Table of Contens
Thematic Issue on “Harmonising European Public Sector Accounting Standards (EPSAS): Issues and Perspectives for Europe’s Economy and Society”
Biondi, Y. Harmonising European Public Sector Accounting Standards (EPSAS): Issues and perspectives for Europe’s economy and society, DOI 10.1515/ael-2014-0015
Biondi, Y., & Soverchia, M. Accounting rules for the European Communities: A theoretical analysis, DOI 10.1515/ael-2013-0063
Calmel, M.-P. Harmonisation of EPSASs (European Public Sector Accounting Standards): Developments and Prospects, DOI 10.1515/ael-2014-0018
Oulasvirta, L. Governmental financial accounting and European harmonisation: Case study of Finland, DOI 10.1515/ael-2014-0006
Jones, R., & Caruana, J. A perspective on the proposal for European Public Sector Accounting Standards, in the context of accruals in UK government accounting, DOI 10.1515/ael-2014-0005
Newberry, S. The use of accrual accounting in New Zealand’s Central Government: Second thoughts, DOI 10.1515/ael-2014-0003
Mussari, R. EPSAS and the public sector accounting unification across Europe, DOI 10.1515/ael-2014-0019
The European Public Sector Accounting Standards (EPSAS) proposal may be puzzling for accountants because it falls between the two different metrics for measuring a government’s income and wealth, namely an accrual-based accounting system and the system of national accounts which has its own accrual methodology (Jones, 2000a, 2000b, 2003, 2014).
The main objective of this paper is to discuss the EPSAS proposal in the context of UK government accounting and budgeting. The paper starts by considering the ambivalent involvement of Eurostat in the proposed public standards for government accounting of EU member states and tries to make sense of the underlying “logic”. Then we try to anticipate the UK government’s reaction to the proposal in the context of the fundamentals of the UK’s government accounting system and traditions. This takes the argument into the role of the UK Whole of Government Accounts as a government tool at both micro- and macro-levels, and hence the overlap with national accounting rules especially with regards to consolidation. Following the UK perspective, the conclusion attempts to rationalise the role and utility of the proposed EPSAS for other EU member states.
2 The proposal for European public sector accounting standards
Eurostat is the statistical arm of the EU Commission; as such, it is the EU’s custodian of the system of national accounts (globally known as the System of National Accounts [SNA]; the EU’s, conforming but more detailed, version is the European System of National and Regional Accounts [ESA951]). Eurostat’s relationship to all of accounting is the same as the national accounts’ relationship to accounting: it gathers data from accounting (among other places) and transforms these data into the national accounts.
The proposal for EPSAS was made by Eurostat. It emerged from a process that began, in 2011, with the EU proposal to require each member state to adopt International Public Sector Accounting Standards (IPSAS), which rather quickly retreated to a requirement for the Commission to assess the suitability of IPSAS, and then with said assessment to be carried out specifically by Eurostat (2012). As part of this assessment, the proposal for the adoption of IPSAS became a proposal to develop EPSAS based on IPSAS, and at the same time, converging the new accounting standards with those used for national accounting, namely the ESA95 (Eurostat, 2013).
Part of the puzzle of the EPSAS proposal is that it is far from obvious why a statistical agency would now become the custodian of government accounting in the member states: what have statistics to do with accrual accounting? It is one thing to say that the statistics draw from the records of transactions that are the essence of accounting (whether cash- or accrual-based); but quite another to say that the statistics have any relation to accrual-based financial statements. Globally and within the EU, the development of the concepts and measurement rules of the SNA have played no role in the development of accrual accounting; nor vice versa.
The “logic” of the EPSAS proposal appears to be as follows: the eurozone has overtly been in crisis since 2008; some governments in the eurozone have serious fiscal problems; an inherent weakness of the eurozone itself is that the government of each member state – rather than the EU as a whole – has sovereignty over each government’s fiscal policies; budgetary surveillance by the EU of each government’s fiscal policies is, therefore, faute de mieux; one aspect of the eurozone crisis was (still is?) weak surveillance of some governments’ budgets (see e.g. Schuknecht, Moutot, Rother, & Stark, 2011, p. 15); and that, since national accounts provide the framework for the data required by that surveillance, there is a need to improve the data (see e.g. Bowles, 2013). If that could serve as the broad logic of the proposal, then it would follow that the custodian of national accounts, Eurostat, would naturally have the responsibility for said improvement.
The logic is included in Eurostat’s (2012, p. 2) own words:
Budgetary surveillance in the EU is based on the European System of Accounts (ESA). ESA is a macro-economic accounting framework based on accruals principles, which is not designed for entity-level accounting. ESA based statistics are in practice a transformation of “primary” accounts, established on the basis of Member States’ national accounting standards. Member States’ national public sector accounting standards are, in the majority, not accrual based. … the Commission supports the implementation of public sector accounting standards providing the information needed to compile ESA-based data for all sub-sectors of general government.
Added to all that, everyone knows (including Eurostat) that it will take years to produce any set of EPSAS, and many more for current cash-based systems in the member states to convert to any accrual basis. It would hardly be surprising to find that the EPSAS proposal was low in particular governments’ priorities.
3 A UK perspective on the EPSAS proposal
To our knowledge, the UK government (either as a whole or in any of its significant parts) has taken no position on EPSAS. The Treasury, the National Audit Office and Parliament have not commented. The Financial Reporting Advisory Board (FRAB) of the Treasury is explicitly monitoring the development of EPSAS; in the minutes of a recent meeting, the following was reported (para. 63, Minutes of Meeting, 13 December 2013):
[A Board member] asked where the developments [of EPSAS] were expected to take public sector financial reporting. The Secretary noted that this is still unclear but given the suggested timescales put forward by Eurostat we would expect to have a much better understanding over the next 12 months…. Treasury confirmed that the expectation was a clear link between EPSAS and ESA, indeed improvements to statistical reporting were the driving force behind the project.
Subsequently, the FRAB (paras. 4 and 7, Minutes of Meeting, 3 April 2014) noted that the UK Relevant Authorities monitoring the progress of the EPSAS project had decided not to respond to Eurostat’s public consultation on EPSAS governance, and that a firm common position on the proposal would be determined after more concrete communication is received from the EU Commission. While the use of accrual accounting by public sector entities is supported, concern is expressed concerning Eurostat’s goal of full harmonisation because:
it would not be possible for the individual public sector context of each Member State to be taken properly into consideration … and would have a detrimental effect on Member States like the United Kingdom who have already converted from cash to accrual accounting and who use accrual throughout the public finance management system and not just for financial reporting… It was felt that Eurostat’s central aim of improving macro-level statistical reporting by ensuring the application of accrual accounting standards at the micro-level could be met by other more proportionate approaches.(paras. 5 and 6, Minutes of Meeting, 3 April 2014)
On the question of whether EPSAS would be developed by a new policy-making body, if EPSAS were to be limited to a role in “statistical reporting”, it is presumably possible that they would be hermetically sealed within the requirements established by Eurostat for submission of data consistent with the ESA. On its face, this would not require any separate body to promulgate the requirements. On the other hand, policy-making within the SNA (and, therefore, ESA) is, especially compared to business accounting, opaque; and given the scale of the eurozone crisis, it does not seem unreasonable to question the role of budgetary surveillance in it, a questioning that might point to a more formal and transparent policy-making for the ESA.
If, however, EPSAS were to be seen to be developed as the accounting policies for the financial accounting and reporting by government departments and by the wholes of governments of member states, we would assume that the UK government’s stance would be to undermine, and ultimately object to, their development. We have no idea how the politics of this would work.
But setting aside the politics, and on the basis of the roots and current manifestation of the UK’s financial accounting and reporting system, we would suggest that the Treasury would not voluntarily cede its sovereign right to make the UK government’s accounting policies to anyone.2 We would also suggest that the Treasury would not voluntarily cede that sovereign right to the private sector, within the UK or outside of it; in the specific case of IPSAS, it is not clear why the Treasury would cede its right to a private sector body that is anyway doing what the Treasury is doing, namely adapting IFRS to the governmental context. We would further suggest that the Treasury would not voluntarily cede its sovereign right to an EU institution: given the long, and separate, traditions of accounting and auditing between the UK (not matters of law) and continental Europe (law), this would be tantamount to fire conceding to ice (or vice versa) (Jones, 2005). Finally, we would suggest that neither the Treasury nor the National Audit Office would countenance auditors as accounting policy-makers: this would be anathema to accounting as we understand it.
4 Some fundamentals of the UK’s system
Unlike Eurozone countries whose monetary policy is dictated by the European Central Bank, the UK government is responsible for its own fiscal and monetary policies. As far as we are aware, neither the International Monetary Fund nor the European Central Bank has a problem with the data that the UK government is required to provide for budgetary surveillance. Budgeting and accounting for the UK government, at both micro- and macro-levels, are – to a degree unparalleled in the major countries of the EU and the US – the responsibility of the executive, and specifically of the Treasury (Jones, Lande, Lüder, & Portal, 2013, p. 435). At the micro-level (meaning for each government department/agency and for the meta-consolidation we know as Whole of Government Accounts), cash-based budgeting and accounting have been supplemented by an accrual basis.
Jones et al. (2013) provide our current understanding of the government’s accounting, except that we now have four consecutive years of Whole of Government Accounts (2010–2013). To focus on policy-making specifically, the 2000 law3 that established accrual-based financial reporting requires the financial statements of each department and of the whole of government to present a true and fair view (a concept and legal requirement drawn from business accounting) and to conform to generally accepted accounting practice (a concept drawn from business accounting) subject to such adaptations as are deemed necessary by the Treasury. The Treasury now uses EU-adopted IFRS as its point of departure for each of its accrual-based policies (HM Treasury, 2013a, pp. 43, 217; Biondi, 2013b).
In this use of business accounting, the Treasury’s policies are, at bottom, part of Anglo-American business accounting and auditing:
At the heart of this influential [Anglo-American] accounting and auditing is the requirement that the accounting policies are set by a private sector (nonprofit) body, formally independent of the accounting profession and independent of the companies preparing the financial statements, with compliance of those financial statements being judged in the first instance by auditors in the private sector, responsible to their professional accounting bodies (and, in the US, to a public body4), who are also independent of the companies being audited.(Jones & Pendlebury, 2010, p. 14)
Notwithstanding this dependence on Anglo-American business accounting, there are two important divergences of the UK government’s system from this business accounting. The first is that the Treasury, in the end, sets its own accounting policies. The second is that compliance with those policies is judged by auditors (in the National Audit Office) who are not in the private sector and who, indeed, are part of the state.
The extent of these two divergences is more difficult to define. Sovereign governments are unique institutions and concepts of independence within and outside them are, by their nature, slippery. In practice, there are ways of securing optimal (never absolute) levels of independence of a Ministry of Finance in setting accounting policies and of a supreme audit institution in auditing their implementation.5
IPSAS have no current role in the UK government’s system. IPSAS are inseparable from Anglo-American business accounting and auditing, except that they were developed and continue to be promulgated by the accounting profession itself, or at least by the world’s umbrella organisation for the accounting profession, which emphasises that it is “non-profit, non-governmental, non-political” (Jones, 2004, p. 49), rather than by bodies now independent of the accounting profession. In this, they may seem an obvious reference for the UK’s system; but they are not. Indeed, as Jones et al. (2013, p. 430) report, while IPSAS were previously referenced in the Treasury’s hierarchy of GAAP, this reference was removed in 2012.
As explained in the opening section, the EPSAS proposal conflates accrual accounting and budgetary surveillance. And, in a sense, the UK’s system does too: its accrual micro-budgeting is determined by accounting standards. The clear difference with the EPSAS proposal is that the UK’s accrual system is not only one of budgetary surveillance: it is one of budgetary control. To what extent the budgetary control system is cash-based and to what extent accrual-based is, however, not clear-cut:
The UK is alone [among France, Germany and the US] in explicitly introducing accrual-based information into the budget and the budgetary accounting. This distinction is unequivocal but the details are not necessarily always clear in UK practice. The purely cash-based system was retained and, since cash-based budgets appear alongside the accrual-based equivalents, there are important respects in which it could be assumed that significant decisions are still being taken with reference to the cash basis.(Jones et al., 2013, p. 435)
Complementing cash-based budgetary accounting with accrual-based numbers is very complicated. This is obviously a problem for national governments in a democracy, which are predicated on the centrality of politicians (in the legislature and the executive), who cannot be assumed to understand accrual budgeting and accounting. Whether managers of government departments can be assumed to understand is an open question. Of course, there are now (presumably) many people in the UK government who understand accrual-based information but whether, or to what extent, this understanding affects budgetary decision is not known by the literature.
We must now put all of this micro-budgeting and accounting into the much wider responsibilities of the Treasury in macro-budgeting (and accounting). Jones (2014) points out that no one appears to have – or if they have, do not appear willing to explain how they have – a comprehensive understanding of the relationship between government accounting and national accounting, and that at the heart of this lack of understanding is the lack of understanding of the relationship between ex-post measures of government income and wealth and ex ante measures. The UK system does provide large amounts of data, especially in its budget documents, concerning this relationship.6 Statistical measures as calculated in national accounting are shown on the budget. They are described as targets, but it is not clear whether the link between decisions taken on budgetary allocations and these targets is understood at all (Jones, 2000a).
The Whole of Government Accounts attempt to explain the connection between the figures disclosed in the financial reports and those derived from national accounts (HM Treasury, 2013a, Chapter 3). These data, however, are hard to understand from the outside and are not underpinned by any conceptual framework or set of rules. National accounts apply a framework driven by economic theory; and financial reporting applies its own framework based on accounting theory; but reconciliations of the two systems appear pointless and do not make much sense (Jones & Caruana, 2014). On the other hand, Heald and Georgiou (2011, p. 446) call for well-documented reconciliations to reduce the risk of accounting manipulation that would distort fiscal transparency.
5 Managing government financial risk
The UK system provides a set of annual audited accrual-based financial statements for the government as a whole; albeit not, as yet, in a timely fashion nor with an unqualified audit report. The utility of the UK’s Whole of Government Accounts in measuring and thus managing government financial risk can be viewed through the consolidation rules, the reported pension liabilities and the resulting negative equity.
The UK’s meta-consolidation uses the SNA’s concept of the reporting entity for government and provides discussion of how it is otherwise different from the SNA (HM Treasury, 2013a, Chapter 3).
The three Commonwealth countries that produce Whole of Government Accounts, that is, the UK, Australia and New Zealand, have all worked directly with IFRS at some point or another but attempt to converge these accounting requirements with national accounting requirements when it comes to consolidation (Grossi et al., 2009, p. 211). In spite of this, differences in the boundary of the reporting entity still arise between them, as pointed out by Heald and Georgiou (2011, p. 473). While it appears that Australia has made the boldest move by presenting SNA financial reports to Parliament and thus eliminating the need of these reconciliations (Barton, 2011).
In an attempt to make these reconciliations understandable, Annexes 1, 2 and 3 of the UK Whole of Government Accounts list the entities consolidated in the accounts; the entities not consolidated; and the minor entities that have been excluded from the consolidation (HM Treasury, 2013a, pp. 197–218). The Treasury justifies this limited consolidation boundary by stating that it is applying the same practices of the Office of National Statistics. The Auditor, however, does not appear happy with this consolidation exercise because it is not in line with IFRS requirements (HM Treasury, 2013a, pp. 185–187), being the latter the retained frame of reference that is expected to be applied.
With the help of these annexes, it is clear from the meta-consolidated balance sheet which assets and liabilities have been included and which debateable assets and liabilities have not. It is also clear that by following SNA concepts of consolidation, the meta-consolidated balance sheet is not as whole as it purports to be (Chow, Humphrey, & Moll, 2007, 2008; Heald & Georgiou, 2009, 2011).
5.2 Pension liabilities
Depending on the purpose for which a financial liability is acquired, it will be classified and accounted for either as a financial liability at fair value through profit or loss or as other financial liability, which will be accounted for at amortised cost (HM Treasury, 2013a, p. 56). The Treasury determines the classification of a financial liability. With particular reference to pension liabilities, given that it is the largest liability recorded in the UK Whole of Government Accounts,7 accounting for pensions can usefully be explained in more detail. There are three major kinds of schemes that have different relationships with Whole of Government Accounts.
The first kind is unfunded pension schemes within central government (e.g. civil servants, armed forces, but also the health service and teachers). The entities that employ the members of these schemes follow IAS 19 “Employee Benefits” as interpreted for the public sector by the Treasury: meaning that they are required to account for the contributions as being related to defined contribution schemes (HM Treasury, 2013b, p. 2, Chapter 12). The financial statements of the schemes themselves also follow IFRS and apply IAS 26 “Accounting and Reporting by Retirement Benefit Plans” as interpreted for the public sector context by the Treasury, with the result that they have no option but to disclose the actuarially determined present value of promised retirement benefits within the Statement of Financial Position (HM Treasury, 2013b, p. 4, Chapter 12). The financial statements of these schemes are consolidated in the Whole of Government Accounts.
The second kind of scheme, being the funded pension scheme, is, most notably, for local government (refer to Table 1). There are many such schemes, each for a group of local authorities, and all are, in principle, fully funded: meaning that they were often in their history fully funded but sometimes, by deliberate action ultimately of central government, the current funding fell below 100%. The net public sector pension liability of each of the funds is included within the accounts of the employing local authorities and consolidated in the Whole of Government Accounts (HM Treasury, 2013a, p. 108).
Finally, there is the state pension scheme (for the whole population) known as National Insurance. This is an unfunded scheme, the financial transactions of which are recorded in the National Insurance Fund. This fund is one of the core, cash-based funds of the central government, managed by the Treasury. The fund’s financial statements are consolidated in the Whole of Government Accounts but, since they are cash-based, liabilities for future state pensions are not included. Even if they could somehow be accrual-based, state pensions would need to be reported differently from the other pension schemes applicable to public sector employees, since state retirement pensions payable to the general public are outside the scope of IAS 19.
The assets and liabilities shown in Table 2 are calculated as required by accounting standards. The difference between the assets and liabilities should represent the total liability faced by the public sector, but, as described shortly, it does not fully reflect the effect of pensions on public finances in the future. The total pension liabilities reflect the net present value of the total liability owed to current pensioners, deferred pensioners (who are no longer in employment but will receive a pension on reaching retirement age) and current employees (entitled to a pension on retirement). The liability allows for salaries projected to retirement (or earlier leaving date), but only reflects the number of years of service to date. The liability does not reflect the pension that may be paid to current employees in respect of future years of service to retirement or to future employees (HM Treasury, 2013a, p. 19).
The value of the public service pension liability is also very sensitive to changes in assumptions that are inherently subject to significant uncertainty, for example, the rate of increase in salaries and pensions inflation and the discount rate.
The net pension liability of the government with regards to benefits for public sector employees is, therefore, estimated and reported in the Whole of Government Accounts and an explanation is given of how this, to some extent, understates the effect of pensions on public finances (HM Treasury, 2013a, pp. 18–19). Moreover, at the end of the day, any shortfall in the cash required to meet the payment of pensions is financed by the Exchequer (HM Treasury, 2013a, p. 103). The balance sheet of a government may resemble that of a financial institution but it is important to bear in mind that it is not (Newberry, 2011, p. 523). The Treasury’s role in managing financial risk is not satisfied through the Whole of Government Accounts. The framework assisting the Treasury’s role in managing the Government’s financial risk is wider than this and includes the Spending Reviews (that set departmental spending budgets over several years) and the Budget and estimates process (required to obtain the statutory authority to consume resources and spend cash) (HM Treasury, 2013a, pp. 28–29).
It is interesting to note that while the net liabilities in the Whole of Government Accounts include the net public service pension liability for the public sector employees, the National Accounts only recognise the cash payments and receipts associated with these pensions. The public service pension liability is not included in public sector net debt reported to Eurostat.
5.3 Negative equity
It is clear from the UK Whole of Government Accounts that there is very material negative equity:
The balance sheet [at end of 09-10], of course, discloses negative equity (described as “Total liabilities to be funded by future revenues”) – of £1,211,800,000,000.8 Since this equity balance includes £758,900,000,000 of non-current, non-monetary assets valued at current cost, future revenues probably have to be somewhat higher than £1.2tn.(Jones, 2012, p. 1 and p. 3)
6 Summary conclusion
The UK Treasury does recognise that the Whole of Government Accounts is not a substitute for the national accounts produced by the Office of National Statistics (HM Treasury, 2013a, p. 21). It emphasises that while they are complementary, the two systems have evolved independently of each other and refer to different international standards. The Treasury recognises that the two systems have been designed to suit different purposes:
While the National Accounts remain the measures used to assess the economic and fiscal position of the UK for policy purposes, WGA (Whole of Government Accounts) provides an accounting standards-based presentation to offer new insights into long-term sustainability, as well as presenting the figures in a format familiar to the commercial sector.(HM Treasury, 2013a, p. 21)
The Treasury also acknowledges the fundamental conceptual differences that exist between the two systems,9 which give rise to different figures of deficit and debts. However, the Treasury still endeavours to reconcile these figures (HM Treasury, 2013a, p. 22). Even though some academics regard such reconciliations as a must for fiscal transparency and accountability (Heald & Georgiou, 2011), the actual meaning of these reconciliations is rather opaque; their purpose could be to provide comfort to the two preparers involved rather than to have any useful purpose (Jones & Caruana, 2014). And how the EPSAS (transformed from IPSAS) will impact this situation is rather mind boggling as to the understandability of the ensuing information, its auditability and control purposes for budgetary surveillance.
When there is profound disharmony, it is not unnatural to yearn for harmony. When the disharmony is accompanied by profound differences in budgeting and accounting systems, it is not unusual for non-accountants to call for harmonised systems. It requires much technical knowledge and understanding of Anglo-American accounting to explain that this does not follow. On the basis of what has been written about EPSAS, the proposal shows a similar disconcerting lack of understanding of what Anglo-American accounting actually is. Independent standard setting of both financial reporting and auditing; and, consequently, an independent audit of financial statements complying with those financial reporting standards, which audit is carried out in line with auditing standards – these are the foundations of Anglo-American accounting. The EPSAS proposal is silent about these issues.
The expectation given by the EU Commission is that EPSAS will have both macro- and micro-purposes (Eurostat, 2013). The result that EPSAS will increase the reliability of national accounts is not something automatic. It is taken for granted that accrual-based financial statements are properly audited. This is what makes them a reliable source of information. But if these data are not used directly for national accounting and need to be turned around to fit national accounting standards – can you then rationally deduce that national accounting is reliable? (Jones & Caruana, 2014) Is national accounting itself being audited? To what extent is it audited or could be audited, and by whom? (Jones, 2003)
The dominance of national accounting over government accounting is apparent from the feedback received by Eurostat on its public consultation regarding the suitability of the IPSAS for EU member states and the resulting EU Commission’s report (Eurostat, 2013). This is understandable for EU member states like the UK, given that this statistical reporting is loaded with value (Jones & Caruana, 2014). While Barton (2011) gives various other reasons why all governments should use government finance statistics for their decision making.
Government accounting is a social and institutional practice, like other types of accounting, and is therefore a product of rational calculations of costs and benefits by self-interested stakeholders (Hopwood & Miller, 1994). The choice of accounting policies by governments can be studied as the result of political and market processes, as in private sector accounting (Watts, 1992). The implementation of new accounting practices in the public sector is intended to improve productivity and efficiency, but the emphasis is always directed to the symbolic power and legitimation roles of accounting information (Carpenter & Feroz, 1992). Once again, this is manifest in the “logic” of EPSAS, which seems to have emerged from a financial crisis. The apparent failure of statisticians is pushing them to seek legitimacy through accounting10 – an institution established by the accountancy profession. While statistics cannot be described as a profession, the standards employed enjoy legal backing, and it is thus trying to urge accounting to take certain approaches that are not in line with accounting principles and objectives. Resistance would be the expected reaction from the accountancy profession given that accounting has always been primarily to control people’s behaviour (Jones, 1992).
An accrual accounting system may help improve financial reporting for public sector entities at micro-level. The publication of financial statements of the various public sector entities could improve accountability and transparency. The UK Whole of Government Accounts is a meta-consolidation, that is, a consolidation of consolidated financial statements. The fact that the UK does not publish financial reports consolidated at central government level perhaps indicates that macro-fiscal considerations are more important than accountability (Heald & Georgiou, 2011, p. 473). For the government practitioner in an EU member state, rules emanating from the EU would naturally have such focus and any potential advantages of an accrual accounting system at micro-level may not be fully appreciated. Moreover, the EPSAS do not cover budgeting; so what purpose could they serve for control at micro-level?
Jones et al. (2013, p. 438) conclude:
it is to be hoped that harmonisation … of government budgeting and accounting is not a necessary part of the resolution of the … eurozone crisis – because, in the light of our research … the likelihood of harmonisation of national government budgeting and accounting any time soon beggars belief.
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