Tender process for the statutory audit

The path to a new auditor

The path to a new auditor Guidelines and best practices for the tender process for the statutory audit

For whom is this guideline relevant?
  • Your company is required by the Financial Market Integrity Strengthening Act (Gesetz zur Stärkung der Finanzmarktintegrität – FISG) to rotate its auditor at intervals of no more than 10 years.
  • You are a member of the Supervisory Board/ Audit Committee and are responsible for the selection of the auditor.
  • You are the project manager for the tender process for the statutory audit of your company's financial statements.
  • You would like to rotate your auditor voluntarily.

Requirements for the tendering of the statutory audit

With the entry into force of EU Regulation 537/2014 (EU Regulation) in 2016, extensive rotations in the audit of financial statements of public interest entities could be identified, not least due to further regulation under FISG in 2021.

As a result, we notice that not only public interest entities are complying with the requirements, but also an increasing number of entities are choosing a transparent and non-discriminatory tendering process and following the explicit requirements of the EU Regulation that do not fall within the definition of a public interest entity.

Strict requirements for public interest entities

After the audit requirements came into force with the effectiveness of EU Regulation 537/2014 (EU Regulation) on June 17, 2016, the maximum term of 10 years must be observed for public interest entities. While there was still the possibility for individual companies to extend the duration by further 10-14 years when the EU Regulation came into force, the maximum term is fixed at 10 years at the latest with the introduction of FISG in 2021.

Voluntary tendering process for the statutory audit

Besides the statutory obligation to rotate the statutory auditor, entities have various reasons for rotating auditors at regular intervals. The main reasons are as follows:

  • Specifically imposed regulations for compliance with auditor independence requirements
  • Ensuring the quality of the audit and thus increasing transparency and trust within the company
  • Pressure from associates and shareholders
  • Dissatisfaction with the current statutory auditor

Entities, which by definition are not public interest entities, have increasingly conducted their tendering procedures in accordance with the above-mentioned EU regulation.

Key challenges at a glance

Irrespective of the motives and the entities, there are, in our view, important aspects that need to be considered when tendering for a statutory auditor. In the course of numerous projects accompanied by PAS consultants, a best practice approach has been developed which guarantees compliance with legal requirements and ensures a structured tendering process.

The cornerstones of a successful tender project are the strategy, resource and project planning as well as the assessment of the status quo, which is followed by the detailed preparation of tender documents and the actual selection procedure.

Due to the process steps to be taken into account, the tendering process for the statutory audit is usually a project lasting several months, which requires both, internal and (in the case of consulting support) external capacities. In many cases, the project has to be initiated years before the actual rotation of the auditor in order to comply with independence requirements (cooling-in period).

For a purposive project implementation, identifying all stakeholders and developing a common strategy is therefore crucial at the beginning of the selection process.
From our point of view, the following questions must be answered at the beginning of the project:

  • Within what time frame do we have to make a decision
  • How do we ensure compliance with all legal requirements?
  • What resources can and must we draw on during the tendering process?
  • Who is responsible for the operational implementation of the tendering process?

Our experience shows that, depending on the company, the tender process for the statutory audit must be approached at an early stage in order to ensure compliance with the statutory independence requirements and to have sufficient time available for a qualitative tendering process. This applies in particular to cases in which not only the audit of the financial statements of the public interest entity is subject of the tendering process, but at the same time any audits of the entire Group, including further audit and assurance services. The same applies in particular to group structures in which various public interest entities are located in different EU countries.

Our recommendation:
Start elaborating your strategy at an early stage and consider sufficient time for the tendering process. Make sure that the strategy is anchored within the project group.
The success of the project depends on detailed resource and project planning throughout the entire project duration. For efficient and, above all, successful project management, it is therefore crucial on the part of the company that it succeeds in achieving the objectives set out in the strategy within the timeframes specified by the company.

Central pillars of the tendering process, especially for public interest entities, are the meetings of the Audit Committee and the Supervisory Board, which are responsible for the main decisions of the tendering process. In most cases, the boards will not have sufficient personnel resources of their own to carry out the tendering and selection process themselves, with the result that a project group is usually established via the Executive Board for operational execution.

Although the resources and scheduling of the bodies for project planning are to be considered as the cornerstones, the resources for operational implementation are no less important for the project. For the tendering process, comprehensive tender documents must be developed and prepared to enable a transparent and non-discriminatory procedure. In particular, the quotations from potential auditors are of higher quality and more targeted if the information provided is of the highest quality.
Our recommendation:
Ensure sufficient resources at the outset of the tendering process and plan the entire tendering process in detail from the beginning. Ensure that the decision-making bodies as well as the project group are adequately informed about the process and the requirements.
Before the actual selection steps of the process take place, a great deal of information about the entity must be collected, selected and processed. This is the only way to ensure that, on the one hand, the legal requirements regarding the content of the tender documents can be met and, on the other hand, that the future auditor obtains a more detailed understanding of the entity and its business activities. Finally, the information should enable comprehensible and comparable calculation of the audit fee across all quotations on the basis of the audit and assurance services to be performed.

While large companies have a variety of systems with different data sources, growing companies usually do not yet have ERP systems or have only recently implemented them. Both present challenges to information gathering.

Since it is not uncommon for the tender to require information that is not kept in the ERP systems, it should be ensured right at the beginning of the project how the necessary information can be consolidated. New system queries or reporting packages can be considered, especially in the case of multinational corporations. At the same time, it must be taken into account that non-financial information is also very important and must be collected in good time. Experience has shown that this relates in particular to information on required audit and assurance services within the corporate group and their legal requirements, as well as software solutions used decentrally in the financial area. These are usually not managed and maintained in uniform group systems.
Our recommendation:
When carrying out the tendering project, the necessary information should already be defined at the beginning to ensure timely consolidation. In doing so, use the newly gained knowledge about possible weaknesses and inconsistencies in your information landscape!

The approach of PAS Financial Advisory AG

PAS is an independent consulting firm for topics along the CFO agenda. We offer audit know-how, but do not provide statutory audits of financial statements. As a result, you cannot find a more objective and experienced advisor for the tendering process than us.

Your advantages at a glance:

  • Absolute objectivity – We find the right auditor for your company.
  • Market overview – From numerous tendering projects, we know the prices, approaches and strategies of large and medium-sized audit firms.
  • Process experience – We guide you effectively and efficiently to the appointment of the new auditor.
  • Professional know-how – We know all legal requirements and best practices.
  • Auditor's perspective – We know the tendering processes from the auditor's side and know what information is needed for a professional process.
  • Access to our database – Self-developed, field-tested tools, presentation templates and other templates are at your disposal.
  • Resource-saving – With us, your day-to-day business does not have to rest in favor of the tender project.

Our solutions for your tender project

We will be happy to assist you with your audit tender with a customized proposal from the following categories:


In addition to project management, we take care of the preparation of all tender documents, prepare the basis for your decision and support you in contract and fee negotiations.

On Demand

We support you in actively designing the tendering process of pre-agreed process steps from our service catalog (PMO, strategy to decision). Task packages can be extended at any time as required.
Quality assurance – We accompany you in complying with the legal requirements of the tendering process and ensure that the process corresponds to an efficient and high-quality procedure. We are your qualitative sparring partner.

Quality assurance

We accompany you in complying with the legal requirements of the tendering process and ensure that the process corresponds to an efficient and high-quality procedure. We are your qualitative sparring partner.

Project management

We take over the project management on the basis of a jointly designed project plan and ensure compliance with budgets and milestones.
We make the difference in your tender and generate real added value.

Go Beyond Your Opportunities!
If you have any questions, please contact our specialists at any time!
Contact us
Florian Görg
Manager Financial Reporting