Technical Article
Technical Article
Key principles underlying the quality standards: The SoQM must address eight components :
o 1. Firm’s risk assessment process
o 2. Governance and leadership
o 3. Relevant ethical requirements
o 4. Acceptance and continuance of client relationships
o 5. Engagement performance
o 6. Resources
o 7. Information and communication
o 8. Monitoring and remediation process
Conclusions :
o ISQM 1 provides a focus on audit quality and a process of risk management with respect to quality that aims
to ensure all firms have quality as a priority when performing audits and other assurance engagements.
o The standard is principles driven with a focus on scalability, flexibility and continuous improvement.
o Quality management is core to audit, and a detailed understanding of the importance of both audit quality
and quality management underlies the performance of an audit.
o Quality is a key part of ensuring that audits are fit for purpose and retain the public trust. As such, it is key to
every audit and every stage of the audit process and candidates should expect to see aspects of quality
management examined at all stages of an audit in exam questions and in either section of the exam.
International Standards on Quality Management – part 2 (ISQM 2 and ISA 220 (Revised))
ISQM 2, Engagement Quality Reviews
ISA 220 (Revised), Quality Management for an Audit of Financial Statements
Note ISQM 2 is same as covered in chapter 2
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ISA 220 (Revised), Quality Management for an Audit of Financial Statements : Covered in Ch 2.
Group audits
Risk and understanding the entity
Auditing in specialised industries
Airline, banking, insurance, oil extraction
these industries specialised because either to have specific financial reporting
standards applicable to them, or to have distinct accounting policies
Audit considerations
Competence :
Knowledge of relevant auditing standards.
IESBA International Code of Ethics for Professional Accountants (the Code) requires :
auditor should have an appropriate understanding of the nature and complexity of the
client’s business, as well as knowledge of relevant industrial regulatory or reporting
requirements
ISA 220 (Revised) Quality Management for an Audit of Financial Statements requires the
auditor to assess whether there are sufficient and appropriate resources to perform the
engagement and that there is the ‘appropriate competence and capabilities’
Audit Planning : Identification of the risk of material misstatement in a specialised industry- by
obtaining appropriate understanding of the business and its environment.
audit firm is likely to have additional resources available.
briefing notes or internal technical guidance on how financial reporting standards should be
applied within the sector
Reliance on Expert : the auditor may plan to use an auditor’s expert to obtain audit evidence.
ISA 620, Using the Work of an Auditor’s Expert which deals with matters including the
evaluation of the objectivity, competence and capabilities of the auditor’s expert, determining
and communicating the scope and objectives of their work, and assessing their findings .
Qualitative disclosures:
Descriptions of significant accounting policies and areas where critical accounting judgement has been exercised, and
rationale for any changes in accounting policies.
Confirmation that the going concern assumption is appropriate, or discussion of significant doubt over going concern.
Information on related parties, and related party transactions.
Explanation of impairment losses recognised in the year.
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Discussion of areas of risk, for example those relating to financial instruments.
A key driver for the IAASB’s consultation and the exposure draft, Addressing Disclosures in the Audit of Financial Statements,
issued in May 2014, is that in recent years, IFRS requirements in relation to disclosures in the notes to financial statements have
become more onerous. The exposure draft states that ‘over the past decade, financial reporting disclosure requirements and
practices have evolved. They now provide more extensive decision-useful information that is more detailed and often deals with
matters that are subjective such as assumptions, models, alternative measurement bases and sources of estimation uncertainty.
As these financial reporting disclosures continue to evolve, challenges have arisen for preparers and auditors in addressing new
types of quantitative and non-quantitative information’.
The challenges for auditors
Sources of information
A key concern of the IAASB is that the information included in the notes to the financial statements, whether quantitative or
qualitative in nature is derived from systems and processes that are not part of the general ledger system. Examples could include,
forward looking statements, descriptions of models used in fair value measurements, descriptions of risk exposures and other
narrative disclosures. This gives rise to several potential problems to the auditor, and respondents involved in the IAASB’s
consultations noted that this issue poses some of the most challenging aspects of preparing and auditing disclosures.
One problem is whether the system or process from which information is derived, when it is outside of normal accounting
processes, has any internal control to provide assurance on the completeness, accuracy and validity of the information. For
example, information on financial instruments may be provided by a company’s treasury management function, which could have
very different systems and procedures to the accounting function, with a different level of control risk attached. The systems and
controls may be deficient, creating higher audit risk. This may particularly be the case when dealing with one-off disclosures, for
example in relation to the situation causing an impairment loss. In some cases, due to lack of the documentation that would
normally be expected for more routine transactions or events captured by the accounting system, it may be difficult to obtain
sufficient, appropriate audit evidence on disclosures.
Timing considerations
The IAASB notes that often disclosures are prepared by management very late in the audit process. Often, when the auditor is
planning the audit, draft disclosures are not available, so it is not possible for the auditor to plan the audit of disclosures until much
later in the audit process. This could lead to higher audit risk in that there may not be much time to assess the risk relating to
disclosures and to perform the necessary audit procedures. This is especially the case where disclosures are complex, for example
in relation to financial instruments, or subjective, for example in relation to fair value measurement.
The IAASB proposals
The IAASB has proposed additional guidance to help establish an appropriate focus on disclosures in the audit and encourage
earlier auditor attention on them during the audit process. There is also a proposal to amend the definition of financial statements
contained in the ISAs, to ensure an appropriate emphasis on the importance of disclosures as part of the financial statements.
Proposed changes to the ISAs include new application material to:
Amend the term ‘financial statements’ as used in the ISAs to include all disclosures subject to audit and to include that
such disclosures may be found in the related notes, on the face of the financial statements, or incorporated by cross-
reference as allowable by some financial reporting frameworks.
Emphasise the importance of giving appropriate attention to, and planning adequate time for addressing disclosures in the
same way as classes of transactions, events and account balances, and early consideration of matters such as significant
new or revised disclosures.
Focus auditors on additional matters relating to disclosures that may be discussed with those charged with governance, in
particular at the planning stage of the audit.
Emphasise that, when agreeing the terms of engagement, the auditor should emphasise management’s responsibility,
early in the audit process, to make available information relevant to disclosures.
Provide additional examples of misstatements in disclosures to highlight the types of misstatements that may be found in
disclosures, and to clarify that identified misstatements, including those in disclosures and irrespective of whether they
occur in quantitative or non-quantitative information, need to be accumulated and evaluated for their effect on the financial
statements.
In terms of specific planning considerations, the IAASB recommends improvements to some aspects of risk assessment and
materiality determination in order to encourage a more robust risk assessment relating to disclosures:
Expanding the guidance on matters to consider when the auditor is obtaining an understanding of the entity and its
environment, including the entity’s internal control, and assessing the risks of material misstatement for disclosures,
including materiality considerations for non-quantitative disclosures.
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Highlighting disclosures, including examples of relevant matters, for consideration during the discussion among the
engagement team of the susceptibility of the entity’s financial statements to material misstatement, including from fraud.
Integrating the separate category for assertions relating to presentation and disclosure into the categories for account
balances and transactions to promote their more consistent and effective use.
Acknowledging, and giving prominence to, disclosures where the information is not derived from the accounting system,
and related considerations pertaining to this source of audit evidence.
In relation to materiality, clarifying that the nature of potential misstatements in disclosures, in particular non-quantitative
disclosures, is also relevant to the design of audit procedures to address the risks of material misstatement.
Where such use is not prohibited by law or regulation, the ISA provides a robust framework to ensure that direct assistance is obtained only in
appropriate circumstances, that the external auditor considers the relevant limitations and safeguards, and that the auditor’s responsibilities
are clearly set out.
It should be noted that the main purpose here is to evaluate threats to objectivity. Take the first factor as an example – if evidence shows that
the internal audit function’s organisational status supports the objectivity of the internal auditors, the external auditor will feel more
comfortable using direct assistance from the internal auditors. The following situations are likely to support the objectivity of the internal
auditors:
The internal audit function reports to those charged with governance (eg the audit committee) rather than solely to management (eg
the chief finance officer)
The internal audit function does not have managerial or operational duties that are outside of the internal audit function
The internal auditors are members of relevant professional bodies obligating their compliance with relevant professional standards
relating to objectivity.
For any particular account balance, class of transaction or disclosure, the external auditor has to take into consideration the assessed risk of
material misstatement when determining the nature and extent of work that they propose to assign to internal auditors. The higher the
assessed risk, the more restricted the nature and extent of work that should be assigned to internal auditors. If the risk of material
misstatement is considered to be anything other than low, the more judgment that has to be involved and the more persuasive the audit
evidence required. Therefore, in these circumstances, in order to reduce audit risk to an acceptably low level it is expected that the external
auditor has to perform more procedures directly and place less reliance on assistance provided by internal auditors when collecting sufficient
appropriate evidence. The ISA provides some specific examples of areas where reliance should be restricted.
ISA 610 (Revised 2013) states that internal auditors cannot carry out procedures when providing direct assistance that:
Involve making significant judgment in the audit
Relate to higher assessed risks of material misstatements where the judgment required in performing the relevant audit procedures
or evaluating the audit evidence gathering is more than limited
Relate to decisions the external auditor makes in accordance with ISA 610 (Revised 2013) regarding the internal audit function and
the use of its work or direct assistance
Relate to work with which the internal auditors have been involved and which has already been or will be reported to management
(or those charged with governance) by the internal audit function. This restriction intends to minimise self-review threats.
ISA 610 (Revised 2013) also states that the following should not be assigned to or involve internal auditors providing direct assistance:
(i) discussion of fraud risks
(ii) determination of unannounced (or unpredictable) audit procedures as addressed in ISA 240, The Auditor’s Responsibilities Relating
to Fraud in an Audit of Financial Statements, and
(iii) maintaining control over external confirmation requests and evaluation of results of external confirmation procedures.
Responsibilities of the external auditor using internal auditors to provide direct assistance
The external auditor should note the following responsibilities at different stages of the audit when using internal auditors to provide direct
assistance:
(1) After determining the use of internal auditors to provide direct assistance
The external auditor has to:
Communicate the nature and extent of the planned use of internal auditors with those charged with governance (in accordance with
ISA 260, Communication with Those Charged with Governance) so as to reach a mutual understanding that such use is not
excessive in the circumstances of the engagement. This communication not only dispels any perception that the external auditor’s
independence might be compromised by the use of direct assistance but also facilitates appropriate dialogue with those charged with
governance.
Evaluate whether the external auditor is still sufficiently involved in the audit.
Audit risk
What is audit risk?
‘The risk that the auditor expresses an inappropriate audit opinion when the financial statements are materially misstated. Audit risk is a
function of material misstatement and detection risk.’
Why is audit risk so important to auditors?
Audit risk is fundamental to the audit process because auditors cannot and do not attempt to check all transactions. Students should refer to
any published accounts of large companies and think about the vast number of transactions in a statement of comprehensive income and a
statement of financial position. It would be impossible to check all of these transactions, and no one would be prepared to pay for the auditors
to do so, hence the importance of the risk-based approach toward auditing. Traditionally, auditors have used a risk-based approach in order to
minimise the chance of giving an inappropriate audit opinion, and audits conducted in accordance with ISAs must follow the risk-based
approach, which should also help to ensure that audit work is carried out efficiently, using the most effective tests based on the audit risk
assessment. Auditors should direct audit work to the key risks (sometimes also described as significant risks), where it is more likely that errors
in transactions and balances will lead to a material misstatement in the financial statements. It would be inefficient to address insignificant risks
in a high level of detail, and whether a risk is classified as a key risk or not is a matter of judgment for the auditor.
Relevant ISAs
There are many references throughout the ISAs to audit risk, but perhaps the two most important audit risk-related ISAs are as follows:
ISA 200, Overall Objectives of the Independent Auditor and the Conduct of an Audit in Accordance with ISAs
ISA 200 sets out the overall objectives of the auditor, and the standard explains the nature and scope of an audit designed to enable an auditor
to meet those objectives. References to audit risk are frequently made by ISA 200, and the standard also requires that the auditor shall plan
and perform an audit with professional scepticism, recognising that circumstances might exist that may cause the financial statements to be
materially misstated. Professional scepticism is defined as an attitude that includes a questioning mind and a critical assessment of evidence.
ISA 315, Identifying and Assessing the Risks of Material Misstatement Through Understanding the Entity and Its Environment
ISA 315 deals with the auditor’s responsibility to identify and assess the risks of material misstatement in the financial statements through an
understanding of the entity and its environment, including the entity’s internal controls and risk assessment process. The first version of ISA
315 was originally published in 2003 after a joint audit risk project had been carried out between the IAASB, and the United States Auditing
Standards Board. Changes in the audit risk standards have arguably been the single biggest change in auditing standards in recent years, so the
significance of ISA 315, and the topic of audit risk, should not be underestimated by auditing students.
The requirements of ISA 315 are summarised in the following table.
(1). The auditor shall perform risk assessment procedures in order to provide a basis for the identification and assessment of the risks
of material misstatement.
(2). The auditor is required to obtain an understanding of the entity and its environment, including the entity’s internal control
systems.
(3). The auditor shall identify and assess the risks of material misstatement, and determine whether any of the risks identified are, in
the auditor’s judgement, significant risks. This is in order to provide a basis for designing and performing further audit procedures.
(4). ISA 330 then deals with the required responses to assessed risks.
The interrelationship of the three components of audit risk is outside the scope of this current article. F8 students, however, will typically be
expected to have a good understanding of the concept of audit risk, and to be able to apply this understanding to questions in order to identify
and describe appropriate risk assessment procedures
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Audit working papers
The auditing standards
ISA 230, Audit Documentation states that the objective (1) of the auditor is to prepare documentation that provides:
1. A sufficient and appropriate record of the basis for the auditor’s report, and
2. Evidence that the audit was planned and performed in accordance with ISAs and applicable legal and regulatory requirements.
The auditor should prepare the audit documentation on a timely basis and in such a way so as to enable an experienced auditor, having no
previous connection with the audit, to understand:
1. The nature, timing, and extent of the audit procedures performed to comply with ISAs and applicable legal and regulatory
requirements
2. The results of the audit procedures and the audit evidence obtained, and
3. Significant matters arising during the audit, the conclusions reached and significant judgments made in reaching those conclusions.
In documenting the nature, timing, and extent of audit procedures performed, the auditor should record the identifying characteristics of the
specific items or matters being tested.
The auditor should document discussions of significant matters with management and others on a timely basis.
If the auditor has identified information that contradicts or is inconsistent with the auditor’s final conclusion regarding a significant matter, the
auditor should document how the auditor addressed the contradictions or inconsistency in forming the final conclusion.
Where, in exceptional circumstances, the auditor judges it necessary to depart from a basic principle or an essential procedure that is relevant
in the circumstances of the audit, the auditor should document how the alternative audit procedures performed achieve the objective of the
audit, and, unless otherwise clear, the reasons for the departure.
In documenting the nature, timing, and extent of audit procedures performed, the auditor must record:
1. The identifying characteristics of the specific items or matters tested
2. Who performed the audit work and the date such work was completed, and
3. Who reviewed the audit work and the date and extent of such review (2).
The auditor should complete the assembly of the final audit file on a timely basis after the date of the auditor’s report.
After the assembly of the final audit file has been completed, the auditor should not delete or discard audit documentation before the end of
its retention period.
When the auditor finds it necessary to modify existing audit documentation or add new audit documentation after the assembly of the final
file has been completed, the auditor should, regardless of the nature of the modifications or additions, document:
1. The specific reasons for making them, and
2. When and by whom they were made and reviewed.
When exceptional circumstances arise after the date of the auditor’s report that require the auditor to perform new or additional audit
procedures, or that lead the auditor to reach new conclusions, the auditor should document:
1. The circumstances encountered
2. The new or additional audit procedures performed, audit evidence obtained, and conclusions reached, and their effect on the
auditor’s report
3. When and by whom the resulting changes to audit documentation were made, and (where applicable) reviewed.
The requirements of the ISA guide the auditor to produce audit documentation that is of an acceptable standard. Understanding and applying
the requirements will protect the auditor from unwelcome and unnecessary litigation.
Importance of working papers
Working papers are important because they:
are necessary for audit quality control purposes
provide assurance that the work delegated by the audit partner has been properly completed
provide evidence that an effective audit has been carried out
increase the economy, efficiency, and effectiveness of the audit
contain sufficiently detailed and
up-to-date facts which justify the reasonableness of the auditor’s conclusions
retain a record of matters of continuing significance to future audits.
The reviewer of audit working papers should ensure that every paper has these characteristics. If any relevant characteristic is judged absent,
then this should result in an audit review point (ie a comment by the reviewer directing the original preparer to rectify the fault on the working
paper).
The accounting systems of many companies, large and small, are computer-based; questions in all ACCA audit
papers reflect this situation.
Students need to ensure they have a complete understanding of the controls in a computer-based environment, how these
impact on the auditor’s assessment of risk, and the subsequent audit procedures. These procedures will often involve the use of
computer-assisted audit techniques (CAATs).
The aim of this article is to help students improve their understanding of this topic by giving practical illustrations of computer-
based controls and computer-assisted techniques and the way they may feature in exam questions.
Application controls
These are manual or automated procedures that typically operate at a business process level and apply to the processing of
transactions by individual applications. Application controls can be preventative or detective in nature and are designed to
ensure the integrity of the accounting records.
Accordingly, application controls relate to procedures used to initiate, record, process and report transactions or other financial
data. These controls help ensure that transactions occurred, are authorised and are completely and accurately recorded and
processed (ISA 315 (Redrafted)).
Application controls apply to data processing tasks such as sales, purchases and wages procedures and are normally divided into
the following categories:
The most common example of programmed controls over the accuracy and completeness of input are edit (data validation)
checks when the software checks that data fields included on transactions by performing:
reasonableness check, eg net wage to gross wage
existence check, eg that a supplier account exists
character check, eg that there are no alphabetical characters in a sales invoice number field
range check, eg no employee’s weekly wage is more than $2,000
check digit, eg an extra character added to the account reference field on a purchase invoice to detect mistakes such as
transposition errors during input.
When data is input via a keyboard, the software will often display a screen message if any of the above checks reveal an anomaly,
eg ‘Supplier account number does not exist’.
General controls
These are policies and procedures that relate to many applications and support the effective functioning of application controls.
They apply to mainframe, mini-frame and end-user environments. General IT controls that maintain the integrity of information
and security of data commonly include controls over the following:
data centre and network operations
system software acquisition, change and maintenance
program change
access security
application system acquisition, development, and maintenance (ISA 315 (Redrafted))
‘End-user environment’ refers to the situation in which the users of the computer systems are involved in all stages of the
development of the system.
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(i) Administrative controls
Controls over ‘data centre and network operations’ and ‘access security’ include those that:
prevent or detect errors during program execution, eg procedure manuals, job scheduling, training and supervision; all these
prevent errors such as using wrong data files or wrong versions of production programs
prevent unauthorised amendments to data files, eg authorisation of jobs prior to processing, back up and physical protection of
files and access controls such as passwords
ensure the continuity of operations, eg testing of back - up procedures, protection against fire and floods.
‘System software’ refers to the operating system, database management systems and other software that increases the efficiency
of processing. Application software refers to particular applications such as sales or wages. The controls over the development
and maintenance of both types of software are similar and include:
Controls over application development, such as good standards over the system design and program writing, good
documentation, testing procedures (eg use of test data to identify program code errors, pilot running and parallel running of old
and new systems), as well as segregation of duties so that operators are not involved in program development
Controls over program changes – to ensure no unauthorised amendments and that changes are adequately tested, eg password
protection of programs, comparison of production programs to controlled copies and approval of changes by users
Controls over installation and maintenance of system software – many of the controls mentioned above are relevant, eg
authorisation of changes, good documentation, access controls and segregation of duties.
Exam focus
Students often confuse application controls and general controls. In the June 2008 CAT Paper 8 exam, Question 2 asked
candidates to provide examples of application controls over the input and processing of data. Many answers referred to
passwords and physical access controls – which are examples of general controls – and thus failed to gain marks.
Using audit software, the auditor can scrutinise large volumes of data and present results that can then be investigated further.
The software consists of program logic needed to perform most of the functions required by the auditor, such as:
select a sample
report exceptional items
compare files
analyse, summarise and stratify data.
The auditor needs to determine which of these functions they wish to use, and the selection criteria.
Exam focus
Sometimes, questions will present students with a scenario and ask how CAATs might be employed by the auditor. Question 4 in
the December 2007 Paper F8 exam required students to explain how audit software could be used to audit receivables balances.
To answer this type of question, you need to link the functions listed above to the normal audit work on receivables. Students
should refer to the model answer to this question.
The following is an example of how this could be applied to the audit of wages:
Select a random sample of employees from the payroll master file; the auditor could then trace the sample back to contracts of
employment in the HR department to confirm existence
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Report all employees earning more than $1,000 per week
Compare the wages master file at the start and end of the year to identify starters and leavers during the year; the auditor would
then trace the items identified back to evidence, such as starters’ and leavers’ forms (in the HR department) to ensure they were
valid employees and had been added or deleted from the payroll at the appropriate time (the auditor would need to request
that the client retain a copy of the master file at the start of the year to perform this test)
Check that the total of gross wages minus deductions equates to net pay.
Data without errors will also be included to ensure ‘correct’ transactions are processed properly.
Test data can be used ‘live’, ie during the client’s normal production run. The obvious disadvantage with this choice is the danger
of corrupting the client’s master files. To avoid this, an integrated test facility will be used (see other techniques below). The
alternative (dead test data) is to perform a special run outside normal processing, using copies of the client’s master files. In this
case, the danger of corrupting the client’s files is avoided – but there is less assurance that the normal production programs have
been used.
The attraction of embedded audit facilities is obvious, as it equates to having a perpetual audit of transactions. However, the set-
up is costly and may require the auditor to have an input at the system development stage. Embedded audit facilities are often
used in real time and database environments.
(i) Planning
The Appendix to ISA 300 (Redrafted) states ‘the effect of information technology on the audit procedures, including the
availability of data and the expected use of computer - assisted audit techniques’ as one of the characteristics of the audit that
needs to be considered in developing the overall audit strategy.
The application notes to ISA 315 identify the information system as one of the five components of internal control. It requires the
auditor to obtain an understanding of the information system, including the procedures within both IT and manual systems. In
other words, if the auditor relies on internal control in assessing risk at an assertion level, s/he needs to understand and test the
controls, whether they are manual or automated. Auditors often use internal control evaluation (ICE) questions to identify
strengths and weaknesses in internal control. These questions remain the same – but in answering them, the auditor considers
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both manual and automated controls.
For instance, when answering the ICE question, ‘Can liabilities be incurred but not recorded?’, the auditor needs to consider
manual controls, such as matching goods received notes to purchase invoices – but will also consider application controls, such
as programmed sequence checks on purchase invoices. The operation of batch control totals, whether programmed or
performed manually, would also be relevant to this question.
(iii) Testing
‘The auditor shall design and perform further audit procedures whose nature, timing and extent are based on and are responsive
to the assessed risks of material misstatement at the assertion level.’ (ISA 330 (Redrafted))
This statement holds true irrespective of the accounting system, and the auditor will design compliance and substantive tests
that reflect the strengths and weaknesses of the system. When testing a computer information system, the auditor is likely to use
a mix of manual and computer-assisted audit tests.
‘Round the machine (computer)’ v ‘through the machine (computer)’ approaches to testing
Many students will have no experience of the use of CAATs, as auditors of clients using small computer systems will often audit
‘round the machine’. This means that the auditor reconciles input to output and hopes that the processing of transactions was
error-free. The reason for the popularity of this approach used to be the lack of audit software that was suitable for use on
smaller computers. However, this is no longer true, and audit software is available that enables the auditor to interrogate copies
of client files that have been downloaded on to a PC or laptop. However, cost considerations still appear to be a stumbling block.
In the ‘through the machine’ approach, the auditor uses CAATs to ensure that computer - based application controls are
operating satisfactorily.
Exam questions on each of the aspects identified above are often answered to an inadequate standard by a significant number of students –
hence the reason for this article.
Dealing with application controls and CAATs in turn:
Application controls
Application controls are those controls (manual and computerised) that relate to the transaction and standing data pertaining to a computer-
based accounting system. They are specific to a given application and their objectives are to ensure the completeness and accuracy of the
accounting records and the validity of entries made in those records. An effective computer-based system will ensure that there are adequate
controls existing at the point of input, processing and output stages of the computer processing cycle and over standing data contained in
master files. Application controls need to be ascertained, recorded and evaluated by the auditor as part of the process of determining the risk
of material misstatement in the audit client’s financial statements.
Input controls
Control activities designed to ensure that input is authorised, complete, accurate and timely are referred to as input controls. Dependent on
the complexity of the application program in question, such controls will vary in terms of quantity and sophistication. Factors to be considered
in determining these variables include cost considerations, and confidentiality requirements with regard to the data input. Input controls
common to most effective application programs include on-screen prompt facilities (for example, a request for an authorised user to ‘log-in’)
and a facility to produce an audit trail allowing a user to trace a transaction from its origin to disposition in the system.
Specific input validation checks may include:
Format checks
These ensure that information is input in the correct form. For example, the requirement that the date of a sales in voice be input in numeric
format only – not numeric and alphanumeric.
Range checks
These ensure that information input is reasonable in line with expectations. For example, where an entity rarely, if ever, makes bulk-buy
purchases with a value in excess of $50,000, a purchase invoice with an input value in excess of $50,000 is rejected for review and follow-up.
Compatibility checks
These ensure that data input from two or more fields is compatible. For example, a sales invoice value should be compatible with the amount
of sales tax charged on the invoice.
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Validity checks
These ensure that the data input is valid. For example, where an entity operates a job costing system – costs input to a previously completed
job should be rejected as invalid.
Exception checks
These ensure that an exception report is produced highlighting unusual situations that have arisen following the input of a specific item. For
example, the carry forward of a negative value for inventory held.
Sequence checks
These facilitate completeness of processing by ensuring that documents processed out of sequence are reject ed. For example, where pre-
numbered goods received notes are issued to ac knowledge the receipt of goods into physical inventory, any input of notes out of sequence
should be rejected.
Control totals
These also facilitate completeness of processing by ensure that pre-input, manually prepared control totals are compared to control totals
input. For example, non-matching totals of a ‘batch’ of purchase invoices should result in an on-screen user prompt, or the production of an
exception report for follow-up. The use of control totals in this way are also commonly referred to as output controls (see below).
Check digit verification
This process uses algorithms to ensure that data input is accurate. For example, internally generated valid supplier numerical reference codes,
should be formatted in such a way that any purchase invoices input with an incorrect code will be automatically rejected.
Processing controls
Processing controls exist to ensure that all data input is processed correctly and that data files are appropriately updated accurately in a timely
manner. The processing controls for a specified application program should be designed and then tested prior to ‘live’ running with real data.
These may typically include the use of run-to-run controls, which ensure the integrity of cumulative totals contained in the accounting records
is maintained from one data processing run to the next. For example, the balance carried forward on the bank account in a company’s general
(nominal) ledger. Other processing controls should include the subsequent processing of data rejected at the point of input, for example:
A computer produced print-out of rejected items.
Formal written instructions notifying data processing personnel of the procedures to follow with regard to rejected items.
Appropriate investigation/follow up with regard to rejected items.
Evidence that rejected errors have been corrected and re-input.
Output controls
Output controls exist to en sure that all data is processed and that output is distributed only to prescribed authorised users. While the degree
of output controls will vary from one organisation to another (dependent on the confidentiality of the information and size of the
organisation), common controls comprise:
Use of batch control totals, as described above (see ‘input controls’).
Appropriate review and follow up of exception report information to ensure that there are no permanently outstanding exception
items.
Careful scheduling of the processing of data to help facilitate the distribution of information to end users on a timely basis.
Formal written instructions notifying data processing personnel of prescribed distribution procedures.
Ongoing monitoring by a responsible official, of the distribution of output, to ensure it is distributed in accordance with authorised
policy.
Evaluation of misstatements
ISA 450 – Objectives and definitions
According to ISA 450, the objectives of the auditor are to evaluate:
The effect of identified misstatements on the audit, and
The effect of uncorrected misstatements, if any, on the financial statements
A misstatement occurs when something has not been treated correctly in the financial statements, meaning that the applicable financial
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reporting framework, namely IFRS, has not been properly applied. Examples of misstatement, which can arise due to error or fraud, could
include:
An incorrect amount has been recognised – for example, an asset is not valued in accordance with the relevant IFRS requirement.
An item is classified incorrectly – for example, finance cost is included within cost of sales in the statement of profit or loss.
Presentation is not appropriate – for example, the results of discontinued operations are not separately presented.
Disclosure is not correct or misleading disclosure has been included as a result of management bias – for example, a contingent
liability disclosure is missing or inadequately described in the notes to the financial statements.
For the auditor it is important to distinguish between these types of misstatements in order to properly discuss them with management, and
ask for the necessary corrections, where relevant, to be made. For example, with a factual misstatement, there is little room for negotiation
with management, as the item has simply been treated incorrectly in the financial statements. With judgemental misstatement there is likely
to be more discussion with management. The auditor will need to present their conclusion based on robust audit evidence, in order to explain
the misstatement which has been uncovered, and justify a recommended correction of the misstatement.
With projected misstatements, because these are based on extrapolations of audit evidence, it is normally not appropriate for management to
be asked to correct the misstatement. Instead, a projected misstatement should be evaluated to consider whether further audit testing is
appropriate.
Correction of Misstatements
Management is expected to correct the misstatements which are brought to their attention by the auditor. If management refuses to correct
some or all of the misstatements, ISA 450 requires the auditor to obtain an understanding of management’s reasons for not making the
corrections, and to take that understanding into account when evaluating whether the financial statements as a whole are free from material
misstatement.
Evaluating the Effect of Uncorrected Misstatements
The auditor is required to determine whether uncorrected misstatements are material, individually or in aggregate. At this point the auditor
should also reassess materiality to confirm whether it remains appropriate in the context of the entity’s actual financial results. This is to
ensure that the materiality is based on up to date financial information, bearing in mind that when materiality is initially determined at the
planning stage of the audit, it is based on projected or draft financial statements. By the time the auditor is evaluating uncorrected
misstatements at the completion stage of the audit, there may have been many changes made to the financial statements, so ensuring the
materiality level remains appropriate is very important.
Some misstatements may be evaluated as material, individually or when considered together with other misstatements accumulated during
the audit, even if they are lower than materiality for the financial statements as a whole. Examples include, but are not restricted to the
following:
Misstatements which affect compliance with regulatory requirements
Misstatements which impact on debt covenants or other financing or contractual arrangements
Misstatements which obscure a change in earnings or other trends
Misstatements which affect ratios used to evaluate the entity’s financial position, results of operations or cash flows
Misstatements which increase management compensation
Misstatements which relate to misapplication of an accounting policy where the impact is immaterial in the context of the current
period financial statements, but may become material in future periods
From an exam point of view, candidates who have reviewed past Paper P7 exams will be familiar with exam requirements that ask candidates
‘the matters to consider and the evidence they expect to find’ when conducting an audit file review in relation to various matters, and such a
requirement is clearly set in the completion stage of an audit.
In performing a file review, the reviewer should consider the sufficiency of evidence obtained and may need to propose further audit
procedures if evidence is found to be insufficient or contradictory. ISA 230, Audit Documentation requires that documentation of the review
process includes who reviewed the audit work completed and the date and extent of such review.
ISA 450, Evaluation of Misstatements Identified during the Audit is relevant during an audit file review. The objective of the auditor when
following the requirements of this ISA are to evaluate both the effect of identified misstatements on the audit, and the effect of uncorrected
misstatements, if any, on the financial statements.
ISA 450 requires that all misstatements identified (other than those that are clearly trivial) shall be accumulated during the audit. The auditor
may need to perform further audit procedures in response to an identified misstatement – for example, to determine whether further
misstatements exist – and it is required that all misstatements are communicated to management on a timely basis, along with a request to
amend the misstatement identified.
Typically, the auditor will present the client with a list of misstatements (often referred to as the ‘audit error schedule’), quantifying the
amount of each misstatement, and proposing the necessary adjustment to the financial statements. The proposed adjustment may be in the
form of a journal entry, an amendment to the presentation of the financial statements, or a correction to a disclosure note. When
management makes the necessary adjustments to the financial statements, the auditor should confirm that the adjustments have been made
correctly.
When misstatements remain uncorrected by management, the auditor is required to reassess the level of materiality to confirm that it
remains appropriate, and should then determine if the uncorrected misstatements are material individually or in aggregate. The uncorrected
misstatements must be communicated to those charged with governance, and the potential implications for the auditor’s report must also be
communicated. The auditor must also obtain an understanding of management’s reasons for not making the necessary corrections to the
financial statements.
ISA 450 also requires that the auditor must request that management provides a written representation as to whether management believes
the effects of uncorrected misstatements are immaterial, both individually and in aggregate, to the financial statements taken as a whole. A
summary of uncorrected misstatements should also be included within, or attached to, the written representation.
The analytical procedures performed at this stage of the audit are not different to those performed at the planning stage – the auditor will
perform ratio analysis, comparisons with prior period financial statements and other techniques to confirm that trends are as expected, and to
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highlight unusual transactions and balances that may indicate a risk of misstatement. The key issue is that, near the end of the audit, the
auditor should have sufficient audit evidence to explain the issues highlighted by analytical procedures, and should therefore be able to
conclude as to the overall reasonableness of the financial statements.
When the analytical procedures performed near the end of the audit reveal further previously unrecognised risk of material misstatement, the
auditor is required to revise the previously assessed risk of material misstatement and modify the planned audit procedures accordingly. This
means potentially performing further audit procedures in relation to matters that are identified as high risk.
As well as reviewing the main elements of the financial statements, the auditor must at this stage carefully review the notes to the financial
statements for completeness and compliance with the applicable financial reporting framework. In many situations, this will be the first
opportunity for the auditor to review this information, as clients often prepare the notes to the financial statements towards the end of the
audit process.
At this stage, the auditor should also read the other information to be issued with the financial statements for consistency with the financial
statements. This is important as inconsistencies may have implications for the auditor’s report. Specific items of other information are subject
to specific regulation in some jurisdictions – for example, in the UK and Ireland the auditor’s report must state whether the Directors’ Report is
consistent with the financial statements.
Typically, the auditor will follow a specific work programme dealing with subsequent events, including procedures such as reviewing internal
accounting records and minutes of management meetings since the year-end and discussing subsequent events with management –
particularly the extent to which management has established procedures adequate to identify relevant subsequent events. It is important that
procedures dealing with subsequent events are performed up to the date of the auditor’s report. If they are performed too early and not
updated close to the date of the auditor’s report, then a significant event may not be identified by the auditor.
Secondly, ISA 570, Going Concern states that the auditor shall remain alert throughout the audit for audit evidence of events or conditions that
may cast doubt on the entity’s ability to continue as a going concern. Therefore, the auditor will conclude on going concern matters near the
end of the audit having reviewed all evidence obtained and after reviewing the final version of the financial statements.
Important outputs of the audit are the matters to be communicated in accordance with ISA 260, Communication with Those Charged with
Governance. The matters to be communicated include significant findings from the audit and matters relating to auditor’s independence. In
addition, the auditor must also consider whether the two-way communication between the auditor and those charged with governance has
been adequate for an effective audit, and have taken appropriate action if not.
The audit clearance meeting is not a requirement of ISAs, but is often used as a means to ensure that there are no misunderstandings
regarding the financial statements, the auditor’s report and any of the other matters discussed.
Going concern
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The auditor's objectives in relation to going concern
ISA 570 (Revised) Going Concern, contains well-established guidance on going concern, including the following objectives for the auditor:
to obtain sufficient appropriate audit evidence regarding, and conclude on, the appropriateness of management's use of the going
concern basis of accounting in the preparation of the financial statements
to conclude, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may
cast significant doubt on the entity's ability to continue as a going concern, and
to determine the implications for the auditor's report in accordance with ISA 570.
All audits should involve an assessment of the appropriateness of management’s use of the going concern basis of accounting, and it is obvious
to say that the auditor may well have to perform additional procedures when there are heightened risks relating to going concern, caused by
difficult economic and market conditions or specific industry considerations affecting the company. But going concern should be considered at
all stages of the audit, not just in terms of specific procedures, and the auditor is required to remain alert to events or conditions which may
cast significant doubt on the company’s ability to continue as a going concern. This requires the auditor to exercise high levels of professional
judgement.
In the exam it is important to remember that going concern is therefore not just something considered at a particular stage in the audit cycle,
but should be an issue that permeates the whole performance and review of an audit.
Auditors should consider going concern indicators and their impact on a particular audit when:
assessing risk at the planning stage of the audit, and when re-assessing risk as the audit progresses
designing and performing audit procedures to respond to the assessed risks
evaluating and concluding on the results of audit procedure, and
forming an audit opinion.
Paragraph A3 of ISA 570 provides good examples of financial, operational and other indicators which may individually or collectively cast
significant doubt on the entity’s ability to carry on as a going concern. This is where the auditor’s judgement is critical as it is not conclusive
that one or more of these items always signifies that a material uncertainty exists.
Assessing risk at the planning stage of the audit
Auditors are required by ISA 315, Identifying and Assessing the Risks of Material Misstatement through Understanding the Entity and Its
Environment, to gain an understanding of the audit client's business and the economic environment in which it operates. This understanding
should then lead to the identification of business risks, which are then evaluated in terms of any risks of material misstatement in the financial
statements.
Business risks include risks that could reduce the company's profit and/or cash inflows, and could ultimately mean that either a company is not
a going concern, or that there are significant doubts over its ability to continue as a going concern. Identification of this heightened risk at this
initial stage in the audit cycle means that additional audit procedures can be planned as a response to the specific risks identified.
All of this means that the auditor must gain a detailed understanding of the environment in which a company is operating, and more
specifically, an understanding of the particular market conditions affecting its operations. Risks can arise from many factors, including reduced
demand for goods and services, customers' inability to pay for goods and services already provided, an inability to raise necessary finance and
the need and renewal of specific operating licences. Such factors must be assessed for their specific impact on a company's operations. It is
important to remember that difficult economic or market conditions do not automatically mean that a material uncertainty exists about a
company's ability to continue as a going concern but these must be considered by the auditor in order to gain a full understanding.
The evaluation of business risks should lead to the assessment of specific financial statement risks. For a company facing going concern
difficulties, the fundamental financial statement risk is whether the financial statements have been prepared on the correct basis of
accounting, or whether any significant uncertainties have been disclosed in the financial statements. However, there are more specific
financial statement risks including:
potential overstatement of non-current assets if impairments caused by reduced market value or value in use have not been
recognised
potential overstatement of inventory if net realisable value has fallen due to reduced demand
potential overstatement of receivables if irrecoverable debts are not provided for
incorrect measurement and recognition of gains or losses on financial instruments due to inactive markets
incorrect measurement and disclosure of assets held for sale or discontinued operations
incorrect measurement or disclosure of provisions or contingent liabilities caused by restructuring of operations.
Paragraph A16 of ISA 570 contains examples of additional procedures that may be used.
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Analysis of cash flow is usually a key feature of any going concern evaluation. In this evaluation the auditor should pay particular attention to
the reliability of the company's systems for generating the cash flow information, and whether the assumptions underlying the cash flow
appear reasonable, applying professional scepticism and challenging those assumptions where needed.
In evaluating going concern, the auditor will consider whether necessary borrowing facilities are in place and in doing so will attempt to obtain
confirmations from the company's bankers. However, the bankers may be reluctant to confirm whether the borrowing facilities will be
available, in which case the auditor should consider the significance of this to the entity's ability to continue as a going concern, and also
consider, through discussion with management, whether there are other strategies or sources of finance available.
Forming an audit opinion
In forming the audit opinion, the auditor should consider two issues: have the financial statements been prepared using the appropriate basis
of accounting and is there adequate disclosure of any material uncertainty regarding going concern.
First, the auditor may conclude that management's use of the going concern basis is inappropriate. This means that the financial statements
are effectively rendered meaningless, and ISA 570 requires the auditor to express an adverse opinion on the financial statements.
In rare circumstances, where the financial statements have not been prepared under the going concern basis of accounting (for example, using
a liquidation basis), and the auditor agrees with the use of this alternative basis for the preparation of the financial statements, the audit
opinion may be unmodified. This is so long as the auditor has also concluded that there is adequate disclosure in the financial statements
regarding the basis of accounting. However, the auditor may consider it necessary to include an Emphasis of Matter paragraph in accordance
with ISA 706 (Revised) Emphasis of Matter Paragraphs and Other Matter Paragraphs in the Independent Auditor’s Report, to draw the user’s
attention to the alternative basis of accounting and the reasons for its use.
It is much more likely that the auditor concludes that the level of disclosure in relation to material uncertainties is inadequate rather than
concluding that the going concern basis of accounting is wholly inappropriate. ISA 570 contains detailed guidance in this area, which is briefly
summarised below:
Where the disclosure of material uncertainty is considered adequate, the auditor will express an unmodified opinion and will also
include a separate section in the auditor’s report entitled ‘Material Uncertainty Related to Going Concern’. This section will draw
attention to the note in the financial statements which discloses the uncertainties. This section will also state that these events or
conditions as disclosed constitute a material uncertainty but the auditor’s opinion is not modified in respect of the matter.
Where the disclosure of material uncertainty is not considered adequate, the auditor should express either a qualified or adverse
opinion in accordance with ISA 705 (Revised) Modifications to the Opinion in the Independent Auditor’s Report. In the Basis for
Qualified/Adverse Opinion section of the auditor’s report, the auditor should state that a material uncertainty exists which may cast
significant doubt on the entity’s ability to continue as a going concern and that the financial statements do not adequately disclose
this matter.
Ethical matters
In situations where entity’s are facing significant economic or operational pressure, auditors may find themselves being asked by audit clients
to perform non-audit services which may create self-review or advocacy threats to objectivity or which would involve assuming management
responsibilities For example for a client who is suffering financial pressure and is seeking to raise additional or alternative finance or
restructure, the audit firm may be asked to perform:
a review of the business including advising on restructuring options
a review of prospective financial information, possibly for presentation to potential providers of finance
advising on corporate finance options or negotiating such options.
The problem created is that the audit firm may not be able to objectively assess going concern factors when in addition becoming involved
with non-audit services pertaining to the going concern status of the company. The audit firm should carefully consider the appropriateness of
providing such non-audit services in these circumstances.
Safeguards may be able to reduce the threats to objectivity and independence to an acceptable level. Safeguards may include:
a review of the going concern assessment and conclusion reached by a partner who is not a member of the audit team
additional procedures as part of an Engagement Quality Control Review
confirmation from the audit client that they remain responsible for any decisions or actions taken as a result of the non-audit service
provided.
Relevant persons
The first step is to consider to whom the communication should be directed. ISA 260 does not specify this exactly, but
states that ‘governance is the term used to describe the role of persons entrusted with the supervision, control and
direction of an entity’. This implies that the communication should be with the highest level of management, including
the executive and non-executive directors, and the audit committee, where relevant. The identity of the relevant
person(s) to whom the communication will be addressed may be clarified in the engagement letter.
Matters to be communicated
In the second step, the auditor should consider the type of issues that should be communicated. ISA 260 provides
some guidance as to the matters which ordinarily could be incorporated in the communication, including:
the overall approach and scope of the audit, including any limitations on the scope of the audit
the accounting policies, and any changes to them, that could materially affect the financial statements
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adjustments arising as a result of audit procedures which could materially impact the financial statements
material events or uncertainties which could jeopardise the going concern status, and which require disclosure
within the financial statements
disagreements with management over accounting treatments or disclosures
any expected modifications to the audit report
material weaknesses discovered in the internal systems and controls.
All of the above are referred to as ‘findings from the audit’ (also often called ‘management letter points’).
The reason for communicating such matters is to ensure that the auditors have brought them to the attention of the
people responsible for the accounting and financial reporting function of the entity. Those responsible can then
discuss the matters and decide any actions that need to be taken in respect of them. For example, if the management
of the entity was totally unaware of the matters regarding control weaknesses, it then has the opportunity to implement
corrective action. It could also be the case that the management lacks technical knowledge; for example, it may not be
appreciated that a specific accounting policy is in breach of acceptable accounting practice. Again, armed with
information from the auditor, management can then resolve the problem by deciding on a new accounting policy.
It is important that material errors found in the financial statements are highlighted to management; if they are left
uncorrected, the audit opinion will be modified. Management must be made aware of this and given the opportunity to
correct the financial statements if necessary, in order to avoid a modified audit report.
Examining evidence
Audit procedures versus audit evidence
Audit procedures are actions that auditors carry out during the audit. Paper 2.6 questions typically ask candidates to describe
audit procedures, also known as ‘audit tests’ or ‘audit work’.
Audit evidence is obtained by the auditor as a result of the audit procedure. For example, ‘performing a circularisation of
receivables/debtors’ is an audit procedure, whereas ‘replies from customers’ is audit evidence. It is very important to be aware
of the difference. If a question asks for audit evidence and candidates state audit procedures, then the question hasn’t been
answered, and gains no marks.
Which of the following are procedures and which are evidence?
1. Inspecting non-current/fixed assets for signs of obsolescence
2. An item of inventory/stock that is present at the inventory/stock count
3. A bank statement
4. Counting petty cash
5. A working paper showing a re-calculation of depreciation
6. A sales invoice
7. Attending a wages pay out.
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Answer
Items 1, 4 and 7 are procedures (because procedures are actions, notice the use of verbs such as ‘inspecting’, ‘counting’, and
‘attending’). The other items are evidence, as they are the result of audit procedures.
However, note that the phrasing is ‘state the audit evidence that you should expect to find in undertaking your review of the
audit working papers and financial statements’. Item 5 meets this criterion because it is a working paper, but items 3 and 6 are
not necessarily included in audit working papers, so one would need to phrase the answer in such a way as to make this clear.
For example, one could say ‘a copy sales invoice’ and ‘a copy bank statement with the balance cross-referenced to the bank
reconciliation’.
Item 2 is definitely not evidence normally seen in working papers, since it is an item of physical inventory/stock. This could be
rephrased as ‘a schedule showing items test-counted at the inventory/stock count’ to make it into a correct answer.
Identifying appropriate audit evidence
Substantive testing questions can be quite tricky, as they can cover a range of accounting standards, and therefore are more
varied than questions on topics such as inventory/stock, receivables/debtors, payables/creditors, or non-current/fixed assets.
Candidates need to be able to think on their feet and develop a ‘sensible answer’ approach to a wide variety of questions, even
if they have never considered the subject previously. One way to do this is to use the financial statement assertions as a starting
point.
The financial statement assertions are those assertions that are implicit or implied when the directors make an explicit
statement that the financial statements give a true and fair view. In other words, they are attributes of the financial statements
that must be true if the financial statements are to give a true and fair view.
Assertions include completeness (all assets, liabilities, transactions, and events are included) and valuation (assets and liabilities
are included at an appropriate carrying value). Auditors design their audit programmes to ensure – as far as possible – that each
of these assertions are true, in order to gain evidence that proves that the financial statements give a true and fair view.
Using the assertions as a starting point to answer a question can be useful if the question is general – for example ‘describe how
you would audit leases’. Candidates could consider what assertions are relevant to leases and then describe audit tests and/or
evidence (depending on the question) to prove each of these assertions.
Example
You are the manager in charge of the audit of Yummy Mummy Co., a listed company with a European-wide chain of fashion
stores for babies and expectant mothers. The audit for the year ended 30 September 2006 is nearing completion. The draft
financial statements show a profit before tax of $50.6m (2005: $95.3m).
The audit senior has produced a schedule of ‘Points for the attention of the audit manager’ as follows:
(a) Due to the falling birth rate, the performance of the stores in Italy has been worse than expected. An impairment review was
performed on 15 October 2006, treating the Italian stores as a single cash-generating unit, which indicated that the recoverable
amount of the assets (based on value in use) was $23m lower than the carrying value. (6 marks)
(b) The company self-manufactures many of its clothing lines, and has a factory in Manchester, UK. Research has shown that the
company could achieve substantial cost savings by outsourcing to south east Asia, and the factory in Manchester is to be closed.
A provision of $3.2m to cover redundancy costs has been included in the 2006 draft financial statements. (7 marks)
(c) The company is planning to open 20 new stores in south east Asia in the next year. To assist in financing the expansion, the
company sold a number of its properties on 28 September 2006 for $200m and leased them back under operating leases. (7
marks)
Required:
For each of the above points:
(i) Comment on the matters that you should consider; and
(ii) State the audit evidence that you should expect to find, in undertaking your review of the audit working papers and financial
statements of Yummy Mummy Co. (20 marks)
The mark allocation is shown against each of the three points.
Formulating an answer
Note the format of the question. There are three mini-case studies, and for each the candidate has to (i) comment on the
matters that should be considered and (ii) state audit evidence. As this article is about audit evidence, we will only consider Part
(ii) of the question. However, the examiner has given guidance on how she wants candidates to answer Part (i), and has said that
matters to consider will normally include risk, materiality, and accounting treatment. In many answers, there is also a
requirement to comment on the type of audit report that would be needed if the company refuses to amend an erroneous
treatment.
Deciding on audit evidence
For each scenario:
1. Think about how the accountant would have calculated the numbers in the financial statements, the source documents
used and the systems followed, and then write about the documents etc, that one would expect to see.
2. Think about how to verify the other relevant facts in each case.
3. Consider the accounting/disclosure requirements of each scenario, and say how one can check if they are being met.
Remember, as the question is about evidence, not procedures, I would advise candidates to begin their answers to each part
with the words ‘I would expect to see’, and then list out the evidence as bullet points. This should stop candidates talking about
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procedures.
Here is an example answer – the bracketed text in italics is not part of the answer, but simply explanation where required.
(a) (Accounting issues in this scenario are subsequent events (adjusting) and impairment.)
I would expect to see:
extracts from the management accounts showing the performance of the Italian stores compared to budget, and the
most recent budget for 2007
a copy of the board minutes detailing management’s plans to improve performance or to sell the stores (if performance
continues to be poor it could affect going concern, if stores are to be sold they may need to be re-categorised as assets
held for sale)
a schedule comparing the carrying value of the assets with the recoverable amount, annotated to show that carrying
value has been agreed to the non-current/fixed assets register, and that any allocation of central assets and goodwill
was reasonable
a completed audit programme for non-current/fixed assets (as the appropriateness of the value of the assets has
already been checked during the audit of non-current/fixed assets, there is no need to check it again)
a calculation of value in use, annotated to show that the cash flows have been compared with budgets for 2007 and
beyond, and with actual cash flows (to see if they are reasonable).
(b) (The obvious accounting issue is provisions, but issues which are not mentioned – but which are potentially relevant – include
assets held for sale and discontinued operations.)
I would expect to see:
a copy of the announcement of the restructuring (has to be before the year end in order for a provision to be made)
a working paper detailing whether redundancy payments are being made in accordance with contractual, statutory, or
constructive obligations, and how the constructive obligations, if any, have been derived (in some countries, companies
are required under statute to pay certain levels of compensation to redundant employees)
a schedule detailing the amount to be paid to each redundant employee. This schedule should be annotated to show
that all relevant employees have been included and that the calculations have been checked for a sample of employees,
including agreement of their pay/service to their contracts where relevant
a point in the management representation letter as to any other costs to be provided for in closing the factory (eg
penalties for cancellation of leases)
a point in the management representation letter detailing whether the factory is to be sold or abandoned (if a decision
is made to sell, then assets are valued as assets held for sale, but not if it is to be abandoned)
a copy of the invitation to tender for the outsourcing contract, and notes of discussions with management as to how the
manufacturer was selected and how quality is to be assured.
(c) (Candidates need to focus on checking whether the leaseback is really an operating lease rather than a finance lease.)
I would expect to see:
a copy of the leasing contract
a schedule comparing the present value of the minimum lease payments with the fair value of the leased assets
a note comparing the length of the lease with the estimated useful life of the assets, and stating whether Yummy
Mummy Co. is responsible for maintenance and insurance
a schedule calculating the amounts that should appear in the financial statements, if the audit team believes this to be a
finance lease
an estimate of the carrying value of the assets at the date of sale, if the lease is an operating lease (if selling price is not
fair value, it affects how profit on sale is recognised)
a point in the management representation letter on the purchaser of these properties, and whether they are related to
Yummy Mummy Co. and, if necessary, a draft of the related party disclosures that will appear in the financial
statements.
This is just one possible answer – there are many other valid points that could be made. Notice that this sample answer reflects
the three points mentioned above:
1. Evidence to show that the accountant has worked out the figures correctly (eg the calculation of the redundancy
payment, the calculation of value in use).
2. Evidence to prove other relevant facts (eg performance in Italy, outsourcing contract, lease agreement).
3. Evidence to prove that accounting standards have been complied with (eg date of closure announcement, comparison
of payments, fair value of leased assets).
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Other assignments (F)
This means that non-accountancy professionals can use ISSA 5000, for example, experts in environmental matters or scientists.
What is ‘sustainability’ in the context of sustainability reporting?
ISSA 5000 (ED) defines ‘sustainability matters’ as ‘environmental, social, economic and cultural matters, including the impacts of
an entity’s activities, products and services on the environment, society, economy or culture, or the impacts on the entity; and
the entity’s policies, performance, plans, goals and governance relating to such matters’.
ISSA 5000 (ED) goes further and provides examples of topics which may be included in sustainability information:
Climate, including emissions.
Energy, such as type of energy and consumption.
Water and effluents, such as water consumption and water discharge
Biodiversity, such as impacts on biodiversity or habitats protected and restored.
Labour practices, such as diversity and equal opportunity, training and education, and occupational health and safety.
Human rights and community relations, such as local community engagement, impact assessments and development
programs.
Customer health and safety.
Economic impacts, such as government assistance, tax strategy, anti-competitive behaviour, anti-corruption and market
presence.
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There is a wide range of information that may be provided, and it could be provided in various ways, for example, in narrative
disclosures, in tables of figures including performance indicators, in diagrams or graphics.
Applying ISSA 5000 (ED)
ISSA 5000 (ED) can be applied whether the engagement is designed to provide limited or reasonable assurance and it can be
applied to all of an organisation’s sustainability disclosures, or just to part of them. The proposed standard is long, and
complicated in parts, and this section of the article aims to provide an overview of the key requirements and concepts.
Objectives
The objectives of ISSA 5000 (ED) are:
‘(a) To obtain reasonable assurance or limited assurance, as applicable, about whether the sustainability information is free from
material misstatement;
(b) To express a conclusion on the sustainability information through a written report that conveys a reasonable assurance or a
limited assurance conclusion, as applicable, and describes the basis for the conclusion; and
(c) To communicate further as required by this ISSA and any other relevant ISSA’.
ISSA 5000 (ED) contains an appendix which illustrates different forms of assurance reports which can be provided, distinguishing
between those reports which include limited and reasonable assurance conclusions. In line with other types of assurance
engagement, the higher the level of assurance that is to be provided, more robust evidence is required to support the
conclusion given by the assurance practitioner.
Acceptance of the engagement
Acceptance of a sustainability assurance engagement adopts principles consistent with those in ISQM 1 Quality Management for
Firms that Perform Audits or Reviews of Financial Statements, or other Assurance or Related Services Engagements. Therefore,
ISSA 5000 (ED) requires assurance practitioners to evaluate whether pre-conditions are present as part of their engagement
acceptance procedures. These preconditions include:
1. Understanding the scope of the work
2. The sustainability information to be reported
3. The reporting boundary (information, including activities and resources, to be included in the entity’s sustainability
information)
4. The existence of suitable criteria, and
5. Determining the level of assurance to be provided.
ISSA 5000 (ED) highlights the importance of both firm-level and engagement-level quality management, stating that the
engagement leader shall take overall responsibility for managing and achieving quality on the engagement and also requiring
that the engagement leader must have competence and capabilities in assurance skills and techniques developed through
extensive training and practical application. The engagement leader is also responsible for ethical considerations and ensuring
that sufficient and appropriate resources are allocated to the engagement.
There is detailed guidance relating to the assurance team, with particularly emphasis on the relationship between the
engagement team and ‘other practitioners’ and whether it is appropriate to use the work of others. There is also recognition
that information on which assurance is provided is often derived from sources up and down the value chain of the reporting
entity, so careful planning is required to ensure that the assurance team can obtain sufficient appropriate evidence in a timely
manner.
Planning the engagement
It is crucial to obtain understanding over the organisation’s processes to identify the sustainability information to be reported.
The assurance practitioner will need to spend time at the start of the engagement to ensure they have a good level of
understanding of what is being reported, how it is being reported, and this includes understanding relevant internal controls.
The assurance practitioner must use risk assessment procedures, including procedures relating to fraud. The requirements vary
depending on whether the engagement is to provide limited or reasonable assurance. For example, in reasonable assurance
engagements, more work is needed on understanding the system of internal control.
Materiality
Materiality is a significant issue, and it needs to be applied using a ‘bifurcated’ approach. This means considering materiality for
qualitative disclosures and determining materiality for quantitative disclosures. Materiality for a reasonable assurance
engagement is the same as for a limited assurance engagement because materiality is based on the information needs of
intended users.
However, it is important to understand that the organisation will have its own materiality process, including ‘double materiality’.
This means consideration of the significance of the impact of a sustainability matter on the organisation, as well as the
significance of the impacts of the business activity on the outside world (‘impact materiality’) . The assurance provider needs to
understand the organisation’s materiality process, but this is separate from their own materiality considerations.
Where the concept of double materiality is relevant, the assurance practitioner should consider both financial and impact
materiality when determining their materiality level for the purposes of planning and performing the engagement. It should be
noted that the IAASB’s view is that it will not be relevant to every engagement.
It is important to note that when considering the materiality of potential misstatements, as with performance materiality, these
may be both quantitative and qualitative in nature.
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Obtaining evidence
When responding to risks of material misstatement, in designing and performing further audit procedures, the requirements
vary depending on whether it is a limited assurance or a reasonable assurance engagement. For a reasonable assurance
engagement:
ISA 5000 (ED) acknowledges that qualitative sustainability information and estimates or forward-looking information are both
potentially difficult areas over which to obtain evidence. Therefore, the assurance practitioner must exercise significant
professional judgement in evaluating what constitutes sufficient appropriate evidence in these circumstances.
Often, sustainability information is forward-looking and based on estimates and future plans. Organisations produce scenarios
based on best-estimate or hypothetical assumptions which might be subject to management bias or great uncertainty. Evidence
can therefore be difficult to obtain, and the assurance practitioner may need to exercise a significant level of judgement in
determining whether they have obtained sufficient and appropriate evidence.
Also, as already stated, this is in addition to the evidence which may be required from external experts and parties within the
entity’s value chain. It is essential that sufficient time and resources are assigned to the engagement.
Reporting
It is important that users of assurance reports understand the level of assurance being provided. The report must state that ‘the
procedures in a limited assurance engagement vary in nature and timing from, and are less in extent than for, a reasonable
assurance engagement and, consequently, the level of assurance obtained in a limited assurance engagement is substantially
lower than the assurance that would have been obtained had a reasonable assurance engagement been performed’.
Greenwashing and other risks in sustainability reporting
Greenwashing is a significant potential problem, this being when an organisation makes false or misleading statements about
sustainability information. This concept is very similar to that of ‘creative accounting’ – where financial information is
manipulated to serve the needs of the preparer of the information, rather than for the needs of the users of that information.
Greenwashing can be considered to be fraudulent reporting. Added to this, the systems and processes that are generating
sustainability information are often subject to change as the sustainability reporting requirements develop. Therefore, there is a
higher risk of error, as well as deliberate misstatement, in the sustainability information that is published.
These risks, when coupled with the potential difficulties of obtaining evidence over qualitative disclosures and future-oriented
information means that there can be danger of issuing an inappropriate assurance opinion. There is a reputation risk for the
assurance provider if they report positively on sustainability information which turns out to the incorrect, inaccurate or
exaggerated.
Given the risks of greenwashing mentioned previously, there is a need to apply professional scepticism and to document how
this has been applied as part of obtaining the evidence which backs up the assurance conclusion.
The ethical angle for assurance providers
Assurance providers need to adhere to relevant ethical codes of practice, just as when they are performing other professional
engagements. The IESBA Code of Ethics includes the principles of integrity, objectivity, professional competence and due care,
confidentiality and professional behaviour.
Perhaps the most obvious threat to ethics relates to the assurance provider’s professional competence. While many
organisations have been reporting on sustainability matters for years, for assurance providers the new reporting standards are
largely unfamiliar territory, so there is a real issue that professional accountants lack the necessary knowledge to provide
assurance on sustainability information. Knowledge can be developed but a deeper level of understanding cannot be developed
overnight. An assurance provider could have a self-interest threat in securing an engagement to report on sustainability
information, giving the firm a foothold in a potentially lucrative new line of work. So, for purely commercial reasons, the audit
firm might take on the job even if they are not competent to do it.
There could also be a self-review threat if an assurance provider is performing the external audit of financial statements as well
as working on the sustainability information of the organisation. In this case, the assurance provider should make sure that
separate teams are used for the different aspects of work.
Ultimately the audit firm would need to apply appropriate professional behaviour, ensuring that commercial objectives are not
prioritised over principles of integrity.
Exam focus
Candidates may be required to consider scenario specific risks in the exam, such as pressures to meet reporting deadlines,
requirements or meeting finance covenants. There may be estimations or other areas where management judgement has
been applied. As in a financial assurance engagement, candidates should be aware of potential bias by management and
the need to obtain sufficient and appropriate audit evidence.
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The assurance of social, environmental and sustainability information (part 1)
Part 1: The need to measure and report, with considerations for the assurance professional
Auditors may be asked to complete assurance engagements on non-financial information, and this is increasingly likely to
include the review of management reports on social, environmental and sustainability information. When management provides
this type of information it is known as Extended External Reporting (EER), which is a requirement for listed and larger private
companies in some jurisdictions. In addition, many companies wish to provide additional information on the environmental
impact of their operations on the environment.
There are challenges in undertaking such engagements, and although this can be a highly specialist area, there are still steps that
the assurance provider can take to mitigate these issues.
This article considers the main reasons why companies produce these reports and the various methods of measurement used.
Auditors may be asked to review the information as part of their review of the annual report, or as a separate assurance
engagement.
This is the first of two articles which considers why sustainability information is published and a brief coverage of the
measurement issues. An assurance professional is most likely to review sustainability information as part of the strategic report,
which is covered briefly here. Increasingly though, assurance professionals are being tasked in reviewing specific sustainability
reports, this is covered in the second article on the topic.
Why is there a need for companies to produce these reports?
National reporting requirements: Some regions require specific sized companies (larger, listed entities usually) or those
in specific industries to report on their environmental, social and governance information. Examples include:
o Corporate Sustainability Reporting Directive (CSRD) is legislation in the European Union (EU) requiring all large
companies to publish reports on their social and environmental impact activities 1
o UK premium listed companies must report their compliance with the Task Force on Climate-Related Financial
Disclosures (TCFD) recommendations for periods commencing 1 January 2021. This is already effective in New
Zealand and Japan 2
Stakeholder needs: Increasingly shareholders, especially larger investors like pension funds, are demanding more
information of the impact of a company on the environment and society.
Voluntary disclosure: Companies may seek to gain a competitive advantage by declaring their ‘green credentials’. Such
voluntary disclosure may be subject to management bias as the reporting requirements are not specified under
legislation.
Companies can choose to include this type of information within their annual report or to produce stand-alone reports on social,
environmental and sustainability matters. In the last decade, Integrated Reporting <IR> has become common, which aims to
provide a holistic view of the company’s financial and non-financial performance and its potential for long term value creation.
Measuring and reporting on environmental, social and sustainability information
The measurement of specialised information can be problematic, because sustainability or environmental indicators may be
reported in different ways even within the same industry and several differing reporting standards may be used, rather than a
single, global reporting basis.
In 2022, the International Sustainability Standards Board (ISSB) commenced a consultation on two proposed sustainability
standards, one regarding general sustainability related disclosures and one regarding climate related disclosures. There are a
variety of different Key Performance Indicators (KPIs) and metrics in use, and comparison between companies and industries is
challenging for the following reasons:
Rapid change in EER requirements and disclosure principles
Diversity of subject matter
Lack of single reporting basis for non financial information
Additional risk of management bias due to the subjective nature of measurement in many cases and selection of the
criteria being presented
Example of a water consumption disclosure within the sustainability reporting section of the Annual Report 2020 for MMC
Corporation: 3
2. Independent assurance engagement over non-financial information which is outside of the statutory financial
statements audit (this is covered in the second part of our article on Assurance on Sustainability Information: Part 2)
Review of non-financial information which is part of the annual report (such as the strategic report)
Guidance on the review of non-financial information as part of the annual report is covered by ISA 720 (Revised). Auditors need
to consider whether there is a material inconsistency between the other information and the financial statements.
Auditors should consider all auditing standards, but a few key ones which may be relevant to the review of other information
are:
ISA 540 (Revised) Auditing Accounting Estimates and Related Disclosures
Management bias – this may arise in both the calculation and the disclosure of information, especially if the information
is provided voluntarily by the company in order to gain a competitive advantage.
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Appropriateness of methods of calculation and whether the basis for estimations are reasonable and appropriate – this
may be an issue where there are no industry standard measurements established and management is responsible for
deciding on the parameters of the estimation.
ISA 250 (Revised) Consideration of Laws and Regulations in an Audit of Financial Statements
If the requirement to report is required by legislation, there may be financial penalties or reputational issues for failure
to report correctly for both the company and the auditor.
If there has been a breach of regulations, for example if any required environmental disclosures are not given, there
may be implications for the financial statements, such as provisions for fines. This increases audit risk. Breaches of laws
or regulations may even impact the ability of the company to continue to trade, for example licences to trade may be
subject to adhering to laws and regulations, or fines or penalties may be substantial enough to significantly impact the
cash flow of an entity.
ISA 315 (Revised 2019) Identifying and Assessing the Risks of Material Misstatement
Assurance providers need knowledge and experience of the industry and subject matter, this may be a highly
specialized area. Independent experts may be required to assist in the assessment of specialist criteria, for example,
greenhouse gas emissions, chemical levels in waste etc. or using an EER expert to manage the assurance process.
There may be industry standard measurements which are used (example) or the criteria may be more widely
recognised, such as greenhouse gas emissions.
Internal controls of the client – consideration of the reliance which can be placed on the information and whether this
information is internally or externally generated.
Information from third parties, these could include environmental bodies (governmental or private) and the reliance
which can be placed on this information.
Consideration of whether the omission of such information may affect the users of the financial statements.
This list is not exhaustive and other auditing standards may need to be considered in order to obtain the relevant sufficient
evidence in an engagement.
The second article in this series considers the challenges of auditing sustainability information in more detail, as well as some
tips on exam technique for your Advanced Audit and Assurance exam.
The reliance which can be placed upon the evidence from third party sources will need to be assessed by the assurance provider
using their professional judgement. There will need to be an understanding of how the information is collected and what, if any,
recognized standards it adheres to. This is an area where the use of an independent expert may be required in order to identify
whether any specialist information is consistent and relevant to the industry.
Substantive procedures to detect potential misstatements re socio-environmental and sustainability matters
ISA 500 Audit Evidence
The auditor shall design and perform audit procedures that are appropriate in the circumstances for the purpose of
obtaining sufficient appropriate audit evidence (para.6). Substantive procedures are designed to detect material
misstatements at the assertion level. They comprise tests of details and substantive analytical procedures.
The assurance provider will need to ensure that they obtain sufficient appropriate evidence, and as there are a wide
range of KPIs which may be used by management in sustainability reports, this may be challenging. However, there
may be financial evidence to support some of the information in the report, as well as discussions with management
or review of the board minutes.
Example
A manufacturer reports on the wastage and pollution in its sustainability report.
Tests which may be performed:
Review of any fines in the financial statements to see whether the company has incurred financial penalties as a result
of environmental breaches.
Enquire and review the legal documentation, including legal expenses, to assess whether legal advice was sought in
response to a breach of regulations.
Enquire whether there are financial impacts of increased waste, such as costs of disposal, or incentives by governmental
bodies to increase recycling or waste reduction. These may be reflected in the financial statements within expenses or
other income.
Significant issues may be reflected in the press or by third party ‘whistleblowers’.
If wastage increases, there may an increase in the cost per unit, this may be assessed by a review of the cost per unit
and whether more material is required to manufacture the units. Performing analytical reviews of the costs may
highlight potential issues in this area.
The audit evidence obtained, depending on the level of assurance required by the scope of the engagement (limited or
reasonable), should be reviewed using the professional judgement of the assurance provider. Responses from management
should be viewed with an element of professional scepticism and considered in the light of the substantive work undertaken.
Professional scepticism may need to be applied to mitigate the risk of management bias in the reported figures, especially
where there are significant impacts on the business if the report is to be relied upon by third parties, such as financial
institutions, government bodies or those issuing licences to trade, which is common in regulated industries like energy
production and supply.
Example from the Annual Report 2021 from Kier Plc 2021:
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The auditor would have to assess the contents of the sustainability report of Kier Plc to ensure that it is materially consistent
with the information in the financial statements. Possible audit evidence may include:
Analysis of the costs attributable to waste and recycling with a comparison of year on year to assess whether the trend
is consistent with the environmental information.
Discussion with management and review of any independent reports which detail the information regarding carbon
emissions. Verify that the independent expert is suitably qualified or registered.
Form and content of independent verification statement of integrated or sustainability information
As in all assurance engagements, issues found during the assurance engagement should be reported to Those
Charged with Governance.
The content and scope of the assurance provider’s report must be considered: If the report is to be included within
the financial statements, which stakeholders will be relying upon it and what level of assurance is required. There
should be an explicit reference to national or international standards for quality management and any reporting
requirements which have been adhered to. ISAE 3000 also requires that the practitioner should be aware of whether
any errors in the final assurance report may lead to reputational damage to the assurance provider.
EER and sustainability reporting is a rapidly changing specialism, and the assurance provider will need to ensure that they have
sufficient expertise and experience when accepting engagements of this type.
Exam technique
The AAA exam does not require knowledge of specific sustainability or climate reporting standards, however
students may be asked in the exam to assess a scenario whereby the assurance provider is asked to consider the risks
of a non-financial engagement. Students should apply their knowledge of auditing and assurance standards and
evaluate the risks in an exam question:
1. Read the requirement carefully – consider whether the engagement is part of the statutory review of the annual report
(and the application of ISA 720 is required) or a separate assurance engagement.
2. Evaluate the risks in the engagement and consider how may the assurance practitioner mitigate these. Think about
some of the problems faced by assurance providers such as challenges in measuring and comparing information across
companies and industries (see 'Measuring and reporting' in Part 1 of this article).
3. Application of knowledge of auditing and assurance standards (such as those stated above, although some scenarios
may also benefit from reference to other standards) when asked to review or provide assurance on a report.
4. Justify the responses, if procedures are requested in the exam, then consider what reasonable evidence may be
obtained and why it is that this is being reviewed.
• help to define performance targets/goals across the key aspects of service delivery, including management of resources
(personnel, infrastructure), customer service and financial viability
• provide a comprehensive picture of the organisation's progress towards achieving its performance targets/goals
• provide an early indication of emerging issues/cost pressures that may require remedial action
• indicate where there is potential to improve the cost effectiveness of services through comparison with other
organisations
The NHS therefore has to produce a range of performance measures relevant to the needs of this wide range of stakeholders.
Different stakeholders have different needs, for example patients may focus on the effectiveness of a certain medical procedure,
whereas management may focus on the cost of providing that procedure. Therefore a very wide range of performance
information may be required yet it would be pointless to set targets and produce performance information on an issue which is
not relevant to any stakeholder.
The audit of performance information
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It is worth reiterating the difference between the audit of performance information and performance auditing as both are likely
to occur in the public sector. Candidates are reminded that the audit of performance information is concerned with the audit of
reported performance information against predetermined objectives. The auditor’s role here is usually to report on the
credibility, usefulness and accuracy of the reported performance. Performance auditing is related to the evaluation of how the
public sector body is utilising resources and often focuses on determining how the public sector body is achieving economy,
efficiency and effectiveness, sometimes referred to as value for money auditing. It is the former that is the focus of this area of
the P7 syllabus.
In some jurisdictions it is part of the audit requirement for public sector organisations that the auditor should report on
performance information. In jurisdictions where this is not a requirement, the auditor may be asked to perform a separate
engagement to the financial statement audit, the objective of which is to report specifically on the performance information. In
either case, the auditor will need to plan procedures in much the same way as in a conventional audit scenario. Candidates are
therefore encouraged to apply their existing knowledge of audit planning (risk assessment) and evidence gathering techniques
to this type of information. The auditor is still looking to ultimately report on the validity of the information included in this
respect. The auditor may find the principles of ISAE 3000 Assurance Engagements other than Audits or Reviews of Historical
Financial Information provide a useful framework for planning and performing the work on performance information.
As with any engagement to provide assurance, this would likely start with an understanding of the entity to ensure knowledge of
the predetermined performance measures, an evaluation of the systems and controls used to derive and capture the
performance information and also performing substantive procedures on the reported measures. The auditor will also need to
understand the rationale behind the measures that are being reported on, considering the relevance and suitability of them in
terms of the objectives of the public sector organisation in order to help assess the usefulness of the information being
provided.
Audit procedures may include:
Tests of controls on the systems used to generate performance information
Performing analytical review to evaluate trends and gauge the consistency of the information
Discussion with management and other relevant individuals, for example those responsible for the reporting process
Review of minutes of meetings where performance information has been discussed
Confirmation of performance information to source documentation; this may be performed on a sample basis
Recalculation of quantitative performance information measures
Of course, the procedures must be specifically tailored to the performance information subject to the audit. Further as in any
audit, the working papers must contain a summary of findings and clear conclusions on the procedures that have been
performed.
Reporting on performance information
There is no specific format or wording that is prescribed by international regulations for reporting on public sector performance
information, though in some jurisdictions the national regulators may issue country-specific requirements.
Generally, the auditor will provide a conclusion on whether the public sector entity has achieved its objectives as shown by the
reported performance information and concludes on the information itself. This conclusion may be in the form of a reasonable
assurance conclusion – ie an opinion is expressed, or may be in the form of a negative assurance conclusion – ie no opinion is
expressed. Essentially, in the absence of any jurisdiction specific requirements, the auditor will agree the type of conclusion with
the public sector organisation and usually its regulating body.
Often the performance information will be provided as part of the public sector organisation’s integrated report, in which case
the auditor’s conclusion will be included within the integrated report.
Forensic auditing
This article explores some of the issues relevant to forensic investigations.
‘Forensic auditing’ covers a broad spectrum of activities, with terminology not strictly defined in regulatory guidance. Generally,
the term ‘forensic accounting’ is used to describe the wide range of investigative work which accountants in practice could be
asked to perform. The work would normally involve an investigation into the financial affairs of an entity and is often associated
with investigations into alleged fraudulent activity. Forensic accounting refers to the whole process of investigating a financial
matter, including potentially acting as an expert witness if the fraud comes to trial. Although this article focuses on investigations
into alleged frauds, it is important to be aware that forensic accountants could be asked to look into non-fraud situations, such
as the settling of monetary disputes in relation to a business closure or matrimonial disputes under insurance claims.
The process of forensic accounting as described above includes the ‘forensic investigation’ itself, which refers to the practical
steps that the forensic accountant takes in order to gather evidence relevant to the alleged fraudulent activity. The investigation
is likely to be similar in many ways to an audit of financial information, in that it will include a planning stage, a period when
evidence is gathered, a review process, and a report to the client. The purpose of the investigation, in the case of an alleged
fraud, would be to discover if a fraud had actually taken place, to identify those involved, to quantify the monetary amount of
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the fraud (ie the financial loss suffered by the client), and to ultimately present findings to the client and potentially to court.
Finally, ‘forensic auditing’ refers to the specific procedures carried out in order to produce evidence. Audit techniques are used
to identify and to gather evidence to prove, for example, how long the fraud has been carried out, and how it was conducted
and concealed by the perpetrators. Evidence may also be gathered to support other issues which would be relevant in the event
of a court case. Such issues could include:
the suspect’s motive and opportunity to commit fraud
whether the fraud involved collusion between several suspects
any physical evidence at the scene of the crime or contained in documents
comments made by the suspect during interviews and/or at the time of arrest
attempts to destroy evidence.
TYPES OF INVESTIGATION
The forensic accountant could be asked to investigate many different types of fraud. It is useful to categorise these types into
three groups to provide an overview of the wide range of investigations that could be carried out. The three categories of frauds
are corruption, asset misappropriation and financial statement fraud.
Corruption
There are three types of corruption fraud: conflicts of interest, bribery, and extortion. Research shows that corruption is
involved in around one third of all frauds.
In a conflict of interest fraud, the fraudster exerts their influence to achieve a personal gain which detrimentally affects
the company. The fraudster may not benefit financially, but rather receives an undisclosed personal benefit as a result
of the situation. For example, a manager may approve the expenses of an employee who is also a personal friend in
order to maintain that friendship, even if the expenses are inaccurate.
Bribery is when money (or something else of value) is offered in order to influence a situation.
Extortion is the opposite of bribery, and happens when money is demanded (rather than offered) in order to secure a
particular outcome.
Asset misappropriation
By far the most common frauds are those involving asset misappropriation, and there are many different types of fraud which
fall into this category. The common feature is the theft of cash or other assets from the company, for example:
Cash theft – the stealing of physical cash, for example petty cash, from the premises of a company.
Fraudulent disbursements – company funds being used to make fraudulent payments. Common examples include
billing schemes, where payments are made to a fictitious supplier, and payroll schemes, where payments are made to
fictitious employees (often known as ‘ghost employees’).
Inventory frauds – the theft of inventory from the company.
Misuse of assets – employees using company assets for their own personal interest.
CONDUCTING AN INVESTIGATION
The process of conducting a forensic investigation is, in many ways, similar to the process of conducting an audit, but with some
additional considerations. The various stages are briefly described below.
Additional considerations include whether or not the investigation is being requested by an audit client. If it is, this poses extra
ethical questions, as the investigating firm would be potentially exposed to self-review, advocacy and management threats to
objectivity. Unless robust safeguards are put in place, the firm should not provide audit and forensic investigation services to the
same client. Commercial considerations are also important, and a high fee level should be negotiated to compensate for the
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specialist nature of the work, and the likely involvement of senior and experienced members of the firm in the investigation.
The investigators should also consider the best way to gather evidence – the use of computer assisted audit techniques, for
example, is very common in fraud investigations.
Gathering evidence
In order to gather detailed evidence, the investigator must understand the specific type of fraud that has been carried out, and
how the fraud has been committed. The evidence should be sufficient to ultimately prove the identity of the fraudster(s), the
mechanics of the fraud scheme, and the amount of financial loss suffered. It is important that the investigating team is skilled in
collecting evidence that can be used in a court case, and in keeping a clear chain of custody until the evidence is presented in
court. If any evidence is inconclusive or there are gaps in the chain of custody, then the evidence may be challenged in court, or
even become inadmissible. Investigators must be alert to documents being falsified, damaged or destroyed by the suspect(s).
The ultimate goal of the forensic investigation team is to obtain a confession by the fraudster, if a fraud did actually occur. For
this reason, the investigators are likely to avoid deliberately confronting the alleged fraudster(s) until they have gathered
sufficient evidence to extract a confession. The interview with the suspect is a crucial part of evidence gathered during the
investigation.
Reporting
The client will expect a report containing the findings of the investigation, including a summary of evidence and a conclusion as
to the amount of loss suffered as a result of the fraud. The report will also discuss how the fraudster set up the fraud scheme,
and which controls, if any, were circumvented. It is also likely that the investigative team will recommend improvements to
controls within the organisation to prevent any similar frauds occurring in the future.
Court proceedings
The investigation is likely to lead to legal proceedings against the suspect, and members of the investigative team will probably
be involved in any resultant court case. The evidence gathered during the investigation will be presented at court, and team
members may be called to court to describe the evidence they have gathered and to explain how the suspect was identified. It is
imperative that the members of the investigative team called to court can present their evidence clearly and professionally, as
they may have to simplify complex accounting issues so that non-accountants involved in the court case can understand the
evidence and its implications.
Changes to the definitions of the fundamental principles of objectivity and professional behaviour.
The addition of new application material in respect of the fundamental principle of integrity to include a
determination to act appropriately.
Strengthening the Code through requiring professional accountants to have an inquiring mind when applying the
conceptual framework and exercising professional judgement.
Emphasising the importance of being aware of the dangers of bias when carrying out professional work and of
professional firms having a positive, internal organisational culture.
The inclusion of the concept of ‘determination to act appropriately in difficult situations’ and its position within the principle of
integrity emphasises the need to do the right thing regardless of the challenges faced by a professional accountant. At a time
when the accountancy profession is under enormous pressure and scrutiny, it seems the focus of the change is to ensure that
the Code convey that it is one thing for an accountant to know something is wrong, but actually having the courage to speak up
will be vital to compliance.
Application of the conceptual framework: having an enquiring mind
Professional accountants should have a mindset that encapsulates the following characteristics:
The ability to obtain and understand information relevant for making reliable judgements based in facts and
circumstances which are known to the professional accountant.
The capability to make informed challenges of the views developed by others.
Sensitivity to the integrity of information, including the source of the information and the appropriateness of its
presentation, and
Be able to withhold judgement until careful consideration can be given to all known and relevant available information.
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The Code is aimed at promoting the need for professional accountants to be inquisitive and curious about the information
available. They should also conduct the necessary assessment or investigation of the integrity, relevance and sufficiency of that
information to reach an informed decision. The application material within the Code defines ‘having an inquiring mind’ as:
i. being open and alert for situations and information (or the lack thereof) that might require further investigation; and
ii. considering whether there is a need to critically evaluate the information obtained where the need for, extent and nature of,
any investigation, including critical evaluation, will depend on the nature, scope and outputs of the professional activity being
undertaken.
This requires all professional accountants to consider or remain alert to whether facts and circumstances have changed and,
therefore, obliges them to exercise an inquiring mind in the judgements they reach. The exercise of scepticism is a vital quality
for all professional accountants.
Application of the conceptual framework: bias
It is important to heighten awareness of the risks arising from bias. This includes making professional accountants’ aware of
individual bias which may affect their application of professional judgement. In addition to this, the Code includes an illustrative
list of other common forms of bias. These include:
Anchoring bias: a tendency to use an initial piece of information as an anchor against which subsequent information is
adequately assessed.
Automation bias: a tendency to favour output generated from automated systems, even when human reasoning or
contradictory information raises questions as to whether such output is reliable or fit for purpose.
Availability bias: a tendency to place more weight on events or experiences that immediately come to mind or are
readily available than on those that are not.
Confirmation bias: a tendency to place more weight on information that corroborates an existing belief than
information that contradicts or casts doubt on that belief.
Groupthink: a tendency to think or make decisions as a group that discourages creativity or individual responsibility.
Overconfidence bias: a tendency to overestimate one’s own ability to make accurate assessments of risk and other
judgements or decisions.
Representation bias: a tendency to base an understanding on a pattern of experiences, events or beliefs that is
considered to be representative.
Selective perception: a tendency for a person’s expectations to influence how the person views a particular matter or
person.
By raising awareness in relation to potential forms of bias, the professional accountant can reduce the risk and impact of its
effect, particularly on the ability to exercise professional judgement. They will be able to identify and mitigate for the
subsequent threats created, such as through consulting others or seeking advice from experts, additional input or appropriate
challenge therefore enhancing the evaluation process.
Application of the conceptual framework: importance of organisational culture
The Code emphasise the importance of a positive internal organisational culture to the effective application of the conceptual
framework by providing application material. In particular, it explains that ethical culture is most effective when:
(a) Leaders and those in managerial roles hold themselves and others accountable for demonstrating the ethical values of the
organisation
(b) Appropriate education and training programs, management processes, and performance evaluation criteria that promote
that ethical culture are in place: and
(c) Ethical values are adhered to in dealings with third parties.
It is also worth highlighting that the Code works closely alongside the International Standard on Quality Management 1, Quality
Management for Firms that Perform Audits or Reviews of Financial Statements, or Other Assurance or Related Services
Engagements, which sets out requirements and application material in the relation to the firm’s responsibility to design and
implement an effective system of quality management.
* NRV testing – comparing the last time an inventory item was purchased with the last time it was sold and at
what price
* Segregation of duties testing by identifying combinations of users involved in processing transactions from the
metadata attached to transactions
better focus on risk. This increase in understanding, aids the identification of risks associated with a client, enabling
testing to be better directed at those areas. This is further enhanced by freeing up auditor time from analysing routine
data so that more time can be spent on areas of risk
increased consistency across group audits where all auditors are using the same technology and process, enabling the
group auditor to direct specific tools for use in component audits and to execute testing across the group. This would
require appropriate consent from all component companies but if granted enables a more holistic view of a group to be
undertaken
increased efficiency through the use of computer programmes to perform very fast processing of large volumes of data
and provide analysis to auditors on which to base their conclusion, saving time within the audit and allowing better
focus on judgemental and risk areas. For example much larger samples can be tested, often 100% testing is possible
using data analytics, improving the coverage of audit procedures and reducing or eliminating sampling risk
data can be more easily manipulated by the auditor as part of audit testing, for example performing sensitivity analysis
on management assumptions
increased fraud detection through the ability to interrogate all data and to test segregation of duties, and
information obtained through data analytics can be shared with the client, adding value to the audit and providing a
real benefit to management in that they are provided with useful information perhaps from a different perspective.
Challenges of data analytics
The introduction of data analytics for audit firms isn’t without challenges to overcome. At present there is a lack of
consistency or a widely accepted standard across firms and even within a firm*. At present there is no specific
regulation or guidance which covers all the uses of data analytics within an audit. This results in difficulty establishing
quality guidelines. It also means that firms with the resources to develop their own data analytics tools may have a
competitive advantage in the market place effectively increasing the gap between the largest firms and smaller firms,
reducing effective competition in the audit industry. Other issues which can arise with the introduction of data
analytics as an audit tool include:
data privacy and confidentiality. The copying and storage of client data risks breach of confidentiality and
data protection laws as the audit firm now stores a copy of large amounts of detailed client data. This data
could be misused by the firms or illegal access obtained if the firm’s data security is weak or hacked which
may result in serious legal and reputational consequences
for a variety of reasons, including the above, and also due to a perception that it may be disruptive to business, the
audit client may be reluctant to allow the audit firm sufficient access to their systems to perform audit data analytics
completeness and integrity of the extracted client data may not be guaranteed. Specialists are often required to
perform the extraction and there may be limitations to the data extraction where either the firm does not have the
appropriate tools or understanding of the client data to ensure that all data is collected. This may especially be the case
where multiple data systems are used by a client. In addition, it may be possible for clients to only make selected data
accessible or to manipulate the data available for extraction
compatibility issues with client systems may render standard tests ineffective if data is not available in the expected
formats
audit staff may not be competent to understand the exact nature of the data and output to draw appropriate
conclusions, training will need to be provided which can be expensive
insufficient or inappropriate evidence retained on file due to failure to understand or document the procedures and
inputs fully. For example, a screen shot on file of the results of an audit procedure performed by the data analytic tool
may not record the input conditions and detail of the testing*, and
practice management issues arise relating to data storage and accessibility for the duration of the required retention
period for audit evidence. The data obtained must be held for several years in a form which can be retested. As large
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volumes will be required firms may need to invest in hardware to support such storage or outsource data storage which
compounds the risk of lost data or privacy issues
an expectation gap among stakeholders who think that because the auditor is testing 100% of transactions in a specific
area, the client’s data must be 100% correct.
Professional scepticism
What is professional scepticism?
The glossary of terms contained in the IAASB’s Handbook of International Quality Control, Auditing, Review, Other Assurance,
and Related Services Pronouncements contains the following definition of the term ‘professional scepticism’:
An attitude that includes a questioning mind, being alert to conditions which may indicate possible misstatement due to error or
fraud, and a critical assessment of evidence.
ISA 200, Overall Objectives of the Independent Auditor and the Conduct of an Audit in Accordance with International Standards
on Auditing, contains more guidance on how and why the auditor should act with an attitude of professional scepticism. ISA 200
contains a specific requirement in relation to professional scepticism:
The auditor shall plan and perform an audit with professional scepticism recognising that circumstances may exist that cause the
financial statements to be materially misstated.
This overall objective is the fundamental driver for the relevant learning outcomes within the Paper P7 syllabus, namely:
To discuss the importance of professional scepticism in planning and performing an audit (B1e), and
To assess whether an engagement has been planned and performed with an attitude of professional scepticism, and
evaluate the implications (B1f).
The application paragraphs of ISA 200 contain more guidance on what is meant by applying professional scepticism when
conducting an audit:
Essentially, ISA 200 requires the use of professional scepticism as a means of enhancing the auditor’s ability to identify risks of
material misstatement and to respond to the risks identified. Professional scepticism is closely related to fundamental ethical
considerations of auditor objectivity and independence. Professional scepticism is also linked to the application of professional
judgment by the auditor. An audit performed without an attitude of professional scepticism is not likely to be a high quality
audit. At its core the application of professional scepticism should help to ensure that the auditor does not neglect unusual
circumstances, oversimplify the results from audit procedures or adopt inappropriate assumptions when determining the audit
response required to address identified risks, all of which should improve audit quality.
How does the auditor apply professional scepticism?
The auditor is likely to apply professional scepticism at various stages from client acceptance and at various points during the
audit process, and some typical examples are given below:
When assessing engagement acceptance – at this stage the auditor should consider whether the management of the
intended audit client acts with integrity and whether there are any matters that may impact on the auditor being able to
act with professional scepticism if they accept the engagement, such as ethical threats to objectivity.
When performing risk assessment procedures – an auditor should be sceptical when performing risk assessment
procedures at the planning stage of the audit. For example, when discussing the results of analytical procedures with
management, the auditor should not accept management’s explanations at face value, and should obtain corroboratory
evidence for the explanations offered.
When obtaining audit evidence – the auditor should be ready to challenge management, especially on complex and
subjective matters and matters that have required a degree of judgement to be exercised by management. The
reliability and sufficiency of evidence should be considered, especially where there are risks of fraud. There may also be
specific issues arising during an audit which impacts on professional scepticism – for example, if management refuses
the auditor’s request to obtain evidence from a third party. The auditor will have to consider how much trust can be
placed on evidence obtained from management – for example, evidence in the form of enquiry with management or
written representations obtained from management. ISA 200 states that ‘a belief that management and those charged
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with governance are honest and have integrity does not relieve the auditor of the need to maintain professional
scepticism or allow the auditor to be satisfied with less than persuasive audit evidence when obtaining reasonable
assurance’.
When evaluating evidence – the auditor should critically assess audit evidence and be alert for contradictory evidence
that may undermine the sufficiency and appropriateness of evidence obtained.
The auditor should also apply professional scepticism when forming the auditor’s opinion, by considering the overall sufficiency
of evidence to support the audit opinion, and by evaluating whether the financial statements overall are a fair presentation of
underlying transactions and events.
Ultimately, the application of professional scepticism should reduce detection risk because it enhances the effectiveness of
applied audit procedures and reduces the possibility that the auditor will reach an inappropriate conclusion when evaluating the
results of audit procedures.
Specific applications of professional scepticism
Fraud
ISA 240, The Auditor’s Responsibilities Relating to Fraud in an Audit of Financial Statements, specifically refers to professional
scepticism stating that ‘when obtaining reasonable assurance, the auditor is responsible for maintaining professional scepticism
throughout the audit, considering the potential for management override of controls and recognising the fact that audit
procedures that are effective for detecting error may not be effective in detecting fraud’ (ISA 240.8).
ISA 240 goes on to state a specific requirement for the auditor: ‘The auditor shall maintain professional scepticism throughout
the audit, recognising the possibility that a material misstatement due to fraud could exist, notwithstanding the auditor’s past
experience of the honesty and integrity of the entity’s management and those charged with governance’ (ISA240.12).
The application paragraphs of ISA 240 emphasise the importance of assessing the reliability of the information to be used as
audit evidence and the controls over its preparation and maintenance. In addition, ISA 240 states that ‘management is often in
the best position to perpetrate fraud. Accordingly, when evaluating management’s responses to inquiries with an attitude of
professional scepticism, the auditor may judge it necessary to corroborate responses to inquiries with other information’ (ISA
240.A17). This is significant in that ISA 240 reminds the auditor that when management provides the auditor with audit evidence
– be that in the form of answers to enquiries, written representations or other forms of documentary evidence – the auditor
should carefully consider the integrity of that evidence and whether additional corroboratory evidence should be obtained from
a more reliable source.
Other aspects of an audit where professional scepticism may be important
The IAASB has issued a Staff Questions and Answers document entitled Professional Scepticism in an Audit of Financial
Statements, which outlines some of the areas of the audit where the use of professional scepticism may be important. These are
outlined below and largely relate to areas of the audit that are complex, subjective or highly judgmental.
Accounting estimates – this can include fair value accounting estimates, the use of significant assumptions by
management in developing accounting estimates, and reviewing the judgements and decisions used by management for
management bias in developing accounting estimates.
Going concern – the auditor should review management’s assessment of going concern and whether management’s
plans are feasible, this being particularly important where there is a significant doubt over the entity’s ability to
continue as a going concern.
Related party relationships and disclosures – it can be difficult to obtain information on related parties, as knowledge
may be confined to management meaning that the auditor may have to rely on management to identify all related
parties The auditor should also be sceptical when assessing the business rationale behind related party transactions.
Consideration of laws and regulations – the auditor should be alert throughout the audit for indications that there may
have been a suspected non-compliance with laws and regulations.