Regulatory Intermediation in Times of Crisis and What It Means for Professional Accounting Bodies

“Regulatory Intermediation in Times of Crisis: The Impact of Independent Oversight on the Functioning of Professional Accounting Bodies” by Brendan O’Dwyer et al. examines how a professional accounting body can become caught between public oversight, member interests, and growing crisis pressure. Rather than portraying the NBA as either fully powerful or fully sidelined, the study shows a more unstable reality in which its role, legitimacy, and influence changed repeatedly as oversight intensified.

What makes the research especially valuable is its focus on the everyday functioning of a professional body caught between governance and representation. Rather than treating those responsibilities as separate or naturally balanced, the authors show that the NBA’s efforts to govern its members and represent their interests became increasingly symbiotic. For audit committees, regulators, and professional bodies, that is a useful reminder that credibility in one role can strengthen credibility in the other, but only if the organization can act with clarity and consistency.

The three roles identified in the study, facilitation, curation, and orchestration, are particularly relevant for governance readers. At first, the NBA tried to calm regulator and firm tensions by facilitating agreement on interpretation issues. Later, it was asked to curate collective reform proposals. Eventually, it attempted to orchestrate a broader structural response across the profession. These shifts show that a professional body in crisis is not static, and that its influence depends on whether it can move from reactive mediation to more credible leadership.

Another important contribution is the concept of role limbo. The NBA did not move smoothly from one intermediary role to the next. Instead, it repeatedly entered periods of uncertainty in which its purpose and authority were unclear. That idea has practical relevance beyond the Dutch case because many governance institutions face similar moments when they are expected to defend their constituency while also enforcing tougher standards. In those moments, ambiguity can weaken the whole system if leadership cannot define a clear purpose.

The paper also makes an important point about subintermediaries. The Monitoring Committee on Accountancy was created to strengthen credibility and independence, yet its autonomy ended up reducing the NBA’s influence over the profession. For internal audit, audit committees, and supervisory bodies, this is a useful warning that delegation does not automatically solve governance problems. A subcommittee or oversight layer can improve legitimacy, but if its design is not carefully aligned, it may dilute rather than reinforce authority.