Statement
IESBA Consultation on Collective Investment Vehicles and Pension Funds

On 17 June 2025, the WPK issued a statement as part of the International Ethics Standards Board for Accountants (IESBA) consultation on collective investment vehicles (CIVs) and pension funds.

While the WPK welcomes the IESBA's efforts to maintain high ethical standards and keep them up to date, it recommends that a thorough analysis be conducted first to determine whether there are any gaps in the existing requirements of the Code of Ethics that would necessitate a change. Only after such an analysis can an informed decision be made as to whether it is necessary and appropriate to amend the Code. Furthermore, the WPK is convinced that the existing principle-based provisions are sufficient and better suited to form a solid basis for assessing and ensuring the independence of the auditor, even in the context of collective investment instruments and pension funds.

WPK against a Shift to rule-based Provisions or special Provisions

A shift to rule-based provisions or even special provisions for certain companies or individual sectors should be avoided at all costs, as this would make the Code overly complex and require constant updates and adjustments, and would also impair the uniform application of the Code.

To the WPK's knowledge, no serious violations of auditor independence have been identified in Germany to date that can be attributed to the lack of specific provisions for CIVs/pension funds or a definition of “connected parties.”

Above all, the WPK currently considers a stabilization phase to be urgently necessary so that professionals and audit firms can implement the recent changes to the Code of Ethics and the IAASB standards, particularly with regard to IESSA and ISSA 5000.

Should the IESBA nevertheless conclude that additional clarification is needed, the WPK recommends the publication of non-authoritative guidance rather than amending the Code itself.