Exposure Draft : a Public Interest Framework for the
Accountancy Profession
Comments of the Ethics Committee
Of Consiglio Nazionale dei Dottori Commercialisti e degli Esperti contabili
Delegated Council member : Stefano Marchese
The notion of “public interest”
We would like first of all to express our appreciation for the proposed definition of public interest
as “the sum of the benefits that citizens receive from the services provided by the accountancy
profession.” Such definition provides a wider perspective on the role of the accountancy
profession, considered as a party that can actively contribute to the achievement of benefits for
the citizens and opens the debate on the importance of professional organizations’ evaluation of
actions and measures also to the purpose of effectively safeguarding such interest.
The Public Interest Framework: Three Criteria
We also agree on the need to identify a framework that may assist in evaluating the extent to
which actions performed by members of the accountancy profession (professional organizations
and their members) serve the public interest. To this purpose, we deem appropriate to highlight
some aspects of the three identified criteria, i.e.:
1. Consideration of costs and benefits for society as a whole;
2. Adherence to democratic principles and processes ;
3. Respect for cultural and ethical diversity.
We would like to point out the following:
 With regard to criterion no.1, we deem appropriate to expressly mention the rationality
principle: explicitly stating such principle would, as a matter of fact, allow to stress the need to
always act rationally, that is in a manner appropriate to the situation, and to identify as the
optimal equilibrium the one that carries out, at the same time, the minimization of costs and
maximization of benefits/revenues. Such equilibrium (which, in economics, is represented by
the Pareto efficiency where no further reallocation can be made that improves at least one
participant's well-being without reducing any other participant's well-being) would allow to
highlight the ‘social’ interaction of individual choices, i.e the impact, in terms of costs/benefits,
of individual choices on society as a whole.
 We believe that the criteria identified at no.2 and no.3 do not represent autonomous criteria
for assessing if the actions performed by professional organizations are responsive to the public
interest. Such criteria seem rather to specify how the general criterion at no.1 is achieved.
As a matter of fact:
a. Adherence to democratic principles and processes refers to conditions (identifying
procedures that should be appropriate, documented, transparent, shared, etc.) that
professional accountancy bodies are recommended to adopt while defining
decision making processes and actions that are responsive to the public interest, as
defined in the proposed draft;
b. Similarly, the criterion of respect for cultural and ethical diversity seem to identify
the second condition required for carrying out the evaluation process of
costs/benefits.
In other terms, the criterion no.1 appears as the only one (among those considered in the
framework identified by the exposure draft) through which organizations representing the
accountancy profession may determine if their conduct serves the public interest.
 In case the three criteria should however be kept as autonomous, we deem appropriate to
specify which criterion should prevail where conflict exist. The identification of the prevailing
criterion allows, as a matter of fact, to avoid a stalemate in the professional body's evaluation
of the responsiveness of their action to public interest.
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