Progress in the 1990s?, The

harmonization of international accounting standards: Progress in the 1990s?, The

Larson, Robert K

The International Accounting Standards Committee (IASC) was established in 1973 to harmonize international accounting standards. The IASC’s standards (IASs) are now accepted in some form by numerous stock exchanges, including those in London, Germany, Hong Kong, Singapore, and Switzerland. The US SEC already accepts use of three IASs and has indicated that it may accept all IASs in late 1998. Though accepted by a growing number of stock exchanges, this may not represent individual country’s accounting standards. This article investigates the recent progress of international accounting harmonization by examining whether countries’ official standards are in compliance with the IASs in the 1990s. Overall, harmonization via IASs appears to increase from 1991 to 1993. However, when the results of the “Comparability of Financial Statements” program became effective in 1995, at least initially, the level of harmonization decreased. This drop is not unexpected given that the 1995 changes eliminated previously approved and practiced accounting methods.

Is harmonization of international accounting standards occurring? The actions of various international stock exchanges are a positive indication. International Accounting Standards (IASs) are now accepted from foreign registrants on a large number of stock exchanges, including those in Australia, London, Germany, Hong Kong, Kuala Lumpur, Paris, Singapore, and Zurich (IASC 1998b). Several stock exchanges do not even require any additional disclosures reconciling IASs to their country’s own domestic GAAP. The US Securities and Exchange Commission (SEC) now accepts IASC prescribed cash flow statements and two other IASs. Moreover, the US SEC may accept all lASs in late 1998.

The International Accounting Standards Committee (IASC) receives widespread support for its efforts to harmonize international accounting. Indeed, the IASC is now regarded as the leading force in the international accounting harmonization effort, with the support of the International Organization of Securities Commissions (IOSCO), the largest international public accounting firms, various businesses and trade organizations, many international development organizations, and most national public accountancy bodies.

Despite widespread public support for accounting harmonization and the work of the IASC, little empirical research has assessed the extent to which harmonization via IASs is actually occurring (Tay and Parker 1992, Rivera 1989). The study explores recent harmonization via IASs in regards to various countries’ actual accounting standards in three parts. The first part briefly reviews compliance with lASs in the early 1990s before rather dramatic changes in IASs became effective on January 1, 1995. The second part examines changes in the early 1990s of countries’ accounting standards to determine whether those changes are resulting in greater compliance with IASs. The third part examines compliance with IASs after January 1, 1995, when the results of the “Comparability of Financial Statements” program became effective. Those changes to lASs eliminated many previously allowable accounting methods for many types of transactions, even though many of those accounting techniques continue to be generally accepted accounting principles (GAAP) in various countries. Potentially, a country’s GAAP could be in compliance with lASs on December 31, 1994, but not in compliance the next day.

In the next section, we provide some background on harmonization, discuss relevant literature, and state our research questions. We then describe the research method before discussing the results and conclusions from the three parts of the analysis.


The international harmonization of accounting has been defined as “the attempt to bring together different systems. It is the process of blending and combining various practices into an orderly structure, which produces [a] ‘synergistic result”‘ (Samuels and Piper (1985, 56-57). While some see harmonization more as a process of moving to a system of uniformity or standardization, most view harmonization as a process whereby the number of allowed accounting alternatives is reduced as a means of promoting greater comparability.

The roots of international accounting harmonization can be traced back to a series of international congresses beginning in St. Louis in 1904. These, as well as other movements and events, increased support for the harmonization of accounting standards over the years. The harmonization movement essentially culminated in the formation of the IASC in 1973.

Headquartered in London, the IASC’s membership consists of professional accountancy bodies. As of January 1998, the IASC had 128 members representing 91 countries (IASC 1998a). Although IASs are not mandatory for members, member bodies agree to work for the implementation of lASs in their own country. While the IASC is not alone in addressing these issues, the IASC does the most comprehensive work in harmonization and is the most prominent player in the pursuit of international accounting standards. Recently, the European Union (EU) decided to support the IASC, especially in its plan to permit large multinational corporations to use IAS when preparing their consolidated financial statements (Flower 1997).

Previous Research

Much of the research on harmonization has been descriptive, analytical, and/or subjective in which the merits of harmonization are debated (Meek and Saudagaran 1990, Rivera 1989, Samuels and Piper 1985). Empirical research assessing the IASC’s success in its pursuit of harmonization, while relatively sparse, has been of two general types ( 1 ) studies analyzing national accounting standards, de jure, and (2) studies analyzing the accounting practices of corporations, de facto (Tay and Parker 1990).

Studies of de jure harmonization. Studies measuring harmonization via IASs through official national accounting standards (de jure) have led to varied conclusions regarding the progress toward harmonization. Several studies used, at least in part, the Price Waterhouse (PW) accounting surveys published in 1973, 1975 and 1979. While the PW data has been criticized accuracy and for mixing practice with actual accounting standards, it was the basis for the earliest studies in this area (Nobes 1987). For example, Nair and Frank (1981) analyzed data from PW’s 1973, 1975, and 1979 surveys regarding 131 items in 37 countries. They found that the period of the IASC’s existence coincided with increasing harmonization.

Doupnik (1987) analyzed both the 1975 PW survey and his own 19u3 survey tor jo countries. Doupnik concluded that differences in financial reporting among countries had decreased and that the quality of financial reporting as measured internationally by compliance with lASs had increased from 1975 to 1983. Doupnik and Taylor (1985) analyzed both the 1979 PW survey and their own 1983 survey regarding compliance with 53 accounting issues contained in the first eight lASs. While they found that Europe had the lowest overall compliance levels with lASs of any region, they also found that European IAS compliance levels had increased the most of any region from 1979 to 1983.

McKinnon and Janell ( 1984) used a more descriptive approach to analyze a few selected IASs and concluded that the IASC had not succeeded in either changing existing standards or setting new ones.

Taylor et al. ( 1986) received surveys from partners in two of the then “Big 8” public accounting firms from 33 countries on accounting relative to lASs 1, 2, 3, 4, and 7. They found the IASC to have been successful in improving the comparability and consistency of international accounting and financial reporting practices.

The IASC (1988) surveyed its members and received responses from representatives of 54 countries. The IASC (1988) found that most member countries, especially former UK colonies, were either using IASs as their own national standards or as the basis for setting their own national standards. Purvis, Gernon and Diamond (1991) use the IASC’s 1988 survey data and expand on the IASC’s general conclusions. However, the 1988 IASC survey has been criticized by several researchers, including Meek and Saudagaran (1990, 171) who are concerned about “wishful thinking”‘ on the part of responding IASC members.

The United Nations (1991) sent surveys to 37 African countries as part of a large study on accounting in Africa. The UN found that 25 of the 37 African countries surveyed use lASs, either with or without modification, in the development of their own accounting standards. However, this study also contains the potential for “optimistic” self-reporting.

Finally, the IASC did a second major survey in the Fall of 1991. Unfortunately, except for a few excerpts, the results were never released (Harding 1993, IASC 1993).

Studies of de facto harmonization. Other studies have examined corporate financial statements to determine whether corporations are complying with lASs (de facto) (Meek and Saudagaran 1990). The IASC (1988) also asked its members whether they believed individual corporations in their countries were actually complying with IASs, and most members responded that they believed so.

Other de facto studies are less positive. Evans and Taylor (1982) investigated the impact of five lASs on 50 corporate financial reports from five countries for the period of 1975 to 1980. They concluded that the IASC had “very little impact” on accounting practices in France, Japan, the UK, US and West Germany. Stilling, Norton, and Hopkins (1984) found that few multinational corporations comply with all lASs. Tonkin (1989) concluded that there had been little or no harmonization of financial reporting by multinational companies during the 1980s. In a narrower study, Nobes (1990) examined 200 US companies and found that less than 50% comply with lASs that require disclosure where US GAAP is silent. Recently, Cairns (1996) sampled 50 international companies that claimed to follow lASs and found that many are using goodwill policies not in conformity with the relevant newly revised IAS.

Research Questions

Previous research produced conflicting results as to whether the harmonization of international accounting has been successful. However, the late 1980s and early 1990s saw growing acceptance of IASs by global stock exchanges, as well as overall increased rhetoric supporting harmonization and the IASC. Large numbers of corporations now claim to use IASs (IASC 1996). Therefore, if the demand in international capital markets helps to drive harmonization and the increased rhetorical support from many parties fosters harmonization, then one would expect harmonization via IASs to have increased in the early 1990s.

The study seeks to determine whether that conventional wisdom can be empirically supported by addressing three questions. First, how many countries complied with lASs in the early 1990s? Second, were countries changing their national accounting standards to bring them into closer compliance with IASs in the 1990s? Third, what is the status of compliance with lASs after the IASC’s major standards revisions that were effective January 1, 1995?

Our study examines the de jure harmonization of international accounting via lASs. We examine official national accounting standards and regulations and compare them with lASs. We believe de jure harmonization must be researched for several reasons, the two most important being the legal authority behind many, if not most, national standards and the fact that most companies’ financial reports do not list all of the accounting principles that they use when preparing their financial statements.


We employed cross-national research methods commonly found in the international accounting literature (Wallace and Gernon 1991, Gray and Roberts 1991) to analyze changes in accounting standards between 1991 and 1995. Most data was extracted from Coopers and Lybrand (C&L) (1991, 1993) and PW (1995). The C&L data are for the accounting standards in effective on January 1 of each year. The PW data was published in May 1995.

The 33 countries in C&L’s 1993 edition were used to obtain information on compliance with IASs before the major revisions effective January 1, 1995. To assess changes in accounting standards, we compared data from the 1991 and 1993 editions of C&L’s work. Twenty-four countries were included in both editions. All accounting changes in those 24 countries were analyzed and compared with IASs. The PW data was complete for 21 countries and was used to determine compliance with [ASs in 1995.

The data was carefully examined and analyzed. Data was extracted that related to actual accounting standards rather than accounting practice. We did not consider a country’s GAAP to be in compliance with lASs if the country did not have an official accounting standard. A country was deemed to be in compliance with IASs if the country had accounting standards for the particular accounting issue and if the country’s standards were at least as restrictive as the corresponding IAS. If a country required a method that was among the alternatives under the corresponding IAS, then that country was considered to be in compliance on that issue. Reconciliation of an alternative method to a benchmark method was not considered necessary to be in substantial compliance because we view harmonization at its core as being a narrowing of allowed practice in order to promote comparability. If a country did not have a standard or if a country allowed alternative accounting treatments not allowed under IASs, then that country was not considered to be in compliance with IASs.

Each accounting change was judged as to whether it resulted in increased compliance with lASs or decreased compliance with IASs, or whether the change did not affect its compliance with IASs. For example, if a country changed from one accounting rule to another and both rules were allowed as a choice under lASs, then that change was not considered to be a movement to or from IASs. Also, if a rule change occurred where the IAS did not specify a particular accounting treatment, then that change was not considered to be a movement to or from lASs. We determined a country’s overall direction by considering all accounting changes and giving them equal weight. Equal weight was appropriate because, although some accounting issues may be more important than others, harmonization advocates expect countries to consider lASs for all accounting changes they make.


How Many Countries Were Complying with IASs in the early 1990s?

Twenty-six accounting and reporting areas were examined for 33 countries in 1993 (see Table 1). Fourteen of the 33 countries analyzed were in compliance with lASs in at least 24 areas. These 14 countries form a fairly homogeneous group consisting of the US, UK, former or current colonies of the UK (including Australia, Canada, Hong Kong, New Zealand, and Singapore), and The Netherlands. With only relatively minor differences, this group resembles Nobes’ ( 1992) micro-based accounting classification of countries in which accounting standards are commercially driven rather than government driven. It appears that countries with accounting standards similar to the US and UK have the highest compliance levels with IASC rules, as expected or suggested (Hoarau 1995, Hove 1990).

In 1993, 17 countries complied with IASs in at least 16 but not more than 23 of the areas examined. The group represents most of continental Europe, as well as Scandinavia, Japan, Korea, India, Indonesia, Mexico, Brazil, and Argentina. As a whole, this group appears to resemble Nobes’ ( 1992) macro-uniform accounting classification of countries in which accounting rules and practices tend to be established by government regulations, laws, and/or tax rules. Such countries would need to change laws and/or tax rules to increase compliance with IASs. Therefore, compliance with IASs may be a more difficult task than in micro-based countries, where accounting rules traditionally have been set by the private sector and hence should be easier to change.

Two countries, Switzerland and China, did not comply with IASs in numerous areas. Traditionally, Swiss accounting practices have been extremely conservative, with the legal encouragement to use hidden reserves and other income-smoothing techniques (Achleitner 1995). Given that lASs are often considered to be market- and disclosure-oriented, Switzerland’s low level of compliance with lASs is not surprising. However, new Swiss company law (most of it effective July 1, 1992) appears to bring their accounting rules much closer to both lASs and EU rules (Achleitner 1995, United Nations 1993). This change in attitude may also be seen in the large number of Swiss firms now using lASs (Murphy 1997).

China is not in compliance with lASs in more than half of the accounting areas. Again, this finding is not surprising given that China had a traditional socialist accounting model for many years. China is another example of a country that is in the process of updating its accounting standards (United Nations 1993). Indications are that China is using lASs as one of its primary models in developing its accounting standards (Xiang 1998).

Which Accounting Areas Have High Compliance Levels?

Compliance varies among the 26 accounting areas examined (see Table 2). In 1993, all or almost all 33 countries were in substantial compliance with lASs in 14 accounting areas, including the basic accounting concepts and conventions, business combinations, property, plant and equipment, accounts receivable, inventories, current liabilities, long-term debt, and revenue recognition. Although these 14 areas represent more than half of the 26 areas and also represent some of the most important accounting principles, lASs allowed for different accounting treatments on the same issues in many of those areas. The IASC (1993) study also reported extremely high compliance in disclosure of accounting policies, presentation of current assets and liabilities, inventories, and property, plant and equipment.

Ten accounting areas had a lower level of compliance with IASs. In this second group of accounting areas, from four to II of the 33 countries did not comply with lASs. Noncompliance was generally in the more recently covered, controversial, and/or technical accounting areas such as cash flow statements, joint ventures, foreign currency translation, leases, research and development, income taxes, and postretirement benefits. The IASC (1993) The analysis shows two other accounting areas in which 19 or 20 of the 33 countries do not comply with IASs, related party transactions and segmental information. Again, this finding is consistent with the IASC (1993) study.

Are Accounting Changes in the 1990s Increasing Compliance with IASs?

Twenty of the 24 countries analyzed made accounting changes from 1991 to 1993 (C&L did not report any changes for Germany, Hong Kong, Italy, and Nigeria). The analysis shows that 11 of the 20 countries that made accounting changes increased their overall de jure compliance with lASs (see Table 3). Thus, a majority of the countries examined appear to be moving toward harmonization via lASs. The countries with the most accounting changes, in decreasing order, were Switzerland, Denmark, Sweden, and Mexico. In all four countries, most of the changes created increased compliance with lASs.

Although the accounting changes in six countries cannot be said to be moving either toward or away from IASs, four of those Some have suggested that recent changes by EU countries to bring their standards into compliance with EU accounting directives may account for compliance with lASs. Of the 12 EU countries, all but Italy implemented the Fourth Directive before 1991 and all but Ireland, Italy and Portugal implemented the Seventh Directive before 1991 (Nobes 1992, 98). So it is possible that the EU directives may have increased many countries compliance with lASs prior to 1991, the beginning of the study’s time period, but that is beyond the paper’s scope.

In order to determine whether the movement toward IASs between 1991 and 1993 coincided with a movement toward EU accounting countries are already in substantial compliance with lASs on either all or almost all accounting issues. Only three countries are categorized as moving their accounting standards away from lASs. Closer examination revealed that those three countries’ changes away from IASs tended to be fairly few and/or minor. For example, Ireland made a change that restricted who must provide a cash flow statement, but Ireland is still in compliance with almost all IASs directives between 1991 and 1993, a similar analysis was performed to determine whether accounting changes in Europe increased or decreased compliance with EU accounting rules. Complete data was available for eight of the 12 EU countries. Neither Germany nor Italy had any real changes. For the other countries, changes were few and/or fairly minor and no discernable pattern was apparent. From 1991 to 1993, it appears that changes toward lASs were independent of changes required by the adoption of EU rules.

Harmonization after the IASC Revisions Effective in 1995

In order to better understand if harmonization via lASs is actually occurring in the 1990s, it is important to see whether the level of compliance is the same in 1995 after the effective date of the many revised lASs. This is necessary because many previously allowed accounting alternatives were eliminated at the conclusion of the “Comparability Project.”

Thus, many countries which may have been in compliance with lASs due to the many alternatives previously allowed by lASs may now have much lower levels of compliance. Overall, the results of the analysis found that, in absolute terms, most countries had lower levels of compliance with IASs after the 1995 changes (see Table 1 ). Relatively speaking, most countries that previously had higher levels of compliance kept their relatively high levels of compliance and those countries that previously had lower levels of compliance kept their relatively low levels of compliance.

Table 4 lists accounting areas where significant change in the level of compliance occurred between 1993 and 1995. Overall, compliance levels with IASs on many issues are lower, sometimes dramatically lower. Numerous examples exist where the elimination of alternatives or the tightening of disclosure rules caused countries to lose their previous compliance status on an issue. Goodwill is a good example. The IASC’s revision caused those countries allowing either the direct writeoff of goodwill or an amortization period of 40 years to be out of compliance with the revised IAS. Interestingly, in a few areas, primarily those that the 1995 revisions did not effect, harmonization actually modestly increased A few factors may account for these changes. First, countries may not have had time to make any planned changes in order to comply with the revised IASs. Many countries continued to allow alternatives that were no longer acceptable under the new lASs. Second, many countries did not have accounting standards that addressed issues detailed in the revised IASs. While PW often stated that a country’s practice is to follow the new IASC rules in a particular area, numerous countries did not have any actual regulations in that area. This was especially true with those countries with a Roman-Germanic Law tradition (per Salter and Doupnik’s (1992) classification).

While some previously criticized IASs for being too general, now IASs are narrower and more specific. While that particular criticism is at least partially addressed, fewer countries now are formally in compliance with IASs. Another interesting finding is that after the 1995 changes, compliance with IASs appears to be less strictly associated with a country’s legal background or general accounting orientation as defined by Nobes.


Our study investigated progress toward harmonization via IASs in the early 1990s. Overall, the results indicate a discernable trend toward IASs through 1993. At that time, the countries in the sample tended to be in compliance with IASC standards in most major areas. Further, countries with standards not in compliance with lASs overall appeared to be changing their accounting standards to be in greater compliance with IASs.

The analysis indicated that in 1993 the countries with the highest levels of compliance with IASs tended to be those countries that have an overall accounting system resembling that of either the US or UK and those with a Common Law legal framework. In addition, most other countries substantially complied with IASs on a majority of issues in 1993, but diverged from IASs in several major accounting areas such as research and development, leases, and income taxes. The study found a trend toward harmonization via lASs as measured by the 1991 to 1993 accounting standard changes in sample countries. Also, the two countries with the lowest IAS compliance level, Switzerland and China, have recently made major changes that appear to bring their accounting standards closer to IASs. However, the results using the 1991 and 1993 data must be viewed cautiously. Then lASs allowed considerable latitude. Many countries may have complied with lASs in 1993 without any concerted effort toward harmonization because of the many alternatives allowed. The revised IASs effective in 1995 eliminated many alternatives and should decrease “accidental” compliance. Not unexpectedly, the analysis in 1995 after the effective date of the major IAS’s revisions is not as positive. Overall, compliance levels with lASs dropped as many accounting alternatives were eliminated and disclosure requirements were increased.

1995 is too early to make definitive statements regarding long-term harmonization. Changing accounting rules is a long and arduous task in most countries. Therefore, many countries desiring compliance with IASs may still be trying to make the required changes.

Finally, it is also important to remember that many companies comply with IASs in order to list on stock exchanges, which may have different rules than the countries’ themselves. While this study examined de jure harmonization, any conclusions on the overall progress of harmonization need to consider country standards, exchange listing requirements, and actual corporate practice. For the user of financial statements, it is important to remember that while there is a great deal of discussion about the international accounting harmonization, that the reality is that harmonization is not yet a reality.


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Robert K. Larson

The Pennsylvania State University at Harrisburg

Sara York Kenny

College of Saint Mary, Omaha, Nebraska

Copyright College of Business Administration. University of Detroit Mercy Spring 1999

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