RG Implementation Tool CSRS 4200 June 2020
RG Implementation Tool CSRS 4200 June 2020
JUNE 2020
The Auditing and Assurance Standards Board (AASB) has issued a new Canadian Standard
on Related Services (CSRS) 4200, Compilation Engagements. CSRS 4200 replaces:
This Implementation Tool for Practitioners (Tool) will assist you with the implementation of CSRS 4200.
It provides guidance to you, the practitioner, when you are asked to perform a compilation engagement.
You will need to adapt the Tool to the specific circumstances of each engagement. This Tool does not
replace the need to read CSRS 4200, including the application and other explanatory material.
This Tool is the fourth document in a series issued by CPA Canada related to CSRS 4200. The
following are the previously-released documents:
• Practitioner Alert was developed to help prepare you and your firm for the transition to
CSRS 4200.
• Management Briefing was developed to inform management about the impact of CSRS 4200
and to assist management in discussions with you.
• Third-Party Briefing was developed to help lenders and other third parties enhance their
understanding of a compilation engagement and to facilitate discussions.
IMPLEMENTATION TOOL FOR PRACTITIONERS 2
The primary objective of this Tool is to supplement the Alert and Briefings and to assist you
with the implementation of CSRS 4200 for a specific compilation engagement.
Effective Date
CSRS 4200 is effective for compiled financial information for periods ending on or after
December 14, 2021. You are permitted to use the new standard before the effective date.
Contents
Scope of CSRS 4200 3
Documentation 26
Additional Resources 30
This Tool includes questions and responses to expand on some of the issues and to anticipate some
of the questions that may arise on the implementation of CSRS 4200. The first of these questions is
related to the term “financial information.”
QUESTION 1
Why does CSRS 4200 refer to financial information and not financial statements?
CSRS 4200 refers to financial information and not financial statements to reflect that
information subject to compilation engagements is often comprised of part of a completed
set of financial information or schedules of financial information.
The term “financial statements” ordinarily refers to a complete set of financial statements,
including a statement of cash flows and note disclosures, as determined by the requirements
of the applicable financial reporting framework. The preparation of such financial statements
in a compilation engagement is rare.
Information subject to a compilation engagement may include:
• a complete set of financial statements, but that is expected to be rare
• a part of a complete set of financial statements
• schedules of financial information
• pro forma financial information (i.e., historical information modified to reflect one
or more “what if” events)
(See CSRS 4200 Para. A1)
CSRS 4200 provides information on which services constitute compilation engagements. Some
services are excluded from the standard that may be considered “new” when compared to Section 9200.
This means that some services you performed under Section 9200 will not necessarily be compilation
engagements under CSRS 4200.
The following table summarizes the scope exclusions in CSRS 4200. These are circumstances that do
not require you to undertake a compilation engagement, and therefore CSRS 4200 does not apply:
Scope Exclusions*
* CSRS 4200 indicates which services are excluded from the scope; however, you may decide or be
requested to issue a communication on the financial information. In that case, the only appropriate
form of communication is a compilation engagement report (see Sample Compilation Engagement
Report included in Appendix B of this Tool) to which all requirements of CSRS 4200 apply.
Applying CSRS 4200 gives you an opportunity to revisit the services you currently provide
to your client and determine which service best meets their needs.
QUESTION 2
How do I know if CSRS 4200 is the appropriate standard / engagement to meet
the clients’ request / needs?
The first step is to identify the client’s needs.
You can start the discussion with such preliminary questions as the following:
• Do they need bookkeeping services?
• Do they need tax compliance services?
• Do they want you to assist them with preparing financial information?
• Do they want a practitioner’s communication?
• Do they have any third parties that intend to use the financial information?
• Do they need assurance on the financial information?
Remember, if management or a third party wants or needs assurance on the financial
information, then a compilation engagement under CSRS 4200 is not the appropriate
engagement. In such case, you may ask your client to consider whether a review engagement
or an audit engagement would better address the needs of their users.
If no assurance is required, you can determine whether CSRS 4200 is the appropriate
engagement.
The following two scenarios illustrate some possible conclusions on the nature of the services
that your client may request:
• If your client requires a bookkeeping service and a tax service and does not request
financial information with your communication attached, then CSRS 4200 need not apply.
• If you are engaged to do the above but your client requests financial information with
your communication attached, because the client wants to provide it to a third party
or for management’s own purposes, then CSRS 4200 will apply.
QUESTION 3
Can I attach a compilation engagement report (or any other form of
communication) on financial information that is excluded from the scope of
CSRS 4200?
There may be circumstances when CSRS 4200 does not apply but management requests a
practitioner’s communication, or when you decide that a communication is necessary to avoid
users’ misunderstanding the nature and limitations of the engagement.
The only form of communication you can attach to the financial information is a compilation
engagement report. In such case, all the requirements of CSRS 4200 apply.
No other form of communication, such as disclaimers, can be included or attached to financial
information excluded from the scope of CSRS 4200. The reason that the only appropriate form
of communication is a compilation engagement report is because such a report appropriately
communicates management and the practitioner’s responsibilities and the limitations of the
engagement. Different forms of communication, such as disclaimers, may be confusing and
misleading to readers, so the standard promotes consistency in reporting on information.
(See CSRS 4200 Paras. 1 – 3 and A1 – A5)
QUESTION 4
I understand that CSRS 4200 does not apply to a bookkeeping service. Does
CSRS 4200 apply if management later asks for compiled financial information
or for a practitioner’s communication in addition to the bookkeeping service?
As discussed, CSRS 4200 does not apply to financial information prepared by a practitioner
engaged to perform a bookkeeping service. However, it is possible that management requests
multiple services which include services that are not scoped out of CSRS 4200, or management
may request a communication be attached, and therefore CSRS 4200 would apply.
The scope exclusion is applicable to a bookkeeping service and the description of a
bookkeeping service in the application material states:
“A bookkeeping service involves collecting, classifying, summarizing and processing data
to create underlying accounting records, which may result in a general ledger, trial balance
or system-generated financial information to which no practitioner’s communication is
included or attached.” (See CSRS 4200 Para. A3)
The above description recognizes that a practitioner may provide an entity with
system-generated financial information in a bookkeeping service, but no practitioner’s
communication can be included or attached to such financial information. Today’s
technology allows bookkeeping and other software to collect, classify, summarize and
process the data to create system-generated financial information. To determine if you
are providing a bookkeeping service or a compilation engagement, you will need to have
a discussion with your client to understand their needs for financial information and a
practitioner’s communication.
The Basis for Conclusions Para. 4 of CSRS 4200 includes the following:
The AASB acknowledged that system-generated financial information may look like
compiled financial information. Today’s technology allows a practitioner or an entity’s
management to easily generate financial information. However, a compilation engagement
and a bookkeeping service are different in their activities and communication. The service
an entity requests, including whether a communication is required to be attached to the
financial information, determines whether the practitioner has been engaged to perform
a compilation engagement or a bookkeeping service.
REMINDER: CSRS 4200 provides the option to issue a communication on financial information
prepared in a bookkeeping service. In such circumstances, the only appropriate
form of communication is a compilation engagement report and all the
requirements of CSRS 4200 apply.
(See CSRS 4200 Paras. 2(c) and A3)
QUESTION 5
Does CSRS 4200 apply if I prepare financial information to be used in government-
prescribed tax forms AND the financial information is also to be provided to
management for other purposes which are not excluded from CSRS 4200?
Yes, CSRS 4200 does apply. Although CSRS 4200 does not apply to financial information
prepared for inclusion in government-prescribed tax forms, if the financial information has
another use that is not covered by the scope exclusion, then CSRS does apply (i.e., preparation
of financial information for submission to management with a communication attached).
For the scope exclusion to apply, the financial information you prepare cannot have another
use outside the circumstances covered by the scope exclusion in Para. 2 of CSRS 4200.
However, if the practitioner provides multiple services and they are all excluded from the
scope of CSRS 4200 (e.g., bookkeeping service and a tax service), then CSRS 4200 would
not apply.
(See CSRS 4200 Paras. 2(d)(i) and A2)
QUESTION 6
Are there any specific terms that are important to my understanding the
requirements of CSRS 4200?
Yes, the following terms are important to your understanding of CSRS 4200:
• Practitioner: a professional accountant in public practice. The term includes the
engagement partner or other members of the engagement team or, as applicable, the firm.
• Third party: the individual, organization or group other than management or those charged
with governance (TCWG).
• Basis of accounting: Financial information may be prepared and presented in accordance
with different bases of accounting. A basis of accounting may be:
— established by an authorized or recognized standards-setting organization (e.g.,
Accounting Standards for Private Enterprises [ASPE]),
— prescribed by law, regulation, or contract, or
— developed by management (e.g., a modified cash basis). A basis of accounting
developed by management is not ASPE (or Accounting Standards for Not-for-Profit
Organizations [ASNFPO] in the CPA Canada Handbook – Accounting). It would be rare
that a basis of accounting applied in the preparation of compiled financial information
under CSRS 4200 would be compliant with all aspects of ASPE or ASNFPO.
As mentioned, a basis of accounting may take the form of an established framework (such
as ASPE), that includes various accounting policy choices, such as accounting for income
taxes or accounting for investments. Therefore, if the basis of accounting is ASPE, the
significant accounting policy choices are described in a note to the financial information.
A basis of accounting developed by management may present limited, if any, accounting
policy choices. This is because the accounting policies are generally included in the
basis of accounting (i.e., there are no “choices” to make). However, certain accounting
policies are nonetheless used, for example in recognizing and measuring inventory in the
compiled financial information. These accounting policies, typically described in the basis
of accounting note in the compiled financial information, help users understand how the
compiled financial information is prepared. Therefore, the separate disclosure of accounting
policies used is not necessary if the basis of accounting is developed by management.
• Management: When CSRS 4200 makes references to “management,” it means
“management and, where appropriate, those charged with governance.” (See CSRS 4200
Paras. 16 and A6)
The Glossary of Terms in the CPA Canada Handbook – Assurance includes the terms defined
in CSRS 4200 and can be used to assist in its consistent application and interpretation.
(See CSRS 4200 Paras. 14 and A6)
FIGURE 1
Ethical Requirements
Acceptance or Continuance
with Management**
• Prepare new engagement letter.
Documentation
** And TCWG, if applicable.
Ethical requirements
As shown in Figure 1, ethical requirements are relevant throughout the compilation engagement.
Ethical requirements are specified in detail in the provincial Code of Professional Conduct / Code
of Ethics.
The provincial Code of Professional Conduct / Code of Ethics does not require you to be independent;
however, when there is a threat to independence such that you may be seen by a reasonable observer
as lacking independence, the Code requires disclosure in the compilation engagement report.
QUESTION 7
Has there been any change in the provincial Code of Professional Conduct /
Code of Ethics regarding the disclosure related to independence?
No, there has been no change in the provincial Code of Professional Conduct / Code of Ethics
related to compilation engagements.
CSRS 4200 requires you to comply with all relevant ethical requirements when performing
a compilation engagement. These requirements are set out in the provincial Code of
Professional Conduct / Code of Ethics issued by the various professional accounting bodies.
The provincial Code of Professional Conduct / Code of Ethics does not require you to be
independent; however, when there is a threat to independence such that you may be seen
by a reasonable observer as lacking independence, the Code requires disclosure in the
compilation engagement report. For example, the following addition to the bottom of
the compilation engagement report may be suitable:
A partner in this accounting firm owns xx% of the Class A shares of Client Limited
Even though there is no requirement for you to be independent, you will need to perform
and document an assessment of independence since any impairment of independence
requires disclosure.
Refer to your respective provincial accounting body for information on the Code of
Professional Conduct / Code of Ethics.
(See CSRS 4200 Paras. 20 and A7 - A8)
Professional judgment
As shown in Figure 1, professional judgment is applied in performing a compilation engagement and is
based on the facts and circumstances that are known to you up to the date of the report. Professional
judgment involves the application of relevant training, knowledge and experience, and relevant ethical
requirements.
• determining the extent of knowledge of the entity required to perform the compilation
engagement
• reading the compiled financial information and considering whether such information
does not appear to be misleading
As shown in Figure 1, communication with management and others may take place throughout the
compilation engagement. This communication can take place in the pre-acceptance (or continuance),
performing and reporting phases of the engagement.
This communication includes formal communications, such as the engagement letter and the
compilation engagement report. However, it also involves other communications, such as inquiry and
acknowledgments. These communications may take place between management, others within the
entity, and TCWG (as appropriate). See Appendix D of this Tool for a summary of the other required
communications.
Documentation
As shown in Figure 1, documentation appears as a label on the “outside” of the figure to illustrate
its relevance throughout the compilation engagement. You are required to document how
the requirements of CSRS 4200 were met. The documentation must be sufficient to enable an
experienced practitioner having no previous connection with the engagement to understand how
the requirements were met. The nature and extent of documentation to be included in the working
paper files involves professional judgment. The documentation requirements of CSRS 4200 and
some examples are discussed in more detail later in this Tool.
This Tool includes a one-page diagram (Figure 1) summarizing the components of a compilation
engagement. It is easily detachable and useful as a reminder. As mentioned, this Tool also
includes various questions and answers that will help you implement CSRS 4200.
This part of the Tool will discuss in more detail the following components of a compilation
engagement introduced in Figure 1:
Compilation engagements performed in accordance with CSRS 4200 can be divided into two types:
When a third party will be using the compiled financial information, CSRS 4200 includes the
additional acceptance (or continuance) conditions discussed below.
• Make inquiries of management regarding the intended use of the compiled financial information,
including whether the compiled financial information is intended to be used by a third party; and
However, when the compiled financial information is intended to be used by a third party, CSRS 4200
includes additional acceptance (or continuance) conditions. You may accept (or continue) the
engagement if, according to management, the third party:
• has agreed with management on the basis of accounting to be applied in the preparation
of the compiled financial information
A common third party would be a lender who is likely to be in a position to obtain further
information through the lending agreement.
If neither of these conditions is met, you cannot accept or continue a compilation engagement
unless the basis of accounting to be applied in preparing the compiled financial information is a
general-purpose framework, e.g., ASPE. It is a rare occurrence that the basis of accounting applied
to compiled financial information would be a general-purpose framework. In such case, you may ask
your client to consider whether a review engagement or an audit engagement would better address
the needs of their users.
REMINDER: As indicated above, when the compiled financial information is intended to be used by a third
party, certain conditions must be met. You must obtain management’s acknowledgment that
the third party is in a position to request and obtain further information from the entity or
that the third party has agreed with management on the basis of accounting to be applied.
This acknowledgment by management must be included in the engagement letter or other
suitable form of written agreement. You are not required to verify whether the third party is in
a position to request and obtain further information from the entity or has agreed to the basis
of accounting; management’s acknowledgment will suffice.
FIGURE 2
Yes
No
No
Yes
No
Yes
QUESTION 8
What steps must I complete to meet the requirements related to the acceptance
(or continuance) decision?
The level of work effort related to the engagement acceptance (or continuance) decision is
a matter of professional judgment and can be summarized into three areas:
1. Inquiries of management about the intended use of compiled financial information,
including whether the information is intended to be used by a third party.
You must make inquiries of management about the intended use of the compiled financial
information. [See CSRS 4200 Para. 22(a)].
In some circumstances, knowledge of the broad user group (e.g., current or potential
lenders for borrowing purposes) rather than the specific user (e.g., ABC bank) may be
sufficient information when considering the conditions for accepting or continuing the
engagement. In other circumstances, the practitioner may need further information
about the third party to consider those conditions. (See CSRS 4200 Para. A11)
2. Obtain management’s acknowledgment of the basis of accounting.
This acknowledgment from management of the basis of accounting expected to be applied
in the preparation of the compiled financial information may take different forms: a written
communication (e.g., in paper form, or by electronic or other medium) or an oral discussion
which you would document.
It is possible that the basis of accounting expected to be applied in the preparation
of the compiled financial information may change while you are performing the
engagement. Therefore, you will also obtain management’s acknowledgment that it has
taken responsibility for the final version of the compiled financial information once the
engagement is completed (See further related discussion later in this Tool).
3. Determine whether the engagement acceptance (or continuance) conditions are met, and
that you can therefore accept the compilation engagement.
When the compiled financial information is intended to be used by a third party, certain
conditions must be met for you to accept a compilation engagement. You must obtain
management’s acknowledgment that the third party is in a position to request and obtain
further information from the entity or that the third party has agreed with management
on the basis of accounting to be applied. This acknowledgment must be included in the
engagement letter or other suitable form of written agreement. You are not required to
verify whether the third party is in a position to request and obtain further information
from the entity or has agreed to the basis of accounting. Management’s acknowledgement
will suffice.
Examples of a third party include, but are not limited to a:
• banker
• supplier or customer
• purchaser of the business
• party to a dispute or litigation, such as matrimonial cases
• funder for a not-for profit organization
The third party may be in a position to request and obtain further information from the
entity through:
• law or regulation
• contract
• negotiation
• other arrangements
(See CSRS 4200 Paras. 22 – 26 and A11 – A23)
It is important that the engagement letter be tailored to the particular engagement. It is recommended
that you review the engagement letter with management so that they have a clear understanding of the
engagement and of their responsibilities. Of course, management must sign and date the engagement
letter to acknowledge their understanding, and you may document any related discussion.
QUESTION 9
Do I have to prepare an engagement letter every year for a recurring engagement?
No, it is not a requirement to prepare an engagement letter each year.
If it is not your normal practice to prepare an engagement letter for a recurring engagement
each year, consider whether any of the following should be factored in as you evaluate whether
to either revise the terms of engagement or remind management of the existing terms of
engagement:
• an indication that management misunderstands the objective and scope of the
engagement
• any revised or special terms of the engagement
• a recent change of senior management (or TCWG) of the entity
• a significant change in the ownership of the entity
• a significant change in nature or size of the entity’s business
• a change in legal, regulatory, or contractual provisions affecting the entity
• an expected change in the use of the compiled financial information
(See CSRS 4200 Paras. 24 – 25, A23 and Appendix 1 to CSRS 4200)
The knowledge related to the entity and the compilation engagement would include the following:
• the basis of accounting to be applied and, where applicable, the accounting policies used in the
preparation of the compiled financial information.
Often, the best way to obtain this knowledge is to ask the appropriate questions as part of your ongoing
process throughout the engagement. You will use this knowledge in exercising your professional
judgment in the various phases of the compilation engagement. Note that the breadth and depth
of knowledge obtained in a compilation engagement is lower than in a review or audit engagement.
QUESTION 10
How much knowledge must I obtain about the entity to perform a compilation
engagement, and how do I obtain this knowledge?
The amount of knowledge needed will vary by engagement, so there is no single correct
answer. An area of professional judgment, the amount of knowledge you obtain needs to
be sufficient for you to be able to assist management in preparing the compiled financial
information according to the basis of accounting they have selected.
In obtaining knowledge of the entity’s business and operations, you may consider:
• the nature of the entity’s assets, liabilities, revenues and expenses
• the size and complexity of the entity and its operations
In obtaining knowledge of the entity’s accounting system and accounting records, you may
consider:
• how transactions are recorded, classified and summarized in the entity’s financial
information to determine:
— the nature and extent of accounting adjustments that might need to be made for
the compiled financial information to be prepared in accordance with the basis of
accounting selected by management; and
— whether the information provided is not otherwise misleading
• the types of matters that required accounting adjustments to the entity’s financial
information in prior periods
The knowledge can be obtained from:
• prior engagements
• discussion with management or others within the entity
• other client engagements
• experience gained with the entity’s industry
(See CSRS 4200 Paras. 27, A9 and A24 – A26)
Basis of accounting
CSRS 4200 requires that the compiled financial information include a note describing the basis
of accounting applied in the preparation of the compiled financial information.
The purpose of the description of the basis of accounting is to assist users in understanding
how the compiled financial information was prepared.
As management may not have the necessary knowledge, you may help them select the basis
of accounting. However, management is responsible for the compiled financial information and
selection of the basis of accounting. Consequently, you are required to ask management to:
• Take responsibility for selecting that basis of accounting in the terms of engagement.
• Acknowledge responsibility for the final version of the compiled financial information.
• rent receivable based on lease terms, less an allowance for doubtful accounts
• revenue producing property amortized in accordance with amounts allowable for income
tax purposes
QUESTION 11
Does the basis of accounting used in the compilation engagement have to be a
general-purpose framework, such as ASPE or ASNFPO?
No, in fact, it would be rare for compiled financial information to be prepared in accordance
with ASPE or ASNFPO. However, in the rare circumstance that management asks you to
prepare compiled financial information in accordance with a general-purpose framework, you
may ask management to consider whether an audit engagement or a review engagement would
better address the needs of users.
If there are multiple third parties requiring different bases of accounting, this is a situation
where a general-purpose framework could be useful. For example, in the year of selling the
business where there is a banker and a potential purchaser, a general-purpose framework
could meet the needs of both parties. However, in such a circumstance you may ask
management to consider whether an audit engagement or a review engagement would
better address the needs of these users.
QUESTION 12
Is it possible that I could develop a standard description for the “basis of
accounting” for all my compilation engagements?
It is possible that many of your clients will have a similar basis of accounting.
However, it is likely that there will be differences. The industry, nature of assets, liabilities,
revenues and expenses will differ, as will the type of compiled financial information (i.e., complete
set of financial statements, a balance sheet and income statement, a schedule) and its use.
The purpose of describing the basis of accounting in the note to the compiled financial
information is to help users understand how the compiled financial information is prepared.
See Appendix C of this Tool for examples of the description of the basis of accounting in
specific circumstances.
QUESTION 13
Can the basis of accounting be described as “ASPE with an exception …”?
It is possible; however, the compiled financial information must be prepared in accordance
with all recognition, measurement, presentation and disclosure requirements of ASPE with
an exception that can be clearly described with no potential for misunderstandings that may
make the compiled financial information misleading. Caution is necessary as a description of
the basis of accounting which refers to ASPE may imply full compliance with ASPE.
A description of the basis of accounting that contains imprecise qualifying and limiting
language (e.g., “the financial information is in substantial compliance with Canadian
Accounting Standards for Private Enterprises”) is not an adequate description, as it may
mislead users of the compiled financial information.
Referring to ASPE in the basis of accounting note would be very rare in a compilation
engagement where the majority of compiled financial information is prepared in accordance
with a basis of accounting that is substantially different from ASPE, as the compiled financial
information would normally exclude a cash flow statement and notes.
REMINDER: Full compliance with ASPE would mean all recognition, measurement,
presentation and disclosure requirements are met, such as inclusion of
a cash flow statement and full note disclosure.
(See CSRS 4200 Paras A29 – A30)
FIGURE 3
Compile the financial information, including a note that describes the basis of accounting
Yes
Has the practitioner assisted management Discuss with management
No with significant judgment? those significant judgments
Read the compiled financial information in light of the knowledge obtained and “standback”
Has the practitioner become aware of matters that may cause the
compiled financial information to be misleading?
No
Yes
QUESTION 14
Is comparative financial information related to the previous period required
in a compilation engagement?
CSRS 4200 does not require or prohibit the inclusion of comparative information in the
compiled financial information.
Therefore, the inclusion of comparative information is a matter of professional judgment.
QUESTION 15
Are notes to the financial statements required in a compilation engagement?
CSRS 4200 requires that you include a description of the basis of accounting but does
not require or prohibit the inclusion of other notes. Additional notes may be included if
considered useful or necessary to prevent the information from being misleading. (See
Appendix C of this Tool for further discussion on the basis of accounting, and for examples
of the description of the basis of accounting in specific circumstances.)
Therefore, the inclusion of notes to the financial information is a matter of professional
judgment.
Note: In the rare occasion that a general-purpose framework such as ASPE is used, all
required notes must be included.
QUESTION 16
If comparative information is included in the compiled financial information and
there is a change in the basis of accounting, do I have to retrospectively change
the comparatives?
Not necessarily, as CSRS 4200 does not address your responsibility when comparative
information is included in the compiled financial information and there is a change in the
basis of accounting from the previous year. The following options are possible:
1. retrospective restatement of the comparative information along with a description in the
compiled financial information of the change in the basis of accounting
2. no retrospective restatement of the comparative information, only the inclusion of a
description in the compiled financial information of the change in the basis of accounting
3. no retrospective restatement of the comparative information or inclusion of a description,
assuming the change in the basis of accounting does not make the compiled financial
information appear misleading
In some circumstances, the restatement and description may be considered necessary
to prevent the compiled financial information from being misleading.
QUESTION 17
Why does CSRS 4200 use the term “misleading” and not the phrase “false and
misleading” to describe the threshold that I apply when performing a compilation
engagement?
CSRS 4200 uses the term “misleading” in paragraph 30, which requires you to read the
compiled financial information in light of your knowledge of the entity and the basis of
accounting applied in the preparation of the compiled financial information, and consider
whether such compiled financial information does not appear misleading. This Tool has
referred to this requirement as a “stand-back consideration.”
CSRS 4200 uses the term “misleading” and not “false or misleading” to describe the threshold
of potential “wrongness” in compiled financial information. It does not use the phrase “false or
misleading” because the term “false” may inappropriately suggest that you have an obligation
to read the compiled financial information to identify errors or incomplete information, even if
insignificant. Nonetheless, a practitioner’s ethical responsibility to not be knowingly associated
with information that is false or misleading applies to all aspects of their work, regardless of
the service being provided.
If you become aware of matters that cause the compiled information to appear misleading,
CSRS 4200 requires that you bring these matters to the attention of management and
request additional or corrected information.
If you become aware of matters that cause the compiled financial information to appear
misleading, and it is not resolved, you are reminded that your provincial Code of Professional
Conduct / Code of Ethics requires that you not associate with such financial information.
(See CSRS 4200 Paras. 30 and A32)
QUESTION 18
How do I consider what may appear to be misleading in the compiled financial
information?
The way to consider what may appear to be misleading requires that you use professional
judgment, taking into account your knowledge of the entity and the basis of accounting
applied, and the facts and circumstances known to you.
The use of professional judgment requires you to apply relevant training, knowledge,
experience and the ethical requirements that exist within the context of CSRS 4200.
(See CSRS 4200 Para. 15 for the definition of professional judgment and Paras. 21 and A9
on the use of professional judgment)
After you have obtained acknowledgment from management (or TCWG, as appropriate) that it
has taken responsibility for the final version of the compiled financial information, you can issue
the compilation engagement report. A sample compilation engagement report is included in
Appendix 2 of CSRS 4200 and Appendix B of this Tool.
QUESTION 19
What date do I use on the compilation engagement report?
The date of the compilation engagement report is the date you have completed the
compilation engagement in accordance with CSRS 4200, which includes having management
acknowledge (or TCWG, as appropriate) that they have taken responsibility for the final
version of the compiled financial information.
(See CSRS 4200 Para. 38)
QUESTION 20
Do I have to label the compiled financial information as “unaudited”?
No, CSRS 4200 does not require you to label the compiled financial information as
“unaudited.”
Section 9200 included a requirement to label each page of the compiled financial information
as “Unaudited – See Notice to Reader.” The reason that this requirement is not included in
CSRS 4200 is that such labelling is not a key driver in informing users about the limitations
of the compiled financial information. Consistent with reporting in an audit engagement and
a review engagement, the compilation engagement report is the appropriate way to inform
users of the limitations of the compiled financial information.
(See Basis for Conclusions Paras. 49 and 50)
QUESTION 21
If management indicated that the compiled financial information is not intended
to be used by a third party, am I responsible for monitoring that management does
not in fact provide the compiled financial information to a third party?
No, CSRS 4200 does not impose obligations on you to monitor the distribution of the
compiled financial information by management after the compiled financial information has
been issued. It is management, not you, that determines the distribution of the compiled
financial information.
There may be circumstances when a third party requests the compiled financial information
(from the client) after you have issued the report, such as when a potential buyer asks for the
entity’s last three years of financial information. As mentioned, you do not control or have to
monitor the distribution of the compiled financial information, you do not have any additional
responsibilities in this situation.
REMINDER: This question addresses the situation where management has indicated that
the compiled financial information is not intended to be used by a third party.
However, you are reminded that the engagement letter (or other suitable form
of written agreement) includes an acknowledgment from management that they
understand that compiled financial information is not to be used by third parties
unless they would meet the following conditions for accepting (or continuing)
the engagement:
• The third party is in a position to request or obtain further information, or
• The third party has agreed with management on the basis of accounting
applied in the preparation of the compiled financial information.
Additional discussion on your responsibilities when, after the compiled financial
information has been issued, and management wants to provide the compiled
financial information to a third party not contemplated when accepting or
continuing the engagement, is included in Paras. 20 to 22 of the Basis for
Conclusions.
(See CSRS 4200 Paras. 25(e)(iii) and A38)
CSRS 4200 addresses situations when it may be necessary to withdraw from a compilation
engagement. You are required to withdraw from the engagement if:
• you become aware of matters that cause the compiled financial information to appear
misleading and management does not provide additional or corrected information, or
• management does not provide you with the records, documents, explanations or other
information needed to compile the financial information
• you become aware of information that was not known at the time the engagement was accepted
that, had it been known, you would not have accepted the engagement
You may communicate either orally or in writing to management the reason for withdrawing from
the engagement.
If withdrawing from the engagement is not possible under relevant ethical requirements, you may
consider it appropriate to seek advice about what professional and legal responsibilities apply in
the circumstances.
If a fact becomes known to you after the date the compiled financial information has been issued
that, if it was known to you at the date of the compilation engagement report, may have caused
you to believe that the compiled financial information appeared misleading, then:
• Determine whether the compiled financial information needs to be amended; and if so,
If the compiled financial information is not amended in circumstances where you believe it needs
to be, or if you become aware that management has not taken the appropriate steps to address
the matter, refer to Canadian Standard on Association (CSOA) 5000, Use of the Practitioner’s
Communication or Name, to understand your responsibilities when you become aware of an
intended or actual inappropriate use of your communication or name.
QUESTION 22
What should I do if management brings to my attention that the compiled financial
information that I have issued is misleading and requests that the compiled
financial information be amended?
If management requests that the compiled financial information be amended and you
provide a new compilation engagement report on the amended compiled financial
information, CSRS 4200 requires that you:
• Prepare the amended compiled financial information, including a note describing the nature
of the amendment, and
• Refer, in the new compilation engagement report, to the note in the amended compiled
financial information that describes the nature of the amendment of the previously issued
compiled financial information and to the earlier compilation engagement report provided
by the practitioner.
In addition, CSRS 4200 requires that you advise management to:
• Inform users in receipt of the previously-issued compiled financial information and the
earlier compilation engagement report that the compiled financial information has been
amended; and
• Provide users with the amended compiled financial information together with the new
compilation engagement report.
An example of the reference to the note in the new compilation engagement report on the
amended compiled financial information follows:
Amended Financial Information
We draw attention to Note X to the compiled financial information, which describes that
the compiled financial information that we originally reported on March 20, 20X2 has been
amended and describes the nature of the amendment of the previously issued compiled
financial information.
Note X
The compiled financial information for the year ended December 31, 20X1 has been amended
to reflect inventory being measured at cost of $100,000 when on the original compiled
financial information, it was measured at cost of $200,000. This amendment was made to
adjust for a correction of the cost of some units. The amendment decreased inventory by
$100,000, increased cost of sales by $100,000, decreased the income tax expense and
payable by $30,000, and decreased net income and retained earnings by $70,000.
(See CSRS 4200 Para. 35)
Documentation
Documentation
Figure 1 includes the word “Documentation” on the outside of the diagram to represent that documentation is
relevant to all aspects of the compilation engagement. CSRS 4200 establishes the minimum:
• work effort and that all work effort must be documented
• documentation requirements to improve consistency in the level of documentation
The main principle of CSRS 4200 is that the documentation be, in the practitioner’s judgment, sufficient
to enable an experienced practitioner having no previous connection with the engagement to understand
how the requirements of CSRS 4200 were met.
The minimum documentation would include the following:
• the engagement letter or other suitable form of written agreement with management
• a description of the entity’s business, operations, accounting system, accounting records and the
basis of accounting applied and, where applicable, the accounting policies used in the preparation
of the compiled financial information
• a reconciliation of the entity’s accounting records to the compiled financial information, including
any adjusting journal entries or other amendments to the compiled financial information that you have
agreed with management in the course of the engagement
• where applicable, the discussion with management regarding significant judgments for which you
have provided assistance in the course of preparing the compiled financial information
• where applicable, the communication to management regarding matters that may cause the
compiled financial information to appear to be misleading and how management has addressed
these matters
• a copy of the final version of the compiled financial information for which management (or TCWG,
as appropriate), have taken responsibility
• a copy of the compilation engagement report
• the communication to management of the reason(s) for withdrawing from the engagement, where
applicable
Though there are specific requirements, the extent of documentation is ultimately a matter of professional
judgment.
(See CSRS 4200 Para. 39)
QUESTION 23
How much work effort and documentation are necessary to meet the requirement
to obtain and document my knowledge of the accounting system and accounting
records?
It is a matter of professional judgment!
The sample working paper excerpts for knowledge of entity below include an example of
a description, obtained through inquiry, related to the accounting system and accounting
records.
[See CSRS 4200 Paras. 27(b) and 39(b)]
An example:
The following example provides an extract of possible documentation related to business
operations, accounting systems and records for a simple entity:
QUESTION 24
Do I have to obtain a management representation letter?
No, there is no requirement in CSRS 4200 to obtain a representation letter from
management.
However, CSRS 4200 requires that you obtain acknowledgment from management (or
TCWG, as appropriate), that it has taken responsibility for the final version of the compiled
financial information, which includes the final basis of accounting applied in the preparation
of the compiled financial information.
REMINDER: This acknowledgment may take different forms, such as:
• a signature on the final version of the compiled financial information
• a written communication (e.g., in paper form, or by electronic or other medium
• an oral acknowledgment documented in the working paper file
(See CSRS 4200 Para. 33)
QUESTION 25
How do I document the reconciliation of the entity’s accounting records to the
compiled financial information?
How you document the reconciliation of the entity’s accounting records to the compiled
financial information, including any adjusting entries or other amendments, is a matter of
professional judgment.
The documentation will include any adjusting journal entries or other amendments to
the compiled financial information that you have agreed to with management during the
engagement. In addition, the documentation may include a note in your working paper file
that describes that:
• The general ledger was imported from the entity’s records and the compiled financial
information agrees to your working paper file,
• You have agreed the compiled financial information to relevant accounting records, such
as the general ledger, or
• You have agreed the compiled financial information to a schedule such as an adjusted
trial balance. This does not mean the adjusted trial balance must be included in the
working paper file.
[See CSRS 4200 Para. 39(c)]
QUESTION 26
When you assist management with significant judgments, you are required
to discuss the significant judgments and document this discussion. What is
a “significant judgment,” and how would I document this discussion?
What would be considered a “significant judgment” in a compilation engagement depends
on the circumstances. A significant judgment could be making an accounting estimate, such
as the allowance for doubtful accounts, or selecting the revenue recognition policy. What is
significant is a matter of judgment and may be based on the nature and size of the related
item and/or the implications to the users of the compiled financial information.
The objective of the discussion is to have management understand the significant
judgment and their impact on the compiled financial information, and to have them accept
responsibility for the significant judgments included in the compiled financial information.
Documentation of the discussion that indicates management understands the significant
judgment and the impact on the compiled financial information could be in the form of a
narrative in the working paper file. Alternatively, if journal entries are prepared to reflect the
discussion, and are well explained, management could approve the related journal entries to
document the discussion and management’s understanding.
(See CSRS 4200 Paras. 29 and A31)
QUESTION 27
How do I document that management (or TCWG) have taken responsibility for the
compiled financial information?
The acknowledgment from management (or TCWG, as appropriate), that it has taken
responsibility for the final version of the compiled financial information may take different
forms, such as:
• a signature on the final version of the compiled financial information
• a written communication (e.g., in paper form, or by electronic or other medium)
• an oral acknowledgment documented in the working paper file
The following steps will help you prepare for these new engagements:
Step 1: Read the new standard (CSRS 4200 including the application material and Basis for
Conclusions).
• the provincial Code of Professional Conduct / Code of Ethics related to independence disclosure
requirements in a compilation engagement
Additional Resources
CPA Canada has developed a specific landing page on its website to house additional resources,
which you can find at: www.cpacanada.ca/compilations
In addition:
• Watch for updates to the Professional Engagement Guide (PEG), expected in August 2020.
• Scope
• Communication
• Documentation
Scope Section 9200 sets out CSRS 4200 sets out CSRS 4200 introduces
some specific exclusions. scope exclusions that further exclusions from
are more extensive than the scope to provide
those in Section 9200. clarity on when the
standard does and
In the circumstances
does not apply.
when CSRS 4200
does not apply, you Some engagements
may decide or be that previously were
requested to issue a completed under
communication on Section 9200 may
the compiled financial no longer be in the
information. In that scope of CSRS 4200.
case, the requirements
of CSRS 4200 apply in
their entirety.
(See CSRS 4200
Paras. 1 – 3)
Engagement Section 9200 did not CSRS 4200 sets CSRS 4200 introduces
acceptance and include requirements for out conditions for engagement acceptance
continuance accepting or continuing accepting or continuing and continuance
when the the engagement when the engagement requirements to provide
compiled financial the compiled financial that were not in clarity on when it is
information is information is intended Section 9200, relating appropriate to accept or
intended to be used by a third to when the compiled continue an engagement
to be used by party. financial information when there is a third-
a third party is intended to be used party user.
by a third party. To
Note: New engagement
accept or continue
letters must be
the engagement,
prepared. An example of
CSRS 4200 requires that
an engagement letter is
the third party:
included as Appendix 1
• be in a position to
of CSRS 4200.
request and obtain
further information
from the entity, or
• have agreed with
management the
basis of accounting
to be applied
A third party that
does not meet these
criteria may be misled
by compiled financial
information prepared
in accordance with a
basis of accounting that
is other than a general
framework.
(See CSRS 4200
Paras. 22 and 26)
Performing the Section 9200 provided The performance CSRS 4200 establishes
engagement limited guidance on requirements of the minimum work
(“work effort”) the required work CSRS 4200 are effort requirements. The
effort, which may have more extensive and new requirements will
led to the variability robust than those in improve consistency
in the extent of work Section 9200. of engagement
performed in practice. performance and
The term “misleading”
reflect good practice.
Section 9200 described describes the principles-
Depending on the
the work effort as based threshold that
way engagements
merely arranging you should consider
were completed under
information into the form when performing
Section 9200, there may
of a financial statement a compilation
be a change in the work
and checking that the engagement.
effort.
assembly of information
(See CSRS 4200
is arithmetically correct.
Paras. 27 – 33)
This work effort
was framed around
the practitioner’s
responsibilities to not
be associated with
financial statements
that he or she knows, or
should know, are false or
misleading.
Describing Section 9200 did not CSRS 4200 requires that Attach a new note in
the basis of address or require a the compiled financial the compiled financial
accounting description of the basis information include a information.
of accounting. note describing the basis
(See the discussion
of accounting applied
earlier in this Tool
in the preparation of
and Appendix C
the compiled financial
for examples)
information.
(See CSRS 4200
Para. 28)
Documentation Section 9200 did not CSRS 4200 sets CSRS 4200 establishes
include requirements out aspects of the the minimum
that addressed engagement that documentation
documentation. you are required to requirements. The
document and maintain new requirements will
in the working paper improve consistency
files. among practitioners
in the level of
(See CSRS 4200
documentation.
Para. 39)
• developed by management
CSRS 4200 requires that you include a note in the compiled financial information describing the
basis of accounting applied in the preparation of the compiled financial information. The purpose
of this note is to assist users in understanding how the compiled financial information is prepared.
Management may not possess the necessary knowledge to identify the basis of accounting and may
need your assistance. While you may provide assistance, management retains responsibility for the
compiled financial information and the selection of the basis of accounting.
Factors that you may consider in helping management identify the basis of accounting to be applied
in the preparation of the compiled financial information include:
• whether there are any specific financial reporting requirements under applicable law or
regulation or contractual provisions with a third party
The following examples of the cash basis of accounting with selected accruals and accounting
estimates are provided for illustration only:
Example 1: Real estate rental company (included earlier in this Tool and reproduced here for
convenience)
The basis of accounting applied in the preparation of the balance sheet of ABC Company as at
December 31, 20X1 and the income statement for the year then ended is on the historical cost
basis, reflecting cash transactions with the addition of:
• rent receivable based on lease terms less an allowance for doubtful accounts
• property, plant and equipment amortized on the same basis as for income tax
• accounts receivable
• amounts receivable
• rental property recorded at historical cost and amortized on the same basis as for income tax
“HOW”
“WHAT” “WHEN” (Form of communication
(Topic of communication that (Suggested – written, verbal,
is needed) timing) Reference* sign-off, etc.)
Intended use of compiled financial Prior to CSRS 4200 This inquiry can be oral or
information engagement Paras. 22(a) written.
acceptance and 23
Inquiries of management about Documentation of the inquiry
(or
the intended use of the compiled related to the intended use
continuance)
financial information, including of the compiled financial
whether that information is information (and the
intended to be used by a third conditions for acceptance
party. if there is a third party) is
included in the working paper
When the compiled financial
file and acknowledged in
information is intended to be used
the engagement letter (or
by a third party, additional inquiries
other suitable form of written
will help determine whether
agreement).
the third party is in a position
to request or obtain further
information or whether they have
agreed with management on the
basis of accounting.
“HOW”
“WHAT” “WHEN” (Form of communication
(Topic of communication that (Suggested – written, verbal,
is needed) timing) Reference* sign-off, etc.)
Significant judgments (if you Performing CSRS 4200 Discussions with management
provide assistance) the Para. 29 can be oral or written.
engagement,
Discussions with management Use a checklist or memo to
if applicable
about significant judgments include documentation of the
for which you have provided discussions in the working
assistance in the course of paper file.
preparing the compiled financial
information, so that management
understands the impact of the
significant judgments on the
compiled financial information and
accepts responsibility for those
judgments.
Matters that may cause the Performing CSRS 4200 Where applicable, you can
financial information to appear the Para. 31 inform management of
misleading engagement, the matters and request
if applicable additional or corrected
Inform management if you become
information; this can be
aware of matters that may cause
orally or written.
the compiled financial information
to appear misleading; request Use a checklist or memo to
additional or corrected information include documentation of the
and discuss how management has discussions in the working
addressed these matters. paper file.
“HOW”
“WHAT” “WHEN” (Form of communication
(Topic of communication that (Suggested – written, verbal,
is needed) timing) Reference* sign-off, etc.)
Facts that become known after After CSRS 4200 Where applicable, discussion
the compiled financial information issuance, if Paras. 34 with management (or TCWG,
has been issued applicable and 35 as appropriate) can be oral or
written.
Discussion with management (or
TCWG, as appropriate) if, after Inquiry of management on
the date the compiled financial how they intend to address
information has been issued, you the matter can be oral or
become aware of a fact that, written.
had you known it at the date of
The advisement to
the compilation engagement
management related to
report, it may have caused you to
amended compiled financial
believe that the compiled financial
information can be oral or
information appeared misleading.
written.
If you determine that the compiled
Use a checklist or memo to
financial information needs to be
include documentation of
amended, inquire of management
the discussion in the working
on how they intend to address the
paper file.
matter in the financial information.
If management requests that the
compiled financial information
be amended, then you need to
advise them to inform the users of
the amendment when providing
them with the amended compiled
financial information.
“HOW”
“WHAT” “WHEN” (Form of communication
(Topic of communication that (Suggested – written, verbal,
is needed) timing) Reference* sign-off, etc.)
Withdrawing from the If applicable CSRS 4200 The nature of the discussion
engagement Para. 32 and communication of the
reasons for the withdrawal
Communication with management
(and related documentation),
if withdrawal from the engagement
will vary in nature and extent
is appropriate. For example,
dependent on the reason for
withdrawal may be appropriate in a
the withdrawal.
circumstance where management
does not address a matter that (Consider seeking advice on
may cause the financial information any professional and legal
to appear to be misleading. The responsibilities applicable in
reasons for the withdrawal will be the specific circumstance.)
communicated to management.
*CSRS 4200 Para. 39 is the relevant reference for the documentation of how the requirements
of CSRS 4200 are met, including these communications.
The views and conclusions expressed in this non-authoritative publication are those of the author.
This publication contains general information only and is not intended to be comprehensive or to
provide specific assurance, business, financial, investment, legal, tax or other professional advice or
services. This publication is not a substitute for such professional advice or services, and it should
not be acted on or relied on or used as a basis for any decision or action that may affect you or your
business.
This publication has not been updated since the publication date of June 2020. Practitioners are
expected to use professional judgment in determining whether the material in this publication
is both appropriate and relevant to the circumstances of each engagement.
CPA Canada expresses its appreciation to the author, Jane M. Bowen, FCPA, FCA, for developing
this Implementation Tool for Practitioners and to the members of the Compilation Engagements
Guidance Task Force for their contribution to its preparation.
Comments on this Audit & Assurance Implementation Tool or suggestions for future publications
should be sent to:
DISCLAIMER
This publication was prepared by the Chartered Professional Accountants of Canada (CPA Canada) as non-authoritative guidance.
CPA Canada and the authors do not accept any responsibility or liability that might occur directly or indirectly as a consequence of
the use, application or reliance on this material. This Implementation Tool has not been issued under the authority of the Auditing
and Assurance Standards Board.
Copyright © 2020 Chartered Professional Accountants of Canada