Employers had until the end of 2021 to complete drawing up action plans for the implementation of professional standards. In particular, they should have established for which positions professional standards have been adopted, which employees meet their requirements, and who needs to be sent for training. Of particular interest is the position of chief accountant, which exists in almost every organization.
But, as practice shows, many of the chief accountants, although they have extensive work experience, work without higher education. Is it necessary to fire such an employee because of this? Let's figure it out.
About the professional standard for the chief accountant
The first professional standard “Accountant” was approved by Order of the Ministry of Labor of the Russian Federation dated December 22, 2014 No. 1061n.
In 2021, by Order of the Ministry of Labor of the Russian Federation dated February 21, 2019 No. 103n, a new standard was approved, which changed the requirements for accountants and chief accountants. Compared to the old standard, the new one establishes an expanded list of possible titles of accounting positions. So, if in the old standard there was only one title “accountant”, now there are three positions: “accountant”, “accountant of category I” and “accountant of category II”.
Instead of one position “chief accountant” with the 6th qualification level, the following positions have now been introduced:
- chief accountant (6th - 8th qualification levels);
- head (manager, director) of the department (management, service, department) of accounting (6th - 8th qualification levels);
- head (manager, director) of the department (service, department) of consolidated financial statements (8th qualification level);
- Director of Operations Management (8th qualification level);
- director of accounting outsourcing (8th qualification level);
- commercial director (8th qualification level);
- Business Development Director (8th qualification level).
According to the requirements of the old standard, in order to work as a chief accountant, an employee must have a higher (specialized) or secondary vocational education with additional programs for advanced training and professional retraining, as well as practical experience related to accounting, preparation of accounting (financial) reporting or auditing activities, for persons:
- with higher education - at least three of the last five calendar years;
- with secondary vocational education - at least five of the last seven calendar years.
Now, in addition to the fact that two more qualification levels have been added for the chief accountant (7 and 8), which has significantly increased the requirements for this position, the requirements for his qualifications have also changed.
Depending on the qualification level, different levels of education, work experience and general labor function are established. We present the requirements for chief accountants of all levels in the table.
Level | Generalized labor function | Education Requirement | experience |
6 | Preparation and presentation of accounting (financial) statements of an economic entity | Higher education - bachelor's degree | At least five years of accounting and financial work |
Secondary professional | At least seven years of accounting and financial work | ||
7 | Preparation and presentation of accounting (financial) statements of an economic entity that has separate divisions | Higher education - master's degree or specialty | At least five years of accounting and financial work in management positions |
8 | Preparation and presentation of consolidated reporting | Higher education - master's degree or specialty | At least five years out of the last seven years of work related to accounting, preparation of accounting (financial) statements or auditing activities (including in management positions); at least three years out of the last five years (including in management positions) with a higher education in economics with a specialization in accounting and (or) audit |
If workers at all levels have non-core higher or secondary education, they must have additional education through professional retraining programs.
In addition, chief accountants of all levels must receive additional education through advanced training programs in the amount of at least 120 hours for three consecutive calendar years, but not less than 20 hours in each year.
Advanced training for accountants
Advanced training of an accountant is necessary not only to move to a higher position, but also to update theoretical knowledge and practical skills in the field of accounting and tax accounting. This event allows specialists to: – get acquainted with new regulatory legal acts of the Russian Federation; – study the modern experience of foreign countries in the field of accounting; – apply in practice the latest methods and methods of accounting; – deepen knowledge in economic disciplines and analysis of enterprise activities.
In order to improve their knowledge, accountants can study innovations in their activities independently or attend various trainings and seminars. However, more effective are advanced training courses that allow you to cover a large amount of information and document this process with an official document. Advanced training courses are necessary for an accountant to increase their professional level and increase wages.
Advanced training for accountants is possible through special educational centers that operate according to programs developed and approved by the Institute of Professional Accountants. Upon completion of advanced training courses, students receive a certificate of completion of training and advanced training.
For whom are the requirements of professional standards mandatory?
Let us remind you that, by virtue of Art.
195.3 of the Labor Code of the Russian Federation, if this code, other federal laws, and other regulatory legal acts establish requirements for the qualifications necessary for an employee to perform a certain job function, then professional standards in terms of these requirements are mandatory for application by employers. That is, only those requirements of professional standards that are introduced either by the Labor Code, or federal laws, or other regulations are considered mandatory. Let us turn to the Federal Law of December 6, 2011 No. 402-FZ “On Accounting”. In accordance with Part 3 of Art. 7 of this law, the head of an organization may entrust accounting maintenance to the chief accountant or other official of the organization, or enter into a civil law agreement for the provision of accounting services.
The chief accountant or other official responsible for maintaining accounting records must meet the following requirements:
1) have a higher education;
2) have work experience related to accounting, preparation of accounting (financial) statements or auditing activities for at least three years out of the last five calendar years, and in the absence of higher education in the field of accounting and auditing - at least five years out of the last seven calendar years;
3) do not have an unexpunged or outstanding conviction for crimes in the economic sphere.
However, such requirements apply only to chief accountants:
- open joint-stock companies (except for credit organizations);
- insurance organizations;
- non-state pension funds;
- joint stock investment funds;
- mutual fund company managers;
- state extra-budgetary funds and their territorial branches.
For other organizations, the requirements of the professional standard “Accountant” are advisory in nature, and the employer himself decides whether to apply the qualification requirements established by the professional standard.
Who is an accountant?
As a rule, people understand only superficially - an accountant counts money. Of course, such a judgment is very narrow. A qualified accountant is a person who is the right hand of the director of the company and is responsible for all the finances of the company. Salaries, contributions to the Tax Service and the Pension Fund, and much more. This type of work requires perseverance and attentiveness from the employee; accounting does not tolerate mistakes. In addition to accounting, you need to know the current legislation, tax laws, legal acts and much more.
Introduction of professional standards
As noted, at the beginning of 2021, government institutions, as well as other state and municipal institutions, had to implement action plans for the implementation of professional standards: to establish, in particular, whether the requirements of professional standards are mandatory for employees of their organization, including chief accountants , conduct an analysis of the professional qualities of employees for compliance with these requirements, and also draw up plans for employee training and additional professional education within the budget for the corresponding year.
The Ministry of Labor reminded about this back in 2021 (Letter dated 04/04/2016 No. 14-0/10/B-2253). For chief accountants of government institutions, the qualification requirements established by the professional standard are recommendations. However, if the employer is interested in competent employees, he can apply professional standards when developing job descriptions, recruiting personnel, organizing training, certification, etc. Accordingly, he can include in the job description of the chief accountant the knowledge, skills and functions established by the standard, as well as qualification requirements.
After changes are made to the job description, new employees will need to be hired in accordance with these requirements.
To fire or not to fire?
Let us say right away that even if the employer is obliged to apply the professional standard for the chief accountant, but his qualifications do not meet the requirements of the standard, it is impossible to fire the chief accountant for this, since there is no such basis for dismissal as, for example, “inadequacy of qualifications.”
If before the employer began applying (either independently or by force of law) the professional standard, the chief accountant was already working, and during the implementation of the standards it was determined that his qualifications do not meet the requirements of the standard, he can be fired only based on the results of certification. And this can only be done after the employer offers the employee to undergo advanced training, including it in the employee professional training plan.
At the same time, even if the employee refused to improve his qualifications, but has sufficient experience and knowledge in his position, then, on the recommendation of the certification commission, he can continue to remain in his position.
If, based on the results of the certification, it is established that the employee is not suitable for the position held due to insufficient qualifications, then he can be dismissed on the basis of clause 3 of part 1 of Art. 81 of the Labor Code of the Russian Federation (inconsistency of the employee with the position held or the work performed due to insufficient qualifications confirmed by certification results). Before dismissal, the employee should be offered a transfer to another job that matches his qualifications.
An employee’s compliance with the requirements of the professional standard can be established as a result of him passing, and with his consent, at the direction of the employer, an independent assessment of qualifications, which is carried out in independent assessment centers.
Do not forget that dismissal under clause 3, part 1, art. 81 of the Labor Code of the Russian Federation may not apply to all workers. For example, a pregnant woman, a single mother raising a child under the age of 14 (a disabled child under the age of 18), and a woman with a child under the age of three are not subject to dismissal.
Blog
Interview with Konstantin Viktorovich Edin
- Executive Director of the Novosibirsk Territorial Institute of Professional Accountants and Auditors (NTIPBiA), member of the Presidential Council of the IPB of Russia.
Novosibirsk Institute of Professional Accountants and Auditors (NTIPBiA)
is a professional accounting community that unites more than 11,000 representatives of the accounting profession in the Novosibirsk region. He is a representative of the regional network of the Institute of Professional Accountants and Auditors of Russia (IPB Russia). It has been successfully operating for more than 18 years.
Konstantin Viktorovich, you are a member of the Presidential Council of the IPB of Russia - the developer of the professional standard “Accountant” and, for sure, have the most current and reliable information. Tell me, what does the introduction of a professional standard for accountants mean?
The introduction of a professional standard for an accountant means stricter requirements for education and work experience. That is, accountants will no longer be able to work without special training and experience. Especially if the applicant is applying for the position of chief accountant.
But, in fact, the introduction of standards is more significant for the employer. First of all, the employer needs to comply with all the provisions of professional standards himself and ensure that his employees comply with them.
Many in our market are afraid of professional standards because they work without special education, do not have any certificates and that they will be forced to fulfill these requirements. Is a professional standard even mandatory for an accountant?
Officially, the professional standard for an accountant is advisory in nature. But, I want to draw your attention to the fact that it was approved by the Ministry of Labor (order No. 1061n dated December 22, 2014), and not by some professional association. Any document approved by this department is mandatory for use by employers.
This means that the employer must be guided by the provisions of the standard when:
- establishing positions
- development of job descriptions,
- concluding employment contracts,
- carrying out internal and external certification of employees,
- when establishing a wage system.
Agree, professional standards have a wide area of application in the activities of any organization. And the employer will rely on their requirements and will strive to ensure that employees comply with them, avoiding possible inspections by regulatory authorities and fines.
An accountant will have to meet the standard one way or another. Now it is necessary to assess whether his qualifications correspond to the functions performed. If not, take professional retraining or advanced training courses.
What requirements does the standard impose on novice specialists and already working chief accountants and ordinary accountants?
The requirements for the chief accountant are as follows: the employee must have a higher education and work experience related to accounting, preparation of accounting (financial) statements, or auditing activities for at least three years out of the last five calendar years.
If there is no higher education in the field of accounting and auditing, such experience must be at least five years out of the last seven calendar years.
The professional standard also sets requirements for responsibilities, skills and abilities.
The responsibilities of the chief accountant include:
- Organizing, planning and regulating the information collection process.
- Compliance with deadlines for submitting information to the relevant authorities.
- Ensuring the possibility of conducting an audit.
- Interaction with management and other departments.
- Preparation of consolidated reporting.
- Practical knowledge of sections of IFRS.
- Knowledge of tax legislation and tax optimization.
- Financial planning and budgeting.
- Requirements for the skills and abilities of a chief accountant:
- Organizational skills: determining the scope of work and resource costs.
- Development and implementation of accounting methods and methods.
- Workflow optimization.
- Excellent knowledge of legislation, judicial practice, and industry-specific areas of law.
For accountants holding ordinary positions and applying for such work, the requirements are less stringent - a minimum of secondary vocational education (training programs for mid-level specialists plus additional professional education in special programs) and work experience with special training in accounting and control of at least three years.
There are also requirements for the duties, skills and abilities of an ordinary accountant.
Responsibilities:
- Maintaining primary records.
- Monitoring the correct execution of all incoming and outgoing primary accounting documents.
- Systematization and registration of documents in accordance with accounting policies.
- Entering data into registers, monitoring property valuation.
- Ensuring the safety of documents.
- Registration of non-standard transactions and preparation of justification for them.
- Formation of SALT, filling out the General Ledger, maintaining all types of registers.
- Skills and abilities:
- Knowledge of the procedure for preparing paper and electronic documents.
- Knowledge of legal norms and the ability to apply them in practice.
- Knowledge of all accounting methods: with and without computers.
How to confirm compliance with these requirements?
According to the requirements of the professional standard “Accountant” and the Federal Law “On Independent Assessment of Qualifications” dated July 3, 2016 No. 238-FZ, in order to confirm compliance with the requirements of the standard, you need to pass a professional exam at a special qualification assessment center (CAC) and receive a certificate of qualification.
Although the Law “On Independent Assessment of Qualifications” will come into force only in January 2021, many of its provisions are already being applied de facto. Employers are already asking accountants to present a document confirming their qualifications meet the requirements of the professional standard.
True, today there is neither an approved list of documents that must be presented to the CSC in order to obtain admission to the professional examination, nor the form of the document issued based on the assessment results.
What should accountants do in such a dual situation? There is an answer. In Russia there are long-standing systems for professional assessment of the qualifications of accountants, such as the IPB of Russia. He has already received the status of a CSC according to the professional standard “Accountant” in the system of independent qualification assessment.
The IPA certification system of Russia contains all the requirements and important provisions of the professional standard, a serious professional exam is conducted, and based on the results of the exam, a certificate of a professional accountant is issued, which confirms a high level of qualifications and its compliance with the professional standard.
Who and on what basis draw the conclusion that the qualifications of a particular accountant meet the requirements of the professional standard? Could this be a subjective assessment by the personnel officer on site?
Neither employees of the HR departments of enterprises, nor the accountants themselves can draw conclusions about the compliance or non-compliance of qualifications.
In accordance with the law, such an assessment must be carried out by the CSC. Based on the submitted documents on education, work experience and professional examination results, a decision is made on compliance with the professional standard.
Who is generally responsible for the fact that the accountant’s qualifications do not meet the standard: the employer or the accountant himself? Are there any penalties?
Responsibility here is mutual, the employer is responsible for hiring applicants in accordance with professional standards, and accordingly, it is in the interests of the applicant to comply with them.
I would like to draw your attention to the fact that if a current employee does not meet the requirements of the standard, then the employer should not rush to dismiss him.
The fact is that the Labor Code does not provide for such grounds for dismissal as “insufficient qualifications.” To terminate an employment contract, a more compelling reason is required - the employee’s inadequacy for the position held or the work performed due to insufficient qualifications, confirmed by certification results.
But for failure to pass a professional exam, the employer has the right to fire an employee.
The situation is different with a candidate employee.
An employer who applies professional standards does not have the right to enter into a contract with a person who does not meet these standards. This conclusion is contained in paragraph 6 of the Information of the Ministry of Labor of Russia dated 04/05/2016.
Article 196 of the Labor Code of the Russian Federation states that the need for training (vocational education and vocational training) and additional professional education of employees for their own needs is determined by the employer. Training of employees and their additional professional education are carried out by the employer on the terms and in the manner determined by the collective agreement, agreements, and employment contracts.
The employer faces administrative liability for violation of labor laws. The fine, in particular for legal entities, as a general rule, ranges from 30 thousand to 50 thousand rubles.
Special liability threatens if the employment contract is not drawn up properly. An employer may be attracted to it, for example, when a position offering benefits is specified in an employment contract without taking into account the professional standard or qualification directory. In particular, a legal entity will pay from 50 thousand to 100 thousand rubles for such a violation.
There are many offers on the Internet for accountants to obtain a certificate of compliance with professional standards. Does an accountant need to obtain such a certificate urgently? Who has the right to issue them? What should these certificates contain? What happens if he doesn't receive it?
Most offers on the Internet are nothing more than a desire to make money from the current situation and have nothing to do with the system of independent assessment of the qualifications of accountants.
I repeat once again - only CSCs have the right to issue a document on qualification compliance, or more precisely, it will be from 01/01/2017, when such a document is approved.
So far there is no liability for the lack of a document confirming qualifications, but you should not wait for the rush to demand for such documents from January 2021. As practice shows, such situations are always associated with a significant increase in prices for such services.
Accountants who do not have special education should now think about advanced training or retraining.
How to get certified as a professional accountant? Tell us about the training and certification system in accordance with the standard.
The requirements for applicants to obtain a professional accountant certificate are similar to the qualification requirements and work experience requirements laid down in the professional standard “Accountant”.
The employee must have a higher education and work experience related to accounting, preparation of accounting (financial) statements or auditing activities for at least three years out of the last five calendar years. If there is no higher education in the field of accounting and auditing, such experience must be at least five years out of the last seven calendar years.
The training program and questions submitted for the qualification exam fully correspond to the knowledge that an applicant must have to meet the professional standard.
To obtain a certificate of a professional accountant, the applicant must undergo training:
- according to the program 80 hours (for category “A” - ordinary accountants),
- according to the program 260 hours (for category “B” - senior employees of accounting services).
Upon completion of training, the applicant must pass a difficult qualifying exam.
I would like to emphasize that the system of training and certification of professional accountants carried out by the IPB of Russia is the oldest and has been implemented since 1996. We can safely say that no one in Russia has such experience in working according to modern rules and requirements in the field of advanced training and certification of accountants.
What additional opportunities does participation in courses on IPB programs provide?
I think additional opportunities include the possibility of further career growth. The chief accountant, having received a certificate, can study further, mastering the additional job functions of a financial director, tax consultant, internal auditor or IFRS expert. Such specialists are now in great demand, and their work is highly paid.
Over the 20 years of existence of the system of certification of professional accountants, the qualification certificate has received support not only from the professional community - to date, more than 280 thousand accountants have received the professional accountant certificate, but also enjoys the trust of employers - when hiring in many companies, the professional accountant certificate is a confirmation of high the level of professionalism of its owner.
Professional accountants are high-level specialists. Anyone who has passed a difficult exam confirms this. How does he maintain a high level of professional competence in the future? After all, an accountant always needs to be aware of all changes?
The professional standard also includes requirements for advanced training of accountants.
Although an accountant who is responsible for his or her job responsibilities is subject to these requirements from the profession itself, constant changes in accounting, tax, civil, and labor legislation lead to the need to constantly maintain the level of one’s qualifications at a high level.
The system of mandatory professional development allows accountants who are full members of the IPB of Russia to keep abreast of changes. A professional accountant annually improves his qualifications in the amount of at least 40 hours.
Konstantin Viktorovich, thank you for the interesting conversation! I think your detailed answers will help accountants understand and understand what the legislator once again requires of them and, of course, what needs to be done to confirm their qualifications and be a sought-after specialist.
Interviewed by Olesya Aleksandrovna Apunnik, director of the Center for Economic Knowledge "Fin-Info" |
Results
In accordance with Federal Law No. 402-FZ, there are no mandatory requirements for chief accountants of government institutions regarding their qualifications.
Therefore, the requirements for the education of a chief accountant, provided for by the professional standard and mandatory by virtue of this law, are advisory in nature for government institutions. The employer has the right to establish in the job description its requirements for the qualifications of the chief accountant or use the requirements of the professional standard.
According to the professional standard, the chief accountant, whose main function includes the preparation and presentation of accounting (financial) statements, may have:
- or higher education in a bachelor's degree program and at least five years of experience in accounting and financial work;
- or secondary vocational education and at least seven years of experience in accounting and financial work.
If higher or secondary education is non-core, the employee must additionally complete a professional retraining program.
Thus, even in accordance with the professional standard, a chief accountant can have a secondary vocational education and seven years of work experience. If the education is non-core, he should be offered to undergo professional retraining, if he has not already had it.
If an employer has introduced a professional standard for application, it is impossible to fire a chief accountant whose level of education does not meet the requirements. You can dismiss only under clause 3, part 1, art. 81 of the Labor Code of the Russian Federation for non-compliance with the position held due to insufficient qualifications confirmed by certification results.