IMPACT Brazil is not the only civil law country that has committed with international organizations to implement accrual accounting IPSAS and prepare whole of public sector accounts. The findings of this paper will be of value to policy-makers from other civil law countries in dealing with the assimilation of new accounting rules in a context of conflict between standard-setters and auditors. This paper shows how the Brazilian Treasury has developed strategies to build legitimacy in a civil law context where the legislature left a vacuum regarding the accrual accounting standard-setting mandate. While the accounting 'rule-enforcers' neglected to require compliance with the rules, the 'rule-makers' co-operated with each other to build normativity for accounting rules and eventually attempted to develop new forms of enforcement, which the 'rule-appliers' lobbied against.