--- title: "EY and Wirecard: the audits from 2009 to 2019" language: en canonical: https://dossiertwist.com/dossiers/wirecard-ag/ey-audits/ as_of: 2026-10-21 keywords: ["Wirecard AG","Wirecard Bank","Markus Braun","Jan Marsalek","EY","third-party acquiring","trust accounts","CardSystems Middle East","Al Alam","PayEasy","Senjo","Citadelle Corporate Services","OCAP Management","BaFin","ESMA peer review","KPMG special investigation","Projekt Ring","Munich I regional court","Michael Jaffé","MB Beteiligungsgesellschaft"] --- # EY and Wirecard: the audits from 2009 to 2019 **Question.** How did EY audit Wirecard, and what have investigators, the oversight body and the courts said about those audits? **Answer.** EY audited Wirecard from the 2009 financial year, jointly with RP Richter for 2010 and alone from 2011, and gave unqualified opinions on every year to 2018 before refusing an opinion for 2019. The special investigators found that EY accepted management's description of the third-party acquiring business, reclassified escrow balances as cash and relied on internal documents and oral statements rather than third-party evidence; EY has called the case an elaborate and sophisticated fraud. In 2023 the auditor oversight body found breaches of professional duties in the 2016–2018 audits, and in 2025 the Federal Court of Justice largely upheld the insolvency administrator's claims to see EY's working files. ## Appointment and opinions - Analysis: RP Richter GmbH and Ernst & Young GmbH were appointed joint auditors of Wirecard AG and the group for 2010 and issued an unqualified opinion on the 2010 individual and consolidated accounts, for fees of EUR 455,000 (Ernst & Young) and EUR 481,000 (RP Richter). Wirecard's 2018 report says that EY had audited the company jointly with RP Richter from the 2009 financial year and alone from 2011, and EY's 2018 opinion states that it had served as group auditor without interruption since 2009; it was elected by the shareholders' meeting of 21 June 2018 and engaged by the supervisory board on 25 June. A European Parliament briefing notes that EY had itself been tasked with a special investigation into allegations of accounting manipulation, a mandate that enabled it to replace Wirecard's former external auditor in 2010. The briefing reproduces a company statement that the investor protection association SdK had sued to challenge the 2008 annual general meeting's discharge of the boards and to have the 2007 accounts declared void, and that in autumn 2008 the supervisory board had EY prepare an expert opinion, which saw no need for corrections; the outcome of that action is not in the record. [src-023] [src-005] [src-025] - Analysis: EY issued unqualified opinions on the 2011 accounts, signed in Munich on 16 April 2012, and on the 2016 accounts, which the supervisory board approved on 5 April 2017. The Finance Ministry's report to the Bundestag finance committee of July 2020 states that the company and the group presented accounts for every year from 2009 to 2018 with EY's unqualified opinion, that none of the audits led to objections and that the 2018 opinion discussed the Singapore whistleblower allegations. The 2018 opinion was signed by Martin Dahmen, responsible auditor from 2018 who had first signed for 2016, and by Andreas Budde; EY's fees were EUR 2.3 million for 2018 and EUR 2.2 million for 2017. According to FREP information in ESMA's report, EY set its materiality limit at EUR 20 million for 2018 and EUR 28.7 million for 2019. [src-010] [src-032] [src-050] [src-069] [src-005] [src-087] ## How EY treated third-party acquiring - Analysis: The special investigators found that EY had the chief financial officer Burkhard Ley and the executive vice president accounting Stephan von Erffa confirm by signature, in a "concurrence memorandum" of 3 March 2016, EY's understanding of Wirecard's role in the business. The memorandum was prepared by an EY senior manager, approved the same day by a partner and signed by ten EY auditors including the quality-control partner; it recorded that no receivable from Al Alam, PayEasy or Rising Sun had gone unpaid in 2011–2013 and that management saw no liability risks in 2014. The working papers contain no contracts between the partners and the merchants or banks to support what management described, and the auditor did not consider whether the extensive collateral Wirecard gave the partners was usual in the market. [src-027] - Analysis: EY's 2015 working papers first classified the escrow accounts as restricted cash and then, in a memorandum, reclassified them as cash on the argument that Wirecard could replace them with a bank guarantee obtainable within three months with the partners' agreement; the investigators found no evidence that such a guarantee existed or could be obtained. In the 2015–2016 audits EY listed external fraud risk factors such as capital-market pressure, share-price-linked pay, EBIT covenants and money laundering at Wirecard Bank, but in the investigators' evaluation did not include the standard risk of management override, documented no analysis of fraud indicators under IDW PS 210 and did not assess whether the partners were service providers whose internal controls needed testing, although it obtained such reports for Wirecard Bank's provider SIX Payment Services. [src-027] - Analysis: Overdue trade receivables stood at EUR 55.3 million at the end of 2016 before allowances, against total trade receivables of about EUR 190 million after allowances; the investigators note that the ageing analysis required by IFRS 7.37a was not disclosed in the 2016 notes and that EY considered the omission immaterial. In their view the business bore the features of a measure designed to shape the balance sheet within the meaning of section 321(2) of the Commercial Code, yet EY's long-form report on the 2015 consolidated accounts contains no explicit section on it, only partial descriptions, a remark on the high volume of unsecured receivables from the partners and Wirecard's intention to monitor them more closely. EY's position on this evaluation is not in the record. [src-027] ## The 2018 audit - Analysis: For 2018 EY named the valuation of receivables and the recognition of revenue from acquiring partners as a key audit matter: the receivables arose from fees and commissions on transactions processed through the partners and from prefinancing of merchant payouts, and Wirecard was treated as principal under IFRS 15, so revenue was shown gross. EY states that it obtained confirmations from the partners, traced their payments, reconciled their settlements with transaction data and had no objections. An emphasis-of-matter paragraph addressed the Singapore whistleblower's allegations and claims for damages over allegedly incorrect or late disclosures; EY states that it compared the findings with work by independent third parties and the internal compliance department, interviewed managers, suppliers, customers and lawyers with its own forensic specialists, and again had no objections. [src-005] - Analysis: According to the special investigators, Wirecard had known since March–April 2018 of the whistleblower information the Financial Times published on 30 January 2019 and had engaged Rajah & Tann, then Fieldfisher, which brought in Control Risks. From February 2019 EY's forensic department joined the audit, identified more than 20 issues from the allegations and kept a file "Wirecard AG Project Tiger 2018" of more than 1,100 documents. The significance of the emphasis of matter was not discussed with the boards; the meeting to approve the accounts on 24 April 2019 was interrupted at 6 p.m. because of a new Financial Times article, which the auditor discussed with the supervisory board's lawyers, the supervisory board and Markus Braun before concluding that it changed nothing in the opinion. [src-027] ## Refusal and consequences - Analysis: The Federal Court of Justice records that Wirecard's auditor since 2009, which also audited Wirecard Technologies GmbH from 2014 to 2019, issued unqualified opinions on both companies' accounts for 2014–2018 and refused an opinion for 2019; Wirecard Technologies filed for insolvency on 1 July 2020. When FREP concluded on 20 July 2020 that the 2018 accounts were erroneous, it notified the auditor oversight body of a possible breach of professional requirements by EY and on 22 July sent it KPMG's full report. [src-057] [src-087] - Analysis: The special investigators concluded on 16 April 2021 that there were indications that EY had not fully applied the IDW standards in planning and performing the audit, that a systematic analysis of fraud indicators could have led to greater professional scepticism and further procedures on the business, and that the audit evidence often consisted of internal documents and oral statements by the management board rather than third-party confirmations; they gave no overall assessment of whether the audit was properly performed, and their conclusion is not a disciplinary or court finding. EY had said in June 2020, as quoted from a news agency in a European Parliament briefing, that there were clear indications of an elaborate and sophisticated fraud involving multiple parties around the world in different institutions with a deliberate aim of deception. The auditor oversight body later found breaches of professional duties in the 2016–2018 audits, and the Federal Court of Justice largely upheld the administrator's claims to the working files, as set out below. [src-027] [src-025] [src-030] [src-057] - Analysis: Germany's auditor oversight body APAS announced on 3 April 2023 that its decision chamber had found on 31 March 2023 that professional duties were breached in the audits of Wirecard AG and Wirecard Bank AG for 2016 to 2018, and imposed sanctions on the audit firm and five auditors, while proceedings against seven others ended because they gave up their auditor status. The fines ranged from EUR 23,000 to EUR 300,000 for individuals and were EUR 500,000 for the firm, which was also barred for two years from accepting new statutory audits of public-interest entities; no breaches were found for 2019. The announcement does not name the firm, which was Wirecard's auditor, EY. On 11 December 2025 the Federal Court of Justice upheld claims of the insolvency administrator of Wirecard AG and Wirecard Technologies against the audit firm for information about and access to its working files for 2016 to 2019, including the 2016 consolidated audit and the "Projekt Ring" special investigation; claims concerning 2014 and 2015 were time-barred. [src-030] [src-057] ## Sources - [src-023] Company statement source · src-023 - [src-005] Company statement source · src-005 - [src-025] European Parliament briefing: Banking Union – Wirecard, European Parliament (Directorate-General for Internal Policies), 2020-06 - [src-010] Company statement source · src-010 - [src-032] Company statement source · src-032 - [src-050] Company statement source · src-050 - [src-069] Federal Ministry of Finance: status report on Wirecard (timeline), Federal Ministry of Finance, 2020-07-17 - [src-087] ESMA fast-track peer review on the application of the guidelines on the enforcement of financial information by BaFin and FREP in the context of Wirecard, European Securities and Markets Authority (ESMA), 2020-11-03 - [src-027] Research source · src-027 - [src-057] Federal Court of Justice: press release 228/2025 (III ZR 438/23), Federal Court of Justice, 2025-12-11 - [src-030] APAS press release on its proceedings concerning the Wirecard audits, Auditor Oversight Body (APAS), 2023-04-03