Interlingual translation of the International Financial Reporting Standards as institutional work

This is a self-archived version of an original article. This version may differ from the original in pagination and typographic details. Author(s): Title: Year: Version: Copyright: Rights: Rights url: Please cite the original version: CC BY-NC-ND 4.0 https://creativecommons.org/licenses/by-nc-nd/4.0/ Interlingual translation of the International Financial Reporting Standards as institutional work © 2016 Elsevier Ltd. Accepted version (Final draft) Kettunen, Jaana Kettunen, J. (2017). Interlingual translation of the International Financial Reporting Standards as institutional work. Accounting, Organizations and Society, 56, 38-54. https://doi.org/10.1016/j.aos.2016.10.001 2017 1 This is the final draft of the following article: Kettunen, J. (2017). Interlingual translation of the International Financial Reporting Standards as institutional work. Accounting, Organizations and Society, 56, 38-54. As standard-setting and regulation take place in an increasingly transnational and multilingual context, accounting concepts travel across borders and languages. On a global scale, the transnational standards originally written in the English language are ultimately translated into financial statements prepared in dozens of different languages. When regulatory texts such as accounting standards are initially drafted, accounting facts are constructed in the regulation process by labelling particular matters with either newly coined or existing accounting terms (Gröjer, 2001; Hines, 1988; Young, 2003). Thereafter, accounting standards are translated into other languages. Despite the rise and spread of English-language regulations (Botzem & Dobusch, 2012; Chua & Taylor, 2008; Djelic & Sahlin-Anderssen, 2006; Mennicken, 2008), we know very little about the processes and related practices that facilitate the use of these standards in non-Anglophone countries. Using the Finnish translation of the International Financial Reporting Standards (IFRS 1 ) as a primary object of investigation, this paper analyses how the IFRS 2 originally drafted in English are translated from one language (the source-language) into another (the target-language), and how the 1 For a list of abbreviations, see Appendix 1. 2 In this paper, the acronym IFRS is used to refer both to a single standard and to more than one standard or the entire set. 1. Interlingual translation of International Financial Reporting Standards as institutional work 2 problems of linguistic equivalence that arise during the translation are handled in their social and institutional context. The article also shows that the translation of the IFRS is a contested area of expertise, and the translation work is governed by different regulators. In this paper, the concept of translation refers to the rendering of a source-language text into the target-language. The limits of interlingual translation are well recognised in the academic field of translation studies, and scholars have argued that very rarely will a translation both render the original text wordfor-word into another language and convey its meaning unchanged (e.g., Catford, 1978; Nida, 1964; Toury, 1995). Moreover, several studies have suggested that accounting is conceptualised in different ways in different languages and their related cultures, which may impede the translation of transnational standards (e.g., Evans, Baskerville, & Nara, 2015; Zeff, 2007). Indeed, the perceived lack of equivalence between languages is manifest in the concerns expressed by academics, professional accountants, 3 and some representatives of European Union (EU) Member States 4 over the adequacy, readability and comprehensibility of the translated IFRS (Dahlgren and Nilsson, 2012; Hellmann, Perera, & Patel, 2010; Nobes, 2006; Sunder, 2011; Wong, 2004). This article makes the following contributions to the field. First, it extends the literature examining transnational accounting regulation (e.g., Botzem & Dobusch, 2012; Cooper & Robson, 2006; Erb & Pelger, 2015; Gillis, Petty, & Suddaby, 2014; Mennicken, 2008; Pelger, 2016). The translation of the IFRS has a unique position at the interface of development, interpretation and implementation of regulations. The article shows that translation processes are governed by transnational regulators – the IFRS Foundation and, within the EU, the European Commission (EC) – and that the translation work involves multiple, often changing, constituents. In doing so, the article 3 See http://www.ifac.org/sites/default/files/publications/files/challenges-and-successes-in.pdf 4 See Thyssen, Marianne (2011). Question for written answer to the European Commission http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//TEXT+WQ+P-2011008747+0+DOC+XML+V0//EN 3 responds to the continued calls to study the development and interpretation of accounting regulations in their social context (Canning & O’Dwyer, 2013; Cooper & Robson, 2006; Humphrey, Loft, & Woods, 2009; Suddaby, Cooper, & Greenwood, 2007). It also responds to the call by Mennicken to investigate ‘the networks of actors, instruments and the activities that support … standardising agendas in local settings’ (Mennicken, 2008, p. 385). Second, by shifting the focus on how translators and translation reviewers address the practical issues of linguistic equivalence, the current research makes a methodological contribution to the literature on the translation of accounting regulations. The problematics of translation in the domain of accounting have previously been addressed by conducting experimental studies (e.g., Doupnik & Richter, 2003), comparing excerpts from translated accounting standards with their English language counterparts (e.g., Dahlgren & Nilsson, 2012; Nobes, 2006) or analysing English-language accounting concepts in comparison to those in other languages (e.g., Evans, 2004; KosmalaMacLullich, 2005). The current article examines the translation of IFRS as a social and institutional practice or, more specifically, as institutional work required to establish and maintain IFRS as a global, multilingual institution (Lawrence & Suddaby, 2006). It provides an empirically grounded understanding of the practical problems of linguistic equivalence, and how they are addressed by translators and translation reviewers. Accordingly, the article highlights the constructed and negotiated nature of linguistic equivalence. This is a novel contribution to the literature because the extant studies pertaining to the translation of the IFRS (e.g., Dahlgren & Nilsson, 2012; Evans et al., 2015; Huerta, Petrides, & Braun, 2013) tell us very little about the activities involved in the creation of these translations. The remainder of this article proceeds as follows. The following section describes the theoretical background to the study. Section three serves as an introduction to the case of translating IFRS into the Finnish language by describing the regulatory context in which the translation of IFRS takes place. Section four provides an outline of the case selection, research methods and empirical 4 materials. Section five analyses how translations of IFRS are created and how the problems of linguistic equivalence are handled in practice by those involved in the translation work. It also illuminates how the translation of the IFRS is a contested area of expertise. The final section presents a concluding discussion of the main arguments and opportunities for future research. This section begins with a review of how prior accounting literature has examined translation in the context of transnational accounting regulation. It then offers a brief overview of how scholars in linguistics and translation studies have conceptualised translation. In particular, the notion of equivalence is introduced to conceptualise the general problematic of translation. Further, the concept of intertextuality is introduced for the analysis of how translators and translation reviewers attempt to make sense of the source text and search for equivalent target-language terms and expressions. In order to shed light on the practical actions through which linguistic equivalence is produced in the translation of the IFRS, the paper draws on the concept of institutional work, which is discussed in the fourth subsection. The final subsection offers a summary. 2.1 Previous research on translation of accounting regulations 2.1.1 Translation as a barrier to transnational accounting harmonisation An emerging body of literature considers translation to be a potential barrier to transnational accounting harmonisation (Baskerville & Evans, 2011; Dahlgren & Nilsson, 2012; Doupnik & Richter, 2003; Evans et al., 2015; Hellmann et al., 2010; Nobes, 2006, 2013; Sunder, 2011; Zeff, 2007). Some scholars point out that translation might change the intended meaning of a regulation, which, in turn, might hinder transnational harmonisation of accounting practices (e.g., Dahlgren & Nilsson, 2012; Holthoff, Hoos, & Weissenberger, 2015; Nobes, 2006, 2013; Sunder, 2011). The 2. Literature Analysis: Translation 5 following paragraphs introduce the different approaches accounting scholars have taken to studying the translation of accounting regulations. Thereafter, the next subsection describes how the empirical topic of the current article complements these approaches and contributes to the wider literature on transnational accounting regulation. First, there is a tradition of conducting experimental research on the translation and interpretation of expressions of probability and uncertainty (such as reasonably possible, probable and virtually certain) in accounting and auditing standards (e.g., Davidson & Chrisman, 1993; Doupnik & Riccio, 2006; Doupnik & Richter, 2003, 2004; Huerta et al., 2013). Experimental studies follow the positivist research tradition in that they apply quantitative methods to examine whether speakers of one language interpret uncertainty expressions differently than speakers of another language. The findings from these studies suggest that the concepts underlying the words differ between languages, which may have a bearing on how adequately uncertainty expressions, and consequently accounting and auditing standards, are translated into other languages (Davidson & Chrisman, 1993; Doupnik & Riccio, 2006; Doupnik & Richter, 2003). Further, the translation of uncertainty expressions (Huerta et al., 2013) and their interpretation (Aharony & Dotan, 2004; Doupnik & Richter, 2003; Laswad & Mak, 1997; Simon, 2002) differ among individuals who are native speakers of the same language. Based on the findings of experimental studies, researchers have concluded that inconsistent interpretation of uncertainty expressions by preparers of financial statements with different native languages can lead to the inconsistent application of accounting standards, especially given that accounting standards include such expressions in abundance (e.g., Doupnik & Riccio, 2006; Doupnik & Richter, 2003). Although languages are embedded in cultures, experimental studies have sought to disentangle the language effect from the culture effect. These two effects have been conceptualised through different theories. Both Davidson and Chrisman (1993), and Doupnik and Richter (2003), conceptualised their studies on different language groups with reference to the notion of linguistic 6 relativism and the Sapir–Whorf hypothesis, which suggests that ‘grammatical forms and categories provided by a language are thought to affect the manner in which speakers of a given language interpret the world’ (Doupnik & Richter, 2003, p. 19; see also Sapir, 1949). The differences in the interpretation of uncertainty expressions between cultural groups (in contrast to language groups) have been hypothesised based on the Hofstede–Gray framework on how national culture affects accounting values (Doupnik & Richter, 2004; Doupnik & Riccio, 2006; Gray, 1988; Hofstede, 1980). Collectively, the studies on probability and uncertainty expressions have provided insights into the interpretation of a very specific category of words. These studies suggest that in the context of accounting and auditing standards there are practical issues around equivalence between languages. However, they do not tell us much about the range of translation problems, or how the translators or those who apply the standards attempt to address these issues. The second stream of research that has addressed the translation of accounting regulations comprises studies that analyse the translated accounting terms in comparison to their Englishlanguage counterparts. Applying qualitative analysis, such as back-translation into English, these studies have often concentrated on terms representing vague concepts such as fair presentation and a true and fair view (TFV) (Aisbitt & Nobes, 2001; Evans, 2003, 2004; Kirk, 2006; KosmalaMaclullich, 2003; Kosmala-Maclullich, 2005; Nobes, 2009; Ordelheide, 1993; Walton, 1993; Zeff, 2007). Some studies have argued that the translation of TFV into other languages has been inconsistent (Nobes, 2009; Nobes, 2013). For example, German translations have rendered true and fair and fair identically, and Danish and Swedish translations include only one signifier for true and fair (Aisbitt & Nobes, 2001; Dahlgren & Nilsson, 2012; Nobes, 2009). Furthermore, when the examined target-language terms are translated back into English, many of the literal back-translations do not correspond to TFV (Nobes, 2009, 2013). Despite the merits of studies on TFV, back-translation as a method of analysis has certain limitations. When a target-language term is back-translated into the source-language, the back- 7 translation can introduce new shifts in meaning. Therefore, comparisons of a source-language term, (such as TFV) and the back-translated term (such as true and sufficient picture) can provide only a limited insight into the quality of a translation. Although back-translation may illustrate whether the translation from source to target-language is a direct translation, it does not address the issues around conceptual equivalence (Douglas & Craig, 2007). Kosmala-Maclullich (2005) surveyed Polish accounting practitioners and found a lack of consensus on the most appropriate translation of TFV into Polish. She argued that this finding reflects the local unfamiliarity with the concept which has been predominantly constructed in the British and American context, and raises issues about the (un)transferability of concepts such as the TFV across languages and cultures. Similarly, it has been argued that the direct translation of other fundamental accounting terms, such as gains and impaired, can be problematic because the closest equivalent target-language terms are defined differently in the local accounting regulations than in the IFRS (Dahlgren & Nilsson, 2012; Evans et al., 2015; Huerta et al., 2013; Mourier, 2004; Zeff, 2007). Third, recent studies point to overt mistakes or inaccuracies in translations that alter the meaning of the IFRS (Dahlgren & Nilsson, 2012; Hellman et al., 2010; Nobes, 2013; Sunder, 2011). For instance, ‘unless the risk is not material’ has been replaced with ‘såvida risken inte är väsentlig,’ which means, unless the risk is material in the Swedish translation (Dahlgren & Nilsson 2012, p. 49), and need not has been translated into German as, weder noch, which is a prohibition (Hellmann et al., 2010). These findings echo the ‘anecdotal stories of how Turkish or Japanese translations deviate from the intent of the original,’ which, according to Sunder (2011, pp. 301–302) are ‘difficult to evaluate in the absence of unanimity behind bilingual authoritative voices.’ Furthermore, Nobes (2006) discussed the Norwegian translation of International Accounting Standard (IAS) 41, para. 34, which requires an unconditional government grant related to a biological asset to be recognised as income when the grant becomes receivable. Receivable is expressed as mottas in the Norwegian version, meaning received, an interpretation that might postpone recognition of the given income and, 8 thus, not match the intention of the original standard. These studies have argued that inaccurate translations can compromise the comparability of the IFRS financial statements. 2.1.2 Translation work in the context of transnational accounting regulation Existing literature has not addressed the translation practices or work involved in attempting to produce acceptable linguistic equivalence in translated accounting and auditing standards in detail. In relation to experimental studies on translation and those examining inaccuracies or inconsistencies in translated regulations, the current article’s contribution is to focus on the translation work and procedures through which transnational accounting regulations are translated. As Toury, a translation theorist, noted, ‘there is no real point in the product-oriented study [of translated texts] without taking into account questions pertaining … to the strategies governed by the norms of establishing a “proper” product’ (Toury, 1995, p. 13). Accordingly, the current study analyses how translators and translation reviewers seek to render the meaning by means of the target-language and make English-language accounting concepts transferable to other languages. Thus, it does not focus on (the inaccuracies or inconsistencies in) the products of translation, and instead, steps back and provides detailed insights into the institutional work required to reproduce the IFRS in other languages. 5 Studying the translation of the IFRS as social and institutional practice contributes to the wider literature on accounting regulation because translation lies at the interface between transnational standard-setting and local implementation. If we wish to understand how transnational accounting standards are created and then translated into accounting practice in a multitude of settings, it is 5 Some accounting scholars have briefly acknowledged that the IASC/IFRS Foundation has developed and put in place a particular translation process for IFRS, including a review by accounting experts (Baskerville & Evans, 2011; Dahlgren & Nilsson, 2012; Evans et al., 2015; Huerta et al., 2013). Evans et al. (2015) referred to a similar translation process for the International Standards of Auditing (ISA). 15 activity rather than one-off event. As new standards are issued and existing ones amended, the IFRS as a translingual institution requires constant maintenance. Following the practice tradition, Lawrence and Suddaby (2006) view institutional work as intelligent, situated institutional action. A practice orientation has been compared to process-oriented studies: Studies of practice focus on ‘the internal life of the process’ (Brown & Duguid, 2000, p. 95 in Lawrence & Suddaby, 2006, p. 218). A ‘practice perspective highlights the creative and knowledgeable work of actors which may or may not achieve its desired ends and which interacts with existing social and technological structures’ (Ibid., p. 219). Accordingly, the current study examines the practical actions undertaken by translators and translation reviewers to render the IFRS into another language while adhering to translation policies set by the standard-setters. 2.5. Summary Research on the translation of accounting regulations has been conducted in relation to (i) the problems of translating expressions of uncertainty in accounting and auditing standards, (ii) the incompatibility of accounting concepts in different languages and (iii) inaccuracies in some IFRS translations. In turn, linguistics and translation studies have suggested that perfect equivalence between languages does not exist. Translators therefore need to balance the different linguistic characteristics of the target text, and the ways in which they correspond to the source text. Furthermore, translation unavoidably involves interpretation of the source text and tends to lead to at least subtle changes in meaning. As translation is not merely a technical exercise, it warrants research within the complex arena of transnational regulation. This paper attempts to address the institutional work employed to produce language translations of the IFRS. The following section introduces the translation and language policies of the IFRS Foundation and the European Commission (EC) concerning IFRS. 16 The working language of the IASB is English, and the standard-setter has stated that the approved version of any discussion document or IFRS should be in English. 9 The IASB also acknowledges that the high-quality translation of the IFRS into other languages is imperative for the international distribution and use of its standards. 10 The IFRS Foundation has its own translation, adoption and copyright policies, which includes a specific translation and review process involving accounting experts. 11 The IFRS Foundation argues that in order to ‘ensure that IFRS remain uniform across all languages and that translations are of the highest standards, the IFRS Foundation maintains ultimate control over the translation process for IFRS.’ 12 However, within the EU, the Directorate General for Translation (DGT) for the EC is in charge of the translation of IFRS because the endorsed standards are enacted as EC regulations. The EC regulations, including the IFRS as adopted by the EU, are equally legally binding in all official EU languages (EC, 1958, 2002; see also Nobes, 2013). In other words, the DGT currently provides the legally binding translations of the endorsed IFRS. The main difference between the translation policy of the IFRS Foundation and that of the DGT for the EC is that while the IFRS Foundation’s translation policy requires a ‘review by a committee of accounting experts who are native speakers with proven knowledge and expertise in the area of the IFRSs’, 13 the translation policies of the DGT do not require any review by accounting 9 http://www.ifrs.org/Use-around-the-world/IFRS-translations/Pages/IFRS-Translation-Review-Committees.aspx 10 IASB. 2008. Changes and challenges. IASB Insight, Q1/Q2: 1 http://www.ifrs.org/Archive/INSIGHT-journal/Q1-andQ2-2008/Documents/INSIGHT_Q1Q208_lowres.pdf 11 http://www.ifrs.org/Use-around-the-world/IFRS-translations/Pages/Official-translation-process-and-policies.aspx 12 http://www.ifrs.org/Use-around-the-world/IFRS-translations/Pages/IFRS-translations.aspx 13 See http://www.ifrs.org/Use-around-the-world/IFRS-translations/Pages/Official-translation-process-and-policies.aspx 3. Introduction to the Case: Situating the Translation of IFRS in the Regulatory Context 17 experts. 14 Consequently, not all legally binding EU language translations are reviewed by accounting experts and/or approved by the IFRS Foundation. Figure 1 depicts the steps for official translation of the IFRS as set out by the IFRS Foundation. This study sheds light on the institutional work employed in the construction of acceptable linguistic equivalence in translation by providing insights into what happens within and between the steps circled in the figure. [Insert Figure 1 here] Figure 1. The IFRS Foundation translation process 15 Each translation review committee (TRC) has a translator and a coordinator 16 , and TRCs are composed of representatives of the large and mid-tier accounting firms, financial statement preparers, academics, and specialists from industries such as the banking and insurance sectors, all of whom are native speakers of the target-language. Translations are further controlled by the IFRS Foundation’s translation coordinator who is based in London. The users of financial statements are not, however, represented on the TRCs which reflects the general tendency of the users not being actively included in standard-setting (Durocher & Gendron, 2011; Hopwood, 1994; Young, 2006). The IFRS Foundation has set the objectives for the review process: The purpose of the review process is to ensure the accuracy of the translated text compared with the English original. The purpose of the translation is not to interpret or 14 Verbal communication with the DGT translator. 15 Adapted from http://www.ifrs.org/Use-around-the-world/IFRS-translations/Pages/Official-translation-process-andpolicies.aspx 16 The Finnish TRC differs slightly from that of other countries in terms of the distribution of its work; The Finnish translator also coordinates the TRC. 18 explain the standards, but merely to render the meaning of the English text in another language. Consequently, Review Committee members may not add, reduce, or alter in any way the substance and the content of the standards and interpretations as approved by the International Accounting Standards Board, although grammatical and syntax adaptations to improve the readability of the text in the language in question are acceptable. (Terms of Reference, IFRS Foundation) This excerpt from the Terms of Reference (for TRCs containing instructions set by the IFRS Foundation on composition of the TRCs, workflow and principles of translation: unpublished) sets out multiple goals: the concern with ensuring the accuracy of the target-language text compared with the English original and a prohibition against interpreting or explaining the text. With regard to the literature on translation introduced in the previous section, the goal of ensuring accuracy compared with the English source text seems an ideal lacking a clear path to its realisation. Translation of the IFRS into Finnish started in 2002. The Finnish TRC originally consisted of a translator and three reviewers. Today, it comprises a translator and 19 reviewers including one representative from the Accounting Regulatory Committee, one from the Ministry of Employment and the Economy, and an observer from the DGT. The Finnish translations, which the TRC produces in cooperation with the DGT for publication in the Official Journal of the European Union, are approved by both the EU and the IFRS Foundation. 4. The Research Setting, Data and Methods 19 A purposive sampling strategy was employed to select the case (Miles & Huberman, 1994). In order to examine translation of the transnational regulations in the realm of accounting, the IFRS were selected for the following reasons: first, such translations are as legally binding as the original English-language standards; second, in the vast majority of countries where financial statements are prepared in accordance with the IFRS, those preparing the financial statements are not native speakers of English. Therefore, many of them are likely to rely on the translated IFRS. The analysis of the practical problems of linguistic equivalence investigates how translation is conducted in practice. This article explores and examines the case of the Finnish translation of IFRS as an illustration (Siggelkow, 2007) of the translation of transnational regulations. As indicated above, the activities and interactions related to translation have received scant attention in the contextualist research even though translation has a unique position at the interface between transnational standard-setting and local implementation. Because it is the native language of the researcher conducting the interviews, the Finnish language was selected to avoid additional translation issues in the exchanges between the researcher and the interviewees (Welch & MarchanPiekkari, 2006; see also, Sunder, 2011). It also allowed the researcher to examine the archival records in the target-language. The Finnish language belongs to the Finno-Ugric language group within the Uralic language family, in contrast to English and, for example, French, German and Swedish, which are of the IndoEuropean language family. Finnish vocabulary and syntax differ substantially from those of English. For example, the Finnish language does not differentiate between him and her, and there are neither prepositions nor articles in Finnish. This can be illustrated by a simple example: ‘in the house’ translates literally to Finnish with one word, talossa, and the ending of the word indicates a meaning that is similar to an English preposition. The specifying meaning, which the definite article ‘the’ carries, is lost in translation. In addition to the languages having different roots, the translation of IFRS between the language pair English-Finnish is further complicated by the fact that the respective 20 legal systems have little in common. Accordingly, translation issues are to be anticipated (Baskerville & Evans, 2011; Evans et al., 2015). From the institutional viewpoint, translation into Finnish is representative of translation within the EU in that all EU language versions of the endorsed IFRS are equally legally binding. The Finnish case is particularly interesting as the translations are also created in accordance with the official translation process set out by the IASB. 17 In other words, the same Finnish translation is approved by both the IASB and the EU. Examples of such IASB-approved translations also exist for German, Japanese, and Russian translations but not those in Estonian, Italian or Swedish. 18 An enquiry into translation into Finnish thus allows us to examine the creation of the IASB-approved translations. In order to understand the translation work and the interactions between the translators and the accounting professionals reviewing the translations, semi-structured interviews were carried out with eleven Finnish TRC members including the TRC translator, and one professional translator working for the DGT in Brussels. The empirical part of the research project commenced in June 2010 with a meeting with the TRC translator in Finland. The data analysis was interwoven with data collection to guide later interviews and to select archival data for closer analysis (Miles & Huberman, 1994). The initial three-hour interview with the key informant helped in phrasing questions for the subsequent interviews. The TRC translator also provided documentary material including Terms of Reference for TRCs [including instructions set by the IFRS Foundation about the composition of the TRC, workflow and principles of translation (unpublished)] and minutes from meetings where decisions on terminology had been made. 17 http://www.ifrs.org/Use-around-the-world/Documents/Jurisdiction-profiles/Finland-IFRS-Profile.pdf 18 http://www.ifrs.org/Use-around-the-world/IFRS-translations/Pages/Available-translations.aspx 21 The preliminary idea for the research was to explore the types of linguistic problems inherent in translating accounting regulations, given the references to such problems in the prior literature published around the time of the transition to the IFRS in the EU (e.g., Doupnik & Richter, 2003; Evans, 2004; Nobes, 2006; Zeff, 2007). It was soon discovered, however, that not only are the challenges of translation are extensive, but that the translation processes are far more complex and are more heavily influenced by the different regulators than the prior academic literature and publicly available materials had indicated. Specifically, the recurrent shifts between the EU and IFRS Foundation in the governance of translation have resulted in recurring changes in the translation practices and in the constituents who participate in translation. 19 Therefore, I decided to broaden the investigation to include the work required to address the practical problems of equivalence between languages. The interviews yielded more than 16 hours of material, of which 12 could be directly transcribed from audiotape. While the TRC members were invited to participate in the interviews for this study based on their roles on the committee, it is important to note that the work of translation is not their principal duty as accounting professionals. All the interviewees apart from the DGT translator were senior accounting professionals, and the group included advisory directors in accounting firms as well as senior accounting experts from financial supervisory authorities (see also IFRS Foundation, 2012, p. 1 for the composition of TRCs). The data from the interviews were supplemented with a diverse range of documents including excerpts from the translated standards. The archive data proved central to understanding the translation work and conceptualising the more general problems of translation through specific 19 See http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//TEXT+WQ+P-2011008747+0+DOC+XML+V0//EN 22 examples. It also helped to address the recurrent methodological concern associated with the bias that may arise from retrospective recall of the decision-making processes that underpin the translation process (Toury, 1995). Specifically, the archival data used for this study consist of nine different types of written materials: (1) the guidelines for the composition and workings of the translations review committee issued by IFRS Foundation (Terms of Reference, unpublished), (2) a list of new terms and their context plus the translator’s suggestions for alternative translations of the term, (3) records of TRC meetings, most including terminology decisions, (4) records of TRC subgroup meetings in which amendments to draft translations were determined, (5) draft translations, and TRC members’ suggested amendments to them, (6) translated IFRS, (7) the forewords to the actual standards, (8) printed email correspondence between translators and TRC members and (9) training materials for EU translators relating to common mistakes arising in the prior translations of the IFRS. In the first stage of analysis, I searched and examined publicly available data on the translation policies of the EU and the IFRS Foundation (e.g., the process chart of the official translation model of the IFRS Foundation, Figure 1), which form the background of the construction of the translations (Bhatia, 2004). In the second stage, I made notes on the translation problems raised during the interviews and on the ways in which the TRC members sought solutions to these problems. In addition, I noted the interviewees’ criticisms of translations that they had (not) selected. Although the interviews were transcribed verbatim, I listened to the recordings several times because transcriptions do not capture non-verbal information (Bucholtz, 2007). By listening to the recordings I was better able to infer the interviewees’ opinions, such as whether they seemed to consider that a particular translation problem was significant. Then, similar translation problems identified by the interviewees were merged into broader categories such as terminology, ambiguity and indeterminacy of source text, and complexity and foreignness of the substance. 23 The third stage of analysis concentrated on seeking to identify particular means adopted by the TRC members to interpret the source text and how they participated in the creation of the translation. In addition, I noted what the accounting experts said about their role as reviewer and what they sought to accomplish through the work of translation. Drawing on the notion of intertextuality, I also paid attention to the ways in which other texts were used to aid comprehension of the source text and to construct the target text (Bhatia, 2004). I identified reoccurring phases in the translations, and generated visualisations of the workflow of the translation review committee. The visualisations and narrative descriptions were then compared with the IFRS Foundation’s official process description (see figure 1) and other publicly available material identified in the first stage. In the fourth stage the findings from the interviews were compared with documents copied from the archives of the TRC. The archive material was especially helpful clarifying the practical problems of constructing linguistic equivalence described by the interviewees, and for analysing the suggestions and criticism expressed during the terminology work. Accordingly, selected excerpts from the Finnish translations were compared with the source text in order to infer a more detailed understanding of the issues described by the interviewees. For example, some interviewees indicated that the TRC had held lengthy discussions on how to translate problematic terms, such as asset, measurement, dealer market, broker market, observable and domestic partner. Therefore, I compared the contexts in which these terms are used in the source-language against the target-language standards, and the ways in which the terms link to concept systems in the respective languages so as to analyse why rendering these concepts adequately in the target-language was problematic. Furthermore, the archival materials were not only used to illustrate but also to contrast the findings from the interviews. Because the interviews were conducted over a longer period of time, stages two, three and four were repeated to refine the analysis each time that additional data was collected. 24 Maintaining the influence of the IFRS as a global institution requires sustained institutional work, some of which takes place in local settings and through micro-level activities. The institutional work of translation contributes to the maintenance of the IFRS as a translingual institution and is essential if the standards are to have global reach. The translation of the IFRS into the Finnish language, which is the empirical focus of this section, connects the financial reporting in Finland to the IFRS. It also enables the local accounting profession to be part of ‘the new world’ of the IFRS, as an interviewee put it. Without translation work, Finnish financial reporting and the IFRS would have a considerably weaker connection. This section also elaborates on the complexities of translation, illustrating that translation is more than a technical activity in the local implementation of the global standards. The section consists of three subsections. The first subsection focuses on the translation of terminology and shows that one-to-one equivalence between a given English-language term and the corresponding target-language term – as required by the IFRS Foundation’s translation approach – is often constructed during translation as opposed to merely being a given. The efforts involved in the maintenance of one-to-one equivalence created in previous translations and those made to select target-language terms capable of being embedded in other texts are also examined in the first subsection. The second subsection analyses how translators and the reviewers of translations deal with inherent ambiguity and uncertainty as they seek to convey the meaning of the source text in the targetlanguage. It is argued that translation inevitably involves a degree of interpretation of the source text, and that the TRC members infer its meaning by drawing on their respective bodies of knowledge, by 5. Constructing Acceptable Linguistic Equivalence: The Case of Translating the IFRS into Finnish 31 Although I do not know those languages that well, one can come to a conclusion concerning the basis for the translation. Is it based on valuation or measurement? It looks like only English-speaking countries have taken this measurement road. Elsewhere they still use the term valuation. I also dug into older literature in English. Before the 1960s, the term measurement did not exist. In the fifties and sixties there were a few articles and books discussing whether valuation and measurement carried different meanings. And in 1971, the committee of the Accounting Review made the choice to use the term measurement. Some of the interviewees described how they theorised certain choices of term by referring to various texts or bodies of knowledge, as illustrated by the above quotation. Having discussed the alternative target-language terms in a meeting, the TRC translated the term measurement using the target-language equivalent of valuation, a term traditionally used in the accounting contexts in the Finnish language. Similarly, the TRC considered what sort of observation the observable in observable prices or observable market designates and to what extent it might be captured by alternative target-language words. Maintaining a consistent translation The IFRS Foundation’s translation policy requires that each source-language term is always translated with the same target-language term (IFRS Foundation, Terms of Reference, unpublished), and any exception to this rule must be justified. According to the translators interviewed, the Directorate General for Translation has a similar requirement. The practice of ensuring the consistent translation of terms within and across standards may be an important form of institutional work for the maintenance of the IFRS as a translingual institution. An outcome of the term-for-term 32 correspondence may be that issues around conceptual equivalence remain unproblematised in situations where different language versions of an IFRS are read in parallel. 20 The interviewees reported the TRC worked to maintain consistent terminology across different standards, and often referred to the translations of previous standards when a new standard or an amendment was being translated. Additionally, the DGT translators might suggest aligning the terminology to a certain extent with other EU texts. As a consequence, there is a strong intertextual patterning between the translations of different IFRS as the choice of vocabulary and phrasing for the translations of any newly issued or amended IFRS is strongly affected by the way earlier standards have been translated (cf. Bhatia, 2004). In addition to collaborative activities between TRC members, maintaining consistency across different IFRS was facilitated technologically through the use of translation memory 21 software and the list of translated terms. Despite the technological aids, maintaining terminological consistency requires effort and judgement. The translation reviewers frequently underlined the significant role of the TRC translator in maintaining the consistency of terminology across standards. They pointed out that the translator had the most knowledge of the basis for the decisions made in translating previous standards. However, previous translations were not simply mechanically reused in subsequent standards due to the context-dependent meaning of words in both languages. Difficulties arose partly because target-language equivalents must be chosen based on their perceived appropriateness in the context of the standard where they first appeared. When source-language terms reappear in 20 To give an example of the opposite, translations of the true and fair view (TFV) into different languages have been problematized in several studies on the grounds that the term has been translated inconsistently (Dahlgren and Nilsson, 2012, Nobes, 2009; Nobes, 2013). Furthermore, an interviewee indicated that it is not uncommon that she or her colleagues read at their daily work the original IFRS and the translation in parallel to interpret a certain requirement. 21 A translation memory is a database that consists of text segments in the source-language and their previous translations to the target-language. Translation memory software suggests possible translations of segments based on prior translations, and shows the technical level of equivalence between a given source-language segment and the previously translated text segment in percentage form. 33 subsequent standards in different contexts, or as a part of another word combination, the previously selected target-language equivalents might not carry a meaning that is appropriate in the new context. A TRC member described the difficulties arising when fundamental concepts are used in the source text in a manner that appears inconsistent to a Finnish reader. Interviewee D: And then, relating to the terminology, it has been clear to us in Finland what expenditure is (in Finnish, meno), what expense is (kulu), and what a cost (kustannus) is, but in English it is much less well-defined because the term cost encompasses costs in cost accounting, but it is also meno, expenditure, in other contexts as meno would be defined in Finnish. When the same term has varying meanings in English, it is utopian to think that some absolute consistency could be attained. There have been some differences in usage and probably will be because of these traditions... This is another illustration of why the term-for-term requirement is problematic in translation when the meaning depends on the context. Abstract concepts often cover a certain semantic field rather than referring solely to a well-specified referent. Therefore, the TRC strives to determine whether the meaning of a previously selected target-language term overlaps with its source-language counterpart in a given context, thus, implicitly defining the boundaries of the concepts. Another example of conceptual differences is the translation of the terms depreciation and amortisation. The English language conceptualises the gradual decreasing usefulness of assets by writing off costs in a process called depreciation for tangible fixed assets and amortisation for goodwill and other intangible assets; In contrast, the Finnish language uses the same term, poisto, for both. 22 The English 22 According to Dahlgren and Nilsson (2012), similar difficulties arose with the translation of ‘depreciation’ and ‘amortisation’ into Swedish. 34 language also uses the term amortisation, in the context of repayment of a debt by a borrower, while the Finnish language uses a different term, takaisinmaksu, as poisto is strictly an accounting term. The Finnish TRC chose, however, to translate both amortisation and depreciation of assets using same term, subsequently justifying the choice in the foreword to the translated bound volume of the standards. Translation problems arising from changes in source-language terminology It is recognised that language is dynamic, and accounting terminology changes over time (Evans, 2010; Mills, 1989). However, the current research establishes that the terms used in the IFRS and the underlying concepts do not always change simultaneously. The shifting meaning of a term, or changes to the term when its referent has not changed, combined with the word-for-word requirement in particular, creates issues for those involved with the translation. In such circumstances the translators and translation reviewers pondered whether and when the translation should reflect terminological changes in the source text as compared to earlier standards. An event that was often brought up in the interviews was the decision-making process regarding the translation of the statement of financial position when this term replaced the balance sheet in IAS 1 in 2007. Before the terminology meeting, all but one of the TRC members signed on to a suggestion to adopt a more literal translation of the statement of financial position. But during the meeting, one member convinced the rest of the committee that the Finnish term could not be changed. Interviewees recalled her saying, for example, that ‘the balance sheet [in Finnish tase] is the balance sheet and it can’t be anything else’. 23 This decision making by consensus also illustrates that 23 Similarly, the term Bilanz was retained in the German translation (Evans et al., 2015). ‘This is not an oversight – the possibility of using alternative translations was debated during the translation of the 2007 revision of IAS1, but the reviewer chose to retain the term ―Bilanz. We are grateful to Robin Bonthrone for pointing this out.’ (Evans et al., 2015, p. 17.) 35 meetings significantly affect the decisions made by the TRC. An interviewee remarked that ‘luckily’ they did not change the term because ‘doing so could have confused financial statement users and the media.’ Indeed, introducing a new target-language term would have created new terminological differences between the Finnish language IFRS and local accounting regulations. The decision not to amend the Finnish term corresponding to the balance sheet may be interpreted as reflecting a concern with ensuring the success of translation in the form of forthcoming intertextuality. The familiar and concise target-language term, tase, continues to be embedded in other texts, including financial statements. When the target-language IFRS terms are used in other contexts by the preparers of financial statements and the media, among others, these constituents implicitly preserve and reproduce the one-to-one equivalence constructed by the committee. This serves to maintain the equivalence of terminology constructed in the translation. In summary, this section has examined the practical problems of linguistic equivalence, and the activities that trigger the creation and maintenance of a formal correspondence of terminology between languages. The lack of a pre-existing conceptual equivalence between the languages is apparent, in that often several different target-language terms were suggested as translations for one source-language term. However, the TRC coined new terms to describe IFRS concepts, and a few source-language terms were left untranslated. It was also argued in this section that the consistent translation of terms appears to be an important form of the institutional work in the maintenance of the target-language IFRS. As a result, there is a strong intertextual patterning across different standards in the translated IFRS. The terms used in the IFRS and the underlying concepts do not, however, always change simultaneously, which, combined with the term-for-term requirement, causes issues for those involved in translation. Due to the context-dependent meaning of words, the TRC engages in defining the boundaries of concepts by deciding whether their meanings overlap adequately in a particular context. Occasionally, the translation reviewers also focused on selecting target-language terms capable of being embedded in 36 other texts, thus reproducing the constructed linguistic equivalence intertextually in texts outside the actual standards, such as in forthcoming financial statements or media articles. 5.2 Coping with ambiguity and uncertainty in the meaning The ambiguity and indeterminacy of language have attracted considerable attention in linguistics and legal theory (e.g., Cao, 2007; Joseph, 1995). It is argued in this subsection that these inherent properties of language pose considerable practical challenges to the IFRS translators and translation reviewers. A certain degree of interpretation appears to be an unavoidable aspect of the translation of IFRS, although the IFRS Foundation maintains that the ‘purpose of the translation is not to interpret or explain the standards’ (IFRS Foundation, Terms of Reference, unpublished). This subsection investigates how translators and translation reviewers deal with the ambiguity and uncertainty around intended meanings within the source text. Although the translation process established by the IFRS Foundation highlights the formal correspondence of terminology, the translators and translation reviewers underlined the efforts made to render the meaning(s) of the source text appropriately in the translation. Rendering the intended meaning beyond individual words is undoubtedly a desirable goal. Furthermore, the constituent perceptions of the extent to which that goal is being achieved will likely have an impact on the stability of the IFRS as a translingual institution. For each standard, a subgroup of TRC members was chosen to review the draft translation to ensure that the meaning was not altered in translation (see figure 2). A TRC member described the difficulty of interpreting and rendering the meanings of longer text segments in translations as follows: Interviewee G: One of the main problems in the translation of IFRS is not terminology, which is also a difficult issue, but understanding what something means. A single 37 sentence in which there is no foreign word can be discussed in the group for a long time. Sometimes the text can be understood in several ways. Also, native speakers who we consult can have difficulties [with understanding the text]. Another TRC member emphasised that ‘The role of the reviewer requires that you should see not only if it looks fluent, but also that the idea corresponds to what has been said in the original text.’ These statements show that translators and translation reviewers find it problematic to make sense of the source text and transfer the meaning unchanged to the target text. They also illustrate that the interviewees strive to convey the meanings of longer segments of text, rather than the individual words, into the target-language. While research has acknowledged that translators should not try to resolve ambiguities but aim to capture them in the translation (Evans et al., 2015), ambiguity cannot always be maintained in translation, as some of the interviewees pointed out. The data informing the current study indicate that uncertainty about the meaning of the source text arises from two main sources. First, with regard to how the text is structured verbally (including syntax), both the translators and accounting experts noted that it is not always clear which word or phrase a particular (relative) pronoun refers to (i.e., what the antecedent of the subordinate clause is). The following excerpts briefly illustrate this problem of grammatical ambiguity, in particular that of ambiguous cross-references: When management is aware, in making its assessment, of material uncertainties relating to events and conditions that [italics added] may cast significant doubt upon the entity’s ability to continue as a going concern, the entity shall disclose those uncertainties (IFRS, 2008; IAS 1.25). 38 … eliminate all deferred losses and gains arising on derivatives that [italics added] were reported in accordance with previous GAAP as if they were assets or liabilities (IFRS, 2008; IFRS 1.B4). In the first excerpt above, the term that could refer to either uncertainties or events and conditions. In the latter excerpt, that could refer to either losses and gains or derivatives. Ensuring that the translation correctly captures the intention in these sentences, if a dual reference was intended, is not possible in Finnish. Theoretically, a translation carrying either of the two possible meanings is a correct translation. While a certain degree of indeterminacy may sometimes be intentional in order to allow the standard to be applicable in different business environments, the referential ambiguity in the above excerpts is scarcely likely to be intentional on the part of the standard-setter. For these reasons, TRC members needed to decide which meaning to render in a translation. If the translator is not an accounting expert, it may be even more difficult to infer the referential relationships (and thus the standard-setter’s intended meaning) in each context. As the DGT translator noted: Referential ambiguity brings forth [a problem], because none of us [in the translation team at DGT] is an accounting expert. And then if there is a short elliptical sentence, we may invert the referential relationship when translating. According to more than one translation reviewer, however, accounting experts can also struggle with sentences in which the grammatical structure permits of two interpretations, although accounting experts can draw on the context to resolve such ambiguities. Second, issues with comprehending the original standards, and uncertainty about the standardsetter’s intentions, were said to derive from the general complexity or foreignness of the substance of 39 the regulation. One of the accounting experts interviewed reflected on the need for interpretation and the difficulty of comprehension as follows: Interviewee C: [the] IFRS can be difficult, which is not only a linguistic matter. It’s just that they are so difficult to comprehend that also we as professionals can have [difficulty understanding] what IASB wants, if it’s not totally clear...and they are forthcoming norms…and they have not been in use yet, so it’s not even known…what the IASB is seeking… To some extent, making sense of the source text may become a negotiation about another negotiation, in that the TRC members negotiate the content produced by negotiations conducted at the IASB. It should be noted, however, that the word negotiation is not used here in the sense that TRC members would have sought to create translations in a self-interested manner. Instead, the differing professional backgrounds of TRC members seemed to influence which issues they considered in the course of the translation. It is worth noting that the translation reviewers are able define the bodies of knowledge they deem relevant in terminological decision making (cf. Pelger, 2016). For example, the academic (whose research interests include measurement theories) presented viewpoints on the meanings of terms such as observable, and measure/measurement versus valuate/valuation and on their conceptual equivalence with target-language terms in various contexts. This again illustrates that the meaning is inferred in relation to other texts or bodies of knowledge invoked during the reading and translation process (Bhatia, 2004). Furthermore, TRC members reported they found translation problematic because ‘standards are by nature a compromise,’ and because ‘the IFRS are [written in] neither American nor British English’ or ‘some standards have been created in a rush.’ Indeed, the conceptual roots of standards are diverse and the standard-setters have tried not to bind the terms tightly to any geographical 40 location. One could also say that the perceived difficulty of translating a text is not independent of who is translating it. An interviewee noted that TRC is heterogeneous and they ‘are in contact with the standards in different ways,’ also saying that: [The relative difficulty of comprehension] is related to our differing backgrounds. I follow all the time what happens with the IFRS, beginning from when they are being developed. So I have some kind of understanding of what they want to say. Then, what is the final English-language version of the standard…I know…or I think that I know, what they mean by it. But if you haven’t followed it …or read the basis for conclusions …and if you really haven’t followed it from the beginning of the project, when they made some preliminary decisions and when they changed it, and those bases and discussions…then it is certainly more difficult. The meaning of the original text to be conveyed in the target-language was not only inferred from the final text of any standard per se. Rather, the meanings were constructed intersubjectively and intertextually based on the TRC members’ interpretations of the standard-setters’ intended meanings. Those intended meanings in turn tend to be formed in the course of the standard-setting process and with reference to other texts such as similar standards or the Conceptual Framework. In particular, the goal of dynamic equivalence cannot be achieved in translation, if it can be achieved at all, only on the basis of the current text as the meanings of sentences in the present standards are the result of developing and revising standards since the formation of the International Accounting Standards Committee (IASC). In summary, the TRC members make efforts to infer the meaning in the source text as intended by the standard-setter and to convey it unchanged into the target-language. The institutional work aimed at capturing the meaning in translation takes different forms ranging from the grammatical 47 translation of the IFRS. As was discussed in this subsection, the IFRS Foundation’s translation policy delegates a more integral role in translation work to the accounting profession than does the translation policy of the EU. Notably, the difficulties of the translating the IFRS into the EU languages have not dissipated, despite the fact that the IFRS were adopted by the EU more than a decade ago. Despite changes in how the translation of the IFRS is organised at the transnational level, the particular case of the Finnish language translation studied in this paper does not stand out as an illustration of a struggle between professions. Rather, the DGT translators and the former members of the Finnish TRC continue their collaboration (albeit under an amended arrangement) to maintain what both parties consider good translation practice, and thereby to maintain the legitimacy of the translations. In other words, the local actors resisted the institutional change taking place at the transnational level, specifically by continuing the provision of the IASB-approved translations of the EU-endorsed IFRS. This action contributed to preserving the existing translation process by retaining an expert review. The continued expert review in the case of Finnish language translation appears to be an exception to current practices of translating the IFRS into the EU languages, and it is important to note that studying the trajectory of the organisation of the translation work for other languages such as French, German or Swedish would have yielded a quite different account. This paper has shed light on the practical problems of linguistic equivalence by enquiring into the empirical topic of the translation of the IFRS into the Finnish language. Drawing inspiration from the notion of institutional work (Lawrence & Suddaby, 2006), the present study has explored the detailed practical activities and institutional interactions aimed at creating and maintaining an 6. Discussion and Conclusions 48 acceptable linguistic equivalence in the course of translation, and thereby maintaining the IFRS as a translingual institution. Indeed, the institutional work of translation is essential for the global reach of the IFRS. It has been shown in the paper that the formal, one-to-one equivalence between terms in the English-language IFRS and their translations is often constructed during the translation committee processes, as opposed to simply being apparent. Similarly, the translators and translation reviewers strive to maintain the previously established one-to-one equivalence when translating the current standard. Efforts are also made to select target-language terms that it is assumed will embed well into other texts, ensuring the long-term sustainability of the translations. Overall, the translation of the IFRS is an ongoing activity which involves negotiation and the balancing of case-specific criteria that the committee members present and must reach an accord on. The present study contributes to two related bodies of accounting literature. First, it contributes to the literature on the translation of accounting and auditing standards by examining the procedures through which different regulators, translators and accounting experts reviewing the translations address the practical problems of linguistic equivalence. This is a novel contribution to the literature because extant studies have examined the outcomes of translation activities, that is, translated text segments and terms, focusing primarily on inaccuracies, translation errors (e.g., Dahlgren & Nilsson, 2012; Nobes, 2006; Sunder, 2011), or differences in the interpretation of uncertainty expressions (e.g., Aharony & Dotan, 2004; Doupnik & Richter, 2003). Several accounting studies have suggested that translation is inherently problematic (Baskerville & Evans, 2011; Evans, 2004; Evans et al., 2015, Zeff, 2007). When compared with prior research, the present study clearly elaborates on the complexities of translation and contributes a focus on translation work in its social and institutional context. While prior accounting research on translation recognises that accounting concepts may not neatly overlap in different languages, the findings from the study of Finnish language translation illustrate that issues arise in attempting to render the meanings of text segments (as opposed to words) 49 into another language. In particular, inferring the meaning in the source text was considered problematic because of the occasional foreignness of the substance and the inherent ambiguity and indeterminacy of language. In other words, problems of translation do not only arise from the absence of the means to render a specific meaning in the target-language (which is also a common problem) but from the need to make sense of the source text. Following the standard-setting process from its early stages contributes greatly to making sense of the final text in the IFRS. Overall, the meaning was not merely carried by the text under review itself but the TRC members drew on other texts and their professional knowledge bases to infer the meaning of the source text to be rendered in the targetlanguage. Second, with regard to the scholarship on transnational accounting regulation and standardsetting, the study of the translation of regulatory texts furthers our understanding of the institutional interactions and activities within the transnational financial regulatory arena. The translation of the IFRS has a unique position at the interface of setting and implementing standards, and it also lies in the middle ground of activities supporting regulation governed by the IFRS Foundation and those by the EC. Apart from transnational standard-setters and regulators, the translation review committees are a node of interaction between representatives of large and mid-tier audit firms, industry specialists, the preparers of financial statements, and other constituents approved by the standardsetter. Importantly, the IASB-approved translations of the IFRS are not created by a single translator but are the outcome of collaborative activity between translators and selected constituents following a specific process. Despite the detailed process set up by the standard-setter, however, the committee members have the responsibility for the translation and it is they who ultimately decide what aspects are taken into consideration in translation. While the present study has focused on institutional work carried out by translators and translation reviewers to maintain the IFRS as a translingual institution, the standard-setter also engages in institutional work to maintain the status of the translations of the IFRS. For instance, the 50 IFRS Foundation argues that ‘multiple translations of IFRSs into the same language would endanger comparability, transparency and the long-term sustainability of high-quality IFRS translations.’ 30 Equally importantly, multiple translations might serve to problematise the ideal of linguistic equivalence, and in particular the one-to-one equivalence of terminology between languages, which the IFRS Foundation’s translation process relies on. The developing and shifting nature of the organisation of the translations of the IFRS into EU languages aligns with other analyses of the dynamics associated with the transnational financial regulatory structures (see e.g. Humphrey et al, 2009). The organisation of the translation of the IFRS is not a static phenomenon but one that shifts and changes. The roles of the transnational agencies, and accordingly, the actual constituents undertaking translation have changed recurrently, often abandoning or reintroducing the IFRS Foundations’ translation approach. For the moment, the end of the contract between the EU and the IFRS Foundation appears to have prompted discontinuing the expert review of several EU language translations. Interestingly, large and mid-tier audit firms, or other private-sector constituents are no longer represented in the reproduction of the non-Englishlanguage versions of the endorsed IFRS. This observation on the present situation contrasts with the findings of several studies pointing to the large audit firms occupying more terrain in transnational accounting regulation and related activities (e.g., Cooper & Robson, 2006; Humphrey et al., 2009). The interviews and archival materials this paper draws upon are restricted to the case of Finnish language translation, and so the paper does not address the intraor inter-organisational negotiations and decision making of the IFRS Foundation and the EU on the organisation of translation work. Similarly, although it is stated that ‘The IASB is keen to avoid issues problematic to translation in these documents’ (IFRS Foundation, 2010, p. 2), we do not know whether and how the standard-setters or the staff attempt to address issues of translation during the standard-setting 30 http://www.ifrs.org/Use-around-the-world/IFRS-translations/Pages/IFRS-translations.aspx 51 process. While this paper has examined the organisation of translation for an EU language, the IFRS are translated in a multitude of jurisdictions beyond the EU. The institutional and linguistic contexts where translation activities take place are diverse and might differ substantially from those examined in the present paper. This issue could be a matter of future research. In sum, there are clear opportunities for research to understand better how accountants and auditors deal with the issues of multilingualism and translation. It would be useful to gain insights into various language and translation related practices in the realm of financial reporting, including the interpretation of transnational standards and regulations by accountants and auditors who are not native English speakers, and the preparation of financial statements in multiple languages. Despite the growing body of literature on translation as a potential barrier to transnational accounting harmonisation we have very little insight into the views of those who prepare, use and audit financial statements on the approaches they adopt to address the practical problems involved in handling linguistic equivalence in the context of their daily work, or into the negotiations on the degree of discretion possible with specific translations. This again, as suggested by Cooper and Robson (2006), highlights the sustained importance of conducting research on the broader topic of the interpretation and implementation of rules. References Aharony, J., & Dotan, A. (2004). A comparative analysis of auditor, manager and financial analyst interpretations of SFAS 5 disclosure guidelines. Journal of Business Finance and Accounting, 31(3&4), 475–504. Aisbitt, S., & Nobes, C. (2001). The true and fair requirement and its recent national implementations. 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