Funktion und Stellung des Abschlussprüfers nach deutschem und englischem Recht

The recent EU reforms of the law concerning the annual auditing have given reason to examine the changes of the auditor’s role in corporate governance. By comparing German and English law, these changes become apparent. Starting from the beginnings of auditing, the author demonstrates how national corporate governance movements and reforms initiated by the EU have caused the perceptions of the function and position of the auditor to converge considerably, and that the same applies to the corporate governance of both countries. The intention of this work is to document the success of both national and European reforms in these legal areas while also discussing which issues still have to be dealt with in the future.