Harmonization relating to auditor independence: the Eighth Directive,the UK and Germany

The European Union Eighth Directive on the approval of auditors covers auditor independence only to a very limited extent. The provisions in the five articles on this subject are far less detailed than they were in the drafts of the directive, so that almost all specific regulation is left to the Member States. An examination of the development of the articles dealing with independence and integrity shows how the need to compromise, in order to reach an agreement, frustrated the intentions of the harmonizers. This paper traces the development of the independence rules in the Eighth Directive from the avant projet through the drafts to the final directive. It assesses the extent to which pre-Eighth Directive regulation in the UK and Germany may have affected the directive and then examines the implementation of the directive in the two countries. It concludes that national culture and accounting traditions prevented harmonization of independence rules through the Eighth Directive.