Back to roots! The singular introduction of statutory auditing in France, Germany and Great Britain (1844–1935)

Abstract

Purpose This paper aims to better understand auditing practices as a social phenomenon and management practice through a comparative historical analysis of the emergence of statutory auditing in three European countries, namely, France, Great Britain and Germany between 1844 and 1935. Design/methodology/approach The authors’ approach is a comparative history relying on a literature review, books pertaining to the period of interest and relevant archives. Findings The three countries’ trajectories were similar. All featured the promulgation of acts at the second half of the 19th century, the development of the accounting profession and the introduction of new acts to further strengthen statutory auditing around the Great Depression. However, each country took a different path because of the degree of regulation. For instance, the regulation strength and the degree of professionalism differed considerably by country. Business secrecy was also a departure point; it ranged from the rejection of auditors as intruders in France to Germany’s exclusively internal auditing and the UK’s peer auditing. The countries also differed on perceptions of the auditor’s role. Auditors were seen through the lens of a general interest mission in France, as advisors to internal governance bodies in Germany and as shareholders’ agents in Great Britain. Originality/value This paper compares three main European countries in the specific context of the introduction of statutory auditing. The findings of this paper are helpful for the international harmonization of auditing standards, as the derived insights provide a better understanding of the differences in the standards’ implementation.