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Tackling the auditor shortage: is progress being made?

What impact is the auditor shortage having on the sector, and is progress being made to fix it? Michael Lloyd and Social Housing reporters explore the issue

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What impact is the auditor shortage having on the sector, and is progress being made to fix it? Michael Lloyd and Social Housing reporters explore the issue #UKhousing #SocialHousingFinance

At a glance
  • The ongoing shortage in auditors available to the social housing sector is caused by a mix of factors
  • Bodies including the National Housing Federation and the G15 are taking steps to tackle the issue
  • Social Housing analysed the external auditor data for the full-year financial accounts of housing associations in Great Britain, finding movement around which firms were most active during the period
  • The data also shows a steady increase in the aggregate annual fees paid by the sector, rising 51.8 per cent since 2018

 

The social housing sector is suffering from a shortage of auditors, with the same handful of firms serving the majority of the larger providers, and tenders often failing to produce multiple options.

 

Trade bodies such as the National Housing Federation (NHF) have been actively engaging with auditors and attracting more to the sector in an attempt to tackle this problem, but worry over the shortage remains.

 

The ultimate risk from a shortage of auditors is that some audits do not get done or are late, so legal obligations are not met, and providers breach their covenants.


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Last year, two large housing associations (HAs) – Notting Hill Genesis and A2Dominion – notified markets that they would be delayed in finalising their results, due to staff availability at their audit firm. In separate trading updates in September, the groups said it was due to a senior member of the team at BDO being signed off on long-term sick leave.

 

NHG said that it had obtained consent from bond trustees to postpone the requirement for the accounts by two months, while A2Dominion said it had notified the Regulator of Social Housing (RSH) that it would miss its submission deadline. While the issue related to a specific case of staff availability, the mitigations each took highlight the breadth of the stakeholder relationships potentially impacted by auditor availability. However, there is no suggestion the two were close to breaching covenants. BDO did not wish to comment further.

 

Social Housing reported in February 2022 the potential for a “perfect storm” of regulatory and commercial shifts leading to a shortage of auditors for the sector. Efforts have been made to tackle the shortage, including by the NHF, which launched an engagement drive a year ago. But is progress being made?

Significant challenge

 

Peter Benz, executive director of finance at Network Homes and chair of the G15’s finance director group, tells Social Housing the shortage of auditors in the sector obviously poses a “very significant challenge” and the G15 considers it a “systematic risk”.

 

“There are different levels of exposure [in the G15],” he says. “So, we’re not all in exactly the same position. But we certainly all agree that this is an issue that needs addressing and it needs addressing sooner rather than later.”

 

Will Perry, director of strategy at the Regulator of Social Housing (RSH), says that the shortage is something that the regulator discusses with HAs. He says that if a provider is having difficulty getting an auditor appointed, the RSH will expect the organisation to notify it.

 

“It’s one of those technical matters that is between a provider and their lenders and, thus far, it’s not been a specific problem,” Mr Perry says. “Everybody has got their accounts audited, it has just taken a bit longer at times.

 

“And it’s really down to lenders to take a view on how flexible they want to be. There is an expectation to publish on time, but there is an understanding that the market is difficult. 

 

“And if you can demonstrate that you have done what you can to find an auditor, or that your audit is in progress, then lenders are inclined to be sympathetic. If you’re not doing anything in advance, and you just get overtaken by events, then I think we’d be concerned by that as well.”

 

Currently, a large proportion of the sector is being served by a handful of auditors.

The auditor audit

 

Social Housing looked at the external auditor data for the full-year financial accounts of housing associations in Great Britain (English HAs with more than 500 homes and Scottish and Welsh associations with more than 1,000 homes) from financial years 2018 through to 2022. 

 

The analysis shows an increase in total fees over the four years, but also movement around which auditors were most active in the sector during the period.

 

Aggregate annual fees (covering a total of 369 clients) rose from £14.9m in 2018 to £22.7m in 2022, with the biggest annual increases seen in 2020 (14.5 per cent) and 2021 (13.9 per cent).

 

Some firms saw their HA client portfolio boosted during the period, while others saw it diminish. Comparing the ‘top 12’ auditors by number of associations served (for external audit) during the year, the movement from 2018’s top players to 2022 shows some big firms dropping down the ranks, while other names enter the list.

 

KPMG, top of the list in 2018, fell to third place by 2022, swapping places with Beever and Struthers, which climbed from third to first place.

 

The former remained prevalent among the largest providers, however, with KPMG auditor to all but two of the 10 largest UK housing associations by stock in 2022, including all of the top five.

 

In 2018 and 2022, BDO remained consistently in second place for the number of associations in its client portfolio, and RSM likewise stayed in fourth. Movement was seen lower down the list, with Grant Thornton moving from fifth place in 2018, with 34 associations in tow, to joint 10th in 2022, having only seven sector clients. It is replaced in fifth place in 2022 by Crowe’s 24 associations – a firm that did not feature in the top 12 in 2018 as it had just two sector clients for external audit at the time. 

 

Maria Hallows, executive partner and head of social housing at Beever and Struthers, says: “We are delighted to see the results of the survey. Our number one ranking is a testament to the hard work and dedication of our team.

 

“Beever and Struthers has been committed to the social housing sector for many decades. We are passionate about the sector and our commitment to our social housing clients will always remain central to what we do as a firm.”

 

Julia Poulter, head of social housing, London at Crowe, says: “We’ve grown rapidly in this space over the past four years, while ensuring that growth does not impact on the quality of service we offer to our current client base.

 

“Social housing is an area that Crowe will continue to invest in and grow so we can provide even more associations with efficient, effective services that add value.”

 

A spokesperson for RSM UK says: “We’ve invested heavily in the growth of our audit business these past few years, so we’re pleased to have maintained our position in what continues to be a competitive market.

 

“We continue to engage with the social housing sector, in all accountancy and business advisory-related services. Our sector and service line capability is among the broadest in the UK.

 

“This allows us to balance our social housing audit work between meeting client expectations, auditor resource, the critical nature and regulation of PIEs, and the ability to meet the needs of our wider audit sectors.”

Lee Cartwright, partner at auditing firm Beever and Struthers, says he believes the problems are most acute for the largest HAs, which need to appoint a big firm but may be unable to, and for the very small HAs.

 

He says: “The problem for the very small housing associations is that an audit will inevitably be complex because they are a registered provider, and yet the audit fee [they are offering] may be disproportionately small given the complexity of the audit and the risk involved. 

 

“So, trying to find an auditor with experience of the sector and that can provide the service at the right price can be tricky.”

 

Reasons behind the shortage

 

There are several reasons for the auditor shortage in the sector. The majority of HAs share the same March year end so resources are focused at the same time.

 

Social housing is seen as a specialist sector that requires new entrants to train their staff – and, when tendering, some providers may have been unrealistic about the fees offered for auditors.

 

Many audit firms are struggling for capacity while facing a huge demand so can pick and choose their contracts, so some have left the sector in favour of more lucrative work, or opted to provide other services to associations.

 

Furthermore, there has been a regulatory shake-up following collapses such as construction and services giant Carillion. The Financial Reporting Council (FRC), the regulator for auditors, has increased the scrutiny and accounting requirements for auditors, leading to an increase in the time taken for audits and the costs involved.

 

In addition, as they have listed debt, many HAs are classified as public interest entities (PIEs), which have increased audit requirements and auditor scrutiny. There are new rules being introduced that require partners of audit firms to register in order to conduct PIE audits. Therefore, some auditors may see HAs as higher risk and less attractive.

 

“Across the whole economy there’s a shortage of skilled people,” says Mr Cartwright. “And if you couple that with audit reform, increased audit regulation and so on, it’s created a perfect storm.”

 

Guy Flynn, financial reporting director at Hyde Group, who spent 18 years as an auditor and was a director at PwC, says that some audit firms have exited the sector due to a number of contributory factors.

 

These include the increased complexities of the larger housing associations, increased audit regulations particularly impacting housing associations with listed debt, and the need for each audit to be financially sustainable. This has meant audit firms have needed to exit certain audits to focus their resources accordingly.

 

He says that there is a shortage of audit staff in firms because of the challenges and pressure faced from the higher audit regulations, which includes exposure to personal risk.

 

Mr Flynn says alongside tightened audit regulations, there was a more than 10-year period in which the sector was price-driven when tendering for auditors, rather than quality-driven.

 

He says: “Audit firms have made losses in social housing, in particular when having to retender every five years.”

Number of housing associations audited annually by firms: top 12 in 2018


AuditorNumber of HAs audited in 2022Number of HAs audited in 2021Number of HAs audited in 2020Number of HAs audited in 2019Number of HAs audited in 2018
KPMG3834475556
BDO6352705552
Beever and Struthers7354463940
RSM3431403936
Grant Thornton79213234
Mazars2023293331
Nexia Smith & Williamson117192019
Alexander Sloan1919191818
Bevan Buckland1614131110
PricewaterhouseCoopers02579
Armstrong Watson Audit12256
Scott Moncrieff00676

 

Note: Data includes English associations with more than 500 homes and Scottish and Welsh associations with more than 1,000 homes

Progress

 

The NHF has been addressing the shortage head on, by engaging with auditors outside the sector to attract them into auditing social housing providers.

 

John Butler, policy leader at the NHF, says that since starting these talks around this time last year, the trade body has brought about 20 auditors into the sector. The NHF has grown its member-only list of auditors in the sector, which is published on its website, from around 10 to about 30.

 

Almost all of those firms on the list reported that they are keen to come into the sector and have the resources to be a part of the list, Mr Butler says.

 

“We’re really pleased that some of these firms have been signed up,” he adds.

 

He observes that the NHF is already starting to see some traction, with two HAs – Flagship Housing Association and Watford Community Housing Association – having engaged two of the audit firms that the trade body has brought into the sector.

 

Paul Richmond, deputy chief executive at Watford Community Housing, says: “Due to circumstances outside our control, we were required to undertake a short-form tender in February 2023 to appoint external auditors for the 2022-23 financial year.

 

“We were able to use the NHF auditor list to invite a range of auditors to engage with us, both those existing and new to the sector. We appointed Buzzacott to conduct our audit and while noting they are new to the sector, we were encouraged by their commitment to entering the sector and their broader not-for-profit experience.”

 

In addition, six or seven audit firms came to the NHF’s Finance Conference in Liverpool to discuss their organisations with social landlords. The trade body hosted two meet-and-greet sessions at the conference, which Mr Butler says were “very popular”. The NHF also carried out a training day for 13 audit firms in October.

 

Mr Butler says “the more important work” now is to persuade the sector to engage with the new entrants.

 

Meanwhile, Mr Benz says the G15 has been trying to engage productively with auditors on this in a “two-way conversation”. He says the shortage is a shared problem that can only be fixed with a shared solution, which will require flexibility on both sides.

 

Mr Benz says the G15 is reflective on HAs’ own tendencies, for example, that they should provide longer planning horizons for procurement exercises and ensure that working papers required for auditors are prepared to an acceptable level of quality.

 

He says that while the group is willing to be reflective, the G15 also wants to “productively and proactively” challenge auditors to find a way to solve this issue.

Number of housing associations audited annually by firms: top 12 in 2022


AuditorNumber of HAs audited in 2022Number of HAs audited in 2021Number of HAs audited in 2020Number of HAs audited in 2019Number of HAs audited in 2018
Beever and Struthers7354463940
BDO6352705552
KPMG3834475556
RSM3431403936
Crowe2411722
Mazars2023293331
Alexander Sloan1919191818
Bevan Buckland1614131110
CLA Evelyn Partners140000
Grant Thornton79213234
Chiene + Tait75454
Azets76200

Mr Benz adds that the next step is ongoing engagement with auditors. “From talking to auditors, we’ve found the intentions are there,” he says. “What we now need to do is to find practicable, executable ways forward to within a reasonably short period of time have more participants in the markets.

 

“That will require flexibility from both sides. It will require a fundamental rethink about how we engage with the external audit market, but also how the external audit market engages with us.”

 

Mr Butler says that addressing the auditor shortage is a priority. He says: “Last year, there was a sense housing associations were not getting the auditors needed and also, when you go to tender and don’t get any submissions, any bids, that in itself is a significant problem. So, this couldn’t happen soon enough. But audits only take place once a year. And in that year, we have done quite a lot of work.”

 

Beever and Struthers’ Mr Cartwright thinks that progress to date has been adequate, with the NHF bringing in auditor firms to the sector, increasing competition.

 

“There are a handful of new firms that now have a foothold in the sector,” he says. “I think things are moving in the right direction from a competition perspective, and the change has been pretty rapid.”

 

However, Mr Benz says that progress has not been fast enough. “We don't have a pathway yet,” he says. “Certainly not one that I think that is understood or agreed upon.”

 

Mr Benz says that while the G15’s initial approaches to engage with auditors have been “positive”, progress is not yet being made at the pace required.

 

“We need to ensure the process is accelerated, but I’m dedicated to ensure that we achieve that,” he says. “And, indeed, there is no alternative but a positive resolution to this issue.”

 

What can HAs do?

 

Besides the obvious addition of more auditors, there are some things HAs can do to help themselves. They are encouraged to go out for procurement early, be realistic about auditor fees and to have their working papers in order prior to the audit.

 

Mr Butler says that HAs should bring the procurement of external audit into the remit of their finance department. He advises HAs to use the NHF’s template tender document and go out to tender a year or two early as auditors plan that far in advance to ensure they have the resources for their audits.

 

He says: “If you are in there having those conversations, they understand what your requirements are, then they are better able to respond to the tender which you then put out later on. But already those organisations will have an understanding of your requirements and your timings.”

 

Hyde’s Mr Flynn says that providers should also invest in their finance teams to increase their bandwidth and better prepare for audits. He says they should also be realistic about fees. Analysis by Social Housing shows that these have continued to rise annually in aggregate over the past four years (see bar graph, above).

 

Mr Flynn says: “I think fees will continue to go north. And there needs to be a commercial understanding that for audit firms to work in the sector it needs to be profitable.”

 

While more progress is required, some has been made already and existing auditors in the sector tell Social Housing of their commitment to the sector and why they are well placed to serve providers.

 

While efforts by the likes of the G15 and the NHF continue, HAs can take steps themselves to ensure they are best prepared for procuring both new entrants and existing players.

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