21/09/2026
AFRICA DOES NOT NEED WEAKER STANDARDS. IT NEEDS BETTER STANDARDS.
Why Kenya and Africa must have a stronger voice in the future of global reporting and regulation in IFRS Standards.
There is an important debate taking place within the global accountancy profession about the future of international standard-setting.
At its heart is a deceptively simple question:
When should a regulator intervene, and when should it exercise restraint?
Andrew Conway, CEO of the IPA Group, has challenged the profession to think more carefully about the cumulative complexity created by international standards, ethical requirements, sustainability reporting, assurance obligations, technology and regulatory overlays.
His argument is not an argument for weaker professional standards.
It is an argument for better standard-setting discipline.
From an African perspective, that conversation deserves even greater attention.
AFRICA DOES NOT NEED WEAKER STANDARDS.
Africa needs standards that are:
▪ Rigorous
▪ Proportionate
▪ Implementable
▪ Evidence-based
▪ Responsive to institutional capacity
▪ Designed with African realities at the table
Kenya has embraced global standards. Now it must help shape them.
Kenya has demonstrated a long-standing commitment to international financial reporting. IFRS has been part of Kenya's financial reporting architecture for decades, providing a common reporting language for businesses, investors, lenders, auditors and other users of financial information.
That commitment should not be questioned.
International standards have delivered enormous benefits. They improve comparability, transparency and confidence. They facilitate cross-border trade and investment and provide a common framework through which capital providers can assess businesses operating in different jurisdictions.
The IFRS Foundation now describes IFRS Accounting Standards as a global accounting language used across more than 140 jurisdictions.
But adoption is only one side of the equation.
THE HARDER QUESTION IS IMPLEMENTATION.
Can the smallest entity expected to comply with a requirement actually implement it effectively?
That question should be central to the future of international standard-setting.
THE PROBLEM IS NOT ONE REGULATION. IT IS THE ACCUMULATION.
A new reporting requirement may appear entirely reasonable when considered on its own.
The problem arises when it is added to everything else.
A Kenyan business may simultaneously confront:
▪ Financial reporting standards
▪ Taxation requirements
▪ Electronic invoicing
▪ Company law
▪ Employment regulation
▪ Data protection requirements
▪ Beneficial ownership requirements
▪ Anti-money-laundering obligations
▪ Sector-specific regulation
▪ Sustainability reporting
▪ Increasingly sophisticated digital compliance requirements
Each may have a legitimate public-interest purpose.
But businesses do not experience regulation one standard at a time.
They experience it cumulatively.
This is particularly important for small and medium-sized enterprises and small and medium-sized practices.
A multinational corporation may have technical accounting specialists, legal advisers, sustainability teams, sophisticated enterprise systems and substantial compliance budgets.
A small Kenyan enterprise may have a finance manager, OR perhaps one accountant responsible for almost everything.
The regulatory objective may be identical.
The implementation capacity is not.
That difference cannot simply be ignored.
PROPORTIONALITY IS NOT LOWER STANDARDS
There is sometimes a misconception that asking for proportionality means asking for lower standards.
It does not.
A rigorous standard can have a proportionate implementation pathway.
The public-interest objective should remain demanding.
What should vary, where appropriate, is the complexity and cost of the mechanism through which that objective is achieved.
This distinction is fundamental.
We should not ask whether SMEs deserve "lower-quality" financial reporting.
We should ask:
Can the same public-interest outcome be achieved through a framework that recognises an entity's scale, resources, risk profile and institutional capacity?
That is not deregulation.
It is intelligent regulation.
BEFORE CREATING A NEW STANDARD, ASK WHETHER ONE IS ACTUALLY NECESSARY.
This should become a central discipline of international standard-setting.
Before embarking on a new standard or major regulatory intervention, standard-setters should demonstrate:
1). EVIDENCE — Before Intervention
▪ What exactly is the public-interest problem?
▪ Is there reliable evidence demonstrating the problem?
2). GAP — Before Prescription
▪ Why can't existing standards address the issue?
▪ Why can't existing guidance, enforcement or professional judgement address it?
3). CASE FOR INTERVENTION — Why a New Mandate?
▪ Why is a new mandatory requirement superior to education?
▪ Could implementation guidance be sufficient?
▪ Would stronger enforcement address the problem?
4). PROPORTIONALITY — What Will Intervention Cost?
▪ What will the requirement cost different categories of entities?
▪ What will it require from practitioners and assurance providers?
▪ Will the burden be proportionate to the expected public benefit?
5). CUMULATIVE IMPACT — What Happens When It Is Added to Everything Else?
▪ What existing requirements will entities already be implementing?
▪ What additional systems, documentation, technology and training will be required?
6). IMPLEMENTATION FEASIBILITY — Can It Actually Work?
▪ Can SMEs and MSMEs implement it?
▪ Can professionals operating in developing economies realistically support it?
▪ Is the necessary technology, data and assurance capacity available?
7). THE COUNTERFACTUAL — What Happens If We Do Nothing?
▪ What is the measurable public-interest harm of non-intervention?
▪ Is intervention genuinely necessary?
That last question is particularly important.
Regulators often examine the consequences of intervention.
They should also examine the consequences of non-intervention.
Sometimes the evidence will justify a new standard.
Sometimes it will point towards guidance.
Sometimes better enforcement will be sufficient.
Sometimes education is the answer.
And sometimes the evidence may demonstrate that further regulation is unnecessary.
The ability to reach that final conclusion is not regulatory weakness. It is regulatory maturity.
KENYA'S SUSTAINABILITY REPORTING TRANSITION ILLUSTRATES THE CHALLENGE
This debate is no longer theoretical.
Kenya is entering a new phase of corporate reporting through the adoption of IFRS Sustainability Disclosure Standards.
ICPAK launched Kenya's roadmap for adoption of IFRS Sustainability Disclosure Standards in 2024, and current Kenyan guidance provides for phased implementation.
This is an important development.
Sustainability-related financial information increasingly matters to investors, lenders, boards and other capital providers. IFRS S1, for example, focuses on sustainability-related risks and opportunities that could reasonably be expected to affect an entity's prospects, including cash flows, access to finance and cost of capital.
The question therefore should not be whether sustainability reporting matters.
It clearly does.
The better questions are:
▪ Which entities should report first?
▪ What information is genuinely decision-useful?
▪ Do the entities have systems capable of generating reliable data?
▪ Do their boards understand what they are signing off?
▪ Is there sufficient assurance capacity?
▪ Can SMEs and MSMEs realistically support implementation?
▪ What will compliance cost relative to the expected public benefit?
These questions do not weaken sustainability reporting.
They make its implementation more credible.
AFRICA SHOULD NOT MERELY ADOPT STANDARDS. IT SHOULD INFLUENCE THEM.
This is perhaps the most important lesson.
Africa has often approached international standards primarily from the perspective of adoption.
A global standard is developed elsewhere.
African institutions study it.
African regulators adopt it.
African professionals train on it.
African businesses implement it.
But there must be another stage.
African professionals must increasingly participate in shaping the standards themselves.
Africa represents a significant part of the global IFRS landscape. The continent's jurisdictions have extensive experience with IFRS adoption and implementation.
That experience is not merely local knowledge.
It is international evidence.
African economies can tell global standard-setters whether a proposed requirement works in environments characterised by:
▪ Large informal sectors
▪ Rapidly formalising SMEs
▪ Developing capital markets
▪ Uneven digital infrastructure
▪ Different levels of professional capacity
▪ Evolving regulatory institutions
▪ Limited assurance resources
▪ Significant differences between large corporations and smaller enterprises
These are precisely the conditions under which the scalability of an international standard is tested.
Africa should therefore move from being primarily a consumer of standards to a co-designer of those standards.
SMEs and MSMEs should be in the design room.
SMEs AND MSMEs SHOULD BE AN EARLY STRESS TEST
There is a recurring mistake in regulatory design.
The largest and most sophisticated organisations are often represented during the development process.
Smaller practitioners and businesses become heavily involved later, when implementation problems emerge.
That sequence should be reversed.
Before a proposed requirement is finalised, We need to ask:
▪ Can a small enterprise understand it?
▪ Can a small practice implement and audit it?
▪ What technology will it require?
▪ What additional documentation will it generate?
▪ What training will be required?
▪ What will it cost?
▪ Will it improve the quality of information or simply increase the volume of information?
▪ Will it produce genuine accountability OR encourage box-ticking?
▪ Will the requirement work outside the world's most sophisticated economies?
If the answer is no, then the standard is not yet sufficiently international.
HOW SHOULD WE MEASURE REGULATORY SUCCESS?
There is an institutional danger in measuring standard-setting by activity.
More consultations.
More amendments.
More standards.
More guidance.
More implementation material.
More compliance requirements.
These may demonstrate regulatory activity.
They do not necessarily demonstrate regulatory success.
The real measures should be outcomes:
▪ Did financial reporting improve?
▪ Did decision-useful information increase?
▪ Did investor confidence improve?
▪ Did audit quality improve?
▪ Did fraud risk decline?
▪ Did access to capital improve?
▪ Did comparability improve?
▪ Did the cost imposed on businesses produce a commensurate public benefit?
This is the difference between regulatory output and regulatory outcome.
The accounting profession should be much more interested in the latter.
THE ETHICS QUESTION DESERVES SIMILAR SCRUTINY
The global debate about the increasing complexity of professional ethical requirements raises another important issue.
No serious African professional should argue for weaker ethics.
Africa certainly does not need weaker professional ethics.
We need stronger:
▪ Integrity
▪ Independence
▪ Competence
▪ Accountability
▪ Public-interest responsibility
But there is a legitimate question about whether an ethical framework can become so extensive and technical that its practical accessibility is compromised.
The purpose of an ethical code should ultimately be to help a professional:
▪ Recognise an ethical threat
▪ Exercise sound judgement
▪ Apply appropriate safeguards
▪ Act in the public interest
TECHNICAL SOPHISTICATION IS VALUABLE.
But complexity should never become a substitute for ethical judgement.
A professional who understands the underlying principles and applies them honestly is ultimately more valuable to society than one who merely knows how to navigate a vast rulebook.
The objective should therefore be:
SIMPLE PRINCIPLES + RIGOROUS JUDGEMENT + CLEAR ACCOUNTABILITY + APPROPRIATELY DETAILED TECHNICAL GUIDANCE.
AFRICA'S REAL REGULATORY CHALLENGE IS IMPLEMENTATION CAPACITY
There is another uncomfortable truth.
Many African countries do not suffer from an absence of laws, regulations, standards and policies.
They sometimes suffer from a gap between rules and institutional capacity.
We can write sophisticated standards.
But standards require:
▪ Competent professionals
▪ Reliable data
▪ Functioning systems
▪ Effective boards
▪ Independent assurance
▪ Credible regulators
▪ Appropriate technology
▪ Enforcement capacity
▪ Institutional accountability
Without those foundations, sophisticated regulation can produce:
Sophisticated-looking compliance rather than genuine control.
That distinction matters.
A 100-page compliance report is not necessarily better than a 20-page report.
A highly sophisticated control framework is not necessarily effective merely because it is sophisticated.
A longer standard is not necessarily a better standard.
The real question is always:
DOES IT WORK?
A KENYAN–AFRICAN FRAMEWORK FOR DISCIPLINED STANDARDS & REGULATIONS
Perhaps Kenya and the wider African professional community should champion seven principles:
1). EVIDENCE — Before Intervention
Do not create a new requirement merely because an issue is fashionable, technologically novel OR attracting international attention.
Demonstrate the problem.
2). GAP — Before Prescription
Establish that existing standards, guidance, enforcement OR professional judgement are genuinely inadequate.
3). PROPORTIONALITY — Before Complexity
Design implementation around different categories of entities and different institutional capacities.
4). ALTERNATIVES — Before Mandates
Consider education, guidance, technology, enforcement and capacity-building before creating another mandatory requirement.
5). CUMULATIVE IMPACT — Before Approval
Evaluate the new requirement alongside the existing regulatory burden.
6). OUTCOMES — Before Activity
Measure whether the regulation actually improves reporting, governance, accountability and decision-making.
7). REVIEW — Before Permanence
Every significant regulatory intervention should be capable of being simplified, amended or withdrawn when evidence demonstrates that it is not achieving its intended purpose.
These principles would not weaken global standard-setting. They would make it more intellectually disciplined.
THE FUTURE IS NOT DEREGULATION. IT IS BETTER REGULATION.
There is an important distinction that should not be lost in this conversation.
The choice is not between regulation and deregulation.
The real choice is between:
▪ Good regulation and bad regulation
▪ Proportionate regulation and disproportionate regulation
▪ Outcome-oriented regulation and activity-oriented regulation
Kenya needs credible financial reporting.
Africa needs strong professional standards.
Investors need reliable information.
Boards need accountability.
Businesses need sound governance.
Capital markets need confidence.
None of this is controversial.
But the regulatory system should serve these objectives rather than becoming an objective in itself.
The ultimate purpose of accounting standards, auditing standards, ethical requirements and sustainability reporting is not to produce more rules.
It is to produce:
▪ Better information
▪ Better decisions
▪ Better governance
▪ Greater accountability
▪ Greater public trust
That should be the test.
AFRICA MUST HAVE A SEAT AT THE INTELLECTUAL TABLE
The next phase of global standard-setting presents Africa with an opportunity.
Not simply to ask:
“How do we comply?”
But to ask:
“How should the global system evolve?”
That is a much more ambitious question.
African professional accountancy organisations, regulators, universities, practitioners, businesses and policymakers should contribute evidence from African markets to the global standard-setting process.
Kenya, in particular, has the professional and institutional experience to contribute meaningfully to this conversation.
We should not approach international standard-setting as passive recipients.
We should approach it as professional partners.
The message from Africa should therefore be neither anti-regulation nor anti-IFRS.
It should be much more constructive:
We support high-quality international standards. But international standards must be capable of producing high-quality outcomes in the real economies in which they are expected to operate.
That requires:
▪ Evidence
▪ Proportionality
▪ Implementation capacity
▪ Continuous evaluation
▪ Listening to those who actually have to implement the standards
The future credibility of global standard-setting will not depend merely on its ability to respond to every new risk, technology or reporting demand.
It will depend on something more difficult:
The wisdom to know when to intervene, how far to intervene, and when not to intervene at all.
AFRICA DOES NOT NEED WEAKER STANDARDS.
IT NEEDS A STRONGER VOICE IN DESIGNING THE STANDARDS THAT GOVERN THE GLOBAL ECONOMY.
And Kenya should be part of that conversation, not at the margins, but at the table.
AUTHOR'S POSITION
The future of global standard-setting should not be designed only for the most sophisticated markets. It should be tested against the realities of the economies in which those standards must work.
Africa does not need weaker standards.
It needs a stronger voice in making global standards work.
AMOS NG’ONGO, CPA(K)
Governance | Public Policy Analyst
Kenya.