not hidden;
revenue is not brought forward without basis; and auditors approach important
claims with professional care. It also means timely correction when weakness is
found.
A disciplined reporting system rests on four connected
elements. First, standards must be clear and suited to the legal and economic
setting. Second, preparers and auditors must possess the knowledge and
independence to apply them. Third, monitoring must identify material departures
and require proportionate correction. Fourth, enforcement must be credible,
fair and consistent. Standards without monitoring may become optional in
practice. Enforcement without guidance can produce caution without improvement.
The FRC can connect these elements.
Bangladesh's FRC already has a broad statutory foundation.
Its official functions include adopting or setting financial reporting and
auditing standards with reference to international frameworks, monitoring
reports of public interest entities, overseeing audit practice and supporting
professional conduct. Its recent adoption activity also reflects the expanding
global reporting agenda, including IFRS 18, IFRS 19 and the IFRS S1 and S2
sustainability disclosure standards. The value of adoption, however, will
ultimately be measured by implementation rather than publication.
From standards on
paper to reliable company accounts
International Financial Reporting Standards create a common
language, but a common language does not guarantee a truthful conversation.
Many reporting failures arise not because a standard is absent but because
judgement is weak, evidence is incomplete or commercial pressure influences the
accounting outcome. The FRC can narrow this gap through risk-based financial
statement review.
A risk-based approach would not attempt to review every line
of every report. It would select entities and topics according to public impact
and likelihood of material error. Indicators might include rapid growth
unsupported by cash flow, repeated changes in accounting policy, large
related-party balances, unusual gains, persistent operating losses combined
with reported profits, major estimates, qualified audit opinions, delayed
reporting, large tax differences or sectors facing economic stress. Selection
criteria should be published at a broad level so that the market understands
the areas of concern without compromising individual reviews.
The review process should distinguish an acceptable
judgement from a material breach. Accounting often requires estimates, and two
careful professionals may not always reach the same number. The proper question
is whether the method, assumptions, evidence and disclosure fall within a
reasonable application of the standard. Where they do not, the response might
range from clarification and future correction to restatement, public notice,
investigation or sanction, depending on seriousness and intent.
Publishing an annual report on common findings would
multiply the value of individual reviews. It could explain recurring weaknesses
in revenue recognition, asset valuation, expected credit losses, related-party
disclosures, going-concern assessment, consolidation, tax accounting and
cash-flow statements. The report should anonymise cases unless publication is
legally required. Its purpose would be preventive: thousands of preparers and
audit committees could correct a weakness before it becomes an enforcement
matter.
Audit quality as a
national economic concern
Financial statements become more useful when an independent
auditor has tested the material claims. Yet an audit report is valuable only
when the work behind the signature is competent, independent and sufficiently
sceptical. The FRC's inspection of audit firms should therefore focus on the
quality of evidence and judgement, not only the presence of files and
checklists.
Global experience supports independent audit oversight. The
World Bank notes that a movement toward independent oversight developed after
major corporate failures exposed the limits of relying solely on professional
self-regulation. The International Forum of Independent Audit Regulators
requires its members to be independent of the audit profession and engaged in
public-interest regulation. Its inspection surveys continue to identify
inconsistency in audit execution and weaknesses in firm-wide quality
management, showing that even mature markets must keep improving.
Bangladesh can draw several practical lessons. Audit
inspection should be risk-based and proportionate to the public significance of
the engagement. Inspectors should have strong technical training and consistent
review methods. Findings should distinguish between an isolated engagement
failure and a weakness in the firm's quality system. Firms should prepare
measurable improvement plans, and the FRC should verify whether promised
changes work in later audits. Serious or repeated failures require firm action,
while less serious matters may be corrected through guidance and monitored
remediation.
Auditor independence deserves particular attention.
Independence is affected not only by direct financial interest but also by long
association, dependence on one client, provision of conflicting services, fee
pressure and close familiarity with management. Rotation rules and ethical
requirements help, but the audit committee also has a central role. It should
understand why the auditor was selected, how fees were determined, what major
judgements arose, and whether management restricted access to people or
information.
The connection with
tax value added tax and customs revenue
A careful boundary must be maintained. The FRC is not a
revenue-collecting authority, and financial reporting profit is not
automatically the same as taxable profit. Tax laws permit or require
adjustments that accounting standards do not. Value added tax is generally
linked to taxable supplies and input credits, while customs duties depend on
classification, value, origin and other legal rules. It would therefore be
incorrect to assume that an accounting profit can simply be converted into a
tax demand.
Even so, trustworthy accounts can materially improve the
information environment in which revenue laws operate. Sales records, inventory
movements, receivables, imports, capital expenditure, related-party
transactions, provisions and cash flows provide connected evidence. When these
records are complete and reconciled, businesses can prepare more accurate
returns, and revenue officials can focus their work on genuine differences
rather than basic uncertainty. Better information supports both collection and fairness:
compliant businesses face fewer avoidable disputes, while intentional
misstatement becomes harder to conceal.
The strongest contribution of the FRC is therefore indirect
but important. By improving financial statements and audit quality, it can reduce
the space for inconsistent reporting across shareholders, banks and revenue
authorities. A company should not present one economic story to lenders,
another to investors and a third to the tax administration without a documented
legal reason for the differences. Reconciliations between accounting profit and
taxable income, between reported sales and VAT returns, and between imports
recorded in accounts and customs documents can make legitimate differences
visible.
Cooperation should respect confidentiality and due process.
The FRC, National Board of Revenue, Bangladesh Securities and Exchange
Commission, Bangladesh Bank, Registrar of Joint Stock Companies and Firms,
Insurance Development and Regulatory Authority and other relevant bodies could
agree on lawful information-sharing arrangements, common identifiers and
referral procedures. Data should be shared for a defined purpose, protected
against misuse and made available to the affected entity where fairness
requires. The objective is not to create overlapping investigations but to
prevent a material finding from becoming trapped inside one institution.
Digital reporting offers a further opportunity. Structured
financial statements can allow authorised systems to compare related figures,
identify unusual changes and trace inconsistencies more efficiently.
International practice increasingly uses digital tax reporting, electronic
invoicing and standardised business-reporting formats. Bangladesh should
proceed in stages, beginning with common definitions and reliable source data.
Automating poor-quality information only produces errors more quickly.
Transparency that
supports business rather than burdening it
Businesses sometimes view regulation as a cost, especially
when several agencies request similar information in different forms. A
well-designed FRC regime can reduce this burden. If a high-quality set of
audited financial statements becomes a dependable common record, banks,
investors and regulators can rely on it instead of repeatedly asking companies
to recreate the same facts. Greater trust can shorten due diligence, improve
access to finance and make comparisons across companies easier.
Proportionality is essential. Public interest entities
require close oversight because their reporting affects many stakeholders.
Smaller private businesses need simpler requirements suited to their size and
users. Applying the full complexity of listed-company reporting to a small
enterprise may increase cost without improving decisions. The global approach
recognises this distinction through standards designed for smaller entities and
through proportionate disclosure regimes. The FRC can clarify which framework
applies to whom and coordinate with other authorities so that thresholds are
coherent.
Transparency should also be useful, not merely extensive.
Long financial statements can hide important matters as effectively as short
ones. Clear explanation of business performance, liquidity, major estimates,
related parties, risks and uncertainty is more valuable than repeated standard
wording. The FRC's review letters and guidance can encourage entity-specific
disclosure in plain language while discouraging immaterial detail.
Better reporting and
economic development
The relationship between reporting and development is
practical. Savings become investment through banks and capital markets. Those
institutions allocate funds by comparing expected return with risk. When
accounts are reliable, productive businesses are more likely to receive finance
on reasonable terms. When accounts are weak, lenders rely excessively on
collateral, personal connections or short-term security. This can direct credit
away from innovative but asset-light firms and toward businesses that own
property even when their economic prospects are less promising.
Reliable reporting also improves the governance of
state-owned enterprises and other entities using public resources. The OECD's
2024 guidance states that state-owned enterprises should meet high standards of
accounting, disclosure and independent audit. Transparent reporting enables the
state to act as an informed owner, evaluate performance, identify fiscal risks
and distinguish a public-policy obligation from commercial underperformance.
Such clarity protects both the enterprise and the public purse.
Foreign and domestic investors also value comparability. An
investor who understands the accounting framework and trusts its enforcement
can evaluate a Bangladeshi business with greater confidence. This does not
remove commercial risk, but it reduces uncertainty about the information
itself. Over time, stronger reporting can support deeper capital markets, more
disciplined bank lending and a lower cost of assessing investment
opportunities.
The World Bank treats effective corporate reporting as part
of a broader development framework because it strengthens the business climate,
access to finance, financial-sector stability and the oversight of state-owned
enterprises. The contribution is cumulative. One improved audit may not change
national investment, but a system that consistently produces credible
information changes how thousands of decisions are made.
The next global
frontier of reporting
The accounting world is expanding beyond historical
financial statements. Investors increasingly ask how climate change, resource
use, workforce conditions, supply chains and governance may affect an entity's
cash flows, access to finance and long-term prospects. The International
Sustainability Standards Board issued IFRS S1 and IFRS S2 to create a global
baseline of investor-focused sustainability information. Bangladesh's FRC has
taken steps toward adopting these standards, placing the country within an
important international transition.
Implementation should be gradual and evidence-based.
Sustainability reporting must not become a collection of attractive claims that
cannot be verified. Entities need governance, data ownership, measurement
methods and internal controls. Auditors and other assurance providers need
suitable competence. The FRC can issue a phased roadmap that begins with larger
public interest entities, provides limited transition relief, identifies
sector-relevant information and builds assurance requirements as data quality
improves.
Technology creates another global challenge. Automated
accounting and artificial intelligence can increase speed and detect patterns,
but they can also reproduce errors at scale. Responsibility must remain with
directors, preparers and auditors. The FRC should encourage documentation of
important automated decisions, controls over data, protection from unauthorised
change and human review of material estimates. Regulation should remain neutral
about particular software while being clear about the quality of the resulting
information.
An institutional
agenda for a stronger FRC
The FRC can increase its economic contribution through a
focused programme built around the following priorities.
A published
risk-based oversight plan. The plan should explain how public interest,
sector risk, market significance and prior findings influence financial
statement review and audit inspection.
A single view of
reporting quality. Findings from financial reporting review, audit
inspection, enforcement and standard setting should be analysed together so
that recurring causes are visible.
Timely thematic
reports. Short public reports on common weaknesses should provide examples
of better practice without disclosing protected information.
Consistent and
proportionate enforcement. A transparent range of responses should
distinguish inadvertent error, weak competence, repeated failure and deliberate
misconduct.
Stronger audit committee
engagement. Guidance and outreach should help audit committees challenge
accounting estimates, related-party transactions, auditor independence and
correction plans.
Formal regulatory cooperation. Written arrangements with
relevant regulators and revenue authorities should define lawful referral,
confidentiality, data standards and avoidance of duplicate work.
Digital financial
reporting. A staged programme should introduce structured, machine-readable
reports for major public interest entities and create validation rules at the
point of filing.
Professional
capacity. FRC reviewers need continuing training, sector knowledge and
competitive career paths. Preparers, auditors and directors also require
practical implementation support.
Sustainability
reporting readiness. A national roadmap should align adoption, data
systems, assurance capacity and proportional relief.
Measurement of
outcomes. The FRC should report not only inspections completed but also
restatements, corrected practices, recurring findings, remediation rates and
improvements in filing quality.
Independence
accountability and institutional trust
An oversight body can require independence from the
profession it regulates while remaining accountable for its own conduct. Independence
protects technical judgement from improper influence. Accountability requires
published procedures, reasoned decisions, conflict safeguards, review or appeal
mechanisms, financial discipline and regular reporting on performance. Both are
necessary for legitimacy.
The FRC should also maintain a constructive relationship
with the accounting profession. Independent oversight and professional
development are not competing goals. Professional bodies possess education
systems, member networks and technical knowledge; the FRC holds the wider
public-interest mandate. Cooperation in training, research and standard
implementation can raise quality, provided that inspection and enforcement
decisions remain independent.
Regulation works best when those affected understand both
the rule and its purpose. Consultation on major standards, plain-language
guidance, roundtables with preparers and users, and publication of reasoned
responses can improve compliance and reveal unintended cost. Openness does not
weaken authority. It helps ensure that authority is informed and predictable.
A quiet institution with a wide economic reach
The FRC will not build a factory, collect a tax return or
approve a bank loan. Yet it can improve the information behind all three. Its
work determines whether reported profit can be trusted, whether an audit
signature carries weight, whether related transactions are visible and whether
economic differences across records can be explained. This is a quiet form of
public infrastructure, but its reach is wide.
The most valuable future for the FRC is not measured by the
number of penalties alone. Success would be seen when companies correct
problems before filing, audit committees ask better questions, auditors gather
stronger evidence, regulators rely on consistent information, honest taxpayers
face fewer disputes and investors can compare opportunities with greater
confidence. Enforcement remains necessary, but prevention and improvement
create the larger return.
Bangladesh has already established the legal foundation and
is engaging with new global standards. The next task is to join standard
setting, monitoring, audit oversight, regulatory cooperation, digital reporting
and capacity development into one coherent system. If pursued with
independence, fairness and professional depth, the FRC can help turn accounting
from a year-end obligation into a national asset: a dependable record of
economic activity on which trust, revenue and sustainable development can grow.
The author is a
Chartered Accountant and a professional with experience in financial reporting,
audit oversight, banking and risk governance. The views expressed are personal
and intended to contribute constructively to public discussion.