Review of amendments to the Law on Auditing

July 25, 2025

The Law of the Republic of Belarus No. 95-Z “On Amendments to the Law of the Republic of Belarus “On Auditing” was adopted on July 14, 2025.

The main amendments to the Law on Auditing (hereinafter – “the Law”) are as follows:

The definition of audited entities has been clarified:

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New version

audited entities are legal entities established in accordance with the legislation of the Republic of Belarus, their branches, representative offices and other separate divisions with a separate balance sheet, representative offices of foreign and international organizations, holding companies, simple partnerships (parties to a joint venture agreement), individual entrepreneurs and other persons in respect of whom accounting and (or) financial statements are audited and (or) other audit services are provided (hereinafter, unless otherwise specified, – audit services)

audited entities are legal entities established in accordance with the legislation of the Republic of Belarus, their separate divisions, representative offices of foreign legal entities and other organizations registered in accordance with the established procedure in a foreign country, branches of foreign legal entities, holding companies, simple partnerships (parties to a joint venture agreement) and other persons in respect of whom accounting records and (or) financial statements are audited and (or) other audit services are provided (hereinafter, unless otherwise specified, -audit services)

Thus, the main changes are:

the categories of foreign organizations have been clarified:

- representative offices of foreign and international organizations were mentioned earlier;
- now they are more specifically stated: representative offices of foreign legal entities and other organizations registered in accordance with the established procedure in a foreign country, as well as branches of foreign legal entities.

individual entrepreneurs are not named;
the list of separate divisions has been expanded:

- it was previously clarified that they should have a separate balance sheet;
- this requirement has been eliminated in the new version.

The powers of the Council of Ministers of the Republic of Belarus to regulate auditing activities have been supplemented by the following paragraphs, now the Council of Ministers also:

approves the regulations on business (professional) reputation;
establishes the specifics of the provision of audit services in relation to providing additional protection of information about the activities of organizations of special economic importance to the Republic of Belarus and included in the list determined by the Council of Ministers of the Republic of Belarus.

In accordance with the new version of paragraph 4 of article 5 of the Law, the National Bank has the right to request information necessary to perform its functions in the field of auditing:

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from the Audit chamber, audit organizations, and auditors – individual entrepreneurs engaged in auditing activities in banks, banking groups and bank holding companies	from the government agencies, the Audit chamber, auditors, auditing organizations, and auditors – individual entrepreneurs engaged in auditing activities in banks, banking groups and bank holding companies

Regarding the powers of the Ministry of Finance of the Republic of Belarus to regulate auditing activities in terms of requesting information necessary to perform its functions in the field of auditing, the amendments to the Law are as follows:

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The Ministry of Finance has the right to request information necessary for the performance of its functions in the field of auditing from the Audit chamber, audit organizations, auditors – individual entrepreneurs, other legal entities and individual entrepreneurs.	The Ministry of Finance has the right to request information necessary to perform its functions in the field of auditing from government agencies, the Audit chamber, audit organizations, auditors, individual entrepreneurs, other legal entities and individual entrepreneurs, auditors and individuals applying for an auditor’s qualification certificate.

Thus, in the new version of the Law, the Ministry of Finance has the right to request information from:

the government agencies;
auditors (not only Sole Proprietor auditors- individual entrepreneurs);
individuals applying for an auditor’s qualification certificate.

Paragraph 2 of article 7 of the Law has been amended which concerns the requirements for an auditor to have the right to participate in auditing activities:

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2. An auditor has the right to participate in auditing activities from the date of inclusion of information about them in the audit register and loses this right from the date of exclusion from the audit register. An auditor who is registered with healthcare organizations in connection with a mental disorder (illness), alcohol dependence syndrome (alcoholism), narcotic drugs or psychotropic substances (drug addiction), substance abuse or who has an outstanding or outstanding criminal record for crimes against the interests of the service, property and the conduct of economic activities, for commission of other crimes related to the use of official powers, has no right to participate in the implementation of auditing activities or to carry out auditing activities.

2. An auditor has the right to participate in auditing activities from the date of inclusion of information about them in the audit register and loses this right from the date of exclusion of this information from the audit register. The auditor has no right to participate in auditing activities or carry out auditing activities if he or she:

— is registered with healthcare organizations due to a mental disorder (illness), alcohol dependence syndrome (alcoholism), narcotic drugs or psychotropic substances (drug addiction), substance abuse;

— does not meet the requirement of having an impeccable business (professional) reputation.

For the purposes of this Law, an auditor (an individual applying for an auditor’s qualification certificate) has an impeccable business (professional) reputation, which means that there is no outstanding or outstanding criminal record for committing serious or especially serious crimes, as well as for committing minor or less serious crimes provided for in articles 209–212, 222–228, 229, 231–241, 243–243³ , 252, 254, 255, 341¹, 342, 342² , 361–361⁵ , 369¹ –369³ , 373–375³ , 424–427, 429, 431–433 of the Criminal Code of the Republic of Belarus; absence of facts of bringing to administrative responsibility for the commission of administrative offenses provided for in articles 12.23, 12.24, 12.32, 13.3, 23.6 of the Code of the Republic of Belarus on Administrative Offenses, unless the deadline has expired after which the auditor (an individual applying for an auditor’s qualification certificate) is considered not to have been subjected to administrative penalties; absence of facts of acts discrediting the profession of an auditor and presence of a positive assessment by participants in civil turnover of the business (professional) qualities and business behavior of an auditor (an individual applying for an auditor’s qualification certificate) established in accordance with the regulation on business (professional) reputation approved by the Council of Ministers of the Republic of Belarus.

In order to carry out auditing activities, for an audit organization it is now necessary to have at least three (note — previously there were five) auditors on staff who are required to participate in the audit organization’s audit activities for whom this organization is the main place of work.
For an audit organization in order to provide audit services for conducting a mandatory audit of annual financial statements prepared in accordance with IFRS, it was previously necessary for an audit organization to undergo at least once every three years an external assessment of the quality of its work with a result that meets the criteria for providing audit services for conducting a mandatory audit of annual financial statements prepared in accordance with IFRS. The new version of the Law provides for an external quality assessment at least once every five years (note –previously it was three), but not earlier than one year after the inclusion of information about the audit organization in the audit register.
Audited entities, customers of audit services have the right to report violations of the legislation on auditing activities committed by the auditing organization, the auditor – individual entrepreneur, the auditor to the Ministry of Finance, the National Bank, the Audit chamber and other authorized bodies.
An individual with, among other things, an impeccable business (professional) reputation is allowed to be certified for the right to obtain an auditor’s qualification certificate.
The auditor’s failure to comply with the requirement of having an impeccable business (professional) reputation is the basis for the Ministry of Finance’s decision to cancel the auditor’s qualification certificate.

The amendments will enter into force on August 1, 2025 with respect to paragraphs 1-4, 7-10 of article 1, and with respect to paragraphs 5 and 6 of article 1 – on January 1, 2026. Other provisions of the Law of the Republic of Belarus No. 95-Z on July 14, 2025 “On Amendments to the Law of the Republic of Belarus “On Auditing” come into force after its official publication (17.07.2025).

The Council of Ministers of the Republic of Belarus has been instructed to ensure that the legislative acts are brought into line with the new Law by August 1, 2025.

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