ISA 520 (adopted via IBR-IRE) · Belgium

Analytical Review Tool — Belgium

Perform ISA 520 analytical procedures aligned with FSMA and IBR-IRE expectations, tailored to the Belgian bedrijfsrevisor/reviseur d'entreprises framework and Belgian GAAP considerations.

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The Auditor's Guide to Analytical Procedures Under ISA 520

Complete guide: ISA 520 requirements quick reference, decision flowchart for when to use analytical procedures vs. tests of details, industry-specific ratio checklists for 12 sectors, threshold-setting guide by risk level, sample completed working paper, common quality-review findings, and documentation checklist.

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Analytical Review Under ISA 520 in Belgium

Belgium has adopted ISA 520 Analytical Procedures as part of its auditing standards framework, implemented through the Instituut van de Bedrijfsrevisoren / Institut des Réviseurs d'Entreprises (IBR-IRE). The Belgian statutory auditor — the bedrijfsrevisor (Dutch) or réviseur d'entreprises (French) — is required to perform analytical procedures in accordance with ISA 520 as adopted for use in Belgium. The adoption of ISAs in Belgium follows the EU framework for statutory audit, with the IBR-IRE responsible for standard-setting and the Autorité des Services et Marchés Financiers / Autoriteit voor Financiële Diensten en Markten (FSMA) providing oversight of audit firms that audit PIE entities. Belgium's bilingual regulatory framework (Dutch and French) requires auditors to navigate standards and guidance published in both languages. The Belgian statutory audit framework is governed by the Code des Sociétés et des Associations / Wetboek van Vennootschappen en Verenigingen (CSA/WVV), which establishes mandatory audit thresholds and defines the scope of the auditor's reporting obligations. The bedrijfsrevisor/réviseur d'entreprises has responsibilities that extend beyond the financial statement audit, including reporting on contributions in kind, mergers and demergers, and the financial plan for newly incorporated entities, each of which may involve analytical review techniques.

FSMA and IBR-IRE Quality Oversight

The FSMA exercises oversight of audit quality for PIE audits in Belgium, while the IBR-IRE's quality review programme covers non-PIE audit engagements. Both oversight bodies have identified analytical procedures as an area where Belgian audit quality can be strengthened. The FSMA's annual transparency reports on audit quality highlight findings from its inspection programme, and analytical procedures feature as a recurring area of concern. Common findings include the following themes. The auditor's expectation is not always developed with sufficient rigour or documented with sufficient clarity to demonstrate that the procedure would be capable of identifying material misstatements. The threshold for investigating differences between expected and recorded amounts is not consistently established before the procedure is performed. The investigation of differences that exceed the threshold does not always include adequate corroboration of management explanations through independent evidence. The IBR-IRE's quality review programme (contrôle de qualité / kwaliteitscontrole) applies to all bedrijfsrevisoren/réviseurs d'entreprises and examines a sample of audit files to assess compliance with auditing standards. The IBR-IRE's quality review findings are communicated to individual auditors and, in aggregated form, to the profession. The IBR-IRE also provides continuing professional education and practice guidance to help Belgian auditors improve the quality of their analytical procedures.

Belgian GAAP Framework Considerations

Belgian entities that report under Belgian GAAP apply the accounting requirements set out in the Arrêté Royal du 30 janvier 2001 (Royal Decree on annual accounts) and the advices of the Commission des Normes Comptables / Commissie voor Boekhoudkundige Normen (CNC/CBN). Belgian GAAP differs from IFRS in several respects that affect the design and interpretation of analytical procedures. The Belgian chart of accounts (plan comptable minimum normalisé / minimum genormaliseerd rekeningstelsel) prescribes a standardised account structure that facilitates comparative analysis but produces financial statements with a different presentation than IFRS. Key Belgian GAAP characteristics that affect analytical review include the treatment of formation expenses (which may be capitalised and amortised under Belgian GAAP), the prohibition on revaluing financial assets to fair value for most entities, the detailed rules for provision recognition under Belgian GAAP that are more prescriptive than IAS 37, and the impact of the notional interest deduction (notionele intrestaftrek / déduction pour capital à risque) on the relationship between equity, tax, and profitability. Auditors performing analytical procedures on Belgian GAAP financial statements must develop expectations that reflect these framework-specific measurement and presentation rules, and must avoid applying IFRS-based assumptions to Belgian GAAP data.

Practical Considerations for Belgian Audits

Belgian auditors have access to several independent data sources that support the development of precise analytical expectations. The Banque Nationale de Belgique / Nationale Bank van België (BNB/NBB) operates the Centrale des Bilans / Balanscentrale, which collects and publishes annual accounts filed by Belgian entities. This database provides aggregated financial statistics by sector, size, and region, enabling auditors to benchmark entity performance against industry norms with considerable granularity. The BNB/NBB also publishes macroeconomic forecasts, business confidence surveys, and credit conditions data that serve as forward-looking inputs for analytical procedures. The Bureau fédéral du Plan / Federaal Planbureau provides medium-term economic projections for the Belgian economy. Statbel (the Belgian statistical office) publishes consumer price indices, industrial production data, and employment statistics. For audits of Belgian entities with cross-border operations in the Benelux region, analytical procedures should consider the economic interdependence of Belgium, the Netherlands, and Luxembourg, including shared trade patterns and coordinated regulatory developments. The IBR-IRE has published practice notes addressing the application of analytical procedures in the Belgian audit context, including guidance on the use of the Centrale des Bilans data for benchmarking purposes and the integration of data analytics into the analytical review process.

Common Inspection Findings — FSMA (Financial Services and Markets Authority) / IBR-IRE (Institute of Registered Auditors)

The following are typical findings from FSMA (Financial Services and Markets Authority) / IBR-IRE (Institute of Registered Auditors) inspections relating to analytical procedures:

Auditor's expectation not developed with sufficient rigour — reliance on general entity knowledge rather than quantified expectations based on identified data relationships

Investigation threshold for analytical differences not established before performing the procedure, reducing the objectivity of the assessment

Insufficient corroboration of management explanations for significant differences — auditor accepted explanations without obtaining independent supporting evidence

Documentation does not clearly demonstrate the data sources, assumptions, methodology, and conclusions underlying the analytical procedure

Local Standard: ISA 520 (adopted via IBR-IRE)
Regulatory body: FSMA (Financial Services and Markets Authority) / IBR-IRE (Institute of Registered Auditors)

Frequently Asked Questions — Belgium

How has Belgium adopted ISA 520 for statutory audits?
Belgium adopted ISA 520 as part of the ISA framework implemented through the IBR-IRE. The standard applies to all statutory audits performed by bedrijfsrevisoren/réviseurs d'entreprises. The adoption follows the EU framework for statutory audit, and ISA 520 as applied in Belgium is consistent with the international version. The IBR-IRE has supplemented the standard with practice guidance addressing Belgian-specific considerations, including the use of Centrale des Bilans data and the impact of Belgian GAAP on analytical expectations.
What have FSMA and IBR-IRE quality reviews found regarding analytical procedures?
Both the FSMA (for PIE audits) and the IBR-IRE quality review programme (for non-PIE audits) have identified recurring deficiencies. These include insufficient rigour in developing the auditor's expectation, failure to set investigation thresholds before performing the procedure, inadequate corroboration of management explanations for significant differences, and documentation that does not clearly demonstrate the auditor's thought process and conclusion. Both bodies have required firms to implement remediation measures.
How does the Centrale des Bilans support analytical procedures in Belgian audits?
The BNB/NBB Centrale des Bilans collects annual accounts filed by all Belgian entities and publishes aggregated financial statistics by NACE sector code, entity size, and geographic region. Auditors can use this data to benchmark key financial ratios, revenue trends, and cost structures against industry peers, providing an independent basis for developing analytical expectations. The database is particularly valuable because Belgian filing requirements ensure comprehensive coverage of the Belgian corporate landscape.
What Belgian GAAP features affect the design of analytical procedures?
Belgian GAAP features that affect analytical review include the capitalisation and amortisation of formation expenses, the historical-cost basis for most financial assets, prescriptive provision recognition rules, the impact of the notional interest deduction on profitability ratios, and the standardised chart of accounts that determines financial statement classification. Auditors must develop expectations that reflect these Belgian GAAP measurement bases rather than applying IFRS assumptions. The treatment of subsidies, investment grants, and deferred taxes under Belgian GAAP also creates specific patterns that differ from IFRS.
How does Belgium's bilingual framework affect audit documentation of analytical procedures?
Belgium's bilingual (Dutch and French) regulatory and business environment means that audit documentation must be maintained in a manner that is accessible to the relevant oversight body. The IBR-IRE publishes standards and guidance in both languages, and audit firms may maintain files in either language depending on the location and language of the entity. The underlying analytical data, including Centrale des Bilans benchmarks and BNB/NBB statistics, is published in both languages, ensuring that auditors working in either linguistic community have equal access to relevant data sources.