IESBA Opens Post-Implementation Reviews of NOCLAR Standard and Restructured Ethics Code
The International Ethics Standards Board for Accountants (IESBA) launched two stakeholder surveys on 1 April 2026 to assess how its Non-Compliance with Laws and Regulations (NOCLAR) standard and the Restructured Code are working in practice. The results will shape whether the board takes further action on either standard, making participation directly relevant for accounting firms, auditors, and CFOs who operate under the IESBA Code globally.
What IESBA Is Reviewing and Why
The NOCLAR Standard
The NOCLAR provisions set out how professional accountants in public practice and in business should respond when they become aware of actual or suspected non-compliance by a client or employer. Because the standard sits at the intersection of professional ethics, whistleblowing obligations, and legal privilege, it has attracted varied feedback since adoption. The post-implementation review is designed to test whether those provisions are operating as intended in the public interest.
The Restructured Code
The Restructured Code reorganised the IESBA Code into a clearer, more navigable format without substantively changing its requirements at the time of restructuring. The survey will assess whether that restructuring has achieved its usability goals and whether any gaps or unintended consequences have emerged during implementation.
How the Surveys Work
Scope of Stakeholder Input
IESBA is seeking input from a broad range of stakeholders: audit and assurance practitioners, professional accountants in business, regulators, standard-setters, and those responsible for ethics oversight within firms. The surveys are designed to gather evidence on real-world application rather than theoretical compliance.
What the Findings Will Drive
The board has been explicit that survey insights will feed directly into its assessment of whether further standard-setting action is needed. That could mean targeted amendments, additional guidance, or a conclusion that the current text is sufficient. Firms that respond shape that outcome; firms that do not respond leave it to others.
Relevance to Crypto-Asset Accounting and Reporting
At first glance, a review of professional ethics standards may seem distant from the practical questions firms face around crypto financial statements, whether under IFRS crypto assets rules or the FASB crypto fair value model introduced by ASC 350-60. The connection is closer than it appears.
NOCLAR in a Digital Asset Context
Accountants working on crypto-asset engagements regularly encounter situations where client behaviour may breach tax law, AML rules, or securities regulation. The NOCLAR standard governs exactly how those situations must be handled, from internal escalation through to possible disclosure to a regulator. If the post-implementation review reveals that NOCLAR is not functioning well in practice, any amendments could alter the duties of practitioners dealing with crypto-related non-compliance. Staying informed is not optional for firms with digital asset clients.
Code Usability and Ethics Infrastructure
Crypto-focused advisory and audit teams often operate under tight resource constraints. The Restructured Code review is an opportunity to flag whether the current architecture creates confusion in multi-jurisdictional engagements, including those involving crypto us gaap accounting alongside IFRS treatment. If your firm has encountered inconsistencies, this is the channel to raise them.
For firms building out their ethics and compliance infrastructure alongside digital asset accounting software or broader crypto bookkeeping software implementations, the IESBA review cycle is part of the professional standards landscape they operate within. Tracking the IFAC 2026 International Education Standards update alongside this IESBA review gives a fuller picture of how the global accountancy standards ecosystem is evolving.
Practical Steps for Firms
Engage With the Surveys
Both surveys are live and open to responses. Firms should assign a responsible partner or ethics officer to review the survey questions and coordinate a response. Given the global scope of the IESBA Code, even firms primarily focused on domestic standards will be affected if the NOCLAR provisions or the Code architecture changes.
Document Your Current NOCLAR Procedures
The survey will likely prompt reflection on existing internal processes. Use it as an opportunity to audit whether your NOCLAR response procedures are documented, up to date, and understood by staff working on crypto-asset engagements, where the regulatory landscape, including AML and tax obligations, is still evolving rapidly.
Monitor the Review Timeline
Post-implementation reviews at IESBA typically follow a structured timeline from survey through analysis to a board-level conclusions paper. Firms should add this to their standards-monitoring calendar. Any changes that emerge would feed through to national standard-setters that adopt or reference the IESBA Code, amplifying the eventual impact. This mirrors the kind of structural monitoring firms already conduct for tax treaty developments, such as EU Pillar 2 qualified status confirmations that carry downstream compliance consequences.
Frequently Asked Questions
What is the NOCLAR standard?
NOCLAR stands for Non-Compliance with Laws and Regulations. It is a set of provisions within the IESBA Code that guides how professional accountants should act when they encounter or suspect that a client or employer has breached applicable laws or regulations. It covers both practitioners in public practice and those working in business roles.
Why is IESBA conducting this review now?
Post-implementation reviews are a standard part of the IESBA standard-setting cycle. They allow the board to assess real-world effectiveness after a standard has been in force long enough to generate meaningful practitioner experience. The 1 April 2026 launch indicates the board considers sufficient time has passed for substantive feedback to be gathered.
Who should respond to the surveys?
IESBA is seeking responses from a wide stakeholder base, including audit practitioners, professional accountants in business, ethics and compliance officers, regulators, and standard-setters. Accounting firms of all sizes with international or multi-jurisdictional client bases have a particular interest in participating.
Could the review lead to changes in the NOCLAR provisions?
Yes. IESBA has stated that survey insights will inform its assessment of whether further action is required. That action could range from no change through to targeted amendments or new guidance. The review is therefore a live standard-setting input, not a formality.
How does this affect firms handling crypto-asset clients?
Practitioners advising on or auditing crypto-asset holdings operate in an environment where regulatory non-compliance risks, including tax, AML, and securities law, are elevated. The NOCLAR standard directly governs how those situations must be handled. Any amendments arising from this review will apply to those engagements, making it important for crypto-focused practices to follow the review closely and consider submitting a response.
Source: IESBA