La réglementation de l'audit : une comparaison entre le Canada, les États-Unis et la France

The practice of auditing is regulated by various entities of the State, securities regulatory commissions, and the accounting profession. The totality of this regulation deals with access to the auditing profession, standards to be observed, ethical norms, practice review and discipline, and legal liability. Even though the principal objective of auditing regulation is the protection of the public interest, the manner in which this objective is realized and how the regulation is operationalized varies from one country to another. The regulation of auditing and of auditors derives from economic traditions relating to corporate governance and the commercial laws of each country (Baker et al., 2001, p. 4). The goal of this research is to examine the regulatory systems of three countries with different economic and legal traditions : Canada, the United States, and France. Thus, we examine the regulation of auditing through a framework of analysis offered by Puxty et al (1987) and study the respective roles of the State, the profession and the market in these three countries. Among the aspects of regulation that we study are : (1) the certification of individuals who are allowed to perform statutory audits; (2) the establishment of standards for conducting an audit; (3) the regulation of auditing practice, and (4) the liability of auditors for infractions, including disciplinary, civil and criminal aspects of this liability.