Abstract (EN)

A number of studies have attempted to compare modes of regulation of the accounting profession in different countries. Because their wide scope, most of these studies don’t achieve the level of insight given by local researches. Therefore, it appears necessary to focus on one of these topics. This paper presents a comparison of the disciplinary process of the accounting profession of two countries considered as extremely different: the United States and France. Baker et al. (2005) studied the differences in regulation of the accounting profession (especially the one of statutory audit) in these two countries. They found that the preponderant modes of regulation were a mix of “associationism” and “legalism” in the United States, while a mix of legalism and corporatism in France. If this interpretation seems mostly accurate, the paper suggests that this classification is not exactly true when considering the disciplinary process of the accounting profession in the United States and in France. As a matter of fact, it appears that beyond differences, those countries are fairly close in matter of the power of the State within the disciplinary process, as well as in the nature and the number of disciplinary sanctions taken against public accountants and auditors.