ANACOM considers the distribution of costs between CTT's postal activity and banking activity to be improper

As universal service provider, CTT - Correios de Portugal is required to employ a Sistema de Contabilidade Analítica (Analytical Accounting System) permitting the separation of accounts between the services and products that comprise the universal service and those outside the scope of the universal service. This system is also required to provide separation of accounts between the costs associated with the various basic operations supporting postal services (collection, handling, transportation and distribution).

ANACOM is responsible for approving the analytical accounting systems used, ensuring oversight of their proper application by a competent entity which is independent of the universal postal service provider. ANACOM is likewise required, on an annual basis, to publish a declaration of conformity of the analytical accounting systems used by postal service providers and of the results obtained.

ANACOM contracted Grant Thornton & Associados, as an independent external entity, to conduct auditing of the results of the Sistema de Contabilidade Analítica (Analytical Accounting System) used by CTT for financial years 2016 and 2017.

Following an audit of the 2016 results, the auditors submitted a preliminary report to CTT for comments and concluded the final report.

After analysing the final audit report and in view of the reservations raised by the auditors, ANACOM concluded that the results of CTT's Sistema de Contabilidade Analítica (Analytical Accounting System) for financial 2016 were not in accordance with the system's guiding principles. At issue is the improper allocation of costs between the group's postal activity and banking activity at the level of its retail network (post offices).

Pursuit of banking activity at CTT post offices implies a sharing of resources (e.g. personnel expenses, rents and leases, insurance, condominium fees, water, electricity, consumables, depreciation and amortisation, taxes and charges, etc.), between the postal activity and banking activity. For 2016, the costs of these two activities are improperly separated for a significant proportion of these resources, in accordance with the guiding principles, including the principle of causality.

The issue stems from an overstatement of costs allocated to the postal activity and an offsetting undervaluation of costs charged to the banking activity, especially with respect to depreciation, amortization, rents and leases of tangible assets (fixed and current), cost of capital, taxes and charges, insurance, conservation and repair, utilities (e.g. water, electricity), cleaning and property security, and various consumables.

In an audit of the results of CTT's SCA - Sistema de Contabilidade Analítica (Analytical Accounting System) for 2015, ANACOM already signalled this concern to CTT, given that Banco CTT opened a pilot branch in December 2015.

It should be noted that, in accordance with the current regulatory framework, the pricing of postal services included in the universal service is subject to a set of principles including the principle of cost orientation, so that pricing provides an incentive for the efficient provision of the universal service.

In this context, based on the results of the completed audit, ANACOM approved a draft decision that includes a draft declaration of non-conformity as regards the results of CTT 's SCA - Sistema de Contabilidade Analítica (Analytical Accounting System) for 2016. The draft decision also orders a restatement of the results of the system for 2016 and 2017, in compliance with the guiding principles. CTT is given a period of 20 working days in which to state its position.