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Islamic Accounting in Indonesia: A Review from Current Global Situation

Islamic Accounting in Indonesia:

A Review from Current Global Situation
Aprilia Beta Suandi

Abstract
Despite the existence of the Accounting and Auditing Organization for Islamic
Financial Institutions (AAOIFI) to provide accounting standards for Islamic Financial
Institutions (IFIs), there is still no standardized accounting for Islamic financial transactions.
This study aims at identifying current development of Islamic accounting in Indonesia in
comparison with the global situation of accounting for Islamic financial transactions. The
Asian-Oceanian Standard-Setters Group (AOSSG) survey in 2011 is mainly used to get the
outlook of current global situation of Islamic accounting and later be compared to the current
policies of Islamic accounting in Indonesia. The AOSSG survey shows diverse opinions on
how Islamic accounting should move towards International Financial Reporting Standards
(IFRS) with only two jurisdictions, including Indonesia, emphasize their current intention
to retain Islamic accounting standards. It is found that although Indonesia refers to AAOIFI
accounting standards to develop Islamic accounting standards to a certain extent, it claims
to apply Islamic accounting standards not based on AAOIFI accounting standards due to
different direction in developing Islamic accounting as well as different understanding and
interpretation of Islamic law or sharia on certain issues. This shift may imply that Indonesia
disclaims the idea of a common set of Islamic accounting standards. However, Indonesia
is currently in the process of converging with IFRS which may have influences on Islamic
accounting. Future research on its policies to develop Islamic accounting is likely to be
interesting to explore.

1. Introduction

More than two decades after the establishment of the Accounting and Auditing
Organization for Islamic Financial Institutions (AAOIFI) in 1991 to respond the market
demand for accounting for Islamic financial institutions (IFIs), there is still no uniformity
in how to account for Islamic financial transactions among jurisdictions. The AAOIFI is

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 Islamic Accounting in Indonesia: A Review from Current Global Situation

an international autonomous non-profit making corporate body that prepares accounting,

auditing, governance, ethics, and sharia (Islamic law) standards related to IFIs. Since there
are unique rules, requirements, and restrictions in Islamic finance, it is expected that AAOIFI
accounting standards can increase confidence of the users of IFIs’ financial statement on the
sharia-compliant information about these institutions.

Current discussions in the accounting world, which focus on the issues of International
Financial Reporting Standards (IFRS) as a common global financial reporting language, are
forcing international accounting organizations to consider Islamic accounting. In 2010, the
Asian-Oceanian Standard-Setters Group (AOSSG), a group of accounting-standard setters in
the Asian Oceania region that discusses issues regarding the adoption of IFRS, published a
discussion report on financial reporting issues relating to Islamic finance. In order to have
a more diverse IFRS community, the International Accounting Standards Board (IASB)
listed Islamic transactions and instruments in the Agenda Consultation 2011 as an item
for discussions. In November 2012, KPMG, one of the Big Four accounting firms, and the
Association of Chartered Certified Accountants (ACCA) also published a joint report calling
on the IASB, the AAOIFI, and other Islamic financial standard setters and regulators to work
together to develop guidance and standards to harmonize financial reporting.
Indonesia, as a country with the largest Muslim population in the world (1) and a potential
market for Islamic finance, requires profound consideration on the development of Islamic
accounting. It first implemented specific accounting standards for IFIs in 2003 and has actively
participated in AOSSG discussions on Islamic financial reporting. Although Indonesia is
currently making efforts to converge with IFRS, it still retains its Islamic accounting standards.
This paper is attempting to find out current development of Islamic accounting in Indonesia by
comparing with the global situation of Islamic accounting.
Napier (2009) classifies three main groups of Islamic accounting literature. The
first group discusses the need for Islamic accounting, including the broad principles of an
Islamic accounting system, the second group deals with accounting for specific Islamic
financial products, and the third group falls into the issues of regulation. This paper makes
a contribution to the third group by specifically address the situation of Islamic financial
reporting in Indonesia as well as giving an overview of Islamic accounting in the world. Many
pieces of Islamic accounting writing are not written in English and scattered in not only

(1)
The estimated 2009 Muslim population in Indonesia is 202,867,000 people, which is 88.2% of its total
population and 12.9% of world Muslim population (The Pew Research Center’s Forum on Religion &
Public Life, 2009)

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 Islamic Accounting in Indonesia: A Review from Current Global Situation

academic but also non-academic articles, which results in no considerable amount of research
papers discussing the current conditions of Islamic accounting in specific jurisdictions.
This paper consists of six parts. After the introduction, the second part explains the
reasons of the emergence of Islamic accounting. The third part introduces the notion of
Islamic accounting harmonization, followed by the examination of current global situation of
Islamic financial reporting. The fifth part specifically discusses current development of Islamic
accounting in Indonesia, and the last part concludes the discussions.

2. The Need for Islamic Accounting

2.1 The Emergence of IFIs

The history of Islamic accounting started from the emergence of Islamic finance. Islam
experienced its golden age in the period between 6 th and 12 th century. Although Islamic
commercial contracts were used to structure many financial products at that period, they
gradually disappeared when Islamic civilization declined in the 13 th century (Jamaldeen, 2012).
In 1963, the history of modern Islamic finance noted the reappearances of Islamic
thinking by the establishment of Mit Ghamar in Egypt, a saving bank with the idea of profit
sharing(2) (El-Ashker, 1987; Fisho-Oridedi, 2000; Jamaldeen, 2012; Sharawy, 2000). Although
it closed in 1967 for political reason, Mit Ghamar has inspired the development of many other
Islamic banks in the later years. There was a continued increase in the number of Islamic
banks in the late 1970s and early 1980s, but the changing political climate in many Muslim
countries made some Islamic financial institutions operate without the label of Islam to avoid
the negative worldview towards Islam at that time (Sharawy, 2000).
The creation of modern IFIs was undoubtedly started from the establishment of Islamic
banks, which is the most developed component in the Islamic financial system. IOSCO (2004)
found that the success in developing Islamic banking stimulated the extension of Islamic
practices into other market segments by offering broader Islamic financial products. Demand
of Islamic financing continues to grow and attract not only Muslims’ interest, but also non-
Muslims, by showing a staggering growth rate. (3) Full stages of evolution of the Islamic

(2)
Because of political situation in Egypt which forbade Islamic political elements in the country, Mit
Ghamar did not explicitly describe its practice as an Islamic bank (El-Ashker, 1987).
(3)
“The Islamic funds in global financial institutions is estimated to be at US$1.3 trillion while the Islamic
financial market is estimated to be worth US$400 billion in size, with annual growth rate of 12-15%.
In addition there are over 300 Islamic financial institutions currently operating in about 75 countries

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financial service industry can be seen in Table 1.

Table 1 Stages of Evolution of the Islamic Financial Service Industry

1970s 1980s 1990s 2000s
Institutions: Institutions: Institutions: Institutions:
・Commercial Islamic ・Commercial Islamic ・Commercial Islamic ・Commercial Islamic
banks banks banks banks
Products: ・Takaful ・Takaful ・Takaful
・Commercial ・Islamic investment ・Islamic investment ・Islamic investment
banking products companies companies companies
Area: Products: ・Asset management ・Islamic investment banks
・Gulf/Middle East ・Commercial banking companies ・Asset management
products Products: companies
・Takaful ・Commercial banking ・E-commerce
products ・Brokers/dealers
Area: ・Takaful Products:
・Gulf/Middle East ・Mutual funds/Unit trust ・Commercial banking
・Asia Pacific ・Islamic bonds products
・Sharia-compliant stocks ・Takaful
・Islamic stockbroking ・Mutual funds/Unit trust
Area: ・Islamic bonds
・Gulf/Middle East ・Sharia-compliant stocks
・Asia Pacific ・Islamic stockbroking
Area:
・Gulf/Middle East
・Asia Pacific
・Europe/America
・Global Offshore Market
Source: IOSCO (2004)

The main principle of Islamic finance, which is providing interest-free financial

transactions, has created implications in the application of conventional accounting. Various
Islamic financial products were developed to avoid interest, which basically consist of
mudaraba (profit sharing), musharaka (profit and loss sharing), murabaha (trade with mark

up or cost-plus sale), salam (advance purchase), istisna (purchase order), and ijara (lease
financing). Besides the prohibition of interest, activities related to gharar (uncertainty), maisir
(gambling), and haram (unlawful) products, such as alcohol and pork, are also forbidden.
Thus, there was an urge to provide financial reports that can inform the readers of the
IFIs adherence to sharia and accommodate the unique characteristics of Islamic financial
transactions.

2.2 Criticisms on Conventional Accounting

Many researchers argue the connection between accounting and society. The

worldwide. Out of these IFIs, there is estimated to be more than 100 Islamic equity funds managing
assets in access of US$5billion which is a staggering amount” (Nazeer, 2011, p. 15).

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importance of accountancy in modern society has motivated Roslender (1992) to define

accounting as a social institution. Hines (1988), in his unique piece of writing, also explains
how accounting plays a significant role in creating social reality. Burchel et al. (1980)
discussed the organizational and social roles of accounting, in which accounting is intertwined
with many aspects of social life in a complex relationship.
In 1975, the American Accounting Associations (AAA) mentioned that “the objective
of financial statements should be cast within a broader statement which encompasses social
welfare objective, or at least usefulness should be justified as an appropriate surrogate
social welfare function” (p. 44). In 1977, AAA placed the importance of decision usefulness:
information provided on accounting led to the efficient allocation of resources. However,
efficiency is only an intervening variable that brings a greater aim for society. Hameed (2000)
summarized the AAA discussions in Figure 1 below.

Figure 1 Accounting Route to Social Welfare

Accounting

Information Efficiency

Better Eeconomic Decisions

Efficient Allocation of Resources

Social Welfare

Source: Hameed (2000)

Gray et al. (1996) show disagreement on this accounting route as they posit that
Western conventional accounting is established on the assumption of pristine liberal economic
democracy; individual’s freedom is paramount and all individuals are free to act, free to make
economic decisions, and free to express their political choices. In the condition of government
being neutral and each individual tries to put resources in the most efficient use, maximum
economic growth resulted is assumed to maximize social welfare. This concept thus becomes
a justification for accountants to work for self-interested decision maker in order to maximize
their personal wealth, which apparently ensures that the rich will be still rich or even richer (p.
16-17).

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Hence, Gray et al (1996) indicates that conventional accounting can in fact lead to social
welfare only in the case of superfluous ifs:

“If all agents were equal and if markets were information efficient and if this led to
allocative efficiency and if this led, in turn, to economic growth and if this ensured
maximum social welfare and if maximum social welfare is the aim of the society then
accounting is morally, economically and socially justifiable and may lay claim to an
intellectual framework” (Gray et al., 1996, p. 17).

Similarly, Hameed (2000) argues that conventional accounting is the product of Western
modernity whereby the objectives, characteristics, and consequences of accounting reflect its
values and norms, which aim at the financial enrichment of certain groups. He assumes that
the worldview and values of society influenced its social and economic objectives. In order
to reach the objectives, economic norms and laws are formed, which includes the regulation
to manage transactional behavior. Here, accounting plays a leading role in providing the
information required by various stakeholders.
If the accounting system contains mainly extraneous values to those of the host society,
the information produced may result in incorrect economic behavior, which also leads to the
achievement of incompatible socioeconomic objectives. It consequently changes the economic
norms and laws to be compatible with the new objectives (Hameed, 2000). In other words, it
may be difficult for accounting to be satisfied by a one-size-fits-all format.
The fundamental assumption that all actions are driven by the desire of self-interest
has also led to the development of positive accounting theory, which has been a subject
of criticism by conventional accounting scholars (Christenson, 1986; Sterling, 1990). This
empirical inductive approach also receives disapproval from Islamic scholars (Gambling &
Karim, 1991; Adnan & Gaffikin, 2011) who prefer Islamic accounting to be developed from
normative deductive approach to ensure that accounting practices does not contradict Islamic
principles.

2.3 Accounting from Islamic Point of View

Islamic teachings come from the Quran, the primary source of sharia, and hadith,
which consist of the personal teachings of Prophet Mohammed. The utmost basic tenet in
Islam is tawhid or God’s unity. God, or Allah, is the ultimate Owner and human beings are
merely trustees (khalifa) of what is available on earth. Together with tawhid and khalifa, the

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concept of adalah (justice or fairness) has become one of the fundamental principles of Islamic
teachings.
The ultimate objective of sharia is success in the world and the hereafter. Hence, social
and individual welfare and quality of life is not merely measured in material terms but both
spiritual and material. Muslims are allowed to gain profit, but it has to be legally acquired
and used according to sharia which restricts concentration of wealth in the hands of a few.
El-Ashker (1987) in his study of Egyptian Islamic business enterprise shows that the Islamic
enterprises are still regarded as profit oriented enterprises. However, instead of using the
concept of profit maximization, they prefer to adopt the concept of “sufficient” or “reasonable”
profit by taking into account the state of the market.
Following the rapid growth of Islamic finance, the term “Islamic accounting” started
getting attention and echoed in many discussions. Majority of the early research in Islamic
accounting in 1990s focused on developing the objective of Islamic accounting and reviewing
conventional accounting concepts from Islamic point of view (Adnan, 1997; Adnan &
Gaffikin, 2011; Gambling & Karim, 1990) to find out the ideal Islamic accounting system.
Since accounting from Islamic point of view should ensure the users that the business is in
compliance with sharia, “Islamic accounting is considered a tool which enables Muslims
to evaluate their own accountabilities to God in relation to inter-human and environmental
relations” (Shanmugam & Perumal, 2005, p. 11). Proposed objectives of Islamic accounting
thus put the ability to achieve the primary ability to God at the highest (Adnan, 1997;
Mohamed Ibrahim, 2000; Napier, 2009).
As the concern to realize social justice is central in Islam, Muslims have responsibility
to care for others and avoid selfishness and avarice (Kamla et.al, 2006). It has then become
one of the important considerations in developing Islamic accounting. Quran strictly states
the prohibition of riba,(4) or interest in contemporary terms, and obligation to satisfy zakat
or alms(5). The prohibition of interest refer to the ban of exploiting the poor, since adding a
specific interest rate or premium to a loan will trouble the needy while the wealthy do not have
to bear any risks or make much effort to gain more money. Correspondently, Islam seeks to
have equitable distribution of wealth to all members of society by opposing zakat, an obligation
for every Muslim to set aside a specific portion of one’s wealth and delivering it to the needy.
Prohibition of interest and the obligation to pay zakat are considered as two key factors
that influence Muslim needs relating financial reporting (Gambling and Karim, 1991; Napier,

(4)
Quran 2:275, Quran 3:130
(5)
Quran 2:43, 2:110, Quran 9:71

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 Islamic Accounting in Indonesia: A Review from Current Global Situation

2009). Therefore, some accounting scholars suggest the determination of Islamic accounting
objective to be directed at the purpose of zakat (Gambling & Karim, 1991, Adnan, 1997), to
replace conventional accounting objectives that focus on specific groups. Nevertheless, the
AAOIFI hitherto requires IFIs to provide Statement of Sources and Uses of Funds in the Zakat
and Charity Funds without explicitly mentioning zakat in the objective of financial accounting.
The AAOIFI (2010) considers the objective of financial accounting in the connection
between IFIs and related parties within Islamic context, which are (1) to determine the rights
and obligations of all interested parties in accordance with sharia and the concepts of fairness,
charity, and compliance with Islamic business values, (2) to contribute to the safeguarding of
Islamic banks’ assets, its rights and the rights of others in an adequate manner, (3) to enhance
the managerial and productive capabilities of the Islamic bank and encourage compliance with
its established goals and policies and, above all, compliance with sharia, and (4) to provide
useful information to users to make legitimate decisions in their dealings with IFIs (p. 17).
Although the AAOIFI has highlighted the importance of compliance with sharia, Hameed and
Osman (2003) argue that the AAOIFI is discouraged to introduce an overhaul of conventional
accounting to develop, which results in the strong adherence of Western accounting in Islamic
accounting (Adnan, 1997).
As conventional accounting is not considered in conformity with the socioeconomic
objective of Islamic accounting, some researchers also proposed different format for Islamic
financial statements. The popular idea of value added statement for Islamic financial reporting
to replace income statement was first delivered by Baydoun & Willet in 1994 and widely
followed by other Islamic accounting scholars (Baydoun & Willet, 2000; Harahap, 2005;
Taheri, 2005; Triyuwono, 2001). However, these proposed ideas are still restrained in the
discussion level. Sulaiman (2001) compared Muslim respondents’ opinions regarding value-
added and income statements and the result showed that the subjects in the experiment did
not have favorability of value-added statements over income statements.

3. The Notion of Accounting Harmonization for Islamic Financial

Transactions

As Islam is an ethical religion with deep concerned with the right things to do, the issues
of social justice, equitability, and fairness have been taken into consideration in all activities,
including those related to business. The adherence to sharia has enforced IFIs to set their own
accounting policy due to their dissatisfactions with conventional accounting.

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Considering the growth of IFIs that was still in the form of Islamic banks, in 1987,
Islamic Development Bank (IDB) took the initiative to develop accounting standards for
Islamic financial reporting. At that time, most of Islamic banks set their own accounting
policies. Parallel to the need of harmonization in conventional accounting, regulating financial
reporting for Islamic financial transactions was expected to increase IFIs’ financial reporting
comparability (Pomeranz, 1997), which might encourage the establishment of new Islamic
banks.
However, Karim (1990) noted a major factor of the initiative: there was the fear of Islamic
banks that their regulatory agencies would interfere to regulate their accounting practices,
since they were viewed as an abnormal part in the business community. By having a standard
setting body which develops Islamic accounting standards, IFIs wanted to persuade the
regulatory agencies that their unique activities required accounting standards different from
those used in conventional accounting (Karim, 1990).
As a result of the IDB initiative, the AAOIFI was established in March 27, 1991. In the
beginning, there were debates either the AAOIFI would start by using Islamic normative
approach or start with contemporary accounting and test them against sharia. It eventually
resulted in the implementation of the latter approach since the AAOIFI believes that this
approach will facilitate a timely implementation (Lewis, 2001; Vinnicombe, 2010). Nonetheless,
the method is criticized as significantly influenced by Western accounting (Adnan & Gaffikin,
2011).
Over the last two decades after its establishment, the AAOIFI has promulgated a body
of Islamic accounting standards to communicate the financial statements of IFIs. In its early
period, the AAOIFI issued only two statements, which are Financial Accounting Statements
(SFA) 1 and 2 (Karim, 1995). There have been dramatic changes that the AAOIFI now
has published SFA 1 Conceptual Framework of Financial Reporting by Islamic Financial
Institutions, 25 financial accounting standards (FAS), 48 sharia standards, 5 auditing
standards, 7 governance standards, and 2 codes of ethics (AAOIFI, 2012). The AAOIFI
currently operates with more than 200 members of financial organizations from all over
the world. This growing number of membership shows increase in the global awareness of
AAOIFI standards.
Hamid et al. (1993) contends that compliance with Islamic teachings which influences
accounting policies and practices can pose some problems to the international harmonization
of accounting. With the establishment of the AAOIFI, the discussions ramified into another
possibility: harmonization of accounting for sharia-compliant transactions under AAOIFI

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 Islamic Accounting in Indonesia: A Review from Current Global Situation

standards. Karim (2001) highlights the existence of the AAOIFI, which caters unique
characteristics of IFIs, as a way to provide comparable and transparent financial statements
of IFIs. This notion of Islamic accounting harmonization is favored by the Deloitte Islamic
finance leader survey in the Middle East (2010) in which 93% of respondents believe that
AAOIFI accounting standards are sufficient to ensure best practice and transparency of IFIs’
financial reporting. Among jurisdictions with Islamic financial services, Bahrain, Sudan,
Jordan, Qatar, Syria, Lebanon, and South Africa have applied AAOIFI standards.
However, the AAOIFI still faces several critical problems. Despite the increase number
of members, the establishment of the AAOIFI is merely a name, which has no power of
standard enforcement. IFIs can report and disclose similar transactions in different ways
that later poses problems for those institutions themselves as well as for the development of
Islamic finance in general. Thus, the implementation of common Islamic accounting in the
various Muslim nations highly needs cooperation and strong support of accounting scholars,
regulatory bodies, and IFIs in those countries (Karim, 1995; Shanmugan and Perumal, 2005).

4. Contemporary Accounting Practices for Islamic Financial

Transactions

In 2011, the AOSSG published a survey report on accounting for Islamic financial
transactions and entities. Given the extent of the Islamic finance industry in the Asia-Oceania
region and the effort of regional jurisdictions in converging or adopting IFRS, the AOSSG
conducted a survey to understand how IFIs in certain jurisdictions report their transactions
and tried to search for any differences in Islamic accounting standards.
The AOSSG survey was answered by 33 jurisdictions, but only 24 responses (6) were
valid. To improve the integrity of the results, the AOSSG included only authoritative responses
from the standard setters (AOSSG, 2011). The existence of Islamic financial services and
accounting standards specific to Islamic financial transactions and entities in each responding
jurisdiction vary.
Figure 2 shows that 14 respondents claim to have Islamic financial services available
in their jurisdictions, in which all of them move toward adoption or convergence to IFRS.
Among those 14 respondents, only 5 respondents, which are Dubai, Indonesia, Pakistan,

(6)
The 24 respondents are Australia, Belgium, Cambodia, Canada, Denmark, Dubai, Germany, Hong Kong,
India, Indonesia, Iraq, Japan, Korea, Malaysia, Mexico, New Zealand, Pakistan, Saudi Arabia, Singapore,
South Africa, Sri Lanka, Syria, United Kingdom, and Uruguay.

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South Africa, and Syria, apply distinct accounting for IFIs. Dubai, Indonesia, and Syria
consider applying separate financial reporting standards for IFIs to be compatible with IFRS
adoption/convergence while Pakistan and South Africa consider the opposite despite separate
accounting standards for IFIs in their jurisdictions.

Figure 2 AOSSG Survey 2011 Accounting for Islamic Financial Transactions and Entities

24 jurisdictions

Y N
Availability of Islamic financial services
14 10

Y Y N A
Adopt/converge/plan to converge to IFRS 14 7 1 2

Apply distinct accounting for entities with Y N N N N A

Islamic financial services 5 9 7 1 1 1

Consider Islamic accounting to be compatible Y N N Y N N N A

with IFRS convergence/adoption 3 2 9 2 5 1 1 1

Dubai Pakistan Y : Yes

Indonesia South Africa N : No
Syria A : No answer

Source: data tabulated from AOSSG Survey (2011); figure created by author

The survey shows a global move to IFRS, either the countries surveyed are planning
to, being converged or has already converged or adopted IFRS. (7) Indonesia and Pakistan
are two countries surveyed by the AOSSG that strongly state their intention to retain Islamic
accounting standards (Table 2).

(7)
Mexico is the only country surveyed which responded that it did not have plans to converge with IFRS.

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Table 2 AOSSG Survey 2011(8)

Accounting for Islamic Financial Transactions and Entities in Selected Jurisdictions
Country Q1*1 Q2*2 Q3*3 Q4*4 Q5*5 Q6*6
Dubai IFRS Yes Yes Yes AAOIFI FAS We may need to review some
of the requirements of
Islamic accounting standards.
Indonesia National standards Yes Yes Yes National standards not We will retain our Islamic
based on IFRS based on AAOIFI FAS accounting standards
Malaysia National standards Yes No No
based on IFRS
Pakistan IFRS Yes No Yes National Islamic We will retain our Islamic
standards adapted accounting standards
from AAOIFI FAS
Saudi Banks and other Yes No No National standards not
Arabia insurance companies: based on AAOIFI FAS
IFRS; other entities: and other (No
local standards separate standards for
issued by SOCPA(8) Islamic accounting)
South IFRS Yes No Yes AAOIFI FAS We may need to review some
Africa of the requirements of
Islamic accounting standards.
Syria IFRS Yes Yes Yes AAOIFI FAS We may need to review some
of the requirements of
Islamic accounting standards.
*1
Q1: What financial reporting standards generally apply to entities engaged in finance in your jurisdiction?
*2
Q2: Does your jurisdiction have a policy of convergence with, or adopting, IFRS?
*3
Q3: Do you consider applying different financial reporting standards for entities engaged in Islamic finance
to be compatible with IFRS convergence/adoption?
*4
Q4: Do special financial reporting standards apply to entities engaged in Islamic finance in your jurisdiction?
*5
Q5: What type of Islamic accounting standards applies in your jurisdiction?
*6
Q6: More and more countries are converging with or adopting IFRS. How does this affect your policy on
Islamic accounting standards?
Source: AOSSG Survey (2011); tabulated by author

The two other countries, Saudi Arabia and Malaysia, which are the second and the
third largest countries with sharia-compliant assets (The Banker, 2012), do not provide
distinct accounting standards for Islamic transactions. The Malaysia Accounting Standards
Boards (MASB) even requires its accounting standards based on IFRS to be applied to
Islamic financial transactions and provide additional guidance which should not override the
accounting standards (AOSSG, 2011).
In October 2011, Dubai Financial Services Authority (DFSA) followed the MASB steps
by publishing Consultation Paper No. 79 that discussed the possibility of accounting for IFIs
to move from AAOIFI standards to IFRS. Currently, the DFSA Rulebook: Islamic Financial
Rules has stated that IFIs’ financial statements should follow the DFSA Rulebook: General

(8)
Saudi Organization of Certified Public Accountants

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Module No. 8, which mandates the use of IFRS (DFSA, 2013a, p. 63). Despite the mandatory
application of IFRS, the DFSA also requires IFIs’ financial statements to contain specific
disclosures (DFSA, 2013b, p. 12).
However, this decision is difficult to be followed by some jurisdictions that consider
IFRS unacceptable for Islamic financial transactions. The conflicts between IFRS and Islamic
accounting standards are believed to stem from two fundamental financial reporting concepts,
which are time value of money and substance over form (AOSSG, 2010; ACCA & KPMG, 2012).
Time value of money is claimed to be associated with interest, while IFRS includes the use
of discounted cash flows with reference to interest rates. Under International Accounting
Standards (IAS) 39, for example, the use of valuation techniques that involve the calculation of
net present value of future cash flows discounted at an appropriate rate of interest is necessary
to measure financial assets where active market do not exist.
The notion of substance over form, in which a transaction is measured and reported
in accordance with its economic substance rather that its legal form, is also claimed to be
inappropriate from Islamic perspective. According to sharia, it is the Islamic legal form that
will ultimately determine the accounting form. Ijara muntahia bittamleek, which is an Islamic
form of leasing agreement with transfer of ownership at the end of ijara term, should be
treated as financing lease under IAS 17. AAOIFI FAS 8, on the other hands, states that the
assets remain with the lessor until legal title is transferred.
However, the debates over these points are continuing, as there are various schools
of thoughts among sharia scholars that may result in different interpretations across
jurisdictions. Those who welcome time value of money in reporting Islamic financial
transactions believe that time value of money in term of showing the financing effect
of a transaction is different from charging interest on a loan. Substance over form,
correspondingly, is not contradicted with sharia since reporting economic substance is as
valuable as reporting its legal form, as long as the information about its legal form disclose on
the notes to the financial statements (AOSSG, 2010).
Based on those reasons, the MASB came to a conclusion, “We feel that we can use the
IFRS unless someone can show us that there is a clear prohibition in the sharia, and then we
will amend it accordingly. Until such time, we’ll use the IFRS” (ACCA & KPMG, 2012). The
MASB states that its approved accounting standards shall apply to sharia compliant financial
transactions and events, unless there is a sharia prohibition, with some additional guidelines
to apply MASB approved accounting standards to sharia-compliant transactions (Statement of
Principles (SOP) i-1, IN4).

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Nevertheless, other jurisdictions are also reluctant to accept IFRS for Islamic financial
transactions, since some unique characteristics of Islamic finance are uncovered by IFRS.
Mudaraba, as a most popular form of Islamic transactions, has created a “hybrid” element

between equity and liability, which is reported under AAOIFI FAS as ‘unrestricted investment
accounts (URIA)’(9). AAOIFI FAS classifies this item as a mezzanine level between liability and
equity.
Another uncovered characteristic of Islamic financial services is the profit-sharing
reserves, which are intended to stabilize profit sharing in IFIs. When the overall profit levels
are low, IFIs forgo their own share of profits in favor of their customers. In profit equalization
reserve (PER), the reserve is set aside from profits before applying the profit sharing
distribution in order to match current market return. No consistency in accounting for PER.
How this account is presented under certain accounting standards will be presented in the
later part (see Table 4).
Although the results of the AOSSG survey can assist in giving the outlook of current
global Islamic accounting situation, this survey deals with limitation related to limited number
of respondents; some considerable jurisdictions in Islamic finance such as Iran, Kuwait, and
Bahrain are not listed as participating jurisdictions. There is the necessity for a more abundant
cross-border comparability among primary players in Islamic financial industry to find out
whether any positive future intention of keeping the development of Islamic accounting on
track.

5. Islamic Accounting in Indonesia

5.1 Historical Milestones

In Indonesia, Banking Act No. 7 of 1992 first recognized and allowed the establishment
of Islamic banks, although the term used in this act was “profit-sharing bank” instead of
Islamic bank. It leads to the inauguration of Bank Muamalat Indonesia, the first Islamic bank
in Indonesia, which started its operation in the same year (Kasri & Kassim, 2009). More acts
were established after that, e.g. Banking Act No. 10/1998, Central Bank Act No. 23/1999, and

(9)
URIA is not a liability since IFIs have the no obligation to return the funds in the case of loss, unless the
loss is due to IFIs’ negligence or breach of contract. However, it is also not considered ownership equity
since the account holders do not receive the same rights as the shareholders do, such as voting rights
and entitlement to profits realized from investing funds provided by current and other non investment
accounts.

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Islamic Banking Act No. 21/2008, which strengthened the root of IFIs in Indonesia.
According to the Central Bank of Indonesia or Bank Indonesia (2013), in February 2013,
there are 11 Islamic commercial banks with 1,801 offices, 24 Islamic business units (10) with 524
offices, and 158 Islamic rural banks with 395 offices. As the world most populated Muslims
country, Indonesia is considered as one of the most potential players in Islamic financial
industry, which will create a pool of demand of Islamic financial products. (11)
The accounting standards setting body in Indonesia is the Indonesian Financial
Accounting Standards Board (DSAK), which is established under the Indonesian Institute
of Accountants (IAI). After the initiation of the first Islamic bank in Indonesia, DSAK did
not directly develop Islamic accounting standards. Thus, Islamic banks in Indonesia used
Statement of Financial Accounting Standards applicable in Indonesia (known as PSAK) No. 31
Accounting for Banking Industry and some of AAOIFI standards.
In 1999, Bank Indonesia initiated the preparation of Islamic accounting standards by
issuing decree of Governor of Bank Indonesia No. 1/16/KEP/DGB/1999 which stated that
Bank Indonesia, DSAK, Bank Muamalat Indonesia, and the Ministry of Finance were the
components of standard making team of PSAK for Islamic banking (Wiroso, 2010). After
about 10 years of existence of Islamic banks in Indonesia, PSAK 59 Accounting for Islamic
Banking that was effective in 1 January 2003 became the first milestone of Islamic accounting
in Indonesia.
As certain contemporary issues may need additional explanations from Islamic point of
view, ijma or consensus made by religious scholars is necessary to work out issues peculiar
to this modern day and age, including contemporary financial or accounting issues. In
Indonesia, National Sharia Board of the Indonesian Council of Islamic Scholars (DSN-MUI)
is responsible to produce legal pronouncement on certain Islamic issues that is not directly
mentioned in the Quran or hadith. Therefore, prior to the issuance of Islamic accounting
standards, it is necessary to get official approval from DSN-MUI to ensure that the standards
are in accordance with Islamic principles.

(10)
Islamic business unit refers to conventional banks that have Islamic windows.
(11)
However, IFIs in Indonesia is still facing a huge challenge. From 88% share of Muslim population in
Indonesia, IFIs serve only 4% of its total population (Statistical, Economic and Social Research and
Training Center for Islamic Countries (SESRIC), 2012). Although this number is predicted to be
growing, it shows that current public awareness of consuming sharia-compliant products is still low (Ika
& Abdullah, 2011; Widagdo & Ika, 2007).

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5.2 Current Practices

Due to increasing activity and number of Islamic banks, which have developed into IFIs,
the IAI established Committee of Sharia Accounting in 2005 as a part of DSAK to specifically
prepare accounting standards for IFIs. In 2010, the IAI decided to transform this committee
into Sharia Accounting Standards Board (DSAS) that has equal position to DSAK. Currently,
nine Islamic accounting standards, which are PSAK 101-109, have been approved to replace
PSAK 59. DSAS has also issued a distinct framework for Islamic financial transactions, which
is Framework for Preparation and Presentation of Islamic Financial Statements.
Figure below illustrates the house of Generally Accepted Sharia Accounting Principles
in Indonesia whereby the layer below becomes the foundation of the upper layer. When the
sources in many layers conflict each other, the layer below should be followed first.

Figure 3 House of Generally Accepted Sharia Accounting Principles in Indonesia

House of Generally Accepted

Sharia Accounting Principles in
Indonesia

Financial reporting prectices, Text books, research

Level 3 conventions, and traditions in outcomes, articles, and
conformity with sharia scholar opinions

International or other
countries’ accounting Technical Government Accounting
Operational Level 2 standards in
Framework conformity with Bulletin Regulations Guidelines
sharia

PSAK & ISAK

Level 1 Sharia PSAK & ISAK
in conformity with Sharia

Conceptual Framework Framework for Preparation and Presentation of Islamic Financial Statements

Generally Accepted Sharia Fatwa (Islamic legal pronouncements)

Sharia Framework Hadith

Quran

PSAK: Statements of Financial Accounting Standards applicable in Indonesia

ISAK: Interpretations of Financial Accounting Standards applicable in Indonesia

Source: IAI (2009), translated by author

As the framework in Figure 3 explains, in the case of no standards in Level 1 can

appropriately account for specific Islamic financial transactions, standards in Level 2, which

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include international accounting standards in conformity with sharia, can be used. In other
words, AAOIFI accounting standards can be used as references when no appropriate PSAK
is available. Currently, AAOIFI guides more issues in Islamic financial transactions. Table 3
shows the comparison of AAOIFI FAS and PSAK.

Table 3 The Comparison of AAOIFI FAS and PSAK(12)(13)

AAOIFI FAS PSAK
SFA 1 Conceptual Framework for Financial Reporting Framework for Preparation and Presentation
by Islamic Financial Institutions of Islamic Financial Statements
FAS 1 General Presentation and Disclosure in the PSAK 101 Islamic Financial Statement Presentation
Financial Statements of Islamic Banks and
Financial Institutions
FAS 2 Murabaha and Murabaha to the Purchase PSAK 102 Accounting for Murabaha
Orderer
FAS 3 Mudaraba Financing PSAK 105 Accounting for Mudaraba
FAS 4 Musharaka Financing PSAK 106 Accounting for Musharaka
FAS 5 Disclosure of Bases for Profit Allocation Between
Owners’Equity and Investment Account Holders
FAS 6 Equity of Investment Account Holders and
Their Equivalent
FAS 7 Salam and Parallel Salam PSAK 103 Accounting for Salam
FAS 8 Ijarah and Ijarah Muntahia Bittamleek PSAK 107 Accounting for Ijarah
FAS 9 Zakat PSAK 109 Accounting for Zakat, Infaq(12), and Sadaqah(13)
FAS 10 Istisna and Paralel Istisna PSAK 104 Accounting for Istishna
FAS 11 Provisions and Reserves
FAS 12 General Presentation and Disclosure in the PSAK 108 Accounting for Islamic Insurance
Financial Statements of Islamic Insurance Transactions
Companies
FAS 13 Disclosure of Bases for Determining and
Allocating Surplus or Deficit in Islamic
Insurance Companies
FAS 14 Investment Funds
FAS 15 Provisions and Reserves in Islamic Insurance
Companies
FAS 16 Foreign Currency Transactions and Foreign
Operations
FAS 17 Investments for Real Estates
FAS 18 Islamic Financial Services offered by
Conventional Financial Institutions
FAS 19 Contributions in Islamic Insurance Companies
FAS 20 Deferred Payment Sale
FAS 21 Disclosure on Transfer Assets
FAS 22 Segment Reporting
FAS 23 Consolidation
FAS 24 Investments in Associates
FAS 25 Investments in Sukuk, Shares, and Similar PSAK 110 Accounting for Sukuk
Instruments

Despite the similarities in some standards, Indonesia at the moment claims to apply
national standards not based on AAOIFI FAS. It relies mainly on DSAS, with approval from

(12)
Any benevolent spending approved by sharia
(13)
Charity

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DSN-MUI to assure the sharia compliance, to create accounting standards for sharia-compliant
transactions. DSAS implements its own Islamic accounting standards because it attempts to
cover a wider coverage compare to those of AAOIFIs’. AAOIFI standards are focusing on IFIs
while DSAS wants to include parties transacting with IFIs. In other words, DSAS also have the
intention to administer non-financial institutions that perform sharia-compliant transactions
(Akuntan Online, 2013).
There are also different opinions between DSAS and the AAOIFI of what is sharia-
allowed and not allowed in Islamic finance and accounting. An example is AAOIFI FAS 9
and PSAK 109. Table 3 shows that those standards are similar in title, which is related to
zakat. However, there is fundamental difference between FAS 9 and PSAK 109. FAS 9 can be

adopted in the cases of IFIs are obliged to pay zakat, namely (1) when the law requires IFIs to
satisfy the zakat obligation, (2) when IFIs are required by its charter or by laws to satisfy the
zakat obligation, and (3) when the general assembly of shareholders has passed a resolution

requiring the company to satisfy the zakat obligation. In other words, FAS 9 recognize the
existence of corporate zakat or zakat paid on behalf of the corporation itself.
In Indonesia, on the other hand, there has been a long debate whether the concept of
muzakki or zakat payer includes only individual or also corporations. (14) Therefore, PSAK 109

is designed only for zakat institutions that collect and distribute zakat. Although Islamic banks
in Indonesia are allowed to collect zakat, Islamic banks normally hand over the distribution of
zakat to zakat institutions that makes Islamic banks are not subject to PSAK 109. Nevertheless,

IFIs in Indonesia, e.g. Bank Muamalat Indonesia and Bank Syariah Mandiri, pay corporate
zakat based on the decision of general assembly of stockholders each year by simply

calculating at general rate of zakat, which 2.5%, from net profit. It is different from FAS 9 which
administers specific methods to calculate corporate zakat namely net assets method and net
invested methods.
There are other differences that are not yet compromised. Table 4 shows examples of
different treatments under AAOIFI FAS and Indonesia Sharia PSAK. How the treatments
under MASB GAAP are also presented to show how a local GAAP based on IFRS differs from
Islamic accounting.

(14)
Although Zakat Management Act no. 38/1999 stated that muzakki could be either individual or
institutions owned by Muslims, the debate is continuing.

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Table 4 Different Treatments on Specific Accounts

Standards MASB GAAP AAOIFI FAS PSAK Sharia
Treatments based on IFRS
Mudaraba-based transactions No Yes, called URIA Yes, called shirka funds
create mezzanine level
between liability and equity
PER Accounted for as Accounted for as No PER account (PER is
liabilities equity considered haram)
Ijarah muntahia bittamleek Similar to finance Similar to operating Similar to operating lease
(ijara with purchase option) lease lease
Corporate zakat Tr i-1 (guidelines) FAS 9 No accounting standards or
guidelines for corporate zakat

DSAS is currently working on exposure drafts of several Islamic accounting issues. One
of them is accounting for fee-based income (Akuntan Online, 2013), which is widely used in
Islamic finance. Until now, IFIs in Indonesia use PSAK mudaraba to account for fee based
income because of the unavailability of specific accounting standards for fee-based income.

6. Concluding Remarks

The rapid growth of Islamic financial industry has been one of the important factors
behind the emergence of Islamic accounting. Conventional accounting, which is developed
based on Western worldview, is considered insufficient to accommodate unique characteristics
of IFIs. Prior to the establishment of the AAOIFI, almost every IFI set its accounting policy
internally (Karim, 1990). Nowadays, based on the accounting standards used, there are five
groups of IFIs: those reporting Islamic financial transactions (1) under IFRS or local GAAP
based on IFRS, (2) under IFRS or local GAAP based on IFRS with some additional guidelines,
(3) by adopting AAOIFI FAS, (4) by adapting AAOIFI FAS, and (5) by using national Islamic
accounting standards.
As previously discussed issues have shown, Islamic accounting does not refer to a
uniform set of standards. Each jurisdiction has diverse understandings on Islamic rulings,
which results in different accounting treatments for Islamic financial transactions. These
different opinions and understandings of sharia have become the biggest challenge of a
common set of global Islamic accounting standards. Additionally, the global movement
towards IFRS convergence or adoption is likely to influence the choice of accounting
standards for IFIs. Dubai, South Africa, and Syria which implement AAOIFI accounting
standards are rethinking about the future of Islamic accounting in their jurisdictions, as
they are currently moving towards IFRS (AOSSG, 2011). In 2013, Dubai revised its rules by

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mandating IFIs to follow IFRS, with some additional specific disclosures. Thus, harmonizing
Islamic accounting standards under AAOIFI accounting standards is presumably to be a long
way to accomplish.
Despite the similar movement towards IFRS in Muslim-majority jurisdictions, there are
diverging opinions on how accounting for IFIs should move towards this global accounting
phenomenon. In the AOSSG survey, only two out of five jurisdictions with Islamic accounting
standards, including Indonesia, revealed the intention to retain their Islamic accounting
standards.
Indonesia adopts dual accounting system that separates between conventional and
Islamic accounting. Looking at the history, Indonesia referred to AAOIFI standards to develop
its Islamic accounting standards. After more than ten years of Islamic accounting in Indonesia,
instead of adopting or adapting more AAOIFI standards, it now claims to apply national Islamic
accounting not based on AAOIFI FAS (AAOSG, 2011; Akuntan Online, 2013). DSAS tries to
develop a more comprehensive set of Islamic accounting standards, which is not limited to
only IFIs. Moreover, there are also different views between the AAOIFI and the DSAS on how
to treat specific sharia-compliant transactions, which also exist among Islamic accounting
scholars from other jurisdictions.
This condition is different from the decision on conventional accounting towards IFRS.
As the process of convergence with IFRS in Indonesia has entered the implementation phase
since 2012, and is currently still ongoing, there is possibility that it will have implications
on Islamic accounting. The intention to develop Islamic accounting not only for IFIs, but
also for parties transacting with IFIs, have potential conflicts with IFRS. However, Indonesia
clearly stated on the AOSSG survey that it would retain its Islamic accounting standards. It is
interesting to explore whether any well-defined future policies or development framework for
Islamic accounting in Indonesia, since the era of accounting globalization will surely provide
huge future challenges.

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