The ethics code that binds Kenyan accountants

Which edition of the international ethics code and independence standards ICPAK applies, how breaches reach discipline, and an annual ethics routine.

By Achekam · 11 October 2026 · 4 min read · For Accountants & audit firms in Kenya

Kenyan accountants do not have a home-grown ethics code to learn. They follow the same international code as members of professional bodies across much of the world, in the edition current at the time. That makes the rules easier to research and harder to keep up with, because the international code is revised regularly and each new edition becomes the Kenyan standard.

This article sets out which code applies, where independence fits, how compliance is checked through quality reviews, how a breach can become a disciplinary matter, and what Achekam does and does not do to help a firm manage independence.

The code ICPAK requires

IFAC, in its member profile of ICPAK under the membership obligation on ethics (SMO 4), reports that ICPAK requires its members to comply with the latest International Code of Ethics for Professional Accountants, including the International Independence Standards, with the 2025 edition in use.

Two points follow for a practice.

"Latest" means the current edition. When the international code is revised, the Kenyan requirement moves with it. A firm's ethics manual written around an older edition needs reviewing whenever a new edition takes effect, not only when someone notices.

The independence standards are part of the code. They are not a separate add-on for audit firms to consider when convenient. Members are expected to comply with them as part of the code ICPAK requires, and a firm's independence policy should be written with them in mind.

IFAC's member profile of ICPAK summarises how Kenya applies the international standards, including the auditing standards, the ethics code and the quality management standards, and how ICPAK runs audit quality reviews. The wider standards picture is covered in auditing and quality standards in Nigeria and Kenya.

Independence in practice

The independence standards ask the same questions in every firm. Does anyone on the team, or in the firm, have a financial interest in the client? A family relationship with a director? A loan, a gift, a business relationship? Has the firm provided services that would create a self-review threat? How long has the same partner led the engagement?

Answering those questions once, at acceptance, is not enough. People's circumstances change during an engagement: someone inherits shares, a relative joins the client's finance team, a client offers hospitality at year-end. The firm needs a way to capture those changes when they happen.

Quality reviews as the check

Compliance with the code is not left to self-assessment alone. IFAC reports, under its membership obligation on quality assurance (SMO 1), that ICPAK runs Kenya's audit quality assurance review system, has adopted International Standards on Quality Management 1 and 2, and reports review findings through consolidated Audit Quality Review reporting.

A firm preparing for a review should expect questions about how it manages ethics and independence, and should have its records ready to show.

How a breach can reach discipline

When something goes wrong, the route runs through ICPAK's committees. IFAC reports that under the Accountants Act, 2008, ICPAK's Registration Committee handles investigation and evidence gathering, while its Disciplinary Committee handles disciplinary inquiries and sanctions. IFAC also notes, under SMO 6, that gaps remain in the independence of the investigation and appeals functions.

An ethics breach might come to ICPAK's attention through a complaint, or might surface in a quality review. Either way, the investigation stage will ask for evidence of what the firm knew and did. The process is described in more detail in how ICPAK investigates and disciplines members.

Independence records in Achekam, and the step that is missing

Achekam provides an independence register. Staff record annual independence declarations and any interest, relationship or gift involving a client. Anyone can check whether a person has an active independence exception for a client before work is allocated.

There are two limits a firm must manage around:

• No approval step. Achekam has no way to approve an independence declaration. Every declaration stays "awaiting the quality partner". The quality partner's review therefore has to be recorded outside Achekam, for example in a signed review note filed with the firm's quality records.
• No check at assignment. Assigning a person to an engagement does not check the independence register. The engagement partner, or whoever staffs the job, must look up the register before assigning and keep a record that they did.

Neither limit makes the register less useful as a record. They mean the firm's own procedure has to supply the review and the check that the platform does not. The practical workaround is set out in independence declarations today.

An annual ethics routine

Where to begin

Check that the firm's ethics manual refers to the edition IFAC reports ICPAK is using, then make sure every person in the firm has a current declaration on the register. Those two steps put the basics in place before the next engagement is staffed.

General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.