Tag: #localgovernment

Councils should ‘comply or explain’ on governance code

ICAEW welcomes proposed statutory guidance that establishes a corporate governance code for local authorities in England, but says councillors need better training and support if they are to be able to hold leaders to account.

Financial collapses and major stresses in local government finances have led the government to undertake a major rewrite of the applicable statutory guidance, in effect establishing a corporate governance code for local authorities in England.

ICAEW has formally responded to welcome the proposed new guidance, while also making some recommendations for improvements.

The government is introducing the new guidance in response to a series of high-profile collapses of local authorities in England in which governance failures were identified as a common feature, as well as an increasing number of local authorities reporting that they are in financial difficulty or at risk of being so.

Local authorities in Thurrock, Woking and Croydon are together estimated to have lost local and national taxpayers in excess of £1bn, with their communities adversely affected by significant cuts to local public services and higher council tax bills. Central government has also stepped in to provide additional funding and loans, some of which are unlikely ever to be repaid.

The proposed guidance technically relates to the ‘best value duty’, a legal obligation placed on specified public sector bodies, including local authorities, to have arrangements in place to secure continual improvement in how they carry out their work. Relevant public bodies are required to have regard to any statutory guidance issued by the government in deciding how they comply with this duty.

As the proposed guidance acknowledges, meeting the best value duty will only be possible if councils have adequate governance arrangements in place. It goes on to set out a series of characteristics of well-functioning authorities, as well as indicators of potential failure, covering continuous improvement, leadership, governance arrangements, culture, use of resources, service delivery, and partnerships and community engagement.

Accountability is not accidental

ICAEW has suggested a need for accountability events. These should include a formal presentation on financial performance and position each year by leaders and officers to councillors within four months of the end of the financial year, and proper consideration and adoption by full council of the annual financial report once the external audit is completed. The latter should cover the financial statements and accompanying narrative reports on financial performance and position, audit reports, and statements on governance arrangements; regard for the statutory guidance on best value duty; and responsibilities for the preparation of the financial statements and internal financial control.

ICAEW has recommended a ‘comply or explain’ approach when local authorities report on how they have had regard to the guidance. This would provide clarity on how local authorities have set about applying the guidance, where they have chosen to diverge, and where they have been unable to comply.

A feature of recent failures has been inadequate accountability, with councillors not being properly equipped to hold leaders and officers to account for unwise debt-leveraged investment strategies, poor individual financial decisions, and inadequate governance arrangements. In most cases councillors were not fully aware or did not fully understand the scale of the risks that were being assumed and the consequent financial implications for their local communities. ICAEW’s response stresses that councillors need sufficient training, information and support to undertake this role.

ICAEW has separately submitted evidence to the House of Commons Levelling Up, Housing and Communities Select Committee on how local authority financial statements must be understandable if they are to provide the information councillors need to hold their local authorities to account and to be used effectively in governance and risk management processes.

Good governance is critical

The proposed guidance stresses the importance of good governance and strong financial management, providing a useful framework for local authorities in how they set about ensuring they have appropriate governance arrangements in place.

However, the proposed guidance does not make it clear that performance management should include monitoring and management of the balance sheet and financial risks, a feature that was missing in recent local authority failures that saw debt-leveraged investments significantly increase balance sheet risk.

ICAEW’s response also highlights the role that internal audit can play in assuring governance arrangements are in place, while noting that local councillor codes of conduct will need to be updated to reflect the new guidance.

The role of the audit committee is extremely important to an effective system of governance, and ICAEW calls for the government to legislate, as promised, to require independent members of local authority audit committees.

Alison Ring OBE FCA, ICAEW Director for Public Sector and Taxation, commented:

“We are very pleased that the government has recognised the need for a corporate governance code for local government in the form of new statutory guidance on the best value duty. This is particularly welcome in the light of recent financial collapses at Thurrock, Woking and Croydon that together have cost local and national taxpayers in excess of £1bn, as well as increasing levels of financial stress on local authorities across England.

“We believe that accountability does not happen by accident. There is a need for regular accountability events covering financial performance and the annual financial report as well as budgets, for a ‘comply or explain’ approach to reporting on how the best value duty guidance has been implemented, and for councillors to be properly equipped with the training, information and support they need to hold leaders and officers to account.

“Good governance is essential if local authorities in the UK are to ensure they obtain value for the more than £200bn of public money they spend each year on our behalf.”

Read ICAEW’s response to the consultation here.

This article was first published by ICAEW. The article, and the consultation response it refers to, were written by Martin Wheatcroft of behalf of ICAEW.

Spotlight on local audit also shines on the accounts

Alison Ring, ICAEW Director Public Sector and Taxation, says we must take a once-in-a-generation opportunity to fix long-standing underlying problems with the way local government financial statements are used. 

There is a crisis in local government financial reporting and audit in England that urgently needs resolving. Some 74% of 2021/22 local authority financial statements were still not signed off after a year, 31% after two years, and some audited accounts are still not published from 2018/19 or earlier. These delays are not just a compliance issue – they are fundamental to how our local democratic institutions operate at a time when many authorities are struggling amid difficult economic conditions.

Getting local audits back on track must be the immediate priority, even if it will mean accepting some unpalatable measures, such as temporary relaxations in some audit requirements, or the postponement of new accounting standards. All parts of the system will need to compromise a little to unlock audit sign-offs, clear the backlog, and get the system up and running and sustainable again. 

However, the spotlight focused on local audit illuminates some uncomfortable truths about the underlying effectiveness of audited financial statements in ensuring that councils are well managed and public money is spent wisely. They are often not understood, not read by enough people, and not used by councillors and other stakeholders in holding local authorities to account, as part of governance processes or when approving major financial decisions.

Many of these problems were identified by the Redmond Review, but progress in addressing its recommendations is, perhaps inevitably, much slower than anyone would like. In the meantime, there have been several well-publicised disasters as the financial tide has swept out to expose the naked vulnerability of some local authorities.

Much more than an informative read

Done well, financial statements are much more than an informative read that sets out the story of the most recent financial year. They are a multi-purpose tool for accountability, governance, risk management, strategic decision-making, regulatory and system oversight. They are also the apex of the system of internal financial control and the vehicle through which external assurance is delivered.

The trouble is that financial statements can only serve these purposes if they are read, understood, and actively utilised in each of these roles. When I hear that “nobody reads the accounts” I start to worry. Even though I know this is an exaggeration and that many people do of course read the annual financial report, the implication is that accounts are not being used to their full extent.

This poses some big questions. Are councillors able to properly hold their local authority and its management team to account if they aren’t actively using the principal tool designed to help them do so? 

Are governance committees able to ensure their local authority is well run if they aren’t using the official document that brings together the effects of thousands of financial decisions made every year into a single assured report that summarises financial performance as well as the end-of-year financial position? 

Are they able to assess the effectiveness of risk management if they aren’t looking at the balance sheet and the financial exposures disclosed in the notes to the financial statements? 

Where decisions are being made, are council leaders, cabinets, officers, and management teams able to make effective strategic choices, potentially transforming their balance sheets, if they aren’t starting from the foundation provided by the audited financial statements? 

Are DLUHC and other government departments, including HM Treasury, able to make good funding decisions, or assess the effectiveness of the overall system of local government in England, if they aren’t reading the accounts in some detail? 

Finally, how can the preparation of financial statements be a key factor in promoting financial control if they lack the challenge of having an interested readership?

Of course, this is not the whole story. Unlike in the private sector where internal financial reports are confidential, a whole swathe of financial documents are in the public domain. 

Why would anyone need to read a long and complicated set of accounts when they have access to this other “more useful” stuff?

The answer is that in many cases councillors and other stakeholders can’t properly understand the budget or other financial information provided to them if they haven’t first read and understood the annual report and accounts, and the financial context in which decisions are being made.

“The accounts are impenetrable”

This brings us on to another point that I have also heard frequently, which is that a reluctance to read the accounts is forgivable given how long and complicated many local authority annual financial reports are – “impenetrable”, in the words of some. Given my own attempts to grapple with some local authority annual accounts, I have sympathy for this claim.

To get this system working better, financial statements and accompanying narrative reports need to be much more understandable, so more people read them and use them as the multi-purpose tool they should be.

These concerns about whether accounts are being used effectively is one of the reasons I am so pleased that the Levelling Up, Housing and Communities Commons Select Committee is conducting an inquiry into the purpose and use of local authority financial statements and external audit in England, to which ICAEW and others have given evidence. 

The committee is focusing on both the overall financial reporting and audit framework for local authorities in England as well as the immediate challenges of clearing the backlog of unaudited accounts.

A vision for local financial reporting and audit

To make the system work better we need everyone to agree on a clear vision for local financial reporting and audit, which is why ICAEW developed its own.

ICAEW’s vision is to bring confidence to the finances of local public bodies through a valued and thriving profession, high-quality understandable financial reports, high-quality timely local audits, strong financial management, good governance, value for money, and protecting the public interest. 

When we started this project, it reminded us that everything starts with the financial statements. Not because they are more important than high-quality timely external audits, strong financial management, good governance, or a proper system of accountability, but because they are the rock on which everything else stands. 

We need financial statements to be as understandable as they can be. We need them to be read. And – most importantly – we need them to be used.

This article was written by Martin Wheatcroft on behalf of ICAEW and was originally published in Room 151, an online news, opinion and resource service for local authority finance officers covering treasury, pensions, strategic finance, funding, resources and risk, and subsequently published by ICAEW.

ICAEW chart of the week: Public sector segments 2022/23

Our chart this week illustrates just how centralised the UK is by looking at the disparity between receipts and expenditure between central and local government.

Step chart for the financial year 2022/23, showing receipts of £1,018bn (first column) less expenditure £1,155bn (middle column) and deficit £137bn (last column). Central government: £931bn receipts - £919bn expenditure = £12bn surplus before intra-government transfers. Local government: £59bn receipts - £204bn = £145bn shortfall before transfers. Other public sector: £28bn receipts - £32bn expenditure = £4bn shortfall before transfers.

Most people living in the UK would be surprised to discover just how big a gap there is between the council taxes and other income received by local councils, police and fire authorities, and the amount that they spend on public services.

Our chart of the week illustrates this disparity by looking at public sector segments in 2022/23 and how receipts and expenditure match up, before taking account of intra-government transfers.

Fiscal reporting in the National Accounts is broken down into five segments, of which the two largest are central government and local government. The former includes UK government departments, the devolved administrations in Scotland, Wales and Northern Ireland, and several hundred government agencies and other public bodies. Local government principally consists of local authorities across the UK, the Greater London Authority and regional combined authorities in England, police and fire authorities in England and Wales, and local public transport bodies (the largest of which is Transport for London). The other three segments are public corporations (comprising publicly owned businesses plus social housing), funded pension schemes (mostly local authority schemes as central government schemes are generally unfunded), and the Bank of England.

The latest provisional numbers for the financial year ended 31 March 2023 reported that the UK public sector generated £1,018bn in receipts and incurred expenditure of £1,155bn, giving rise to a deficit of £137bn – a shortfall that has been funded by central government borrowing.

Central government raised £931bn in 2022/23 and spent £919bn, a net £12bn surplus before intra-government transfers. Local government received £59bn and spent £204bn, a shortfall of £145bn. And the three remaining fiscal segments together generated £28bn in receipts, and recorded £32bn in expenditure, a net shortfall of £4bn.

By excluding transfers in this way, the chart highlights just how centralised the UK state is, with local government dependent on central government largesse to pay for 69% of its spending in 2022/23. 

Local authorities received £41bn in council taxes and £18bn in non-tax receipts, with intra-government transfers amounting to £141bn, comprising £127bn in revenue grants and £14bn in capital grants. Transfers included a redistribution of £25bn in business rates, which although collected by local authorities are national taxes whose disposition is determined by central government. The rest came from a combination of block grants, subsidies, and specific grants (some of which councils need to bid for) as part of a complex and complicated web of funding arrangements for local authorities that makes them highly dependent on the decisions of government ministers.

After transfers there was a reported deficit of £137bn in central government and £4bn in local government, while £8bn in net transfers converted a £4bn shortfall between receipts and expenditure in the three other segments into a net £4bn surplus.

The big picture is of the most centralised state among medium and large economies in the developed world, with local authorities almost entirely dependent on the largesse of central government to fund the essential public services they deliver.

Distributing power to the devolved administrations in Scotland, Wales and Northern Ireland has started to see a share of national taxes dispersed (such as income tax in Scotland and Wales) and some limited tax-raising powers. This contrasts with the debate about devolution in England, which has primarily focused on structures with the partial creation of a regional tier of local government in the form of combined authorities, rather than on more fundamental questions of whether this very centralised system of funding for local authorities needs reform.

This chart was originally published by ICAEW.

IFRS 16: A lot of effort, but a great opportunity too

In an article for Room 151, ICAEW Public Sector Director, Alison Ring writes that bringing leases onto the balance sheet from 1 April provides council finance teams with a real “opportunity” to help councillors better understand the scale and scope of local authority finances.

The introduction of International Financial Reporting Standard 16 ‘Leases’ (IFRS 16) on 1 April 2022 will have a significant impact on many local authority balance sheets as well as require a huge effort from council finance teams.

Many finance officers will be glad just to get the work needed to comply with IFRS 16 done, but they should also grasp the opportunity to use the comprehensive review of contracts they are undertaking to educate council leadership teams and councillors on the scale and scope of the local authority finances they are responsible for.

Capturing lease contracts

IFRS 16 abolishes the distinction between off-balance sheet ‘operating leases’ and on-balance sheet ‘finance leases’ and brings almost all leases longer than a year onto the balance sheet. The deadline for public sector entities to become compliant with the standard is April this year, so local authorities need to ensure they are not caught out.

The purpose of IFRS 16 is to provide financial statement users with a better understanding of the resources available to an organisation by requiring assets utilised via contractual arrangements to be recorded on balance sheets alongside legally-owned assets. This will cover many leased office buildings, that will now need to be included in the primary financial statements, rather than being disclosed in the operating lease note towards the end of the accounts.

The standard captures most contracts that give the right to use an asset for a period of time of more than one year, as well as lease arrangements where that right is “embedded” into a larger contract. The latter was already the case for embedded rights that met the old criteria to be treated as finance leases, including many private-finance initiative contracts started a decade or two ago, but IFRS 16 means that other types of lease arrangement will need to be identified and—if they meet the criteria—capitalised as an asset and a related lease liability.

Identifying lease assets

In theory, finance teams should have all the information they need to calculate the amounts to record for both asset and liability sides of the balance sheet, as well as recording depreciation and interest in place of lease payments in the expenditure statement.

However, in practice there needs to be a thorough exercise to review thousands of contracts to see if they are leases or contain embedded lease arrangements that fall within the scope of IFRS 16.

In addition to office buildings, there will be a range of assets to identify, ranging from office equipment to vehicle fleets, to leased facilities and equipment. This is not just about reviewing the legal text of contracts, but also involves working with operating departments to understand whether there is a right to use an asset.

Fortunately, there are two main exemptions that should make this exercise easier, with contracts with a term of 12 months or less or below a de minimus value in the order of £3,500 excluded completely.

Unlike in the private sector, the requirement to revalue local authority assets within the balance sheet adds to the complications that finance teams face. This is in addition to the raft of information required for disclosure purposes, such as sub-leasing arrangements, sale and leaseback transactions and variable lease payments.

There will also be challenges in accounting for lease modifications, where a change to the original terms and conditions requires a reassessment of the carrying value for an asset and its associated lease liability, based on the new pattern of lease payments and discount rate.

Beefing up management controls

The good news is that this exercise, while onerous, has benefits too. Creating an inventory of contracts with key terms identified and understood provides a resource that can be used for other purposes, including controlling costs and monitoring financial exposures.

A more comprehensive understanding of the assets in use across the organisation will help in ensuring that resources are being fully utilised for the benefit of service users and council taxpayers.

Processes to vet new contracts for their accounting implications also provide an opportunity to beef up risk management controls. And there may be opportunities to renegotiate contract terms such as lease lengths and renewal options, or to identify contracts that are no longer needed and that can be dispensed with.

Just as importantly, IFRS 16 implementation provides finance teams with a real opportunity to educate council leadership teams and councillors on the finances of the organisations they are responsible for.

Not only is there a need to explain the accounting change and what this means for the financial statements, but the outputs of the implementation exercise can be used to help those charged with governance to better understand the scale and scope of contracting undertaken, the nature of the assets available to be utilised and, most importantly, the commitments and risks that have been made to suppliers and to service users.

There is a temptation to see IFRS 16 as a problem, and I can understand why yet another major compliance exercise may not be embraced with overwhelming enthusiasm. However, I believe that this particular problem is an opportunity – one that should definitely be grasped.

This article was originally published by Room 151.

Local authorities need to invest in finance teams

Alison Ring, ICAEW director for public sector, tells Room 151 that local audit reform is not enough on its own.

Alison Ring, ICAEW director for public sector, recently contributed an article to Room 151, an online news, opinion and resource service for local authority section 151 and other senior officers.

Reforms mean local government will soon see a new audit regulator, but investing in local government finance teams and better reporting are priorities too.

The government’s decision to set up a dedicated local audit unit within the new Audit, Reporting and Governance Authority (ARGA) addresses one of the key recommendations of the Redmond Review – that there be a ‘system leader’ for local audit, bringing together many of the different aspects of audit regulation currently dispersed across a variety of bodies, including ICAEW.

Nevertheless, ARGA has a big challenge on its hands.

Problems

The National Audit Office reported recently that 55% of local authorities in England missed the deadline to obtain an audit opinion on their 2019-20 financial statements, despite an extension of four months to take account of the pandemic. While there were significant practical issues facing both local authority finance teams and audit firms that contributed to these delays, they are symptomatic of wider problems in the local audit market and in the preparation of local authority financial statements.

Local audit in England relies on a small pool of eight firms to audit hundreds of NHS trusts and local authorities within a short time frame each year. Audit firms struggle to find sufficient qualified and experienced individuals to deliver local authority audits, an issue that will only grow as the existing cohort of experienced auditors approaches retirement over the coming decade.

Even with the additional £15m in funding provided this year by the government, audit firms highlight how the risk profile of many councils has increased in recent years as reserves have declined and balance sheets have weakened, with many councils borrowing to invest in commercial activities. The impact of the coronavirus pandemic has damaged the financial position of councils even further.

At the same time, more intensive regulation has – quite rightly – put pressure on audit teams to improve the quality of their work, but that has cost implications too, with firms expressing concern about the viability of their local audit practices. There is a real risk that one, or more, firms could withdraw from the market, reducing competition and putting even more pressure on the remaining firms.

There are also significant barriers to entry, starting with a requirement for audit partners to qualify as a key audit partner in addition to being a registered auditor, a requirement specific to the local audit market and not applicable to other sectors requiring equal or much greater sector-specific knowledge and expertise.

This is an obstacle to new firms considering bidding for local audit contracts, even where they have audit partners with experience that would make them eligible to apply and the ability to train and recruit staff with the necessary capabilities. The limited number of key audit partners in each individual firm also makes it more difficult to manage multiple audits within the short time frames needed to achieve audit deadlines.

Stabilising the local audit market and working with the government to ensure there is a viable pool of expertise available to carry out quality audits will be one of the first items on the ARGA agenda.

Priorities

However, audit reform is only part of the story. There is also a need to invest in local authority finance teams and in making the local authority finance profession an attractive career choice. Local authorities need to place a higher priority on the importance of producing high-quality financial statements that meet best practice and how doing so can increase financial understanding among both officers and councillors. Success in this area would also benefit local taxpayers’ understanding of and ability to scrutinise spending decisions, improving accountability and transparency.

There also needs to be investment in the quality of the underlying financial records and the supporting working papers provided to external auditors – a cause of delays in some audits. Not as sexy as many of the budget proposals that go to councillors for approval, but we know that poor financial controls and a lack of financial understanding by decision-makers and those to whom they are accountable can cost a lot more in the long run.

Unfortunately, far too many local authorities appear to treat their annual financial statements and the audit as a compliance exercise, something to be ‘got through’ rather than an opportunity to give a full account of how well they have stewarded public resources on behalf of residents.

Poorly formatted and difficult to read, too many council financial reports and accounts are seemingly designed for depositing in the round filing cabinet, rather than taking their place alongside flagship reports. Such reports are often of much less importance and priority than the hundreds of millions of pounds of public money spent on delivering local services or, in some cases, that have been wagered in speculative commercial investments.

I believe that the new regulator will need to look beyond the audit firms and engage with local authorities and their finance teams to demand and encourage improvements. Although audit firms can, and do, insist on changes to financial statements where they fail to comply with accounting standards or are actively misleading, they can’t insist local authorities follow best practice or that they invest in making the financial statements understandable to elected representatives and to the public. There is a role for the new regulator to bring up reporting quality across the sector.

It is important to realise that the proposed new standardised statement of service information and costs won’t be enough on its own. Readers need to be able to understand the wider financial position of each local authority, such as the level of usable reserves and balance sheet risks—and that requires investment in the entire annual report and accounts to make the financial information presented more understandable.

High standard

The overall package of reforms is positive: a new system leader for local audit and a rationalisation of the regulatory environment; a new audited statement of service information and costs to enable budgets and spending to be compared; a review of audit requirements for smaller bodies; auditors to provide an annual report to full council; an independent member with financial expertise on council audit committees; and a willingness to look again at audit deadlines.

But we should not forget that external audit comes at the end of the process and that solving the problems in the local audit market will only go so far.

Ultimately these reforms will only be successful if the financial statements subject to audit are of a high standard in the first place. That means greater investment in finance teams and—most importantly—council leaders and officers placing a higher priority on the quality and understandability of the financial information they produce.

This article was originally published in Room 151, an online news, opinion and resource service for local authority section 151 and other senior officers covering treasury, strategic finance, funding, resources and risk, and subsequently published by ICAEW.

ICAEW chart of the week: Metropolitan France

This week’s chart examines how France inserted a layer of regional administration between the national government in Paris and the 96 departments in mainland France and Corsica.

Map of Metropolitan France divided into 12 mainland regions and Corsica, subdivided into departments. Île de France 12.3m people Auverne-Rhône-Alps 8.1m Hauts-de-France 6.0m Occitanie 6.0m Nouvelle-Aquitaine 6.0m Grand Est 5.5 Provence-Alpes-Côte D'Azur 5.1m Pays le la Loire 3.8m Brittany 3.4m Normandy 3.3m Burgundy-Franché-Comte 2.8m Centre-Val de Loire 2.6m Corsica 0.3m

France’s regional tier of government was created in 1982 with 22 regions in Metropolitan France (ie mainland France and Corsica) and has generally seen to be a success. However, it was concluded that there were too many regions, resulting in a consolidation in 2015 into the current 13 regions, as illustrated by the #icaewchartoftheweek.  

The regions range in size from the 12.3m population eight-department Île de France that includes Paris, to the 2.6m six-department Centre – Val de Loire region in mainland France and the 0.3m two-department Corsica region. This excludes the five overseas one-department regions of Guadeloupe, French Guiana, Réunion, Martinique and Mayotte. 

Regional councils in mainland France and the assembly in Corsica can raise taxes and control substantial budgets, in particular over education and infrastructure investment, as well as having some regulatory powers (but not statutory law-making powers). Elections are on a proportional representation system, with regional presidents chosen by the elected councillors or assembly members.

The establishment of the regions has been part of a process of devolving power from the central government, moving away from the highly centralised control exercised since the French Revolution, which saw the establishment of departments, broadly equivalent to county councils in England. Although each of the 96 departments in Metropolitan France has an elected departmental council and president, many responsibilities for local administration (such as policing) still sit with departmental prefects and subprefects that are appointed by the central government. The lowest tier of local government comprises 36,552 communes, each with an elected council and mayor, with the exception of central Paris, Lyon and Marseille that are further divided into municipal arrondissements.

The comprehensive reforms adopted in France for regional government contrast with the patchwork approach in England, where regional authorities in the form of metropolitan councils were abolished in 1986, only to see a regional tier return in 2000 with the creation of the Greater London Authority. This has been followed over the last decade by the establishment of 10 regional combined authorities, comprising Greater Manchester (2011), Liverpool City Region (2014), Sheffield City Region (2014), North East (2014), West Yorkshire (2014), Tees Valley (2016), West Midlands (2016), West of England (2017), Cambridgeshire & Peterborough (2017) and North of Tyne (2018).

The stop-start approach in England has involved a process of negotiation between central and local government on whether to establish regional combined authorities in particular areas, with a number of proposals across the country under consideration. However, even if they are approved, this will still leave many parts of the country without a regional tier of government. The elections in May in England will therefore see elections for regional authorities only in some areas (including the first-ever elected mayor of West Yorkshire), for between one and three different tiers of local government, and for police & crime commissioners outside of Greater London and Greater Manchester. A rather complex picture!

Back in France, the regional elections scheduled for March have had to be postponed. Instead, a new set of regional administrations across the entirety of Metropolitan France are expected to be elected in June 2021.

This chart was originally published by ICAEW.