Convergence patterns in accounting regulation: Six country cases of the transforming regulatory landscape

This paper inquires into recent changes of accounting regulation in six OECD countries: Germany, France, England, USA, Canada and Japan. Having formerly been embedded into different institutional environments, accounting systems varied widely in the heyday of the interventionist nation state. Since then, international harmonisation has been transforming national accounting systems, leading to increasing convergence between the various systems. It is the aim of this paper to describe these changes systematically, estimate the degree of international convergence and assess how different institutional origins affect convergence patterns. We develop a framework for comparing accounting systems and identify four criteria that describe the anatomy of a national accounting system: (1) Predominant uses of accounting, (2) Extent of professional self-regulation, (3) Legal backing and (4) Degree of internationalisation. Our findings indicate that global convergence in accounting regulation exists, although limited variations between nation states still remain and depend upon the prevailing national institutional arrangements, which have not (yet) converged.