IESBA's exposure draft contains three key proposals in the following areas:

• Management responsibility. The exposure draft proposes additional guidance and clarification regarding what constitutes 'management responsibility' and enhanced guidance on how the auditor can be satisfied that management are fulfilling their responsibilities.
• Preparing accounting records and financial statements. The exposure draft proposes guidance and clarification on the concept of "routine or mechanical" services relating to the preparation of accounting records and financial statements.
• Emergency exception. The exposure draft proposes removing the provision that permits an audit firm to provide certain bookkeeping and taxation services to public interest entity audit clients in emergency situations.

In relation to these proposals, the FRC support the majority of the proposals around management responsibility, as well as the changes in relation to the emergency exception and "routine or mechanical" services.

One area in with the FRC has concerns is IESBA's proposal that:

"providing advice and recommendations to assist management in discharging its responsibilities is not assuming a management responsibility."

In this regard, the EU Audit Regulation prohibits auditors from playing any part in the management or decision-making of an audit client which is a Public Interest Entity (PIE), which the FRC believes may potentially conflict with the IESBA proposal. They recommend IESBA consider this further.

The full response can be accessed on the FRC website.