INSTITUTIONAL THEORY AND
ADOPTION OF ACCOUNTING STANDARDS INTERNATIONALLY ACCEPTED: STUDY OF THREE
French CASES OVER THE PERIOD 1989 - 1993
Philippe,
TOURON
Professor,
Accounting and management control department Edhec, 58 rue du Port, +33 (0)3 20
15 48 46, philippe.touron@edhec.edu
Abstract
Several researchers have been used New-institutional theory in organizational theory (Meyer and Rowan, 1977; DiMaggio and Powell, 1983, Mezias, 1995). The paper has two objectives: to explain the decisions of adoption of international accounting standards and to identify relative roles of the three types of isomorphism (coercive, normative and mimetic). Implemented method is inspired of Miles and Huberman (1994) and is applied to three cases studies three: Aerospatiale (1989), Usinor (1991) and Coflexip (1993).
Keywords : Accounting decision, international and US GAAP, agency theory, new-institutionalism theories, cases studies
This article leans on the neo-institutional
theory of organizations. We argue that institutional theory provides a better
understanding than agency theory of the adoption of internationally recognized
standards. These internationally recognized standards are US GAAP promulgated
by Financial Accounting Standard Board
(FASB) and IAS standards
promulgated by International Accounting
Standard Committee (IASC). Indeed, institutional theory helped to explain
the emergence of different accounting forms. (Carpenter & Feroz,
1992; Covalesky & Dirsmith, 1988; Fogarty, 1992; Mézias, 1991;
1995). These studies cover the entire domain of accounting: the accounting
companies, the professionals and standards setters, and management control.
In a first theoretical part in which the limits
of agency theory to explain accounting change are put in evidence. Also, the
explanatory propositions of adoption deviated from institutional theory are
described (loose coupling, coercion, transmission of norms and imitation). The
second, empirical part of the paper consists of three case studies. They allow
clarifying the relative part of the three types of isomorphisms from the
institutional theory.
In the first part of this paper, We elaborate
propositions to enrich the explanations of the adoption of internationally
recognized accounting standards. For that we put into evidence the limits of
agency theory to explain accounting changes, we use the neo-institutional
theory of organizations (NIT) and the findings obtained stemming from the
accounting literature to
Generally, the studies on Generally Accepted
Accounting Principle's (GAAP) adoption fall within the framework of agency
theory in the lineage of Jensen and Mekling's (1976) works.
According to agency theory, organizations are analyzed in term of conflict of interest between principal and agent (Jensen & Meckling, 1976). The principals are the owners of the assets of the company and delegate the control of organizations to the managers who are their agents (Fama & Jensen, 1983). The managers use discretionary margins to maximize their interest to the detriment of the interests of the principal, what is called residual losses (Jensen & Meckling, p. 308). Such losses are to a certain extent avoided by means of control mechanism such as accounting standards and audit (Watts, 1977).
The studies which concern GAAP's adoptions show that managers make efficient accounting choices because of the existence of contracts which integrate their opportunist behavior (Zimmer, 1986 ; Wittread, 1987 ; Mian & Smith, on 1990 ; Whittred & Zimmer, 1994). Most of these studies concern the determination of a set of accepted accounting procedures - that is the GAAP - and explain them by the existence of contractual constraints. These studies insist on the binding role of contracts between the firm and its partners for the definition of accounting standards used in the accounting policy. It is not any more the contractual constraints which determine the accounting procedures but the nature of the activity which leads simultaneously to a series of contractual constraints and accounting procedures. The choice of a bookkeeping system is not explained by the opportunism ex post of the administrators but by a control by means of contracts ex ante, i.e. potential transfers of wealth. The GAAP is one of these contracts.
Zimmer (1986) study the choice between the capitalization or the registration in charge of interest charges for a sample of Australian companies in the sector of the property promotion. Contracts between the firm, the customers, the lenders and the associates are so written to prevent the opportunist behavior of the managers. The interpretation of results is that the decisions of production and investment imply simultaneously a financial structure and a bookkeeping system, debts and book-keeping systems are correlated but the two depend on the nature of the assets of the firm.
Withread (1987) puts in evidence the determining role of the existing contracts for a guarantee between the parent company and the subsidiaries in the adoption of consolidated financial statements in Australia. Results show that consolidation is adopted in the presence of guarantee contracts between the parent company and its subsidiaries. These conclusions align themselves with the conclusions of agency theory i.e.: "The consolidated financial statements are the result of contractual procedures which aim to reduce the costs of agency" (Whittred, 1987, p. 283)
Mian and Smith (1990) by studying accounting practices before the implementation of the standard SFAS 94 show that accounting decisions reflects a choice of organizational structure and are determined by the nature of the link between the parent company and its subsidiaries. The central hypothesis is that the more dependant activities among a company and her subsidiaries are, the more the performance of the subsidiary is reported according to a consolidated base. Three levels characterize dependence: operational, informative and financial. The contribution of the authors is to have introduced the organizational choice into the analysis. They think that accounting decisions have to reflect the organizational choice. Thus, the accounts of management determine financial accounts and will be determined organizational practices.
Taking as a point of departure the statement that the posting of the operations of joint ventures varies between firms in the various phases of the mining industry (investigation versus production), Whittread and Zimmer explain the accounting choices through the various types of assets and the way they are financed.
Zimmerman and Christies (1994) tried to see if the accounting choice of the managers recovers from an opportunist or efficient behavior. Results show, according to the authors, that: " efficiency is more important than opportunism to explain the accounting choice" (p. 562) and so strengthens the weight of studies done within the framework of the contractual theory of the efficiency.
Studies on the determinants of the consolidation Controversial results
Results on the determinants of the consolidation are the object of rival interpretations of those developed in the previous paragraph. It seems establishes today that the adoption of the consolidation is influenced by state rules at first, then by several factors, notably the growing acceptance of the technique by trade organizations and practitioners (Walker 1978; Bircher, 1988).Walker indicates that in Great Britain, the introduction of the consolidation is a means for holding companies to realize their activity. It is an answer to the maladjustment of the usual procedures of valuation of assets and recognition of products to take into account inter-corporate stock-holdings. On the contrary in the United States, the absence of rule before the 1930s was a source of experiment and it is the introduction of a fiscal regulation allowing consolidation that was a significant factor in the awareness of the profession of the importance of the consolidation. The regulation plays a role by confirming, for example, good practice. Bircher (1988) in his interpretation insists on the imminence of a state regulation as a dominant factor of adoption. The author contributes to the understanding of the adoption by making a distinction between on the one hand the acceptance of the idea of consolidation in the field- the preference of the actors for this kind of publication – and, on the other hand, the wide distribution of the technique (p. 5). The model precedes practice. The author demonstrates that while a consensus on the desirability of the consolidation developed in Great Britain in the 1930s (p. 6), there was a significant distance between literature and practice. Consolidation was not widely adopted in Great Britain before the end of 1940's. Furthermore, Withtred's results for the choices of consolidation are disputed in Australia (Walker, 1998).
Usually, studies of the adoption of
international and American standards are made within the framework of voluntary
information that states that companies publish information that is not
compulsory to satisfy the expectations of stakeholders, particularly
shareholders. Three studies were made on the IAS GAAP and one on the US GAAP. Results establish
correlations between the part of sales abroad and the international quotation
and the use of IAS GAAP
in the Swiss context. In the Middle East, Al-Basteky indicates a correlation between
an international listing and the adoption of IAS GAAP
The interpretations of results by the
researchers are sometimes contradictory. Raffournier and Dumontier indicate
" these results do not confirm the
hypothesis according to which voluntary correspondence with tougher standards
is used to resolve problems of guidance among the managers, the shareholders
and the creditors " (, p .240). While Murphy interprets similar
results as a signal sent by the managers who demonstrate their use credible
standards that prevent them from creating hidden reserves.(Murphy, 1998 , p.
125).
A plethora of research handles with the
determinants of the accounting choices and on position with regard to
accounting exposure-drafts, we notice the very restrained number of research,
even though it tends to grow these last years, having for object the adoption
of standards internationally recognized. Furthermore, some studies end in
rather disappointing results. Taking into account the Institutional
environments in the organization seem to be a relatively more sensible way.
Moreover, the case study of an Indian computer company the INFOSYS Company
based on interviews is richer from the point of view of results.
(Narayanaswamy, 1996).
According to the new-institutional theory,
companies use formal structures as the accounting GAAP in a concern of
legitimization and independently of consequences in term of efficiency.
The first contribution of the theory lies in
taking in account a neglected facet of the environments: faiths, rules and
institutionalized roles. (Meyer and Rowan, 1977)
[1]Indeed, the professionals, the State and the
public opinion, as far as they produce them and infer them, are the foundation
of complex rules and framework of institutionalized behavior, which are
rationalized myths. These frameworks are myths because they are at first
widely shared faiths effects of which are real " here, not in the fact that the individuals believe them but in the fact
which they know that the others make it, and that 'practically', myths are true
". (Meyer, 1977, p. 75.) They are rationalized because they take
the shape of rules, which specify necessary procedures to reach a given end.
Besides, accounting literature demonstrated
that accounting was often used as a symbol of legitimacy. The rational forms of
organizations, as the recognized accounting principles, are the resultant of
exogenous forms of rationality, which are necessary as a means of
legitimization. Organizations are recognized through a commitment in a
rationality, as the use of a kind of justifiable language: accounting,
obviously guaranteed, objectives and relevant (Meyer, 1986). Accounting defined
as a "set of faiths and techniques which connect actions and values, that is
which returns justifiable actions". (Richardson, 1987, p. 341) is a
tool of legitimization toward the environment.
Practices can be more or less
disconnected from the technical aspects of organizations. Rationalized myths
have a structuring role for organizations, which as a consequence, adopt
practices of management, as accounting standards because they are socially
legitimized independently of considerations of efficiency. By following these
rationalized myths, organizations receive support and legitimacy.. By acting
so, organizations are going to convince their audiences - the public in the broad
sense beyond stakeholders - that they
are justifiable entities that it is advisable to support. (Meyer & Rowan,
1977) Westphal and Zajac (1994, 1998) suggest that the managers can satisfy
external demands and increase their responsibility toward the shareholders by
adopting apparently structures of external control in interest of the
shareholders without implementing them.
And they strengthen at the same time these actions with the used of a
legitimizing language. They show through the example of executives'
compensation plan in the United States where tools of can be adopted without
being applied effectively.
This disconnection between the
adoption of a practice and its
implementation seems to be applied to accounting standards. Companies
claiming compliance with certain accounting) standards, do not implement them
completely. Two studies put in evidence some practices of formal compliance in
the choices of accounting politics of companies. (Sha, 1998; Rutherford, 1999)
Already in 1983, a study showed that standards were not applied in a
corresponding way. (Evans & Taylor, 1982) A study on the application of
international accounting standards in the world find some evidences of the
loose coupling between the standards supposed to be in used and the actual
accounting practices of companies. Eleven modalities of compliance were
identified going from the total compliance with standards IAS to a description
not quantified by distances with regard to standards IAS (Cairns, 2000).
Besides, a study made from a sample of 49 annual reports of the 1996 of
companies applying IAS, reveal significant points of nonconformity; notably the
definition of the extraordinary result, the capitalization of the expenses of
research and development, the posting provisions of commitments toward the
employees. (Street & al., 1999)
Second contribution is of for DiMaggio and
Powel (1983). Noticing that organizations are more and more similar, they
ask the following question: Why are organizations similar? In the answer they
give, organizational structures result from conformity with the institutional
environments. Their contribution lies in the identification of the modalities
that lead organizations to adopt structures or similar tools of management. In
search of legitimacy, organizations fit the society according to a collective
rationality inferring from the institutionalization of the structure within a
field. Organizations adopt similar structures as accounting standards under the
pressures of institutional environments following three mechanisms: coercition,
transmission of norms and imitation.
Coercitive isomorphism appears with " formal and informal pressures exercised on
the organization by the other organizations on which they depend and
expectations of the society in which the company works "
(DiMaggio and Powel, 1983). In other words, power is so one a central variable
in the coercion, it is of use of base to the institutional influence which encourages
the correspondence of behavior by means of " organized with rulers, with mechanism of surveillance and of the
activities of penalty ". (Scott, 1995). It suggests a
"instrumental" logic (Scott1995) or " according to consequences " (March & Olsen, 1989)
Three stakeholders exerce coercive influences: The financiers who have the
financial resources the company needs, the customers without whom it can not
survive and the State which promulgates rules and laws which are binding for
organizations.
The role is well known in the organizational
and accounting literature. By not respecting law, the company incurs penalties.
It can be forced to pay fines or still to question the righteousness. The
influence of the State by means of rules on companies should not be
demonstrated any more (Fliegstein,1990). The State promulgates laws and rules,
which favor the institutionalization of certain practices either on the
contrary slow down the diffusion of these practices. Tolbert & Zucker
(1983) demonstrate that a new budgetary practice was adopted faster in the
federal States, where law has been promulgated for a long time. Mills finds
that already in the Middle Age, Royal 'wit' obliged some people to give
accounts. (Mills, 1990) In the accounting domain, the rules are anticipated and
are taken into account by the actors (Ginner Inchausti, 1997). A study led on a
sample of 49 Spanish companies demonstrate the important role of the European
legislation in the increase of the level of publication during the years
studied on 1989, 1990 and 1991.
Accounting literature puts in evidence the
determining role of the providers of money. Companies needed financial
resources face the obligation to respect the demands of the most important
investors (Shleiffer & Vishny, 1986). With the presence of institutional
investors and reference shareholders, there should be less problems of agency.
(Hill & Snell, 1989). So, institutional theory can be an alternative to the
theory of the agency in the hypothesis of strong field (Toms, 1998). The
dispersal of the property would not so be a determining factor of the
accounting practices of companies. Individuals shareholders have less power of
negotiation to reach information than institutional investor's (Zeckhauser
& Pound, 1990).
At the same time, Pressures are strengthened by
the demands of information made by the financial analysts. The decisions of
investment are taken on the basis of the financial analysts'forecasts
(Williams, 1996). The number of analysts who follow a company is correlated to
the relative part of capital possessed by institutional investors. This result
is substantial with the idea of an alignement of the analysts in the interests
of institutional investors (Potter, 1992). The decision of the analysts to
follow certain companies would even push the investors to increase their
participation in the capital (O’Brien & Bushan, 1990). So, the analysts
exerce coercive influences on the companies they follow, all the more strong as
the number of analysts following the company would be brought up.
Coercive pressures on companies result not only
from the providers of capital but also from the customers (Zarzesky, 1996)
These last ones are the source of the profits of companies and thus can
threaten the survival of the company by not buying products. The localisation
of sales in the choice to submit itself to "big GAAP" is turned out
empirically. The internationalization of companies combined with the expansion
of financial markets determine the increasing homogeneity of the practices of
financial accounting. . Studies dealing with
adoption of international standards identify as essential factor the
part of sales in abroad (Murphy, 1999; Dumontier & Raffournier, 1998 and
El-Gazzar al., 1999).
Within the business world, the professionals
prescribe practices. Practices are adopted because they are prescribed. Then,
norms are transmit by the process of authorization defined by Scott (1995). The professionalization of the
management activities of companies is the reason of the adoption of certain
structures and practices. Indeed, the professionalization leads to a normative
isomorphism that is based on the transmission of norms. Normative isomorphism
to exist supposes two elements: a transmission of norms by professionals and a
mechanism of prescription. The phenomena of accreditation recover two types of
accreditation in the accounting field:
the auditors and the regulation bodies of stock exchange.
The auditors guarantee the
financials statements of companies but they can refuse if they judge that
accounts are not satisfactory, whether they do not give a "accurate
image" of financial situation and patrimony of the company in
Europe, or whether accounting practices are not corresponding to standards in
the United States. Results are reserved; on three studies studying the association
between the adoption of international accounting standards and the listing
status (Al-Basteky, 1995 Dumontier
& Raffournier , 1995 and Murphy , 1999), only Al-Basteky results are significant towards the role of the auditors. A case
study demonstrate the determining role of the auditors. (Narayanaswamy, 1996)
Similarly, , international standards are more binding than French standards
in regard to the volume of information to be published and the publications of
voluntary information is correlated with the status of the auditors. Then, the
companies for which a "quality" auditor audits financial statements
will adopt more easily accounting standards internationally recognized.
Stock exchanges impose certain standards on their members. The volume of information to be published is variable according to the place of quotation. Numerous studies show the effect of accounting rules on the financial policy of companies. The choice of a place of quotation is influenced in a negative way by the constraints of publication (Saudaragan & Biddle, 1992; Saudaragan & Biddle , 1995).
The “authorization”, contrary to the coercion supposes that subordinate entities are not obliged but look voluntarily for the approval of the authorizing agent. Stock-exchange rules apply only to companies that decided to be registered with a stock exchange. Companies can delocalize an issue of loans because of differences in accounting obligations (Flanigan et al. , 1999). It is not so a link of dependence but a relation of recognition centered on a normative legitimacy.
Imitation consists in granting a central place
to the similar organizations in its choices. (DiMaggio and Powell, 1983). In
situations of uncertainty, when the link between the appearance and the
substance is not established, organizations model themselves to the others. In
other words, the administrators of companies facing a situation of uncertainty,
adopt more gladly behavior similar with the behavior of the organizations with
which they liked to be assimilated either companies exercising the same
activity, or the companies having the same financiers either still the most
talented companies (leaders). Mimetic
adoption supposes the three elements: an uncertainty towards the effects of the
tools, a copied and adopted model and a mechanism that makes link among the
first two elements (cognitive legitimacy).
Generally, accounting literature shows that
industry is a key variable in determining accounting policy. The study of Neu
(1992) is the first, which interprets the influence of the sector as an
influence of mimetic order. The companies of the mining sector and the
financial institutions publish more frequently forecasts of profits at the time
of public appeals to the saving. It demonstrated statistically that the
variable " sector membership "
is significant.
Let us add that imitation is made possible by
the approval of the managers. The perceptions of the individuals play so the
role of catalyst in the accounting choices. (DeBos, 2000; Adam, 1996). So,
American authors stand out that companies having adopted by anticipation
standard FAS number 106 have managements' teams with twice more individuals
having a training in finance and in accounting that the companies which did not
adopt this standard by anticipation (Ciccotello et al., 2000, p. 102).
The research question is the following one:
Which are the respective roles of the coercition, the transmission of norms and
the imitation to explain the adoption of international GAAP by French firms?
Our objective is to explain a decision, case study is the methodology of
adapted search (Yin, 1994 ; Eisenhardt,1989).
The objective of the analysis is to obtain
representative cases. Indeed, the choice of cases is not make in an
unpredictable way. Naturally, accessibility to the ground is necessary as a
constraint. The modalities of use of accounting standards internationally
recognized were reserved criterion. Considered period is marked with the
institutionalization of the IASC. Cases are so representative of behavior
"types". Aerospace industry in 1989 marks a clear choice for the IASC
while Usinor in 1991 chooses standards IAS while publishing a reconciliation
with US GAAP. Finally, Coflexip opts for American standards in 1993 at a moment
where IAS is become strongly institutionalized.
In organizations, the written tracks are
particularly important (Atkinson and Coffey,1995) Multiples sources of evidence were used:
, the documentation (Annual reports (at least 5 years by case)the 20-K of SEC,
press), and interview with managers (auditors or companies chief accountants).
We use interactive model recommended by
Huberman and Miles (1994). It appeals to three constituents or convergent
activities: a phase of condensation of data, a phase of organization and
presentation of data and a phase of interpretation and check.
First of all, a stage of coding allows so
transform a multitude of documents, the transcriptions of interviewsinto a
coherent analysis capable of answering the question of search. The coding
allows only to generate an index of narrative fragments which, took insulation,
have a priori no sense.
In second place, from then on for every case, a
work of articulation and structuration of data is led "to test" our
propositions. This work of articulation is realized due to matrix and figure of
presentation, built as the case may be and according to meditative data, with
the aim of getting in touch the variable among them and to cast the bases of an
explanation and a possible interpretation.
Finally, lastly, cases are presented and analyzed individually and a
synthesis of results based on the comparison of cases.
The company is in the aerospace industry. It
began to use international accounting standards in 1989: "Aerospatiale Consolidated financial
statements are established for the first time in 1989 according to Accounting
principles generally accepted internationally, recommended by the IASC."
(RA, 1989). Compared to previous accounting practices, changes in accounting
practices without being revolutionary are real because " restatement (were) little except as those
regarding the reprocessing of the leasing, the consideration of the commitments
of pension and the consideration of the aspect GIE (at first IAS
implied stake in equivalence)". (Interview with MC) Furthermore, since 1991, the group applies the standard IAS 31, which allows
integrating proportionally participation into joint ventures.
On the one hand, the company is subject to
coercive forces from the State but not from the lenders. On the other hand, The
Company is not actually subject to investor’s desiderata's at the time of the adoption. Moreover, the company is
subject to the pressures of foreign customers.
The French State legitimates consolidated
accounting, but leaves the actual implementation relatively unspecified. At
first, as French group, Aerospatiale
has to respect the legal obligations of the law of January 3, 1985 and its
decree of application of February 17, 1986. The law becomes applicable for
fiscal year opened after December 31 for the year 1990 at the latest for the
unquoted companies (and for those that did not emit commercial paper).
Furthermore, it is compulsory for companies to produce consolidated accounts
following the methodology recommended by the "Arreté" (“wit”) of
December the 9th of 1986.
In fact, this framework ensured a fairly large
degree of flexibility in the accounting rules and choice. The article 357-7 of the
law on July 24, 1966 (modified by the law of 1985) stipulates that "consolidated financial statements are
established according to accounting principles and rules of evaluation of the
Commercial law. It considers the
resultant indispensable characteristics of organizations appropriate for
consolidated accounts with regard to statutory accounts ".
In other words, optional restatements allow
retaining accounting practices in contradiction with those, usual in statutory
accounts in France, prescribed by the Commercial law. The article 357-8
clarifies that "under reserve to
prove it in the appendix, the parent company can use rules not corresponding to
those fixed with articles 12 - 15 of the Commercial law in provision with the
article 11 of the Commercial law ". (Article 348 - 8 of the law of 1966
modified by the law of 1985)
By allowing a disconnection between statutory
accounts (taxation and legal entity purposes ) and consolidated financial
statements it opens the way to the adoption of practices in phase with those
usually used by multinationals, such as the capitalization of the lease or the
presentation of the income statement by destination and not by nature as usual
in France (Hoaraux, 1995) A study of the « Société Française d’Analyse
Financière » (Chartered French Financial Analysts) demonstrates the
compatibility of the Methodology of the CNC with the US GAAP and with IAS
Framework. So we notice that the law and the methodology are not really a
constraint but on the contrary are an opportunity for the company.
The figure 1 below, which resumes debenture
loans by Aerospatiale, shows well that the group did not issue any
"international" debenture loan at the moment of adoption. There are
no actual pressures of the investor's in 1989. Debenture loans in Francs and in
Euro francs were issued previously, there has not been any new issue from 1988
till 1990 included.
Figure 1: The public loans of the Aerospace industry from 1987 till
1993
We note an increasing amount of foreign
financing after the adoption. This element has probably been anticipated in the
decision. According to the accounting manager, "the choice of the GAAP deals with the financial strategy, the aim is
eventually a presentation of financial statements according to principles
internationally recognized for an intervention on the American markets.
Aerospace industry is a heavy consumer of funds and the European markets are
too narrow". (Interview with MC). International accounting standards are
adopted to demonstrate a commitment to the international financial community.
It is by anticipation on a voluntary base and not in answer to a constraint
that international standards are adopted.
The company depends very strongly on foreign
customers who represent the two third of the sales. The company has to satisfy
the customers in generally known term. To make the use of international
practices of management is an asset.
Figure 11:
Distribution of the turnover France - foreigner for Aerospatiale
The certification of accounts is anterior to
the adoption. Except the reference to the new standards in their
1989's report: "We confirm you
the changes of methods resulting from the adoption of accounting principles
generally accepted in the international plan" (Report of the auditors
in April 10, 1990), there is no significant change in the process of
certification. Young. Financial statements
are always signed in Paris evenven, if "Castel Jacquet & Associés" is a member of the
international network Ernst & Young Furthermore, the second auditor
called "Robert Mazard" is typically French.
Apparently, the obligations of publications
were already respected before the adoption of IASC's standards. The quotation
of obligations on a foreign stock exchange has taken place since 1987, "at the moment, debenture loans in Francs and
in Eurofrancs were issued on the stock exchange of Luxembourg."
(Interview with MC). Besides, the stocks of the company are not quoted on a
stock exchange,
Neither auditor’s, neither stock exchange seems
to exercise an influence in the adoption of international standards.
The
mimetic isomorphism seems to be a possible explanation for the adoption. All
the elements of mimecry have been identified.
The company faces a situation of uncertainty.
The managers know that they are going to have to face a demand of investor’s
but they do not know the precise nature of this demand. As we saw, managers
explain that needs of funds are probably going to appear and the European
financial market is too narrow. As a consequence, they do not know which
solution to adopt to inform them.
IASC standards are becoming true accounting
standards and not just a kind of “Smaller common multiple” of practices in
different countries.
The institutionalization of IAS's standards is
becoming stronger in 1989 than before at the international level as well as in
the French context. We can say that a structured framework of standards is
emerging and is now competing with US GAAP.
Two reasons explain this tendency. First, from a technical point: new important standards have been recently promulgated in 1990. At the same time, from the institutional point, the IASC is setting up a strategy of alliance with bodies in the field of international accounting to support and to apply standards.
From the technical point, in 1988, the IASC
published "the Framework for the preparation and presentation of Financial
Statement". It objective is to give conceptual foundations to
promulgate standards.
In 1989, the IASC constituted a real framework
of consolidation. According to the table below accounting standards for consolidation (IAS 27, IAS 28 and IAS 31) were
promulgated in 1989.
Figure 3 : the most recent standards of the IASC
The IASC, criticized because of the existence
of alternative treatments become more credible accounting framework in 1989
with the exposure draft 32. By doing so, it undertakes a program towards the
reduction of the number of options allowed by various standards.
From the institutional point, the IASC receives
the approval of important bodies to increase its credibility with regards to
the international financial community.
At international level, the American standards
setter joins the consultative group in 1988 and associates stock-exchange
bodies to his works. The decision of the IASC to start
"comparability project" was strengthened with the support of the
OICV. This support deals with representatives' participation of the OICV (the
chief accountants of the French Stock Exchange, the Ontario Stock Commission
(Canada) and the SEC (USA) in the meetings of working groups dedicated to the
improvement of international standards. The Comparability project takes into
account the opinion of the stock-exchange regulators. One of four criteria used
explicitly to choose between alternative treatments was the "sight of regulators and their
representative organizations, as the OICV ". (IASC, 1989, p. 12)
French actors have an actual role in the structuration of the field. They are strongly involved in the various organizations and, they possibly influence standards promulgated in favor of the French companies. Since 1987, the president of the IASC, Georges Barthes de Ruythers is French. One of the representatives of the OICV is French.
IASC is so becoming legitimate at two levels:
international level and national level. So, the framework is becoming institutionalized
in a field in development
The IASC standards became legitimate in France.
The graph below puts in evidence the number of French companies (except
financial institutions) having adopted internationally recognized standards
(made abstraction of change of alternative standards).
Figure 22:
Number accumulated by adoptions from 1970 till 1996
The IASC has the influence to encourage
adoption of a particular practice but it lacks the influence to mandate them.
Thus, adoption has been done only because managers are receptive to the
standards. Manager’s perceptions seem to play an important role in the
adoption. The company chooses the IAS's because it is justifiable in the eyes
of the accounting director but also because US GAAP does not appear as a
solution. The accounting director would like to apply accounting standards on
which he can weigh: "FASB's is above
all national, standard IAS is a synthesis of continental standards and
Anglo-Saxon standards a bigger common denominator), one can press on these
standards and participate in their elaboration. The Lobbying is very important
because it would be dangerous to apply standards on which one can not weigh." (Interview with MC)
The accounting s back American standards used
by the competitors. Moreover, the comparability with the competitors is a
priority. The competitors of Aerospace industry are not numerous and use
American standards but anyway, their accounting policy is not comparable "Our accounts are careful with regard to
those of Boing which immobilizes the ' triangle of starting up ' then
amortized) on a series of planes. " (Interview with MC). The adoption of US GAAP
does not change the figures.
In the case of Aérospatiale, the relative dependence of the Group on the foreign
stakeholders is condition of the decision of adoption. It explains mimetic
isomorphism Managers were probably a catalyst. No element allows making
reference to possible normative sources.
In 1991, Usinor-Sacilor adjusts accounting
policy to standards promulgated with the IASC "The
group decided to adopt accounting principles generally allowed in the
international plan recommended with international Accounting Standard Committee
(IASC). " (RA 1991, page 12) Besides, it supplies a
reconciliation of net income and stockholder’s equity computed under IAS
standards with corresponding amounts computed under U.S. G.A.A.P. A complete
note of appendices is dedicated to a "summary of differences between accounting principles followed by Usinor
Sacilor and those generally accepted in the United States (US GAAP)."
(RA, 1989) Simultaneously, correspondence with the French law and the decree of
application is always indicated.
Law does not prevent the company from using
international accounting principles which an answer to the pressures of
stakeholders.
Law has a coercive effect on accounting practices,
but, here, paradoxically, it allows departure from practices used in statutory
accounts. So, as in the case of Aérospatiale,
accounting principles, in phase with international principles can be so
implemented. As soon as 1988, most of changes concerning evaluations were
anticipated: consideration of the provisions of pensions, for the French
companies, in 1988 and capitalization of the lease in 1990. The two concomitant
changes of the adoption concern the durations of amortization of Goodwill from 5
to 20 years and the adoption of the SFAS 87 (compatible with the IAS 19).
On the other hand, with the adoption the
presentation of financial statements evolved: the classification of expenses is
now made by destination and not by nature as recommended by the French “Plan comptable” in the income statement,
the presentation of the balance follows the criterion of liquidity and a
statement of cash flow appears.
Officially, that adoption is made to answer the
expectations of the investor’s. The report of the Board of directors clarifies:
"Usinor Sacilor decided to adopt for
the presentation of consolidated financial statements in 1991, accounting
principles recommended by the IASC, principles generally allowed by the
international financial community" (RA, on 1991, page 3).
The search for capital may have played a role
in the adoption. Although the managers of the group do not seem a priori interested in American capital
"The European markets are not
unimportant compared to the volume of American markets. "
(Interview with MG). From 1989 till 1992, the part of foreign financing passes
of less than quarter to almost the half of total financing. That is that the
year of the adoption financing in foreign currencies represents 45 % of the
amount of loans.
Even though the administrators do not intend to
raise capital in the United States, reconciliation with US GAAP is used. Let us
underline that " the technique
of connecting is enough for the comparability with the leaders " (Interview
with MG). By using IAS in financial statements and providing a
reconciliation, the comparability with all the competitors is assured because
"the leaders are Japanese (Japanese
Steel) and Korean; they adopted FASB GAAP. The Europeans (FRG) have IAS GAAP.
" So, IAS GAAP also answers the concern of comparability.
The accounting manager qualifies his comment by
explaining that the choice of the reconciliation was able to exercise only in
technical limits: "no communications
problems provided that distances between figures IAS and US are weak."
(Interview with MG),
Figure 33:
Distances between the accounting indicators calculated according to standards
IAS and FAS (USINOR SACILOR)
The table above quantifies incidence on the net
result and on the stockholders' equity of the two GAAP.
Calculated income following American standards
is systematically more important than the same calculated income following
international standards. The year of adoption, the distance is almost 20 %
(weak for the manager!). It increases later. Stockholders' equities are
systematically more important when they result from the application of the
American standards than according to IAS GAAP.
The group is strongly internationalized because
it realizes the major part of its sales abroad.
Figure 44:
Sales in billions
Adoption corresponds to an internationalization
of the certification. Since, 1991 the certification is made collectively with
an American auditor. So, in 1991, consolidated accounts receive a real
international certification. Accounts remain signed by the French usual
auditors. Arthur Andersen, established in Chicago signs consolidated accounts.
It can explain the use of international. In order to sign accounts the auditors
required the use of credible accounting standards.
The group is not quoted on a stock exchange.
Thus, no particular rules concerning the disclosure of information are applied.
. Nevertheless, a possible privatization is envisaged. The adoption of method
of rational management can serve then to demonstrate that the group, even
though it is controlled by the State, works as the other groups of the sector
or as the other multinationals.
Companies becoming identified as Global Players can opt either for American GAAP, or for IAS GAAP. They will choose the most justifiable which is IAS in European context.
The strategy of legitimization of the IASC
continues. The organization completes a program of modernization in association
with top bodies like stock-exchange regulations, the national and regional
accounting standards setters.
From 1990, a first annual conference, aiming to
help to reach the objectives of comparability standards, was organized by the
Union of the Experts-comptables European
(FEE), the FASB and 19 other standards setters. Since March 1990, the
European Commission has an observer's status within the Board of the IASC. So
the IASC start to be recognized in Europe.
Several persons represented the IOSCO: the
chief accountants of the French Stock Exchange commission and the Ontario Securities Commission (OSC) and
a chief accountant of the SEC and a representative of the UK securities (p.
61).
On the technical plan, the council of the IASC
take place on June 20 and 22 in Paris. The agenda deals with:
" Comparability of financial statement ". (Gélard, 1990b).
At the same time, the project of Comparability was transformed into an improvement project) to implement the
changes of the phase of Comparability. The table below shows that
"Comparability Project" is at the heart of the debates of the
council of the IASC. In a general way, the improvement of existing standards
with the reduction of the number of options in standards is already well moved
at the end of the year 1991.
Figure 55:
the meetings of the council of the IASC in 1990 and 1991
For several years, the totality of the
adoptions of GAAP has been in favor of the IASC. We can say that Usinor-Sacilor
adopts dominant GAAP.
One finds nevertheless a partial disconnection
with the actual accounting policy of the firm that is guided by several American
standards.
The accounting GAAP have more or less an
American substance while appearing to follow at first the IAS confers on the
group a cognitive legitimacy.
The perceptions of the leader influenced the
modalities of adoption. The group is an European group while American GAAP
are perceived at first as national " the GAAP of the FASB are national which sticks on the normalization US
adapted to the American environment." (Interview with MG).
Figure 8: New International's GAAP adoptions from 1985 till 1989
The case of COFLEXIP is interesting, as the group adopts the American norms during a period of strong institutionalization of the IAS standard.
The group Coflexip adopts American standards in
extenso (in their entirety) even if
its practices remain compatible with the French legal frame. The consequences
concern essentially the volume of information published, with the production of
a document 20 - K deposited with the SEC. One notes few changes in the methods
of evaluation, with the exception of the long-term contracts, which are booked
in advance, and not upon completion. On the other hand, the volume of
information to be supplied is all the more important as the company capital was
closed previously. Furthermore, new sizes of presentation appear like the
charges, which are presented by nature.
French law would have been able to prevent
adoption, but the chosen options remain compatible with the French law. Even
though compatibility is less evident than with the IAS. The chosen options
allow to make practices compatible with both GAAP: American and French.
The adoption of American accounting standards
is concomitant in the passage of the status of the company from closed to that
of open company. From none in 1992, the fraction of public capital increased
considerably since 1993 (30 % at the end of 1993 and about 50 % at the end of
the year on 1996). Knowing that shares were emitted only in the United States
in 1993, the American financiers possess a third of the shares at the end of
1993, the company faces explicit pressures of their part because "the addressees of financial status are above all, firstly
the American investors". (Interview with MC) As a consequence, the
financiers associated with the financial analysts play a binding role. Constraint
does not directly result from the quotation, which can be only symbolic but
because this quotation is translated by a real thorough appeal because
" the companies which finance
on the American market are in the obligation to adopt American references, at
least the table of passage. Only the companies, which do not have to be
financed on the American market, face a choice. " (Interview with
JMK) It is not so a choice but on the contrary an answer to an outside
constraint: " The leaders were
convinced that US GAAP standards are not adopted as the result of a
choice but are necessary as a fatality. " They had the feeling
that they could not go on the market without the US GAAP. " (Interview
with M.C.)
There are necessities of hard capital, one was
able to find a " effect of the
sector, required by sector-based comparisons … No French analysts specialized
in this sector… in the United States,
one is confronted with analysts who know the profession. The American analysts
well know the aroundpetrol sector, the companies of these sectors are going so
to prefer to make their placements on
this market " (Interview with M.C.) This effect could have been an
indication of imitation but the comparability, is hoped. So it involves a
precise result.The decision of the analysts to follow certain companies would
even lead to a decision of the investors to increase their participation in the
capital (O’brien and Bushan, 1990)
The phenomenon of transmission of standards
appears to two levels:
-
At the level of
the auditors who have the influence's' role;
-
At the level of
the NASDAQ.
Before the adoption, the firm of auditors in
charge of the certification is a purely French cabinet (Exco-Audit )
represented by Jean-Pierre CORDIER and the French representative of Ernst and Young. Adoption did not bring
about a change as firm of auditors. The representative of an international
cabinet already guaranteed accounts. Nevertheless, everything else unchanged,
the year of adoption of American standards corresponds to the arrival of a
pro-US personality, an American auditor JMK, connected with the French
representative of the group Ernst and Young. The year of adoption, consolidated
accounts are explicitly guaranteed in New York.
The intervention of the auditors as prescriptor
is sure: " JMK's driving, proactive
Role, is its speciality " (Interview with MC) It was facilitated
by the fact that "the President was
not fascinated by accounting problems.". (Interview with MC.) So the
listener was capable of imposing his vision of things. Now, it is evident that
Mister JMK makes a real plea in favor of American standards.
Coflexip has to adopt American standards by
obligation (coercitive isomorphism) but the choice of the GAAP is the resultant
of normative isomorphism..
«The Bank of New York» introduces the company
on the NASDAQ on November 18, 1993. It is about a level quotation III that
has for consequence to increase in a significant way information to be supplied
to the investors. "The adoption of
standards is bound to the NASDASQ. Standard US is repository is the national
reference" (Interview JMK) But To do it, a reconciliation would have
be enough but it was not chosen "no
discussion during the AG, I do not say that the problem was not evoked ".(Interview
with MC) Anyway, " quotation is the decisive factor "
even though the other factors as: " people who played a role, the banks who place the paper maybe, it is
not excluded " ( MC) should be taken into account
Several indications could be interpreted as
being imitation but they are not. At first, the behavior of the firms in the
petrol sector adorned tanker quoted in financial information in United States
is to imitate not because of an uncertainty but for reasons of
efficiency: to return legible accounts for the analysts as indicated above. Then, the leaders were not able to
interiorize standards because, as engineers, they are not familiar with the
accounting department. This case thus questions the generally accepted
hypothesis of the susceptibility of the managers in environmental
prescriptions. The managers allowed themselves to be convinced because they are
foreign to the accounting department and not because they were confronted with
the tools during their training or during their past experiences as indicated
in the literature.
Coercive isomorphism was the catalyst of the
adoption. A double normative isomorphism (pressure of the auditors and
accreditation of the NASDAQ) determined the modalities of the adoption finally retained.
Conclusion puts in evidence the relative place
of various isomorphisms when comparing cases. Then, we insist on the
contribution of the theory, which substitutes a criterion of legitimacy for a
criterion of efficiency to explain the adoption of accounting standards.
Finally, we show which are the limits of this search to open perspectives of
future searches.
The comparison of cases shows that there are
two internationally recognized Accounting framework (GAAP) that answer peculiar
necessities. American standards are adopted because they are beneficial for
companies. By this way, Coflexip fulfills the expectations of the investors and
the American financial analysts and Usinor compares the group with its
Non-European competitors. Standard IAS is adopted because they make
organizations understandable (cognitive legitimacy) in an international
context. Aérospatiale and Usinor, even though they remain controlled by the
French State belongs to the global
Players and therefore they use standards IAS.
Accreditation by the NASDAQ is suitable for
high-tech companies such as Coflexip. Furthermore, in the case of a company as
Coflexip, with leaders rooted in an engineering culture, the auditor played the
role of the influencer's. On the other hand, the auditors do not appear to play
a particular role when the administrators are actively receptiveto the
internationally recognized standards (Aerospace industry), except when
adoption, as in the case of Usinor, is credibly bound to the
internationalization of the certification.
Figure 9: Comparison of cases
The role of legitimacy is not unimportant in
institutional theory as far as a fundamental consequence of the isomorphism is
the acceptance of the organization by its external environments, that is the
organizational legitimacy. Recently, legitimacy was defined an " hypothesis or (a) generalized perception
that the actions of an entity are desirable, appropriate and suited inside a
system of standards, values, faiths and definitions that are socially
constructed " (Schuman, 1995, p. 574) The rationality of
institutional theory is based on the legitimacy. This constitutes the
regulating mechanism by being a functional alternative to efficiency, that is
that organizations can look not for the efficiency of the result but for
legitimacy by conforming to the expectations of the environment on the way things
are done. Within a field a tendency towards conformity, called isomorphism, is emerging.
Figure 10: links between institutional pressures and legitimacy
Institutional theory is not a theory of
organizational change but an explanation of the similarity and the stability of
institutional classifications in a field or a given population. The adoption of
international accounting standards is not so the result of a change but the
product of a registration in an institutional field, in an arena. Maybe it
explains " the contextual dynamics which precipitate the organization
towards the change " (Greenwood and Higgins, 1996 , p. 1003) but it does not allow to say
exactly why organizations adopt certain practices while the others do not in spite of identical institutional
contexts. The theory is not strong enough to analyze the internal dynamics of
the change. Recent works recognize that organizations influence, escape and
resist to institutional pressures (Oliver, on 1991). This open perspectives for future
research.
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Figure
1: The public
loans of the Aerospace industry from 1987 till 1993
|
Date issue) |
AMOUNT |
Interest |
Type |
|
1973 |
Loan Gifos / Ufremer |
|
|
|
1984 |
|
TMO |
Dom |
|
1984 |
|
TAM |
Dom |
|
1987 |
75 billions Ecus |
75/8% |
Inter |
|
1987 |
True 600 billions Luxemburg |
7,5 % |
Inter |
|
February, 1991 |
1000 BF |
9,6 % |
Dom |
|
September, 1991 |
1000 BF |
9,4 % |
Dom |
|
September, 1991 |
100 Billions Ecus ( 698 MF) |
9 ¼ % |
Inter |
|
February, 1992 |
140 BF |
Zero coupon |
Dom |
|
March, 1992 |
1 000 BF |
9,375 % |
Inter |
|
March and June, 1992 |
1 800 BF |
9,125 % |
Inter |
|
November, 1992 |
1 000 BF |
8,7 % |
Dom |
|
February, 1993 |
1 000 BF |
8,375 % |
Inter |
|
May, 1993 |
100 Billions Swiss francs
(377 MF) |
4,75 % |
Inter |
|
July, 1993 |
1 500 BF |
7 %- |
Inter |
Figure
2: Distribution
of the Sales France - foreigner for
Aerospatiale
|
|
France |
|
Export |
|
Total |
|
1993 |
16388 |
0,32 |
34462 |
0,68 |
50850 |
|
1992 |
19829 |
0,36 |
35427 |
0,64 |
55256 |
|
1991 |
17090 |
0,35 |
31496 |
0,65 |
48586 |
|
1990 |
15846 |
0,45 |
19391 |
0,55 |
35237 |
|
1989 |
13699 |
0,40 |
20204 |
0,60 |
33903 |
|
1988 |
13088 |
0,34 |
25129 |
0,66 |
38217 |
Figure 3: Most recent
standards of the IASC
|
E28: The posting of participations in the
associated companies and the joint ventures (in July, 1986) |
|
" Framework for the preparation and
the presentation of financial statements " (ED, may1988) |
|
E32: Comparability of Financial Statements (January, 1989) |
|
IAS 27: Consolidated Financial statement and
accounting for investments in subsidiaries. (In April, 1989) |
|
IAS 28: Investment in associated companies
(April, 1989) |
|
IAS 29: Financial Reporting in
Hyperinflationary Economies (July, 1989) |
|
E35: Financial Reporting of Interests in Joint Ventures (December, 1989) |
|
IAS 31: Financial Reporting of
Interests in Joint Ventures (December,
1989) |

Figure 4: Number
accumulated by adoptions from 1970 till 1996
Figure 5: Distance between US GAAP and IAS GAAP for Usinor Sacilor
|
|
1991 |
1992 |
1993 |
1994 |
|
Net
result (Franco-IAS) |
-3032 |
-2421 |
-5741 |
1006 |
|
Net
result US GAAP |
-2556 |
-1867 |
-5062 |
1713 |
|
|
-476 |
-554 |
-679 |
-707 |
|
|
-0,19 |
-0,30 |
-0,13 |
-0,41 |
|
Stockholders'
equity Franco-IAS |
23669 |
20973 |
15080 |
16012 |
|
Stockholders'
equity US GAAP |
24325 |
22283 |
17119 |
19862 |
|
|
-656 |
-1310 |
-2039 |
-3850 |
|
|
-0,03 |
-0,06 |
-0,12 |
-0,19 |
Figure 6: Sales in France and abroad for Usinor Sacilor
|
|
1991 |
|
1992 |
|
1993 |
|
1994 |
|
|
France |
33157 |
34,12
% |
28
483 |
32,76
% |
24237 |
32,18
% |
25227 |
31,75
% |
|
The
other EEC |
38851 |
39,98
% |
37
288 |
42,88
% |
27363 |
36,33
% |
28623 |
36,02
% |
|
The
United States |
12049 |
12,40
% |
10
455 |
12,02
% |
11222 |
14,90
% |
13337 |
16,78
% |
|
Rest
of the world |
13120 |
13,50
% |
10
724 |
12,33
% |
12487 |
16,58
% |
12271 |
15,44
% |
|
Total |
97177 |
|
86950 |
|
75309 |
|
79458 |
|
Figure 7: Sales in billion (Usinor-Sacilor)
|
Place
and date |
Important
decisions |
|
Amsterdam (March, 90) |
Tables of streams, immaterial immobilizations,
comparability financial statements, standards of the PVD, financial
statements of banks and assimilated establishments and financial instruments |
|
Paris (June, 90) |
Project of standard on the financial
statement of banks, project of statement of intention
" Comparability of financial statement ", project on the
posting of the immaterial |
|
JULY 1990 |
Statement of Intent - Comparability of Financial Statements |
|
Singapore (November, 90) |
Exam of E35 for approval, profit by action,
reaction to the contents of the project on the immaterial, project on
financial instruments |
|
London (February, 91) |
Publication of a statement - sounding on the
statement of cash flows and statement - sounding on the expenses R&D |
|
Milan (June, 91) |
Two texts (IAS 2 on the evaluation of stocks
and IAS 23 on the capitalization of interest charges) within the framework of
the statement of intention following on the project of comparability |
|
Seoul (November, 91) |
Approval of 3 statements soundings (IAS 11,
18 & 22) |
Figure 9: New International's GAAP adoptions from
1985 till 1989
|
|
Companies |
1ière adoption |
Following changes |
|
20 |
DMC |
Inter, 1986 |
IASC, on 1987 |
|
21 |
Lagardère Groupe |
Inter, 1986 |
Application of the FAS 52
since 1982 |
|
22 |
Air(sight) France |
IASC, 1986 |
|
|
23 |
Clarins |
IASC, 1986 |
|
|
24 |
Total |
IASC, 1988 |
Desolation IASC in
31/12/95 SFAS 87 , 95 , 106, 109 ,
115 and 119 in 1994 SFAS 13 , 19 , 52 in 1995 |
|
25 |
Essilor |
IASC, 1988 |
|
|
26 |
Télémécanique |
Inter, 1989 |
IASC, on 1990 |
|
27 |
Aerospace industry |
IASC, 1989 |
|
|
28 |
Bongrain |
IASC, 1989 |
|
|
29 |
Canal + |
IASC, 1989 |
SFAS 53 in the 31 12 95 |
|
30 |
CBM PACKADGING |
IASC, 1989 |
Disappearance in 1992 |
|
31 |
Schneider |
IASC, 1989 |
IASC and |
|
32 |
Valeo |
IASC, 1989 |
|
|
33 |
Axe Guérin |
IASC, 1990 |
|
|
34 |
Pinault |
IASC, 1990 |
Desolation of the
reference in 1991 |
|
35 |
Moulinex |
IASC, 1991 |
|
|
36 |
Usinor |
IASC, 1991 |
SFAS 87 and SFAS 106 in
1991 SFAS 106 and SFAS 109 in
1992 |
|
37 |
OCP |
IASC, 1/10/1991 |
|
|
38 |
Five-Live |
Inter, 1993 |
|
Figure10: Links between institutional pressures and legitimacy
|
Institutional
pressures |
Isomorphisms |
Collective
rationality |
|
Pressure |
Compulsory standards |
Pragmatic legitimacy |
|
Transmission of standards |
Recommended standards |
Moral legitimacy |
|
Imitation |
Used standards |
Cognitive legitimacy |