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Memorandum of Understanding on Reciprocal Arrangements with Public Accountants and Auditors Board (Zimbabwe)
1. Definitions
In this Memorandum, the following phrases shall have the meaning ascribed to them below:
aACCA (Zimbabwe) means the Zimbabwe branch of the Association of Chartered Certified Accountants, a registered body corporate in the United Kingdom governed by its Royal Charter and Byelaws.
bAppropriate qualification means an approved third country qualification under section 1221 of the Companies Act 2006 supplemented by an aptitude test under that section.
cAudit Qualification means a qualification awarded to an individual who satisfies the prescribed criteria which permits that person to apply to be registered to undertake audit work in either Zimbabwe or the United Kingdom.
dConstituent Body means ICAZ and ACCA (Zimbabwe). A reference to a Constituent Body in this Memorandum shall be a reference to either or both of these bodies as the context requires.
eFRC means the Financial Reporting Council Limited, which is, amongst other things, the competent authority for statutory audit and an independent regulator in the United Kingdom, responsible for regulating auditors based on its obligations and authority under applicable legislation, including the Companies Act 2006 and the Statutory Auditors and Third Country Auditors Regulations 2016.
fICAZ means the Institute of Chartered Accountants of Zimbabwe, a statutory body in Zimbabwe that is governed by its Byelaws.
gPAAB means the Public Accountants and Auditors Board, which is, amongst other things, responsible for audit regulation in Zimbabwe. It is the statutory regulator established under the Public Accountants and Auditors Act [Chapter 27:12] as at 31 December 2016.
hParticipants means the FRC and the PAAB.
iRecognised Professional Qualification means a professional qualification recognised under sections 1219 and 1220 of, and Schedule 11 to, the Companies Act 2006.
jRecognised Qualifying Body means a United Kingdom body which offers a Recognised Professional Qualification.
kRecognised Supervisory Body means any of Chartered Accountants Ireland ("CAI"), Institute of Chartered Accountants in England and Wales ("ICAEW"), Institute of Chartered Accountants of Scotland ("ICAS") and Association of Chartered Certified Accountants ("ACCA") to which the FRC has delegated the task of registration of statutory auditors under a delegation agreement made pursuant to regulation 3 of the Statutory Auditors and Third Country Auditors Regulations 2016. A reference to a Recognised Supervisory Body in this Memorandum shall be a reference to the bodies identified above jointly or individually as the context requires.
lRegistered Public Auditor means a person registered as an auditor under the Public Accountants and Auditors Act (Chapter 27:12) of Zimbabwe.
mResponsible Individual means a principal or employee responsible for audit work and designated as such by a registered audit firm in the United Kingdom.
nUnited Kingdom Applicant means a person who is a Responsible Individual.
oUnited Kingdom Audit Qualification means the qualification of a Responsible Individual in the United Kingdom.
pZimbabwe Applicant means a person who is a Registered Public Auditor and is a member of a Constituent Body
qZimbabwe Audit Qualification means the qualification of a Registered Public Auditor in Zimbabwe.
2. Objectives and purpose
aThis Memorandum of Understanding ('Memorandum') is between the FRC and the PAAB.
bThis Memorandum covers: (i) Responsible Individuals whose United Kingdom Audit Qualification is recognised by the PAAB; and (ii) Registered Public Auditors who are regarded by the FRC as holding an approved third country qualification.
cThe United Kingdom bodies defined as Recognised Supervisory Bodies are recognised by the FRC as Recognised Qualifying Bodies.
dThe purpose of this Memorandum is to outline the basis upon which each Participant recognises persons who are qualified to audit accounts under the law of the other's jurisdiction and records their understanding of the application processes whereby:
iZimbabwe Applicants may be regarded as holding an approved third country qualification for the purpose of becoming a Responsible Individual in the United Kingdom; and
iiUnited Kingdom Applicants may have their qualification recognised for the purpose of becoming a Registered Public Auditor in Zimbabwe.
eThe PAAB has provided assurances to the FRC regarding the basis for recognition of United Kingdom Audit Qualifications in Zimbabwe (see section 3 below) and that persons who hold a United Kingdom Audit Qualification recognised by the PAAB will receive comparable treatment to holders of a Zimbabwe Audit Qualification (see section 6 below).
fThe FRC has provided assurances to the PAAB regarding the basis for regarding Registered Public Auditors as holding an approved third country qualification (see section 3 below), and that Registered Public Auditors regarded as such by the FRC will receive comparable treatment to holders of a United Kingdom Audit Qualification (see section 7 below).
gUnited Kingdom Audit Qualifications that are held by individuals and have been assessed as equivalent in Zimbabwe are recognised by PAAB in accordance with its approval and governance processes under the Public Accountants and Auditors Act (Chapter 27:12).
hRegistered Public Auditors are recognised by the FRC exercising the power contained in section 1221 of the Companies Act 2006.
iThis Memorandum has no impact on, or connection to, any visa or residency requirements that may be imposed by immigration authorities in the United Kingdom or Zimbabwe.
jThis Memorandum does not alter, supersede or replace any reciprocal membership agreements between a Constituent Body and a Recognised Supervisory Body.
kThis Memorandum is not legally binding, and the Participants agree the Memorandum does not create any legal rights or obligations which are enforceable against them by either each other or third parties.
3. Basis of Recognition
aThe Participants have the power to recognise persons qualified to audit accounts under the law of a specified third country as holding an approved third country qualification comparable to Audit Qualifications obtained in their own jurisdiction. The FRC proposes to declare that Registered Public Auditors shall be regarded, under section 1221(1)(a) of the Companies Act 2006, as holding an approved third country qualification for the purpose of becoming a statutory auditor in the United Kingdom. The PAAB proposes to recognise United Kingdom Audit Qualifications as comparable or equivalent qualifications for the purpose of applying for registration as a Registered Public Auditor in Zimbabwe subject to the requirements of section 21 of the Public Accountants and Auditors Act Chapter 27:12 and other applicable laws.
bAlthough an Audit Qualification from the Association of International Accountants ("AIA") has been assessed by the PAAB as a comparable qualification, there are currently no Responsible Individuals who hold an Audit Qualification awarded by the AIA. For this reason, the Participants have agreed that the reciprocal arrangements underpinned by this Memorandum will not currently extend to holders of an Audit Qualification awarded by the AIA. If circumstances change, the Participants will reconsider whether amendment to the reciprocal arrangements and this Memorandum is required.
cThe Participants are satisfied that a Responsible Individual recognised in Zimbabwe will receive comparable treatment to a Registered Public Auditor regarded, in the United Kingdom, as holding an approved third country qualification (and vice versa).
United Kingdom
dThe FRC has declared that Registered Public Auditors are to be regarded, subject to passing an aptitude test complying with sections 1221(7A) and (7AA) of the Companies Act 2006, as holding an approved third country qualification for the purpose of becoming a statutory auditor in the United Kingdom
eThe FRC requires a Zimbabwe Applicant to maintain their membership of the Constituent Body that granted that person their qualification.
fThe FRC requires a Zimbabwe Applicant to become a member, audit affiliate, affiliate or regulated non-member of a Recognised Supervisory Body.
gThe FRC is satisfied that the fact that Registered Public Auditors are qualified to audit accounts under the laws of Zimbabwe, when taken with the requirement to pass an aptitude test, provides an assurance of professional competence equivalent to that afforded by a Recognised Professional Qualification.
Zimbabwe
hThe PAAB has declared that Responsible Individuals are to be regarded, subject to passing an aptitude test, as holding equivalent qualifications to Zimbabwe Audit Qualifications for the purpose of applying for registration as a Registered Public Auditor in Zimbabwe.
iThe PAAB requires a United Kingdom Applicant to maintain their membership of the Recognised Qualifying Body that granted that person their qualification.
jThe PAAB requires a United Kingdom Applicant to obtain membership with a Constituent Body.
Compliance with laws etc.
kThe Participants each recognise that auditors registered to practice in either the United Kingdom, Zimbabwe or both must follow the laws and professional standards of each jurisdiction in which they have been registered to practice, including any rules or regulations relating to an individual's obligations to undertake continuing professional development.
4. Cooperation
aThe Participants will co-operate with each other until a Participant withdraws from this Memorandum in accordance with paragraph 8.
bThe Participants are committed to pursuing the aims and purposes contained within this Memorandum in good faith and to act in accordance with its provisions on a voluntary basis.
cIn the event that there are any differences of opinion in respect of any matters relating to this Memorandum, the Participants will endeavour to resolve any differences of opinion through co-operation and consultation with each other.
dTo the extent permitted by the law in their respective jurisdictions, the Participants both acknowledge and understand that co-operation includes the timely processing of, and response to, requests for information.
eTo the extent permitted by law in their respective jurisdictions, the Participants will co-operate and will endeavour to avoid increasing the other's administrative burdens in connection with the registration of each other's auditors.
fTo the extent permitted by law in their respective jurisdictions, the Participants will make reasonable efforts to co-operate by making the other aware of any matters that may affect this Memorandum or the basis upon which a Participant has recognised an Audit Qualification awarded in the jurisdiction of the other as comparable to an Audit Qualification awarded in that Participant's jurisdiction or the basis upon which a Recognised Public Auditor has been regarded as holding an approved third country audit qualification.
gThe Participants each acknowledge that any changes or circumstances which affect or impact the basis upon which an Audit Qualification from one jurisdiction has been recognised in the other, or the basis upon which a Recognised Public Auditor has been regarded as holding an approved third country qualification, may lead a Participant to review whether that qualification or person should continue to be so recognised.
5. Applicants for the purposes of this Memorandum
The Participants agree that United Kingdom Applicants must be members of a Recognised Qualifying Body and registered as a Responsible Individual by a Recognised Supervisory Body and Zimbabwe Applicants must be members of a Constituent Body and have obtained their membership by completing a typical pathway to membership of that body. A 'typical pathway' is a pathway to membership which is completed through the education and training required by that body.
6. Application process – United Kingdom Applicants seeking registration as a Registered Public Auditor
The PAAB has confirmed to the FRC the process for a United Kingdom Applicant seeking registration as a Registered Public Auditor. The process consists of the following steps:
Recognition of United Kingdom Audit Qualification in Zimbabwe
aUnited Kingdom applicants must apply in such form and providing such information about their Audit Qualification and Responsible Individual status as required by a Constituent Body.
bThe Constituent Body assesses whether the applicant's qualifications and experience meet their eligibility requirements to be granted membership. The assessment will consider whether the applicant is a member in good standing.
cThe Constituent Body may seek verification from the Recognised Qualifying Body that the applicant is a member of that body and how their professional membership was gained.
dThe Constituent Body may seek verification that the applicant is a member in good standing from the Recognised Supervisory Body with which the applicant is registered. The Recognised Supervisory Body may also be the Recognised Qualifying Body under which the applicant originally qualified as a professional accountant.
eUnited Kingdom Applicants are required to pass an aptitude test which includes but is not limited to Zimbabwe tax and law. The aptitude test will be set by the Constituent Body with which the United Kingdom Applicant obtains membership.
fUnited Kingdom Applicants must obtain membership of a Constituent Body. This membership may be obtained through a reciprocal membership agreement between a Constituent Body in Zimbabwe and a Recognised Supervisory Body in the United Kingdom
gThe decision as to whether a United Kingdom Applicant has completed the necessary steps to be granted membership rests with the Constituent Body.
hWhere a United Kingdom Applicant has obtained membership, of a Constituent Body under reciprocal or any other arrangements and subsequently ceases to be a member of a Recognised Supervisory Body, their reciprocal membership of the Constituent Body may be revoked by the Constituent Body.
Registered Public Auditor Process
iOnce the United Kingdom Applicant has passed the aptitude test and obtained membership of a Constituent Body, the applicant may apply to the PAAB for registration as a Registered Public Auditor and for a Practising Certificate.
jThe PAAB is responsible for assessing an application from a United Kingdom Applicant for registration as a Registered Public Auditor.
kThe PAAB assesses whether an applicant meets the eligibility requirements to become a Registered Public Auditor. The assessment will consider whether the applicant is a member in good standing and the requirements prescribed under section 21 of the Public Accountants and Auditors Act.
lThe PAAB may seek verification from the relevant Recognised Supervisory Body that the applicant is a Responsible Individual, is a member, audit affiliate, affiliate, or regulated non-member of that body and is of good standing and as to how their professional membership was gained. Where the applicant has also been registered by the FRC as a Responsible Individual for the audits of Public Interest Entities (PIE) entities, the PAAB may also seek verification from the FRC of this status.
mThe final decision on registration as a Registered Public Auditor rests solely with the PAAB, and all applications shall be considered and determined by the PAAB in accordance with section 23 of the Public Accountants and Auditors Act.
7. Application process – Zimbabwe Applicants seeking registration as a Responsible Individual
The FRC has confirmed to the PAAB that the process for a Zimbabwe Applicant seeking registration as a Responsible Individual consists of the following steps:
Acquisition of Appropriate Qualification in the United Kingdom
aA Recognised Qualifying Body which receives an application from a Zimbabwe Applicant for an Appropriate Qualification will be responsible for assessing the application.
bZimbabwe Applicants should apply in such form and providing such information about their professional qualifications, Audit Qualification and audit experience as the Recognised Qualifying Body may require.
cThe Recognised Qualifying Body assesses whether the applicant's qualifications and experience meet their requirements to grant an Appropriate Qualification valid in the UK. The assessment will consider whether the applicant is a member of a Constituent Body in good standing.
dThe Recognised Qualifying Body may seek verification of a Zimbabwe Applicant's membership, registration, and good standing from the relevant Constituent Body and from the PAAB.
eZimbabwe Applicants will be required to pass an aptitude test (see paragraph 7 (f) below) but shall not be required to obtain any further audit qualifications, provided they hold a Zimbabwe Audit Qualification recognised by the FRC.
fAn aptitude test is set by a Recognised Qualifying Body and tests subjects and skills that are not covered by the Audit Qualification already held by that individual, knowledge of which is required to pursue the profession of statutory auditor in the United Kingdom. The subjects which may be tested include, but are not limited to, United Kingdom tax and audit law.
gThe decision as to whether a Zimbabwe Applicant has completed the necessary steps to be awarded an Appropriate Qualification in the United Kingdom rests with the Recognised Qualifying Body.
Responsible Individual process
hA Recognised Supervisory Body which receives an application from a Zimbabwe Applicant for registration as a Responsible Individual shall assess the application.
iZimbabwe Applicants must apply in such form and providing such information about their professional qualifications, Audit Qualification and audit experience as the Recognised Supervisory Body reasonably requires.
jA Recognised Supervisory Body assesses whether an applicant meets the eligibility requirements to become a Responsible Individual. The assessment will consider whether the applicant is a member in good standing.
kA Recognised Supervisory Body may seek verification from the relevant Constituent Body that the applicant is a member of that body and of how their professional membership was gained.
lZimbabwe Applicants must have been granted an Appropriate Qualification granted by a Recognised Qualifying Body (as explained in sub-paragraphs (a) - (g) above).
mA Recognised Supervisory Body may seek verification from the PAAB that the applicant is a Registered Public Auditor and how this status was gained and if they are in good standing.
nZimbabwe Applicants must obtain membership, audit affiliate, affiliate, or regulated non-member status of a Recognised Supervisory Body. Membership may be obtained through a reciprocal membership agreement between a Recognised Supervisory Body and a Constituent Body. Where there are no reciprocal membership agreements, audit affiliate, affiliate or regulated non-member status is available. This status means that an individual is subject to all the rules and regulations of a Recognised Supervisory Body but does not have membership rights.
oWhere a Zimbabwe Applicant has obtained membership, audit affiliate, affiliate or regulated non-member status of a Recognised Supervisory Body under reciprocal or any other arrangements and subsequently ceases to be a member of a Constituent Body, their reciprocal membership, audit affiliate, affiliate or regulated non-member status of the Recognised Supervisory Body may be revoked by the Recognised Supervisory Body.
pA Recognised Supervisory Body may require Zimbabwe Applicants to complete a further period of audit experience in respect of audits of entities incorporated under the laws of the United Kingdom where it considers the applicant has insufficient audit experience to meet the eligibility requirements for registration as a Responsible Individual.
qThe decision as to whether a Zimbabwe Applicant should be registered as a Responsible Individual rests with the Recognised Supervisory Body.
rWhere an individual has been granted Responsible Individual status by a Recognised Supervisory Body and also wishes to be responsible for work on the audits of Public Interest Entities ("PIE"), they must additionally seek registration as a PIE Registered Responsible Individual under the FRC's PIE Auditor Registration Regulations. The application form and registration guidance can be obtained from FRC website www.frc.org.uk.
8. Duration and Review of this Memorandum
aThis Memorandum will continue until either of the Participants withdraws in accordance with paragraph 8(c).
bThis Memorandum will be reviewed by the Participants not less than every 5 years from the date it becomes effective. The review will consider the ongoing suitability of this Memorandum and whether there have been any changes to the basis upon which the Participants have recognised an Audit Qualification from the other's jurisdiction as comparable or the basis on which Registered Public Auditors have been regarded as holding an approved third country qualification.
cEither of the Participants may withdraw from this Memorandum upon provision of 12 months' written notice to the other. Such a notice shall include, or be accompanied by, a written explanation of the reasons for withdrawal. A written explanation which cites a change to the basis upon which either of the Participants have recognised an Audit Qualification or courses from the other's jurisdiction, or to the basis on which Registered Public Auditors have been regarded as holding an approved third country qualification, as a reason for withdrawal must identify the change(s) and the impacts that change(s) is considered to have on the basis of recognition.
dThis Memorandum may only be amended by the written agreement of the Participants.
Signing
Dated this 10th Day of November 2026
The Financial Reporting Council Limited Signed by authorised signatories:
Richard Moriarty Chief Executive Officer
The Public Accountants and Auditors Board Signed by authorised signatories:
Donald Mangenje PAAB Secretary