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  • Trajectories of accounting and auditing developmentin EU enlargement: comparative analysis of ten newmember states

    Judy Day Peter Taylor

    Published online: 16 July 2009

    Springer Science+Business Media, LLC. 2009

    Abstract This paper presents comparative qualitative analysis of the developmentof accounting and auditing in the ten member states which joined the European

    Union in May 2004, eight with transition economies and two with established but

    emerging market economies. The post-communist eight shared many similarities at

    the outset of transition but subsequent economic and political experiences were

    strongly divergent. In contrast, Cyprus and Malta had established market economies

    (but at relatively lower levels of development than more established EU member

    states). Compared with the transition eight they also differed in having established

    accounting and auditing professions. The papers research questions and associated

    hypotheses address varying institutional characteristics and comparative inter-

    temporal institutional change among the ten member states. In testing these

    hypotheses we use qualitative analysis on descriptive data developed as part of the

    official EU evaluation of accession states suitability for membership. In adopting

    this research approach we are consistent with a range of studies of institutional

    change which have been undertaken in an EU context, largely in political theory and

    political economy. We find evidence that different trajectories of institutional

    development are observable in the ten new member states. This research thus

    documents a major exercise in pan-European regulatory change, adds to the record

    of the transition to market structures and institutions of eight transition economies,

    and assists understanding of accounting development in two emerging economies.

    J. Day (&) P. TaylorManchester Business School, University of Manchester, Crawford House,

    Manchester M15 6PB, UK

    e-mail: [email protected]

    P. Taylor

    e-mail: [email protected]

    P. Taylor

    School of Management, University of Liverpool, Liverpool L69 7ZH, UK

    123

    J Manag Gov (2010) 14:313350

    DOI 10.1007/s10997-009-9103-z

  • Furthermore, it informs understanding of processes under way for other EU

    applicants and for new membership applications which may arise in future.

    Keywords EU enlargement Accounting transition Regulatory change

    1 Introduction

    In 1993, at the Copenhagen meeting of the European Council, it was agreed that the

    European Union (EU) should be further enlarged by the admission of all those

    countries with which association agreements had been concluded, and which wished

    to be admitted. Accession would take place as soon as the applicant was able to

    satisfy the necessary economic and political conditions. Among these conditions

    was a requirement for the existence of a functioning market economy. Appropriate

    administrative and judicial structures would be needed to provide the conditions for

    effective implementation of relevant EU legislation (sometimes referred to as the

    acquis communautaire, henceforth acquis). In 1997 the Luxembourg EuropeanCouncil also agreed that the enlargement of the EU must involve the strengthening

    and improvement of the operation of institutions in keeping with the provisions of

    the Amsterdam Treaty. As a result, significant expansion has taken place and further

    expansion is in prospect. On 1st May 2004 ten new member states, eight of which

    were transition countries, joined the EU. Two additional transition countries have

    obtained EU membership since the influx of 2004 (Bulgaria and Romania, both

    acceding on 1st January 2007) creating a then total membership of 27 countries. At

    time of writing three other countries have outstanding candidatures for member-

    ship,1 four others have been recognised by the EU as potential candidate members,2

    and a range of other countries are possible members of widely varying degrees of

    likelihood.

    The membership criterion of a functioning market economy was explicitly stated

    to involve various prerequisites, among which was that an appropriate legal system,

    including the regulation of property rights, should be in place and laws and contracts

    must be enforceable. Certain necessary conditions to support these essential

    institutions of a market economy did not appear to be explicitly mentioned. Notable

    explicit omissions were the need for a well-functioning system of accounting and

    auditing practices and procedures which were effectively promulgated and

    regulated; and an established accounting and auditing profession. This raises

    research questions in two broad areas: firstly, how applicant countries are and have

    been assessed on criteria relating to accounting and auditing institutions and systems

    1 Namely, Croatia, FYR of Macedonia, and Turkey. Croatia was granted candidate status in 2004 and

    accession negotiations opened in 2005. FYR Macedonia became a candidate for membership in

    December 2005 but accession negotiations have not yet commenced. Turkeys status with regard to EU

    membership has been long, having been an associate member of the EU and its predecessors since 1964, a

    candidate member since 1999, and in negotiations for membership since October 2005. Despite the initial

    screening process having been completed in October 2006, Turkeys final accession remains

    controversial.2 Namely, Albania, Bosnia and Herzegovina, Montenegro, and Serbia.

    314 J. Day, P. Taylor

    123

  • prior to a decision on EU membership; secondly how applicants have developed

    accounting and auditing institutions and systems in ways which would satisfy the

    requirements for accession; thirdly, what patterns are present in this institutional

    development; and fourthly, what might be the determinants of difference in those

    patterns. The first question has been addressed in an earlier paper (Day and Taylor

    2005). In this paper we address the other three research question by presenting a

    comparative analysis of the experiences of institutional change in accounting and

    auditing of the ten member states which formally joined the EU in May 2004. This

    analysis may be applicable to subsequent accession applications.

    Our analysis focuses on how the ten 2004 new member states developed

    accounting and auditing practices and procedures, accounting and auditing

    professions, and relevant regulatory systems. Such an analysis is made interesting

    by the magnitude of the simultaneous institutional changes which were represented

    and by the variety present amongst the new member states. These new member

    states comprised eight transition economies (the Czech Republic, Estonia, Hungary,

    Latvia, Lithuania, Poland, the Slovak Republic, and Slovenia) and two emerging

    market economies (Cyprus and Malta). Apart from the differences implied by

    transition and emerging status other differences can be noted both within and

    between these two groups. The transition eight includes countries from Central

    Europe (the Czech Republic, Hungary, Poland, the Slovak Republic, and Slovenia)

    and the Baltic (Estonia, Latvia, and Lithuania). In addition, although the post-

    communist countries as a whole shared many similarities at the outset of the

    transition process, their economic and political experiences have been strongly

    divergent. Some succeeded in stabilising their economies relatively early and

    became set on course for rapid growth and convergence with Western market

    economies whilst others have been less successful. Transition economies in general

    vary significantly in their level of economic and social development, political,

    economic and social stability, and position in the transition cycle and the transition

    eight, despite their commitment to and relative success in transition when compared

    to the generality of transition countries, exhibit important differences of experience.

    Cyprus and Malta, as emerging economies, had established market economic

    systems which were at relatively lower levels of economic development at least in

    comparison with the more established members of the EU. In comparison with the

    eight transition countries they had another interesting difference in that they both

    already had established accounting and auditing professions. Thus these ten new

    member states represent an interesting and varied sample for analysis.

    We consider the research reported in this paper to be important for a number of

    reasons. It adds a new dimension to the record of the transition to market structures

    and institutions of the eight former communist countries which joined the EU in

    2004, as well as assisting in understanding the accounting development of the two

    emerging economies which already had democratic and market institutions. It also

    further informs our understanding of the EU accession process which is presently

    under way for the three countries which are currently candidates for membership

    and which are now at various stages on the road to accession and it provides a

    framework for the analysis of accounting institutional development in both future

    Trajectories of accounting and auditing development 315

    123

  • candidates for EU membership and transition and emerging countries more

    generally.

    The paper is organised as follows. We present a literature review in Sect. 2 and

    go on to outline and discuss our hypotheses. In Sect. 3 we present analyses of

    comparative data on the ten countries paths to accession as tests of our hypotheses.

    Section 4 contains our conclusions and suggestions for directions for further

    research.

    2 Literature review and development of hypotheses

    In this section of the paper we consider literature relating to institutional differences

    between the sample countries, in particular but not exclusively relating to their

    accounting and auditing systems, and also to analyses of institutional change in

    other contexts.

    It is well-documented that extensive differences existed between communist

    accounting and capitalist accounting (Bailey 1988; Garrod and McLeay 1996).

    Accounting in the centrally planned economies of the USSR and Eastern Europe

    was designed in accordance with communist economic theory and represented

    Marxist-Leninist accounting (Seal et al. 1995; Daniel et al. 2001) and thus were

    based on quite different objectives, concepts and terminology, and exhibited

    distinctly different practices and professional characteristics from those in market

    economies. For the external audit of enterprises, differences of similar magnitude

    existed. Bychkova (1996) states that auditing as understood in the West never

    existed in either Russia or the USSR, rather systems of external control were

    present. Similar circumstances were observable elsewhere in communist Eastern

    Europe. Furthermore, accounting and auditing did not exist as professions in the

    sense that they do in most capitalist countries (see for example Sucher and Zelenka

    1998 for the Czech Republic).

    The foregoing points to the initial existence of substantial institutional gaps for

    all eight transition economies both in the broad sense of transition to market based

    institutions as well as their more narrowly focussed and administratively driven

    transition to EU structures and practices. Recognition of this raises two related

    questions: were the institutional gaps for each of the eight transition economies

    effectively the same; and were the paths which they followed to close those gaps

    effectively the same (both in terms of speed and other characteristics)?

    Whilst the accounting systems of these eight member states may have possessed

    broadly comparable institutional bases at the end of communism, they also have

    distinct histories and cultural values, both pre- and post-communism, which suggest

    that particular characteristics might emerge in their accounting and auditing systems

    during transition. Thus, accounting in the countries of Eastern Europe before the

    communist era was subject to a range of influences with dominant influences in

    certain countries being Austrian and German (see Seal et al. 1995; Krzywda et al.

    1995). Thus, adopting the methodology of Gray (1988) we might argue that history

    and culture in the eight transition economies would generally tend to favour

    statutory control over professionalism in accounting and audit regulation,

    316 J. Day, P. Taylor

    123

  • uniformity over flexibility in accounting regulation, conservatism over optimism in

    accounting practices, and secrecy over transparency in disclosure and financial

    reporting.3 Empirical evidence from transition countries tends to bear this out.

    Daniel et al. (2001) note in the case of Slovakia that post-1989 changes in the

    accounting system were strongly influenced by Continental European models.

    Borbely and Evans (2006) in an analysis of developments in Hungarian accountingregulation during transition note a persistent influence of taxation on accounting,

    and of other Continental European, code-law regulatory and accounting features,

    reflecting inter alia an over-strong influence of government and legislation and acontinuation of traditional approaches stressing detailed accounting methods in both

    practice and accounting education. The influence of centralised direction is also

    present in Slovakia through the role played in the development of accounting

    practices by the Ministry of Finances Department of Accounting Methodology.

    Kosmala-MacLullich (2003) and Kosmala (2005) in empirical research on the

    introduction of the construct of the true and fair view into Polish financial reporting

    in the context of European harmonisation and EU accession, concluded that Polish

    practice perceived the true and fair view to be primarily a matter of formal and legal

    compliance because of the continuing difficulty of expressing judgements based

    upon accumulated experience when much of Polish experience reflected Continental

    European influence, in particular the German tradition, and the regulatory and

    economic arrangements of a centrally planned economy (see also Dragneva and

    Millan 2002, for both Hungary and Poland).

    In addition, there is some support in the literature for a prediction of degrees of

    homogeneity in trajectories of institutional change arising from an expected high

    degree of commonality in the objectives of policy makers. For example Boross et al.

    (1995) (see also Borbely and Evans 2006) cite as policy objectives for the

    development of accounting in Hungary during transition, fiscal policy and tax

    collection, the need to attract foreign investment, and the presence of international

    accountancy firms, and if we add the needs of general economic liberalisation and of

    improvement in corporate governance, it is arguable that these influences would be

    amongst those facing policy makers in most of these transition economies.

    These issues suggest some commonality in trajectories for transition in

    accounting and audit among the eight transition economies considered in this

    paper but this view may be modified by examining the aims and actions of policy

    makers in particular countries. Some researchers thereby argue for a considerable

    degree of diversity. Thus, Richard (1998) argues that considerable diversity was

    present in the evolving accounting systems of the transition economies, including

    variation in the development of accounting principles. He attributes this variety to

    the influence of short-term strategic alliances made by particular transition

    governments with foreign states and institutions, selected for economic and

    political advantage, overriding more fundamental and longer-term cultural and

    historical factors. This observation is supported by the findings of a number of

    researchers. For example Sucher and Zelenka (1998) note the influence of UK

    3 For a more detailed discussion of Gray (1988), and of further work based on his model, see Day and

    Taylor (2004a, b).

    Trajectories of accounting and auditing development 317

    123

  • legislation in the development of audit in the Czech Republic, whilst Krzywda et al.

    (1998) refer to the diversity of Western influence on the development of audit in

    Poland. Adams and McMillan (1997) note UK and French influences on Polish

    accounting (see also Jaruga 1993 on these issues as perceived in the early stages of

    transition in Poland); Illes et al. (1996) report influences on and reactions to

    accounting reform in Hungary; and Jermakowicz and Rinke (1996) present evidence

    on the Czech Republic, Hungary, and Poland. Bailey et al. (1995) reports

    differences in the pattern of development of accounting reform in Estonia, Latvia

    and Lithuania.

    Taking a wider view of institutional change and development adds strength to

    the argument of heterogeneous experience in transition. Hungary, Poland and the

    former Czechoslovakia had already experimented with economic reform before the

    breakdown of their communist regimes whilst the other four transition economies

    had no equivalent experience. Thus, for example, Hungary was an early

    experimenter with economic reforms which sought to address the basic institutional

    failings of the communist system. Hungarys early experience with institutional

    reform, although clearly flawed, appears to have given it an impetus not shared by

    some other transition economies (Crane 1991), suggesting an early-mover

    advantage in institutional change. Some of the necessary market-orientated

    institutions were in place when the socialist regime was replaced and economic

    agents were already familiar with their working when transition formally began.

    Additionally, the early reforms helped to create an entrepreneurial class. In

    comparison, other transition economies were slow starters and appeared to continue

    to lag in certain areas. Detailed modelling and empirical analysis of institutional

    change in a sample of twenty-five transition economies by Raiser et al. (2000)

    provides evidence to support this conclusion. Raiser et al. find compelling evidence

    that economic reforms and political liberalisation are stronger forces than changes in

    economic structures induced by those changes. From this they conclude that there

    may be positive spillovers from early reforms in liberalisation and privatisation into

    institutional reforms, but with a significant lag. Thus, countries which lag behind in

    making fundamental changes at an early stage may find it very difficult to catch up

    with the leaders in transition. A related theme is the extent to which institutional

    legacy from the pre-Communist era assisted certain transition countries in beginning

    and accelerating institutional change. In some transition countries pre-transition

    institutional legacy was extensive. For example, a stock exchange was established

    as early as 1817 in Poland (the Warsaw Mercantile Exchange) and this exchange,

    together with exchanges in six4 other cities operated until 1939 (Warsaw Stock

    Exchange 2006). Trading recommenced in the recreated Warsaw exchange in 1991.

    Similarly, Poland had a long history of professionalised accountancy (see footnote

    21 below) and first legislated on insolvency in 1934 (EBRD 2003).

    Supporting evidence from a different perspective comes from indices developed

    by de Melo et al. (1996) and the European Bank for Reconstruction and

    Development (EBRD) in various studies to measure the extent of reforms needed

    4 One of these exchanges was in Vilnius, then part of Poland, but now capital of Lithuania, indicating a

    shared institutional legacy.

    318 J. Day, P. Taylor

    123

  • to make markets the main mechanism for resource allocation, and data on these

    indices for the eight transition economies is shown in Table 1. The indices are

    composites of scores against seven elements.5 The indices reported in Table 1 are

    on a linear scale from zero to one where zero represents an unreformed centrally

    planned economy and one the standards of a market economy. The year 1990

    represents an effective starting point for formal transition following the general

    removal of communist regimes around that date.

    In interpreting Table 1 it should be noted that the Czech Republic and the Slovak

    Republic have the same score in 1990 as they then comprised the single country of

    Czechoslovakia. The Table indicates that the three lead countries in institutional

    development were Hungary, Poland and, perhaps surprisingly, Slovenia, with the

    remaining five clustered some way behind. Comparative data suggests, however,

    that the five lagging countries had at least accomplished moderate institutional

    development (in comparison in 1990 Russia had an index of 0.15, the republics of

    the former Soviet Union other than Russia had indices equivalent to that for Russia,

    and Albania had the lowest index at around 0.1 of all transition countries in Europe).

    These differences in part reflect different experiences in the pre-transition phase as

    well as in the early period of transition among the eight transition economies.

    Hungarys opening position was different since it began its transition in 1968 with

    the introduction of the New Economic Mechanism when detailed central planning

    was abandoned. There was a period of recentralisation in the 1970s which was

    followed by additional market-orientated reforms. Thus, many of the reforms

    implemented after political transition had already been developed and had begun to

    be introduced earlier, suggesting much stronger and longer continuity in reforms

    than can be observed for any other transition country (Hare 1991). By early 1991

    Hungary had advanced significantly towards a market economy after 20 years of

    experience in reform. The benefit of this strong foundation can be seen in the

    progress made between 1995 and 1998.

    Table 1 Estimated indices ofprogress in institutional reform

    for selected transition countries

    Source: World Bank (2002),adapted from Fig. 2.1, p. 14

    1990 1995 1998

    Czech Republic 0.24 0.84 0.88

    Estonia 0.27 0.81 0.87

    Hungary 0.56 0.85 0.94

    Latvia 0.22 0.70 0.77

    Lithuania 0.22 0.73 0.77

    Poland 0.64 0.82 0.89

    Slovak Republic 0.24 0.81 0.84

    Slovenia 0.68 0.78 0.82

    5 The aspects of institutional reform included in these indices are: the imposition of hard budget

    constraints on banks and enterprises, the creation of an enabling environment for private sector

    development, legal and judicial reform, macroeconomic stabilisation: price and trade liberalisation:

    reform of the tax system and public finances: and reform of public sector institutions.

    Trajectories of accounting and auditing development 319

    123

  • In the case of Czechoslovakia the communist regime was removed from office in

    the so-called Velvet Revolution of 1989. Some early transition progress had been

    made in 1968 in the Dubcek era but this had been sharply reversed after the Soviet

    invasion which also stifled subsequent attempts at reform and made conditions

    difficult for transition when the opportunity arose (Brada 1991). Once transition

    began in earnest the two parts of Czechoslovakia pursued transition quickly.

    In contrast to the transition economies discussed above, Malta and Cyprus are

    two emerging market economies. Classification studies of international accounting

    and national accounting systems differences, whilst infrequently including either

    Cyprus or Malta directly in samples of classified countries, nonetheless consistently

    provide classifications which would locate the two countries variously as British

    Commonwealth (Nair and Franks 1980) and UK influenced (Nobes 1992) or

    similar.6 Relevant academic research on Malta is sparse but institutional detail

    supports the foregoing. Malta has been independent since 1964 but during its long

    period of association with the UK developed institutions modelled partly on those of

    the UK. Thus, the legal system was based on English common law as well as Roman

    civil law. The Malta Institute of Accountants (MIA) was founded in 1942 and

    following the establishing of an alternative professional body, the Malta Corpo-

    ration of Accountants (founded 1954), emerged in its present form in 1965 from the

    merger of the two bodies (Malta Institute of Accountants 2008). Recognition of

    accountancy as a profession occurred in 1979 through the Accountancy Profession

    Act, which introduced the granting of warrants to Certified Public Accountants and

    Certified Public Accountants Auditors by the Malta Minister of Finance. Under the

    Act the MIA was given statutory recognition and is the only recognised local body.

    Legal control of the profession is governed by the Accountancy Board, a

    government body appointed under the 1979 Act (Malta Ministry of Finance, the

    Economy and Investment 2008). The MIA was approved as a member body of the

    Federation des Experts Comptables Europeens in 1989.

    In the case of Cyprus, classification studies are well supported by empirical

    studies of aspects of Cypriot financial reporting. Thus, Vafeas et al. (1998) observe

    that as a result of the countrys history as a British colony, the accounting system in

    Cyprus is much closer to the Anglo-Saxon model than to the Continental European.7

    The legal system was based on common law with civil law modifications, with

    company law having originally been modelled on UK legislation. After indepen-

    dence in 1960, public companies were incorporated under the Companies Law,

    Chapter 113 of the Laws of Cyprus, which was almost identical to the UK

    Companies Act 1948 (Neocleous et al. 2000, p. 317). The Cyprus Income Tax Law,

    1961 is based on English revenue law and it is common practice for English tax

    cases to be used as precedent in Cyprus and more generally authority from UK Law

    is used extensively in Cyprus. In addition the concept of true and fair view has

    been prevalent in Cyprus (Vafeas et al. 1998). The country has had for many years a

    professional accountancy body, The Institute of Certified Public Accountants of

    6 See also Doupnik and Salter (1995), Roberts (1995), and Nobes (1998).7 In making this distinction we note the controversy over the validity of the distinction (see Alexander

    and Archer 2000; Nobes 2003). .

    320 J. Day, P. Taylor

    123

  • Cyprus but with membership based on qualification overseas.8 Charitou et al. (2005)

    note that a form of over-the-counter stock exchange has been in operation in Cyprus

    since the early 1980s through dealers and brokers, but without a proper institutional

    framework (Vafeas et al. 1998). Some monitoring of this process was provided by

    the Cyprus Chamber of Commerce and Industry but no specialists or official market

    makers were used during this period.9 In March 1996, an official Cyprus Stock

    Exchange (CSE) was established by government through the Securities and Stock

    Exchange Regulations, 1995 and Securities and Stock Exchange Law, 1996,

    regulation being provided by a Council and a Securities Commission, both bodies

    containing heavy government representation (see Krambia-Kapardis and Psaro

    2006). In this respect Cyprus is similar to Malta which established its stock market

    in 1992 and to the eight transition countries discussed in this paper which also

    opened their stock markets during the 1990s. Krambia-Kapardis and Psaro (2006)

    examine the implementation of corporate governance regulation in Cyprus and

    observe the importance for reform of the need for foreign capital and the role played

    by the CSE following a market crash in 2000, noting that the CSE introduced the

    Cypriot Corporate Governance Code in September 2002 and that the Code is

    predicated largely on Anglo-Saxon principles of corporate governance.

    The foregoing review leads us to develop hypotheses concerning the trajectories

    of institutional development of these ten new member states. Firstly, we argue that

    the suitability of the institutional legacy at the beginning of the process of accession

    is likely to be a significant determinant of trajectories of institutional development.

    Thus, the comparatively long isolation of the eight transition economies from

    practices and institutions of Western capitalist accounting and auditing compared to

    the experiences of Cyprus and Malta lead us to hypothesise:

    H1 The two emerging market economies of Cyprus and Malta are expected toexhibit smoother accession trajectories than the eight transition economies.

    Despite the greater volume of (academic) evidence on Cyprus there is little to

    justify a significant distinction between it and Malta and as a consequence we

    hypothesise that:

    H2 Cyprus and Malta are expected to exhibit broadly similar accessiontrajectories.

    Within the group of transition economies we noted variation in pre- and early-

    transition experiences and approaches and, in particular, the presence of an

    observable early-mover advantage amongst transition countries in areas of

    economic activity, suggesting the following hypothesis:

    8 Applicants for membership must be a member of one of the following bodies: the Institute of Chartered

    Accountants in England and Wales; its counterparts in Scotland, Ireland, Canada, South Africa, and New

    Zealand, or the Chartered Association of Certified Accountants. Members of the American Institute of

    Accountants and the Association of International Accountants may also be accepted for membership.9 See Travlos et al. (2001) for, inter alia, analysis of transactions in the CSE between 1985 and 1995 andchanges that occurred in the structure of the CSE during the period.

    Trajectories of accounting and auditing development 321

    123

  • H3 Hungary, Poland, and the Czech Republic are expected to exhibit smootheraccession trajectories than the other five transition economies.

    H3 can also be based on the argument that the overall quality of a countrys

    institutions (and the effectiveness of policy-makers responses to the need for

    institutional improvement and change) will determine the speed and smoothness of

    the accession trajectory. Thus, the weaker are institutions and the more problematic

    are policy-makers responses, the less smooth are likely to be accession trajectories.

    Consequently we can hypothesise further expected relative trajectories within the

    transition group, thus:

    H4 Estonia, Latvia, and Lithuania are each expected to experience less smoothtrajectories than Slovenia.

    H5 Slovenia is expected to experience a smoother trajectory than the SlovakRepublic.

    3 Data, analysis, and discussion

    The research questions addressed in this paper concern institutional characteristics

    and comparative inter-temporal institutional change. There is a large and complex

    academic literature related to the study of such issues embracing micro- and macro-

    approaches and qualitative and quantitative modes of institutional representation

    and analysis applied in a number of disciplines. In this paper we use descriptive data

    developed as part of the official EU evaluation of accession states suitability for EU

    membership and analyse that data qualitatively, focusing on institutional develop-

    ment through time. In adopting this approach we are consistent with a range of

    studies of institutional change which have been undertaken in an EU context,

    largely in political theory and political economy (eg Henderson 2003; Johnson 2003

    on institutional development in the EU; Schimmelfenning et al. 2003 on EU strategy

    to induce institutional change in applicant countries; Sicherl 1999 on disparities

    between the institutions of EU Member States).10

    We shall consider three components of institutional change during accession,

    namely initial institutional gap, accession trajectory, and residual institutional gap.

    An institutional gap will be present because of differences between the requirements

    of the acquis and the actual organisational and institutional structures in place in theapplicant state (ie institutional misfit) and institutional deficiencies in the applicant

    state (ie institutional shortfall).11 The presence of initial institutional gaps for all the

    ten new member states is expected although the expectation is that they will be of

    different sizes and degrees of seriousness depending inter alia upon the institutionallegacy of the country and the effectiveness of pre-accession preparations. These

    expectations are implicit in the hypotheses developed above. The formulation of

    precise expectations on the presence of residual institutional gaps on accession is

    10 In addition there are a number of methodological studies relevant to the analysis of institutional

    change, for example Lindner and Rittberger (2003).11 The concept of institutional gap is widely used in political theory, see for example Borzel (1999).

    322 J. Day, P. Taylor

    123

  • problematic. Accession is not prima facie evidence of the absence of a residualinstitutional gap. Day and Taylor (2005), in a study of the accession assessment

    process by EC officials, reported interview evidence that not being in compliance

    with an article from the 4th or 7th Directive would be very unlikely to be a reason

    for not becoming a member state12 and, despite the possibility of the granting of

    derogation for a transition period in areas of non-compliance, it was reported that

    derogations were unlikely to arise due to the strictness of application of criteria

    related to internal market aspects of the acquis. The path of travel of institutionsduring the accession period (ie between the initial and residual, if any, institutional

    gaps) is the institutional trajectory. The concept of institutional trajectory is applied

    in various disciplines which study institutional change.13 The sense in which

    trajectory is used in such studies, and which is applied in this paper, is as the way in

    which a process (in this case institutional change) develops over time. Thus, it

    involves identifying a series of institutional states in dynamic development and, by

    implication, observing institutional development mechanisms. Underlying the

    analysis is assessment of the relative success of national strategies for wide-

    ranging institutional reform implemented to achieve accession, each of which

    represents a planned trajectory of institutional change through time.

    3.1 Data

    The data we analyse is generated from the bureaucratic administration of the

    accession process itself. The process of accession to the EU broadly begins with the

    negotiation of a Trade and Cooperation Agreement which is normally followed by

    the conclusion of a more formal Association Agreement. In some cases an

    Association Agreement comes into force, or is even negotiated, simultaneously with

    the countrys application for membership. The final stage before actual accession is

    normally an Accession Partnership. Table 2 shows dates at which the ten new

    member states reached these various points in the transition process. Two sources of

    data for the analysis of transition trajectories are generated by the stages reported in

    Table 2. Following an application for membership, EC officials are required to

    produce a report giving an opinion on the application for membership, which is laid

    before the European Parliament. Each EC Report on Membership Applicationcontains a section which considers the applicants ability to assume the obligations

    of membership. In column two of Tables 3, 4, 5, 6, 7, 8, 9, 10, 11 and 12 we

    summarise the findings of the EC Reports on Membership Application for each ofthe ten new member states, with particular emphasis on commentary on their ability

    to comply with the acquis on accounting and auditing issues. These analyses giveindications of the extent of institutional gaps at the beginning of the formal

    accession process.

    12 Sicherl (1999) confirms, at least in the case of Central and Eastern European countries, that decisions

    on integration into the EU would turn on political issues not technical ones.13 As recent examples see, from sociology, Garcelon (2006), social economics, Zukowski (2004) and

    political theory, Duit (2007).

    Trajectories of accounting and auditing development 323

    123

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    324 J. Day, P. Taylor

    123

  • The second source of data relates to accession trajectory and is contained in a

    series of annual reports on progression to accession for the applicant countries

    (henceforth EC Regular Reports). Following acceptance in principle of anapplication for membership, EC officials undertake the preparation, review and

    negotiation of a National Programme for the Adoption of the Acquis (NPAA) for

    each applicant (see Day and Taylor 2005 for a more detailed description of this

    process). Commission officials then produce annual Regular Reports which reviewthe current status of and progress on each individual application for membership.

    These reports on respective NPAAs go to the European Council. These RegularReports cover all areas of the acquis, as well as making more generalrecommendations on political and other issues. Annual reports were prepared on

    each of the ten new member states for the years 19982002, together with a

    composite report (henceforth Comprehensive Monitoring Report) which summa-rised the overall position for all the applicants (see European Union 1998, 1999,

    2000, 2001, 2002, 2003). These reports, together with the judgements on the ten

    applications for membership have been examined for references relating to

    accounting and auditing aspects of the acquis and Tables 3, 4, 5, 6, 7, 8, 9, 10, 11and 12 summarise the findings of this analysis.

    3.2 Data analysis

    Table 2 gives an overall indication of accession trajectory by dating certain key

    events in the accession process for each of the ten new member states. It is clear that

    for the eight transition economies the whole process was compressed into a far

    shorter period of time than was the case for the two emerging market economies.

    We note that Malta concluded an Association Agreement as early as 1971, 20 years

    before the earliest date for an Association Agreement with any of the transition

    eight (Czechoslovakia as was, and Poland). The Association Agreement with

    Cyprus came in 1972, with a customs union protocol following in 1987.

    Applications for membership from Cyprus and Malta were also earlier (Cypruss

    application was 1990, accepted 1993 and Maltas 1990, accepted 1993, suspended

    1996 and reactivated 1998). Moreover, neither Cyprus nor Malta had an accession

    partnership in place until 2000 for political reasons.14 This overview weakens

    support for H1 that Cyprus and Malta are expected to exhibit smoother accession

    trajectories than the eight transition economies. However, we may note additionally

    that the ECs reviews of the ten applications for membership indicated that, as

    expected, Cyprus and Malta had (in 1993 for both) each already achieved

    compliance with a substantial part of the elements of the acquis relating toaccounting and auditing (which come under the heading of Company Law),

    indicating relatively small initial institutional gaps. This is supported by the reviews

    of applications for membership of the transition economies undertaken between

    1994 and 1997 (excepting Slovakia whose application was not fully approved until

    14 Negotiations with Cyprus were delayed mainly because of the issue of reunification with Northern

    Cyprus, and negotiations with Malta were suspended for 2 years in the mid-1990s after a change of

    government.

    Trajectories of accounting and auditing development 325

    123

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    326 J. Day, P. Taylor

    123

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    Trajectories of accounting and auditing development 327

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    328 J. Day, P. Taylor

    123

  • Tab

    le6

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    Trajectories of accounting and auditing development 329

    123

  • Tab

    le7

    Acc

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    330 J. Day, P. Taylor

    123

  • Tab

    le8

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    332 J. Day, P. Taylor

    123

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