Accounting Standards for Islamic Financial Institutions, Experience from the United Kingdom and Indonesia

By: Murniati Mukhlisin @ Mu Kim Ni

A. Introduction

The development of accounting standards in the United Kingdom is far superior to the level of accounting standards in Indonesia. Long commercial history and steady advancement of the financial industry in the UK owes credit to this advanced accounting standards. However, this level of sophistication might not be true with respect to standards applied for Islamic financial institutions (IFIs).

The main objective of this paper is to examine the history of accounting standards as applied to IFIs in the UK and in comparison with Indonesia. The standards in both countries have evolved through different history and left distinct influences to respective industry. Strength or weaknesses found in each of the countries could provide some lessons learnt for the other, or to many other countries with growing Islamic finance industry.

The remainder of this paper is organized as follows. Part two reviews the literature on history of general accounting standard in the United Kingdom and Indonesia. Part three delineates development of accounting standard for Islamic financial institution in general as well as in respective country. Part four presents relevant current issues around accounting standard implementation at Islamic financial institutions in each country. Part five highlights concluding thought.

B. History of Accounting Standards

1. The United Kingdom

Britain, as part of the larger United Kingdom, experienced the transformation from agricultural based economy to trading (mercantile), and eventually manufacturing, based economy between 17th to 18th centuries. During this period, accounting was used largely to monitor debts and check honesty of employees (Day, 2000). Its role was expanded during industrial period from 18th to the early 19th century, where industry managers required more advanced accounting techniques to deal with valuation and profit calculation.

In 1844, under Joint Stock Companies Act, books of account had to show ‘full and fair’ balance sheet but yet without specific profit and loss account. In the later period, in 1957, Punishment of Frauds Act made it criminal offence for any director, officer or manager who falsify company’s books and accounts. In 1907, Companies Act regulated all companies under Registrar of Companies to file balance sheet (ibid).

Accounting profession was formed through the setting up of Royal Charter to the Society of Accountants in Edinburgh and the Institute of Accountants an Actuaries in Glasgow between 1853-1855. After around 20 years, the first accountancy journal “The Accountant” was published.  The institute of Chartered Accountants in England and Wales (ICAEW) was formed in 1880 and the Society of Incorporated Accountants and Auditors was formed in 1885 (later integrated with the English Institute in 1957). During the period, the accounting practice developed balance sheet items such as depreciation until the publication of first accounting book written by Garnsey (1931) on consolidated account. Accounting as a subject taught in the universities first took place in 1920’s where the teachers employed were practicing accountants. It took serious attention to the formation of Research Association on Accounting in London School of Economics (ibid).

As for standard development, during 1930’s the Society of Incorporated Accountants called for the disclosure of subsidiaries’ profits and losses on the holding company balance sheet. That appeared after the issue of accountants arisen that claimed they were only concerned with consolidated statements. In 1939, Stock Exchange required consolidated accounts as listing clause and in 1948 the Companies Act enforced the practice. Mostly, development of legal application on accounting standard practices in the UK was attributed to legal cases, and it was represented by Companies Act that is amended from time to time. In order to improve accounting standard, the Society published regular journal called Accounting Research (ibid).

After insertion of taxation in the accounting standard, ICAEW upgraded the practice to include 29 recommendations on accounting principles between 1942-1969. After the world war, accounting practice made important breakthrough by moving into a new era that consider accounting as important matters for all, beyond directors and shareholders (Cohen Committee, 1947).

In 1970, Accounting Standards Steering Committee (ASSC) was formed and it issued its first standard in 1971. Subsequently, due to widening membership, its name changed to Accounting Standards Committee (ASC) in 1976. All standards issued were then subject to approval of Consultative Committee of Accounting Bodies (CCAB).  However, lacking understanding of the standard issued has persuaded ASC in 1983 to review its standard setting process as suggested by The Corporate Report (similar report issued by American Accounting Association in 1966), which was published by ASSC in 1975.

Further major review was commissioned by Sir Ron Dearing in 1987 and as a result introduced significant changes in the accounting standard setting and 1991, after receiving complains on poor conceptual framework and funding, new accounting standard setting was demanded. This year was said to be the last year for accounting profession to regulate accounting, before the task was taken over by the government. Then ASC comprised members right from professional accounting bodies, academic advisers and observers from government bodies including Bank of England and Stock Exchange (Day, 2000; ICAEW, 2012).

In 1990, Accounting Standard Board (ASB) replaced ASC and, from then onwards, standards issued are now referred to as Financial Reporting Standard (FRS), which follows the amendment of Companies Act 1985 (ICAEW, 2012; ASB, 2012). Unlike its predecessor, the ASC, the ASB can issue accounting standards known as UK GAAP on its own authority, without the approval of any other body.

In general, accounting standard released by each country is referred as “Generally Accepted Accounting Practice” or alternatively “Generally Accepted Accounting Principles” or “Generally Accepted Accounting Policies.” GAAP is a term used to describe the rules generally accepted as being applicable to accounting practices as laid down by standard, legislation or upheld by the accounting profession.

ASB also collaborates with accounting standard-setters from other countries and the International Accounting Standards Board (IASB), both in order to influence the development of international standards and in order to ensure that its standards are developed with due regard to international developments (ASB, 2012). Thus, UK GAAP has been fully harmonized and converged into IFRS and has been in implementation since 2005. This posed a concern on the future of UK GAAP, whether ASB issuance on accounting standards is still relevant and will stay on their own (Stroh, 2011). This is also a question whether such accounting standard setter would still be required to exist when all standards issued by IASB are adopted by the country.

2. Indonesia

After Indonesia’s independence 1945, the foundation of accounting practice was laid out by then two well-known accountants, Prof. Dr. Abutari and Prof. Soemardjo, both studied accountancy in the Netherlands and graduated in 1956. They were joined by the first batch of accountants graduated from local universities who graduated in 1957, among others; Basuki Siddharta, Hendra Darmawan, Tan Tong Djoe, and Go Tie Siem. These four accountants together with Prof. Soemardjo took serious effort to form an association of accountants specifically for Indonesian. They refused to become member of NIVA (Nederlands Institute Van Accountants) or VAGA (Vereniging Academisch Gevormde Accountants) formed by the Dutch colonials. They realized the two mentioned associations would not focus on the development Indonesian accountants (translated from IAI, 2012).

On Thursday, 17 October 1957, the five accountants initiated a gathering at the University of Indonesia and declared the establishment of an association for Indonesian accountants. The attendance however, was not fully dominated by those with accounting background; therefore, it was decided to form a Committee for Establishment of Indonesian Association of Accountants.  The committee was urged to gather all opinions. In the board of the committee was Prof. Soemardjo as chairman, Go Tie Siem as writer, Basuki Siddharta as treasurer, whereby Hendra Darmawan and Tan Tong Djoe assumed positions as commissioners. The letter sent by the committee to the rest of 6 accountants received anonymous approval (ibid).

The association was then, and until today, called Ikatan Akuntan Indonesia (IAI, or Indonesian Association of Accountants) and formerly established on 23 December 1957 (ibid). After its formation, IAI has tremendously progressed along with the growth of businesses in Indonesia. The association does not only focus on education and practices of accountants but also the efforts to improve public trust in its role to formulate public policies.

In 1973, IAI formed a Committee To Collect Materials and Structures from GAAP and GAAS. In 1974, the committee then set up a more permanent committee called Indonesian Accountants Principles (known as Komite PAI). PAI served its function for 20 years to formulate and develop financial accounting standards in Indonesia. After the 7th Congress of IAI, it was agreed that Indonesian accounting standards would be harmonized to International Accounting Standards (IAS). Since then, the issue arised due to duplication in name, PAI was then altered its name to Financial Accounting Standard Committee (known as Komite SAK).  In IAI 8th Congress held on 23-24 September 1998, Komite SAK was again changed to become Financial Accounting Standard Board (DSAK) and it is still in function until now (IAI, 2007).

The IAI Rules and Regulation 2008 designates Financial Accounting Standard Board (DSAK) under IAI to formulate, develop and approve financial accounting standards in Indonesia. The standard should cover basic framework, statement, application guide, interpretation, implementation guide and technical bulletin. DSAK membership varies from representative of every association/compartment under IAI, government body, business association, non-government association, and non-competent professional members. As per shariah standard, the board in charge is referred as Islamic Financial Accounting Standard Board (DSAS).

On 23 December 2008, IAI announced that the convergence of local standard to the international accounting standard (IFRS) should be completed by 2012. In IFRS Regional Forum 2011, IAI together with Malaysian and Singaporean counterparts declared 2012 as the year of IFRS Full Adoption. Even though the decision of IFRS convergence has been decided in 2008, the pressure is increasing, as Indonesia is the only South East Asian country in the G20 Forum. Compliance with IFRS is one of the commitments in G20 with target of completion in mid-year 2011. In line with this commitment, DSAK has been issuing new standards that are purely an adoption from IFRS standards issued by IASB.


C. Development of Accounting Standards for Islamic Financial Institution

1. Development of Accounting in Islamic Civilization

Most of accounting historians agreed that accounting as a practice grew due to the existence partnership in business transactions (Litteton, 1933 in Bedford and Zieglar, 1975). On the other hand, partnerships exist due to normal rapid growth of the business and cannot be claimed as the beginning of accounting. In history, the people of Babylon, ancient Egypt, Greek and Roman, had initiated, practiced and developed a kind of financial transaction recording system (Edward, 1960). This was practiced and also known as maskud dafatir (bookkeeping) in Islamic history, with the purpose to record revenue and expenditure of the government.

Islamic world had also used a book keeping system referred to as al-Qaidul Muzdawaj, 800 years before the Italian/European renaissance in which time Luca Pacioli (1445-1517) lived and later declared as “father of accounting” (Weis & Tinius, 1991). The term was later known as muhasabah (accounting) in the Islamic civilization up to its decline in 1924 with the fall of Osmanli (Ottoman) caliphate. The term muhasabah is still being used in the Islamic society today, although such Islamic government is no longer in existence.

Muhasabah has at least five meanings according to Hayashi (1989, in Harahap, 2011). Yahsaba which means to count, to compute, to measure; it also means to record and to continuously count somebody’s deeds; Hasaba means responsibility, to be neutral; Tahasaba means to keep, try to obtain, expect reward in the hereafter; and lastly to become attention or accountable.

Following rapid growth of Islamic financial activities, accounting played an important role, hence the ideas and theories that have been proposed. The term of Islamic accounting suggested by Shahata in Harahap (1997, 2011) is defined as “accounting postulates, standards, explanations and principles that describes all matters… thus Islamic accounting theoretically adopts Islamic concepts, principles, and objectives too. This is in parallel with development of other aspects such as Islamic economy, social, politics, ideology, ethics, life, justice and law. Accounting is part and parcel of those aspects and cannot be separated.”

Haniffa (2002) highlighted two objectives of Islamic social reporting. It includes: i) To demonstrate accountability of companies not only to God but also to the community, and ii) To increase transparency of business activities by providing relevant information in conformance to the spiritual needs of Muslim decision makers.

This refinement of definition and purpose has strengthened the existence of accounting and auditing standard for Islamic financial institution, as released internationally by Accounting and Auditing Organisation for Islamic Financial Institutions (AAOIFI). AAOIFI, based in Bahrain, released its first standard on Islamic financial reporting standard in 1991.

To date, AAOIFI has issued a total of 86 standards for international Islamic finance industry, covering areas of accounting, auditing, ethics, governance, and shari’ah. As an international governing body, AAOIFI is supported by over 200 institutional members from over 45 countries, including central banks/regulatory authorities, financial institutions, accounting and auditing firms, as well as law firms. It is claimed that its standards are currently adopted by all the leading Islamic financial institutions across the world and have introduced a progressive degree of harmonisation of international Islamic finance practices (AAOIFI, 2012).

As more and more countries adopt IFRS, the consistency of AAOIFI standard compliance is being questioned. In 2010, more than 100 countries have declared to adopt IFRS (SEC, 2010), with the exception of only Qatar, which solely adopts AAOIFI. While Bahrain and Kuwait have decided to adopt both AAOIFI and IFRS (ACCA, 2010). The question remain; does AAOIFI effort in releasing financial reporting standards contribute to the development of Islamic financial institutions? What is further action plan of AAOIFI, when more member countries increasingly ignore its standards in favour of standards issued by the IASB?

Nonetheless, AAOIFI shows its consistent effort at least this year. There are three new consultation papers on financial accounting standards that solicit views and comments that due on 8 April 2012 (ibid, 2012), namely Financial Accounting Standard No. 26 on Investment in real estate; No. 5 on Disclosure of Bases for Profit Allocation between Owners’ Equity and Investment Account Holders; and No. 6 on Equity of Investment Account Holders and Their Equivalent.

2. Development of Accounting Standards for Islamic Financial Institution in the United Kingdom

For all periods up to and including the five months period ended 31 December 2004, all Islamic financial institutions in the UK prepared its financial statements in accordance with UK Generally Accepted Accounting Principles (UK GAAP). From 1 January 2005, all financial institutions elected to prepare its financial statements in accordance with the International Financial Reporting Standards as adopted by the EU and effective for the reporting year ended 31 December 2005 (IBOB, 2012).

This reflects the abiding company law that requires the directors to prepare financial statements for each financial year. Under the current law, IFIs directors have elected to prepare financial statements in accordance with IFRS, which has been adopted by the EU, hence applicable and mandatory to UK financial institutions.

Islamic Bank of Britain is the first Islamic bank approved by UK Financial Service Authority that was established on 6 August 2004. The transition from UK GAAP to IFRS in August 2004 has had no material impact upon the figures previously reported in the financial statements. Consequently, no material adjustments were required of the figures previously reported under UK GAAP to those now reported under IFRS, and, hence, reconciliations of the UK GAAP and IFRS figures are not provided in financial statements of UK Islamic financial institutions (ibid).      

3. Development of Accounting Standards for Islamic Financial Institutions in Indonesia

In Indonesia, the issuance of accounting standard is not through enactment of a company law as in the UK. When Bank Muamalat Indonesia was established in 1991, there was no meaningful change in the regulation. The bank was legalized and established using an existing Law. No. 7/1992 on Banking, which later on replaced amended and ratified as Law No.10/1998 on Banking (Bank Indonesia, 2012). As such, the accounting standard adopted was an existing one, which is Accounting Standard for Banking (PSAK 31) that was applied for all commercial banking operations.

Indeed, the development of accounting standards for Islamic financial institutions in Indonesia only started in 2002, with the issuance of Statement of Accounting Standard No. 59 (PSAK 59), or known as Islamic Banking Accounting Standard. PSAK 59 was released by IAI on 1 July 2002 and taken into effect starting 1 January 2003, with 5 years of implementation period or up to accounting year ended 31 December 2007. The reference of the standard was derived from the standards released by AAOIFI with some modifications to suit local context and needs.

Islamic Banking Directorate (previously known as Islamic Banking Bureau) of Bank Indonesia issued a guideline in 2003, which functions as technical interpretation to the adoption of the standards for Islamic banks. This is known as Guidelines of Indonesian Islamic Banking Accounting Standards (PAPSI) 2003.

In 2008, PSAK 59 was replaced by new PSAKs known as Statement of Accounting Standards for Islamic Business Entity. The new set of standards consists of PSAK 101, 102, 103, 104, 105, 106 and 107 that were approved by Islamic Financial Accounting Standard Board (DSAS). These standards, which were pronounced and taken into effect from 1 January 2008, cover not only Islamic banking operations but also other entities that are categorized as Islamic business entities. PSAK 101 sets out a standard for financial statement presentation; whereby PSAK 102 specifically refers to contract of Mudharabah; followed by PSAK 103 (Salam), PSAK 104 (Istishna), PSAK 105 (Mudharabah), PSAK 106 (Musyarakah), and PSAK 107 (Ijarah). It was then followed with other development such as the release of PSAK 108 (Islamic Insurance) and several exposure drafts i.e. ED on Sukuk and ED on Zakah which are now at final hearing stage (IAI, 2012).

However, PAPSI 2003 was not updated since its first publication. As an alternative, PSAK trainings and books on accounting standards for Islamic banks are available for the preparers; i.e. PSAK 101-107 Training by IAI, LPPM Tazkia and LPM UI, Akuntansi Perbankan Syariah by Sofyan Safri Harahap, Wiroso and Muhammad Yusuf, Akuntansi Perbankan Syariah: Teori dan Praktik Kontemporer by Rizal Yahya, and Akuntansi Syariah di Indonesia by Sri Nurhayati.

D. Current Issues of Accounting Standards for Islamic Financial Institution

Karim (2001) emphasised the need to implement accounting standards promulgated by the AAOIFI, because these standards specifically cater for the unique characteristics of contracts govern the operations of Islamic banks. The AAOIFI’s financial accounting standards are intended to serve Islamic banks in the various countries in which they operate.

It is argued that Islamic financial institutions should follow their own accounting standards i.e. specific Islamic financial reporting such as AAOIFI format, and IFRS cannot be adopted as it can raise Shariah compliance issues or IFRSs do not fully cover the unique characteristics of Islamic financial insitutions including banking transactions (Karim, 2001; Hameed, 2007; ACCA, 2010; Haniffa, 2011). Haniffa (2011) asserts that harmonization of financial reporting for Islamic financial institution does not have the same treatment as the conventional one. It could lead to conflicting accounting treatment and may jeopardise the credibility of the information.

The issue of substance over form is introduced whether Islamic financial institution considers content of practices that must adhere to shariah, or a mere financial reporting should abide by shariah framework regardless of the content. Ideally, both standard practices and written standard of financial reporting must be in accordance with shariah. However, with restrictions in respective country to accept Islamic-based transactions and lack of resources and supports in accounting standard formulation, the options are open. Some argued that substance is more important than form, thus, financial reporting can be made flexible; Islamic financial institutions can produce two types of reporting i.e. Islamic financial reporting and IFRS based financial reporting. Demand for IFRS compliance is due to international transaction that requires quality of financial reporting and must show better comparability and transparency. Hence, for that purpose, IFRS financial reporting is currently a mere labelling for Islamic financial institutions. Does this matter?

Undoubtedly, the effect of shariah principles on accounting methods for Islamic banks points out the rapid acceptance of Islamic finance. Abdullah (2010) explains the fundamental principles and shows three options for the way forward in Islamic accounting: 1) Exclusivity: live side by side with its conventional counterpart; all Islamic financial institution transactions will be recorded by way of Islamic accounting, 2) Harmonisation: International Financial Reporting Standards (IFRSs) are fine-tuned; then certain exemptions are allowed/disallowed, 3) Convergence: Applying IFRS in every aspect.

E. Concluding Thoughts

Accounting standard development in the UK and Indonesia experienced different path and history. Legal foundation, political and social differences of the two countries exhibit unique development and results. There are four principal sources of the UK law i.e. legislation, common law, European Union law and the European Convention on Human Rights. With its more advanced civilization, sine qua non UK has shown strong legal foundation in combining accounting standard parallel with political interest in the country’s company law.

Whereby, Indonesia lives a Dutch-colonial legacy that started developing its legal foundation only after its independence, which is more influenced by Continental Europe and Nederlandsch-Indie legal systems. During its developing stage, the area of accounting standard process moved along side with the business activities.

Rapid growth of Islamic finance and strong influence of 90% Muslims, have urged the development of relevant legal proceedings and accounting policy in Indonesia. In contrary, as the United Kingdom does not regard any interest to specific religion and in addition, 4% Muslims population contribute insignificant impact of Islamic finance development on law and accounting policy in the country.

However, language of accounting is universal, which is to cater the needs of the whole stakeholders. Islam too, aims to bring the message of rahmatan lil alamin that cater the needs of the people regardless of their beliefs or value systems. It is stated in QS Al-Anbiya 107; Wa maa arsalnaka illa rohmatan lil ‘alamiin and the meaning: “And We have not sent you, [O Muhammad], except as a mercy to the worlds. Thus, existence of Islamic financial institutions, guarded by reliable accounting standard, should learn and strive to create value and bring benefits to every market they are operating in the world.

This perspective has been the foundation of an inspirational life led by Prof. Sofyan Syafri Harahap. In his memory, the following quotes remind us that the raison d’etre of establishing an Islamic based economic system in Indonesia is not a selfish journey for material gains, but a selfless endeavour to build a solid Indonesian economy. With it, we can then contribute to the world’s prosperity and make it a much better place to live.

“Future Agenda; The Future will depend on present conduct of the ummah. We are currently facing hidden conflicts between two giant civilizations; Capitalism and Islam. In this situation, Muslims have to be smart in playing their roles especially when explaining various concepts, regulations, systems or values to answer challenges ahead that are undoubtedly getting more complex” (quoted from Article “Akuntansi Sosial Ekonomi dan Akuntansi Islam”, written by the late of Prof. Sofyan Syafri Harahap, 26 March 2011).



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