외부감사제도 개선을 위한 유럽연합(EU)의 법제 동향

Currently, Korea is pushing for a revision of the legal system to increase transparency of external audit with the accounting fraud of Daewoo Shipbuilding & Marine Engineering. This paper examines the contents of legislative actions to strengthen the discipline of external audit through the European Union's 2014 Directive and Regulation Amendments and succeeding internal legislation of Germany and UK. As a result of the comparison, it can be confirmed that the Korean Comprehensive Measures (hereinafter referred to as ‘KCM’) announced in January this year have a similarity with the current legal system of the European Union. This suggests that the legislative system on statutory audit is in keeping with international trends. However, there are some differences: the European Union is attempting to increase the audit capacity of small external auditors, to establish a separate independent body for public surveillance as a separate independent organization. Also there are some differences in that the European Union is taking measures for practical protection for the accused as well as the whistle-blower and that measures are being taken to ensure substantive independence between the external auditors and the audited corporations. This difference may be due to the differences in social and economic backgrounds between Korea and the European Union, but the author thinks that there is some points to be considered in the future improvement of the system by examining the European Union system more closely. At the same time, we should not forget that there are already voices of criticism within the European Union about the various institutions we have accepted and will accept.