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The European Confederation of Institutes of Internal Auditing (ECIIA) is a confederation of national associations of internal auditors speaking for the profession in the wider geographic area of Europe and the Mediterranean basin. It represents a membership base of over 40,000 internal audit professionals. The ECIIA is an associated organisation of the global Institute of Internal Auditors (The IIA), a professional body with more than 181,000 members in some 190 countries. Throughout the world, The IIA is recognised as the internal audit profession's leader in certification, education and research regarding internal auditing. The IIA also maintains the International Professional Practices Framework (IPPF) which includes the International Standards for the Professional Practice of Internal Auditing, the definition of internal auditing, the code of ethics, practice advisories and other guidance.
The ECIIA welcomes the proposed update of the EBA Guidelines on Internal Governance (as described in EBA/CP/2016/16), and is grateful for the opportunity to contribute. We attach in the appendix some specific comments and proposals and would like in this regard to highlight one key point.

The general impression given throughout the Guidelines is that internal audit is understood solely as a traditional and simple control function, checking and confirming adherence to existing rules. However, internal audit has developed significantly in the past decade; and it now plays an important supporting role to management across the range of its management and supervisory functions, giving assurance, advice and insight. This is not clearly reflected in the Guidelines. These Guidelines are not the place to go into exhaustive detail: but we feel that it is essential at least to give a brief mention to this aspect of internal audit, and accordingly we have proposed some brief additions to the text, particularly a new short paragraph 186. We would be very happy to discuss our comments and proposals further with you, if you would find that helpful.

We hope you will find our input useful. Please do contact us if you have any questions or if there are any issues you would like to discuss.

H Stein-ECIIA President TH. Thouvenot-ECIIA Board Member