The IRBA Code (Revised 2024) and who it binds

Who the IRBA Code of Professional Conduct (Revised 2024) applies to, the effective dates of recent changes, and how a firm records independence.

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

A registered auditor who now does mostly tax and accounting work assumes the IRBA Code no longer concerns her, because her registration status is non-assurance. A firm's audit manager is unsure whether a client that recently listed its debt counts as a public interest entity under the new definitions. A partner wants to know whether the firm can still advise an audit client on a restructuring that has a tax angle.

All three questions lead to the same document: the IRBA Code of Professional Conduct for Registered Auditors, in its Revised 2024 version. This article sets out who it binds and which recent changes affect audit work now, with their effective dates.

Assurance and non-assurance registrations alike

The IRBA says its Code of Professional Conduct applies to all registered auditors, firms and individuals, whether their status in the IRBA register is assurance or non-assurance. The current version is the IRBA Code (Revised 2024), issued on 21 November 2024 under Board Notice 699 of 2024.

The first assumption in the opening paragraph is therefore wrong. A registered auditor who does no audit work is still bound by the Code while registered. For a firm, that means every person on the IRBA register, whatever their status and whatever work they currently do, should know which version of the Code applies and have read it.

Listed entity and public interest entity definitions

The IRBA's revisions to the listed entity and public interest entity definitions in its Code are effective for audits of financial statements for periods beginning on or after 15 December 2024, under Board Notice 511 of 2023.

The effect is that the classification of an audit client can change from one year to the next without anything changing at the client. Because the stricter independence requirements apply to public interest entities, a client newly falling within the definition brings new restrictions on services and fees from the first affected period.

A practical step: for every audit client, record at the start of each engagement whether it is a listed entity or public interest entity under the definitions in force for that period, who decided and on what basis. That record is the starting point for every later independence question.

Non-assurance services and fees

The IRBA's revised non-assurance services and fee-related provisions in its Code apply to audits and reviews of financial statements for periods beginning on or after 15 December 2022, under Board Notice 207 of 2022.

Note that these provisions reach reviews as well as audits. A firm that provides accounting, payroll or tax services to a client whose statements it also reviews is within scope. Before accepting or continuing a non-assurance service for an audit or review client, the firm needs to evaluate it under the revised provisions and document that evaluation. The detail of what is and is not permitted is covered in non-audit services for audit clients.

Fee-related provisions also matter for planning. The Code's fee provisions are another reason to know, client by client, how much of the firm's income each client represents. That figure comes from the firm's own receivables and billing records.

Tax planning and related services

The IRBA's final pronouncement on Tax Planning and Related Services is effective for tax planning services beginning after 30 June 2025, with early adoption permitted. It was issued by Board Notice in December 2024.

For the partner with the restructuring question, the date is the first thing to establish. A tax planning service that began after that date falls under the pronouncement. For a firm with a busy tax practice, the simplest approach is to treat every new tax planning engagement as within scope and to record, in the engagement file, how the firm considered the pronouncement before starting.

The dates on one page

Independence records in Achekam, and the missing step

Applying the Code depends on knowing who has what interest in which client. In Achekam, staff record annual independence declarations and any interest, relationship or gift involving a client, under QUALITY & GOVERNANCE > Independence & Conflicts. Anyone can check whether a person has an active independence exception for a client.

Two limits need stating plainly, because they change how a firm should use those records:

1. No approval step. Achekam has no way to approve an independence declaration. Every declaration stays "awaiting the quality partner", so the quality partner's review has to be recorded somewhere else the firm and an inspector can see.
2. No check on assignment. Assigning a person to an engagement does not check the independence register. Before a team is finalised, the engagement partner or manager has to look up each member's exceptions for that client.

A short routine closes both gaps: the quality partner reviews declarations once a year and signs a dated schedule; at engagement planning, the manager checks each team member against the register and notes the check on file.

Independence is not the only Code obligation with a South African twist; reportable irregularities covers the statutory reporting duty that sits alongside it.

Read the Code itself

The IRBA publishes the IRBA Code of Professional Conduct and the Rules Regarding Improper Conduct on one page, together with the effective dates of the recent changes. Bookmark it for the firm's quality partner, and check it at the start of each planning season for anything newer than this article.

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