{"id":"F2009L04096","name":"ASA 580 - Written Representations - October 2009","slug":"asa-580-written-representations-october-2009","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":81687,"registerId":"commonwealth-F2009L04096-current","compilationNumber":null,"startDate":"2026-04-02","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"Obtaining a Copy of this Auditing Standa","sectionType":"section","heading":"Obtaining a Copy of this Auditing Standard","content":"##### Obtaining a Copy of this Auditing Standard\n\nThe most recently compiled versions of Auditing Standards, original Standards and amending Standards (see Compilation Details) are available on the AUASB website: www.auasb.gov.au","sortOrder":0},{"sectionNumber":"Contact Details","sectionType":"section","heading":"Contact Details","content":"##### Contact Details\n\n| Auditing and Assurance Standards BoardLevel 20, 500 Collins StreetMelbourne Victoria 3000AUSTRALIA | Phone: (03) 8080 7400E‑mail: enquiries@auasb.gov.auPostal Address:PO Box 204Collins Street WestMelbourne Victoria 8007AUSTRALIA |\n| -------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------- |","sortOrder":1},{"sectionNumber":"COPYRIGHT","sectionType":"section","heading":"COPYRIGHT","content":"##### COPYRIGHT\n\n© 2023 Commonwealth of Australia. The text, graphics and layout of this Auditing Standard are protected by Australian copyright law and the comparable law of other countries. Reproduction within Australia in unaltered form (retaining this notice) is permitted for personal and non‑commercial use subject to the inclusion of an acknowledgment of the source as being the Australian Auditing and Assurance Standards Board (AUASB).\n\nRequests and enquiries concerning reproduction and rights for commercial purposes within Australia should be addressed to the Technical Director, Auditing and Assurance Standards Board, PO Box 204, Collins Street West, Melbourne, Victoria 8007 or sent to [enquiries@auasb.gov.au](mailto:enquiries@auasb.gov.au). Otherwise, no part of this Auditing Standard may be reproduced, stored or transmitted in any form or by any means without the prior written permission of the AUASB except as permitted by law.\n\nThis Auditing Standard reproduces substantial parts of the corresponding International Standard on Auditing issued by the International Auditing and Assurance Standards Board (IAASB) and published by the International Federation of Accountants (IFAC), in the manner described in the statement on Conformity with International Standards on Auditing. The AUASB acknowledges that IFAC is the owner of copyright in the International Standard on Auditing incorporated in this Auditing Standard throughout the world.\n\nAll existing rights in this material are reserved outside Australia. Reproduction outside Australia in unaltered form (retaining this notice) is permitted for personal and non‑commercial use only.\n\nFurther information and requests for authorisation to reproduce this Auditing Standard for commercial purposes outside Australia should be addressed to the Technical Director, Auditing and Assurance Standards Board, PO Box 204, Collins Street West, Melbourne, Victoria 8007 or sent to [enquiries@auasb.gov.au](mailto:enquiries@auasb.gov.au). Any decision to approve a request may also require the agreement of IFAC.\n\nISSN 1833‑4393","sortOrder":2},{"sectionNumber":"CONTENTS","sectionType":"part","heading":"CONTENTS","content":"# CONTENTS\n\nCOMPILATION DETAILS\n\nAUTHORITY STATEMENT\n\nCONFORMITY WITH INTERNATIONAL STANDARDS ON AUDITING\n\nParagraphs\n\nApplication...............................................Aus 0.1‑Aus 0.2\n\nOperative Date.........................................................Aus 0.3\n\nIntroduction\n\nScope of this Auditing Standard..........................................1‑2\n\nWritten Representations as Audit Evidence..................................3‑4\n\nEffective Date...............................................................5\n\nObjectives..................................................................6\n\nDefinitions.........................................................7‑8\n\nRequirements\n\nManagement from whom Written Representations are Requested..........................9\n\nWritten Representations about Management’s Responsibilities..................10‑12\n\nOther Written Representations...................................................13\n\nDate of and Period(s) Covered by Written Representations..............................14\n\nForm of Written Representations.................................................15\n\nDoubt as to the Reliability of Written Representations and Requested Written Representations Not Provided 16‑20\n\nApplication and Other Explanatory Material\n\nWritten Representations as Audit Evidence.........................................A1\n\nManagement from whom Written Representations are Requested...............A2‑A6\n\nWritten Representations about Management’s Responsibilities.................A7‑A9\n\nOther Written Representations.......................................A10‑A13\n\nCommunicating a Threshold Amount............................................A14\n\nDate of and Period(s) Covered by Written Representations..................A15‑A18\n\nForm of Written Representations.....................................A19‑A21\n\nCommunication with Those Charged with Governance................................A22\n\nDoubt as to the Reliability of Written Representations and Requested Written Representations Not Provided A23‑A27\n\nAppendix 1: List of Australian Auditing Standards Containing Requirements for Written Representations\n\nAppendix 2: Illustrative Representation Letter","sortOrder":3},{"sectionNumber":"COMPILATION DETAILS","sectionType":"part","heading":"COMPILATION DETAILS","content":"##### Obtaining a Copy of this Auditing Standard\n\nThe most recently compiled versions of Auditing Standards, original Standards and amending Standards (see Compilation Details) are available on the AUASB website: www.auasb.gov.au\n\n##### Contact Details\n\n| Auditing and Assurance Standards BoardLevel 20, 500 Collins StreetMelbourne Victoria 3000AUSTRALIA | Phone: (03) 8080 7400E‑mail: enquiries@auasb.gov.auPostal Address:PO Box 204Collins Street WestMelbourne Victoria 8007AUSTRALIA |\n| -------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------- |\n\n##### COPYRIGHT\n\n© 2023 Commonwealth of Australia. The text, graphics and layout of this Auditing Standard are protected by Australian copyright law and the comparable law of other countries. Reproduction within Australia in unaltered form (retaining this notice) is permitted for personal and non‑commercial use subject to the inclusion of an acknowledgment of the source as being the Australian Auditing and Assurance Standards Board (AUASB).\n\nRequests and enquiries concerning reproduction and rights for commercial purposes within Australia should be addressed to the Technical Director, Auditing and Assurance Standards Board, PO Box 204, Collins Street West, Melbourne, Victoria 8007 or sent to [enquiries@auasb.gov.au](mailto:enquiries@auasb.gov.au). Otherwise, no part of this Auditing Standard may be reproduced, stored or transmitted in any form or by any means without the prior written permission of the AUASB except as permitted by law.\n\nThis Auditing Standard reproduces substantial parts of the corresponding International Standard on Auditing issued by the International Auditing and Assurance Standards Board (IAASB) and published by the International Federation of Accountants (IFAC), in the manner described in the statement on Conformity with International Standards on Auditing. The AUASB acknowledges that IFAC is the owner of copyright in the International Standard on Auditing incorporated in this Auditing Standard throughout the world.\n\nAll existing rights in this material are reserved outside Australia. Reproduction outside Australia in unaltered form (retaining this notice) is permitted for personal and non‑commercial use only.\n\nFurther information and requests for authorisation to reproduce this Auditing Standard for commercial purposes outside Australia should be addressed to the Technical Director, Auditing and Assurance Standards Board, PO Box 204, Collins Street West, Melbourne, Victoria 8007 or sent to [enquiries@auasb.gov.au](mailto:enquiries@auasb.gov.au). Any decision to approve a request may also require the agreement of IFAC.\n\nISSN 1833‑4393\n\n# CONTENTS\n\nCOMPILATION DETAILS\n\nAUTHORITY STATEMENT\n\nCONFORMITY WITH INTERNATIONAL STANDARDS ON AUDITING\n\nParagraphs\n\nApplication...............................................Aus 0.1‑Aus 0.2\n\nOperative Date.........................................................Aus 0.3\n\nIntroduction\n\nScope of this Auditing Standard..........................................1‑2\n\nWritten Representations as Audit Evidence..................................3‑4\n\nEffective Date...............................................................5\n\nObjectives..................................................................6\n\nDefinitions.........................................................7‑8\n\nRequirements\n\nManagement from whom Written Representations are Requested..........................9\n\nWritten Representations about Management’s Responsibilities..................10‑12\n\nOther Written Representations...................................................13\n\nDate of and Period(s) Covered by Written Representations..............................14\n\nForm of Written Representations.................................................15\n\nDoubt as to the Reliability of Written Representations and Requested Written Representations Not Provided 16‑20\n\nApplication and Other Explanatory Material\n\nWritten Representations as Audit Evidence.........................................A1\n\nManagement from whom Written Representations are Requested...............A2‑A6\n\nWritten Representations about Management’s Responsibilities.................A7‑A9\n\nOther Written Representations.......................................A10‑A13\n\nCommunicating a Threshold Amount............................................A14\n\nDate of and Period(s) Covered by Written Representations..................A15‑A18\n\nForm of Written Representations.....................................A19‑A21\n\nCommunication with Those Charged with Governance................................A22\n\nDoubt as to the Reliability of Written Representations and Requested Written Representations Not Provided A23‑A27\n\nAppendix 1: List of Australian Auditing Standards Containing Requirements for Written Representations\n\nAppendix 2: Illustrative Representation Letter\n\n  \n\n# COMPILATION DETAILS\n\n### Auditing Standard ASA 580 Written Representations (as Amended)\n\nThis compilation takes into account amendments made up to and including 15 March 2023 and was prepared on 22 March 2023 by the Auditing and Assurance Standards Board (AUASB).\n\nThis compilation is not a separate Auditing Standard made by the AUASB. Instead, it is a representation of ASA 580 (October 2009) as amended by other Auditing Standards which are listed in the Table below.\n\n##### Table of Standards\n\n| Standard       | Date made       | Operative Date                                                                                         |\n| -------------- | --------------- | ------------------------------------------------------------------------------------------------------ |\n| ASA 580 [A]    | 27 October 2009 | Financial reporting periods commencing on or after 1 January 2010                                      |\n| ASA 2011‑1 [B] | 27 June 2011    | Financial reporting periods commencing on or after 1 July 2011                                         |\n| ASA 2013‑3 [C] | 1 July 2013     | Financial reporting periods commencing on or after 1 July 2013                                         |\n| ASA 2015‑1 [D] | 1 December 2015 | Financial reporting periods ending on or after 15 December 2016                                        |\n| ASA 2018-1 [E] | 5 December 2018 | Financial reporting periods commencing on or after 15 December 2019, with early adoption permitted[*]. |\n| ASA 2023-1 [F] | 15 March 2023   | Financial reporting periods commencing on or after 1 January 2023                                      |\n\n\\[A\\] Federal Register of Legislation – registration number F2009L04096, 13 November 2009\n\n\\[B\\] Federal Register of Legislation – registration number F2011L01379, 30 June 2011\n\n\\[C\\] Federal Register of Legislation – registration number F2013L01939, 14 November 2013\n\n\\[D\\] Federal Register of Legislation – registration number F2015L02032, 16 December 2015\n\n\\[E\\] Federal Register of Legislation – registration number F2019L00016, 3 January 2019\n\n\\[F\\] Federal Register of Legislation – registration number F2023L00295, 21 March 2023  \n\n##### Table of Amendments\n\n| Paragraph affected                                                                     | How affected | By … [paragraph]      |\n| -------------------------------------------------------------------------------------- | ------------ | --------------------- |\n| Appendix 2                                                                             | Amended      | ASA 2011‑1 [50]       |\n| Appendix 2Footnote 10                                                                  | Addition     | ASA 2011‑1 [51]       |\n| Appendix 2                                                                             | Amended      | ASA 2011‑1 [52]       |\n| Appendix 2                                                                             | Amended      | ASA 2011‑1 [53]       |\n| Appendix 2                                                                             | Addition     | ASA 2011‑1 [54]       |\n| Appendix 2                                                                             | Addition     | ASA 2011‑1 [55]       |\n| Appendix 1                                                                             | Amended      | ASA 2011‑1 [55]       |\n| Appendix 1                                                                             | Amended      | ASA 2013‑3 [14]       |\n| A1 directly below heading “Management from whom Written Representations are Requested” | Renumbered   | ASA 2015‑1 [168]      |\n| Aus A20.1                                                                              | Deleted      | ASA 2015‑1 [169]      |\n| 10                                                                                     | Amended      | ASA 2015-1 [169]      |\n| Appendix 1                                                                             | Amended      | ASA 2015‑1 [170-171]  |\n| Appendix 2                                                                             | Amended      | ASA 2015‑1 [167, 172] |\n| Appendix 1                                                                             | Amended      | ASA 2018-1 [54]       |\n| Appendix 2                                                                             | Amended      | ASA 2018-1 [55]       |\n| Appendix 1                                                                             | Amended      | ASA 2023-1 [24]       |\n\n  \n\n## AUTHORITY STATEMENT\n\nAuditing Standard ASA 580 Written Representations (as amended to 15 March 2023) is set out in paragraphs Aus 0.1 to A27 and Appendices 1 and 2.\n\nThis Auditing Standard is to be read in conjunction with ASA 101 Preamble to AUASB Standards, which sets out how AUASB Standards are to be understood, interpreted and applied. This Auditing Standard is to be read also in conjunction with ASA 200 Overall Objectives of the Independent Auditor and the Conduct of an Audit in Accordance with Australian Auditing Standards.\n\n##### Conformity with International Standards on Auditing\n\nThis Auditing Standard conforms with International Standard on Auditing ISA 580 Written Representations issued by the International Auditing and Assurance Standards Board (IAASB), an independent standard‑setting board of the International Federation of Accountants (IFAC).\n\nParagraphs that have been added to this Auditing Standard (and do not appear in the text of the equivalent ISA) are identified with the prefix “Aus”.\n\nCompliance with this Auditing Standard enables compliance with ISA 580.","sortOrder":4},{"sectionNumber":"Auditing Standard ASA 580 Written Repres","sectionType":"division","heading":"Auditing Standard ASA 580 Written Representations (as Amended)","content":"### Auditing Standard ASA 580 Written Representations (as Amended)\n\nThis compilation takes into account amendments made up to and including 15 March 2023 and was prepared on 22 March 2023 by the Auditing and Assurance Standards Board (AUASB).\n\nThis compilation is not a separate Auditing Standard made by the AUASB. Instead, it is a representation of ASA 580 (October 2009) as amended by other Auditing Standards which are listed in the Table below.","sortOrder":5},{"sectionNumber":"Table of Standards","sectionType":"section","heading":"Table of Standards","content":"##### Table of Standards\n\n| Standard       | Date made       | Operative Date                                                                                         |\n| -------------- | --------------- | ------------------------------------------------------------------------------------------------------ |\n| ASA 580 [A]    | 27 October 2009 | Financial reporting periods commencing on or after 1 January 2010                                      |\n| ASA 2011‑1 [B] | 27 June 2011    | Financial reporting periods commencing on or after 1 July 2011                                         |\n| ASA 2013‑3 [C] | 1 July 2013     | Financial reporting periods commencing on or after 1 July 2013                                         |\n| ASA 2015‑1 [D] | 1 December 2015 | Financial reporting periods ending on or after 15 December 2016                                        |\n| ASA 2018-1 [E] | 5 December 2018 | Financial reporting periods commencing on or after 15 December 2019, with early adoption permitted[*]. |\n| ASA 2023-1 [F] | 15 March 2023   | Financial reporting periods commencing on or after 1 January 2023                                      |\n\n\\[A\\] Federal Register of Legislation – registration number F2009L04096, 13 November 2009\n\n\\[B\\] Federal Register of Legislation – registration number F2011L01379, 30 June 2011\n\n\\[C\\] Federal Register of Legislation – registration number F2013L01939, 14 November 2013\n\n\\[D\\] Federal Register of Legislation – registration number F2015L02032, 16 December 2015\n\n\\[E\\] Federal Register of Legislation – registration number F2019L00016, 3 January 2019\n\n\\[F\\] Federal Register of Legislation – registration number F2023L00295, 21 March 2023","sortOrder":6},{"sectionNumber":"Table of Amendments","sectionType":"section","heading":"Table of Amendments","content":"##### Table of Amendments\n\n| Paragraph affected                                                                     | How affected | By … [paragraph]      |\n| -------------------------------------------------------------------------------------- | ------------ | --------------------- |\n| Appendix 2                                                                             | Amended      | ASA 2011‑1 [50]       |\n| Appendix 2Footnote 10                                                                  | Addition     | ASA 2011‑1 [51]       |\n| Appendix 2                                                                             | Amended      | ASA 2011‑1 [52]       |\n| Appendix 2                                                                             | Amended      | ASA 2011‑1 [53]       |\n| Appendix 2                                                                             | Addition     | ASA 2011‑1 [54]       |\n| Appendix 2                                                                             | Addition     | ASA 2011‑1 [55]       |\n| Appendix 1                                                                             | Amended      | ASA 2011‑1 [55]       |\n| Appendix 1                                                                             | Amended      | ASA 2013‑3 [14]       |\n| A1 directly below heading “Management from whom Written Representations are Requested” | Renumbered   | ASA 2015‑1 [168]      |\n| Aus A20.1                                                                              | Deleted      | ASA 2015‑1 [169]      |\n| 10                                                                                     | Amended      | ASA 2015-1 [169]      |\n| Appendix 1                                                                             | Amended      | ASA 2015‑1 [170-171]  |\n| Appendix 2                                                                             | Amended      | ASA 2015‑1 [167, 172] |\n| Appendix 1                                                                             | Amended      | ASA 2018-1 [54]       |\n| Appendix 2                                                                             | Amended      | ASA 2018-1 [55]       |\n| Appendix 1                                                                             | Amended      | ASA 2023-1 [24]       |\n\n  \n\n## AUTHORITY STATEMENT\n\nAuditing Standard ASA 580 Written Representations (as amended to 15 March 2023) is set out in paragraphs Aus 0.1 to A27 and Appendices 1 and 2.\n\nThis Auditing Standard is to be read in conjunction with ASA 101 Preamble to AUASB Standards, which sets out how AUASB Standards are to be understood, interpreted and applied. This Auditing Standard is to be read also in conjunction with ASA 200 Overall Objectives of the Independent Auditor and the Conduct of an Audit in Accordance with Australian Auditing Standards.\n\n##### Conformity with International Standards on Auditing\n\nThis Auditing Standard conforms with International Standard on Auditing ISA 580 Written Representations issued by the International Auditing and Assurance Standards Board (IAASB), an independent standard‑setting board of the International Federation of Accountants (IFAC).\n\nParagraphs that have been added to this Auditing Standard (and do not appear in the text of the equivalent ISA) are identified with the prefix “Aus”.\n\nCompliance with this Auditing Standard enables compliance with ISA 580.","sortOrder":7},{"sectionNumber":"AUTHORITY STATEMENT","sectionType":"part","heading":"AUTHORITY STATEMENT","content":"## AUTHORITY STATEMENT\n\nAuditing Standard ASA 580 Written Representations (as amended to 15 March 2023) is set out in paragraphs Aus 0.1 to A27 and Appendices 1 and 2.\n\nThis Auditing Standard is to be read in conjunction with ASA 101 Preamble to AUASB Standards, which sets out how AUASB Standards are to be understood, interpreted and applied. This Auditing Standard is to be read also in conjunction with ASA 200 Overall Objectives of the Independent Auditor and the Conduct of an Audit in Accordance with Australian Auditing Standards.","sortOrder":8},{"sectionNumber":"Conformity with International Standards ","sectionType":"section","heading":"Conformity with International Standards on Auditing","content":"##### Conformity with International Standards on Auditing\n\nThis Auditing Standard conforms with International Standard on Auditing ISA 580 Written Representations issued by the International Auditing and Assurance Standards Board (IAASB), an independent standard‑setting board of the International Federation of Accountants (IFAC).\n\nParagraphs that have been added to this Auditing Standard (and do not appear in the text of the equivalent ISA) are identified with the prefix “Aus”.\n\nCompliance with this Auditing Standard enables compliance with ISA 580.","sortOrder":9},{"sectionNumber":"Auditing Standard ASA 580","sectionType":"part","heading":"Auditing Standard ASA 580","content":"Auditing Standard ASA 580\n\nThe Auditing and Assurance Standards Board (AUASB) made Auditing Standard ASA 580 Written Representations pursuant to section 227B of the Australian Securities and Investments Commission Act 2001 and section 336 of the Corporations Act 2001, on 27 October 2009.\n\nThis compiled version of ASA 580 incorporates subsequent amendments contained in other Auditing Standards made by the AUASB up to and including 15 March 2023 (see Compilation Details).\n\n## Auditing Standard ASA 580\n\n### Written Representations\n\n##### Application\n\nAus 0.1 This Auditing Standard applies to:\n\n(a) an audit of a financial report for a financial year, or an audit of a financial report for a half‑year, in accordance with the Corporations Act 2001; and\n\n(b) an audit of a financial report, or a complete set of financial statements, for any other purpose.\n\nAus 0.2 This Auditing Standard also applies, as appropriate, to an audit of other historical financial information.\n\n##### Operative Date\n\nAus 0.3 This Auditing Standard is operative for financial reporting periods commencing on or after 1 January 2010. \\[Note: For operative dates of paragraphs changed or added by an Amending Standard, see Compilation Details.\\]\n\n##### Introduction\n\n###### Scope of this Auditing Standard\n\n1.  This Auditing Standard deals with the auditor’s responsibility to obtain written representations from management and, where appropriate, those charged with governance in an audit of a financial report.\n2.  Appendix 1 lists other Australian Auditing Standards containing subject‑matter specific requirements for written representations. The specific requirements for written representations of other Australian Auditing Standards do not limit the application of this Auditing Standard.\n\n###### Written Representations as Audit Evidence\n\n1.  Audit evidence is the information used by the auditor in arriving at the conclusions on which the auditor’s opinion is based.[\\[1\\]](#_ftn2) Written representations are necessary information that the auditor requires in connection with the audit of the entity’s financial report. Accordingly, similar to responses to enquiries, written representations are audit evidence. (Ref: Para. A1)\n2.  Although written representations provide necessary audit evidence, they do not provide sufficient appropriate audit evidence on their own about any of the matters with which they deal. Furthermore, the fact that management has provided reliable written representations does not affect the nature or extent of other audit evidence that the auditor obtains about the fulfilment of management’s responsibilities, or about specific assertions.\n\n###### Effective Date\n\n1.  \\[Deleted by the AUASB. Refer Aus 0.3\\]\n\n##### Objectives\n\n1.  The objectives of the auditor are:\n    1.  To obtain written representations from management and, where appropriate, those charged with governance that they believe that they have fulfilled their responsibility for the preparation of the financial report and for the completeness of the information provided to the auditor;\n    2.  To support other audit evidence relevant to the financial report or specific assertions in the financial report by means of written representations if determined necessary by the auditor or required by other Australian Auditing Standards; and\n    3.  To respond appropriately to written representations provided by management and, where appropriate, those charged with governance, or if management or, where appropriate, those charged with governance do not provide the written representations requested by the auditor.\n\n##### Definitions\n\n1.  For the purposes of this Auditing Standard, the following terms have the meanings attributed below:\n\nWritten representation means a written statement by management provided to the auditor to confirm certain matters or to support other audit evidence. Written representations in this context do not include the financial report, the assertions therein, or supporting books and records.\n\n1.  For purposes of this Auditing Standard, references to “management” should be read as “management and, where appropriate, those charged with governance.” Furthermore, in the case of a fair presentation framework, management is responsible for the preparation and fair presentation of the financial report in accordance with the applicable financial reporting framework; or the preparation of a financial report that gives a true and fair view in accordance with the applicable financial reporting framework.\n\n##### Requirements\n\n###### Management from whom Written Representations are Requested\n\n1.  The auditor shall request written representations from management with appropriate responsibilities for the financial report and knowledge of the matters concerned. (Ref: Para. A2‑A6)\n\n###### Written Representations about Management’s Responsibilities\n\nPreparation of the Financial report\n\n1.  The auditor shall request management to provide a written representation that it has fulfilled its responsibility for the preparation of the financial report in accordance with the applicable financial reporting framework, and other statutory reporting requirements, including where relevant their fair presentation, as set out in the terms of the audit engagement.[\\[2\\]](#_ftn3) (Ref: Para. A7‑A9, A14, A22)\n\nInformation Provided and Completeness of Transactions\n\n1.  The auditor shall request management to provide a written representation that:\n    1.  It has provided the auditor with all relevant information and access as agreed in the terms of the audit engagement;[\\[3\\]](#_ftn4) and\n    2.  All transactions have been recorded and are reflected in the financial report. (Ref: Para. A7‑A9, A14, A22)\n\nDescription of Management’s Responsibilities in the Written Representations\n\n1.  Management’s responsibilities shall be described in the written representations required by paragraphs 10 and 11 of this Auditing Standard in the manner in which these responsibilities are described in the terms of the audit engagement.\n\n###### Other Written Representations\n\n1.  Other Auditing Standards require the auditor to request written representations. If, in addition to such required representations, the auditor determines that it is necessary to obtain one or more written representations to support other audit evidence relevant to the financial report or one or more specific assertions in the financial report, the auditor shall request such other written representations. (Ref: Para. A10‑A14, A22)\n\n###### Date of and Period(s) Covered by Written Representations\n\n1.  The date of the written representations shall be as near as practicable to, but not after, the date of the auditor’s report on the financial report. The written representations shall be for all the financial report(s) and period(s) referred to in the auditor’s report. (Ref: Para. A15‑A18)\n\n###### Form of Written Representations\n\n1.  The written representations shall be in the form of a representation letter addressed to the auditor. If law or regulation requires management to make written public statements about its responsibilities, and the auditor determines that such statements provide some or all of the representations required by paragraphs 10 or 11 of this Auditing Standard, the relevant matters covered by such statements need not be included in the representation letter. (Ref: Para. A19‑A21)\n\n###### Doubt as to the Reliability of Written Representations and Requested Written Representations Not Provided\n\nDoubt as to the Reliability of Written Representations\n\n1.  If the auditor has concerns about the competence, integrity, ethical values or diligence of management, or about its commitment to or enforcement of these, the auditor shall determine the effect that such concerns may have on the reliability of representations (oral or written) and audit evidence in general. (Ref: Para. A24‑A25)\n2.  In particular, if written representations are inconsistent with other audit evidence, the auditor shall perform audit procedures to attempt to resolve the matter. If the matter remains unresolved, the auditor shall reconsider the assessment of the competence, integrity, ethical values or diligence of management, or of its commitment to or enforcement of these, and shall determine the effect that this may have on the reliability of representations (oral or written) and audit evidence in general. (Ref: Para. A23)\n3.  If the auditor concludes that the written representations are not reliable, the auditor shall take appropriate actions, including determining the possible effect on the opinion in the auditor’s report in accordance with ASA 705,[\\[4\\]](#_ftn5) having regard to the requirement in paragraph 20 of this Auditing Standard.\n\nRequested Written Representations Not Provided\n\n1.  If management does not provide one or more of the requested written representations, the auditor shall:\n    1.  Discuss the matter with management;\n    2.  Re‑evaluate the integrity of management and evaluate the effect that this may have on the reliability of representations (oral or written) and audit evidence in general; and\n    3.  Take appropriate actions, including determining the possible effect on the opinion in the auditor’s report in accordance with ASA 705, having regard to the requirement in paragraph 20 of this Auditing Standard.\n\nWritten Representations about Management’s Responsibilities\n\n1.  The auditor shall disclaim an opinion on the financial report in accordance with ASA 705 if:\n    1.  The auditor concludes that there is sufficient doubt about the integrity of management such that the written representations required by paragraphs 10 and 11 of this Auditing Standard are not reliable; or\n    2.  Management does not provide the written representations required by paragraphs 10 and 11 of this Auditing Standard. (Ref: Para. A26‑A27)\n\n\\* \\* \\*\n\n##### Application and Other Explanatory Material\n\n###### Written Representations as Audit Evidence (Ref: Para. 3)\n\n1.  Written representations are an important source of audit evidence. If management modifies or does not provide the requested written representations, it may alert the auditor to the possibility that one or more significant issues may exist. Further, a request for written, rather than oral, representations in many cases may prompt management to consider such matters more rigorously, thereby enhancing the quality of the representations.\n\n###### Management from whom Written Representations are Requested (Ref: Para. 9)\n\n1.  Written representations are requested from those responsible for the preparation of the financial report. Those individuals may vary depending on the governance structure of the entity, and relevant law or regulation; however, management (rather than those charged with governance) is often the responsible party. Written representations may therefore be requested from the entity’s chief executive officer and chief financial officer, or other equivalent persons in entities that do not use such titles. In some circumstances, however, other parties, such as those charged with governance, are also responsible for the preparation of the financial report.\n2.  Due to its responsibility for the preparation of the financial report, and its responsibilities for the conduct of the entity’s business, management would be expected to have sufficient knowledge of the process followed by the entity in preparing and presenting the financial report and the assertions therein on which to base the written representations.\n3.  In some cases, however, management may decide to make enquiries of others who participate in preparing and presenting the financial report and assertions therein, including individuals who have specialised knowledge relating to the matters about which written representations are requested. Such individuals may include:\n\n-   An actuary responsible for actuarially determined accounting measurements.\n-   Staff engineers who may have responsibility for and specialised knowledge about environmental liability measurements.\n-   Internal counsel who may provide information essential to provisions for legal claims.\n\n1.  In some cases, management may include in the written representations qualifying language to the effect that representations are made to the best of its knowledge and belief. It is reasonable for the auditor to accept such wording if the auditor is satisfied that the representations are being made by those with appropriate responsibilities and knowledge of the matters included in the representations.\n2.  To reinforce the need for management to make informed representations, the auditor may request that management include in the written representations confirmation that it has made such enquiries as it considered appropriate to place it in the position to be able to make the requested written representations. It is not expected that such enquiries would usually require a formal internal process beyond those already established by the entity.\n\n###### Written Representations about Management’s Responsibilities (Ref: Para. 10‑11)\n\n1.  Audit evidence obtained during the audit that management has fulfilled the responsibilities referred to in paragraphs 10 and 11 is not sufficient without obtaining confirmation from management that it believes that it has fulfilled those responsibilities. This is because the auditor is not able to judge solely on other audit evidence whether management has prepared and presented the financial report and provided information to the auditor on the basis of the agreed acknowledgement and understanding of its responsibilities. For example, the auditor could not conclude that management has provided the auditor with all relevant information agreed in the terms of the audit engagement without asking it whether, and receiving confirmation that, such information has been provided.\n2.  The written representations required by paragraphs 10 and 11 draw on the agreed acknowledgement and understanding of management of its responsibilities in the terms of the audit engagement by requesting confirmation that it has fulfilled them. The auditor may also ask management to reconfirm its acknowledgement and understanding of those responsibilities in written representations. This is common in certain jurisdictions, but in any event may be particularly appropriate when:\n\n-   Those who signed the terms of the audit engagement on behalf of the entity no longer have the relevant responsibilities;\n-   The terms of the audit engagement were prepared in a previous year;\n-   There is any indication that management misunderstands those responsibilities; or\n-   Changes in circumstances make it appropriate to do so.\n-   Consistent with the requirement of ASA 210,[\\[5\\]](#_ftn6) such reconfirmation of management’s acknowledgement and understanding of its responsibilities is not made subject to the best of management’s knowledge and belief (as discussed in paragraph A5).\n\nConsiderations Specific to Public Sector Entities\n\n1.  The mandates for audits of financial reports of public sector entities may be broader than those of other entities. As a result, the premise, relating to management’s responsibilities, on which an audit of the financial report of a public sector entity is conducted may give rise to additional written representations. These may include written representations confirming that transactions and events have been carried out in accordance with law, regulation or other authority.\n\n###### Other Written Representations (Ref: Para. 13)\n\nAdditional Written Representations about the Financial Report\n\n1.  In addition to the written representation required by paragraph 10, the auditor may consider it necessary to request other written representations about the financial report. Such written representations may supplement, but do not form part of, the written representation required by paragraph 10. They may include representations about the following:\n\n-   Whether the selection and application of accounting policies are appropriate; and\n-   Whether matters such as the following, where relevant under the applicable financial reporting framework, have been recognised, measured, presented or disclosed in accordance with that framework:\n    -   Plans or intentions that may affect the carrying value or classification of assets and liabilities;\n    -   Liabilities, both actual and contingent;\n    -   Title to, or control over, assets, the liens or encumbrances on assets, and assets pledged as collateral; and\n    -   Aspects of laws, regulations and contractual agreements that may affect the financial report, including non‑compliance.\n\nAdditional Written Representations about Information Provided to the Auditor\n\n1.  In addition to the written representation required by paragraph 11, the auditor may consider it necessary to request management to provide a written representation that it has communicated to the auditor all deficiencies in internal control of which management is aware.\n\nWritten Representations about Specific Assertions\n\n1.  When obtaining evidence about, or evaluating, judgements and intentions, the auditor may consider one or more of the following:\n\n-   The entity’s past history in carrying out its stated intentions.\n-   The entity’s reasons for choosing a particular course of action.\n-   The entity’s ability to pursue a specific course of action.\n-   The existence or lack of any other information that might have been obtained during the course of the audit that may be inconsistent with management’s judgement or intent.\n\n1.  In addition, the auditor may consider it necessary to request management to provide written representations about specific assertions in the financial report; in particular, to support an understanding that the auditor has obtained from other audit evidence of management’s judgement or intent in relation to, or the completeness of, a specific assertion. For example, if the intent of management is important to the valuation basis for investments, it may not be possible to obtain sufficient appropriate audit evidence without a written representation from management about its intentions. Although such written representations provide necessary audit evidence, they do not provide sufficient appropriate audit evidence on their own for that assertion.\n\n###### Communicating a Threshold Amount (Ref: Para. 10‑11, 13)\n\n1.  ASA 450 requires the auditor to accumulate misstatements identified during the audit, other than those that are clearly trivial.[\\[6\\]](#_ftn7) The auditor may determine a threshold above which misstatements cannot be regarded as clearly trivial. In the same way, the auditor may consider communicating to management a threshold for purposes of the requested written representations.\n\n###### Date of and Period(s) Covered by Written Representations (Ref: Para. 14)\n\n1.  Because written representations are necessary audit evidence, the auditor’s opinion cannot be expressed, and the auditor’s report cannot be dated, before the date of the written representations. Furthermore, because the auditor is concerned with events occurring up to the date of the auditor’s report that may require adjustment to or disclosure in the financial report, the written representations are dated as near as practicable to, but not after, the date of the auditor’s report on the financial report.\n2.  In some circumstances, it may be appropriate for the auditor to obtain a written representation about a specific assertion in the financial report during the course of the audit. Where this is the case, it may be necessary to request an updated written representation.\n3.  The written representations are for all periods referred to in the auditor’s report because management needs to reaffirm that the written representations it previously made with respect to the prior periods remain appropriate. The auditor and management may agree to a form of written representation that updates written representations relating to the prior periods by addressing whether there are any changes to such written representations and, if so, what they are.\n4.  Situations may arise where current management were not present during all periods referred to in the auditor’s report. Such persons may assert that they are not in a position to provide some or all of the written representations because they were not in place during the period. This fact, however, does not diminish such persons’ responsibilities for the financial report as a whole. Accordingly, the requirement for the auditor to request from them written representations that cover the whole of the relevant period(s) still applies.\n\n###### Form of Written Representations (Ref: Para. 15)\n\n1.  Written representations are required to be included in a representation letter addressed to the auditor. In some jurisdictions, however, management may be required by law or regulation to make a written public statement about its responsibilities. Although such a statement is a representation to the users of the financial report, or to relevant authorities, the auditor may determine that it is an appropriate form of written representation in respect of some or all of the representations required by paragraph 10 or 11. Consequently, the relevant matters covered by such a statement need not be included in the representation letter. Factors that may affect the auditor’s determination include:\n\n-   Whether the statement includes confirmation of the fulfilment of the responsibilities referred to in paragraphs 10 and 11.\n-   Whether the statement has been given or approved by those from whom the auditor requests the relevant written representations.\n-   Whether a copy of the statement is provided to the auditor as near as practicable to, but not after, the date of the auditor’s report on the financial report (see paragraph 14).\n\n1.  A formal statement of compliance with law or regulation, or of approval of the financial report, would not contain sufficient information for the auditor to be satisfied that all necessary representations have been consciously made. The expression of management’s responsibilities in law or regulation is also not a substitute for the requested written representations.\n2.  Appendix 2 provides an illustrative example of a representation letter.\n\n###### Communication with Those Charged with Governance (Ref: Para. 10‑11, 13)\n\n1.  ASA 260 requires the auditor to communicate with those charged with governance the written representations which the auditor has requested from management.[\\[7\\]](#_ftn8)\n\n###### Doubt as to the Reliability of Written Representations and Requested Written Representations Not Provided\n\nDoubt as to the Reliability of Written Representations (Ref: Para. 16‑17)\n\n1.  In the case of identified inconsistencies between one or more written representations and audit evidence obtained from another source, the auditor may consider whether the risk assessment remains appropriate and, if not, revise the risk assessment and determine the nature, timing and extent of further audit procedures to respond to the assessed risks.\n2.  Concerns about the competence, integrity, ethical values or diligence of management, or about its commitment to or enforcement of these, may cause the auditor to conclude that the risk of management misrepresentation in the financial report is such that an audit cannot be conducted. In such a case, the auditor may consider withdrawing from the engagement, where withdrawal is possible under applicable law or regulation, unless those charged with governance put in place appropriate corrective measures. Such measures, however, may not be sufficient to enable the auditor to issue an unmodified audit opinion.\n3.  ASA 230 requires the auditor to document significant matters arising during the audit, the conclusions reached thereon, and significant professional judgements made in reaching those conclusions.[\\[8\\]](#_ftn9) The auditor may have identified significant issues relating to the competence, integrity, ethical values or diligence of management, or about its commitment to or enforcement of these, but concluded that the written representations are nevertheless reliable. In such a case, this significant matter is documented in accordance with ASA 230.\n\nWritten Representations about Management’s Responsibilities (Ref: Para. 20)\n\n1.  As explained in paragraph A7, the auditor is not able to judge solely on other audit evidence whether management has fulfilled the responsibilities referred to in paragraphs 10 and 11. Therefore, if, as described in paragraph 20(a), the auditor concludes that the written representations about these matters are unreliable, or if management does not provide those written representations, the auditor is unable to obtain sufficient appropriate audit evidence. The possible effects on the financial report of such inability are not confined to specific elements, accounts or items of the financial report and are hence pervasive. ASA 705 requires the auditor to disclaim an opinion on the financial report in such circumstances.[\\[9\\]](#_ftn10)\n\nIf Management do not Provide Written Representations\n\nAus A26.1 If management do not provide written representations, the auditor would ordinarily:\n\n(a) draw to the attention of those charged with governance any relevant regulatory requirements which give the auditor a right of access to any requested information, explanations or assistance for the purposes of the audit;[\\[\\*\\]](#_ftn11)\n\n(b) consider any other implications of the refusal that may have any effect on the auditor’s report;[\\[#\\]](#_ftn12) and\n\n(c) consider whether the auditor has any regulatory obligation to report that management has not provided a written representation.[\\[†\\]](#_ftn13)\n\n1.  A written representation that has been modified from that requested by the auditor does not necessarily mean that management did not provide the written representation. However, the underlying reason for such modification may affect the opinion in the auditor’s report. For example:\n\n-   The written representation about management’s fulfilment of its responsibility for the preparation of the financial report may state that management believes that, except for material non‑compliance with a particular requirement of the applicable financial reporting framework, the financial report is prepared in accordance with that framework. The requirement in paragraph 20 does not apply because the auditor concluded that management has provided reliable written representations. However, the auditor is required to consider the effect of the non‑compliance on the opinion in the auditor’s report in accordance with ASA 705.\n-   The written representation about the responsibility of management to provide the auditor with all relevant information agreed in the terms of the audit engagement may state that management believes that, except for information destroyed in a fire, it has provided the auditor with such information. The requirement in paragraph 20 does not apply because the auditor concluded that management has provided reliable written representations. However, the auditor is required to consider the effects of the pervasiveness of the information destroyed in the fire on the financial report and the effect thereof on the opinion in the auditor’s report in accordance with ASA 705.","sortOrder":10},{"sectionNumber":"Written Representations","sectionType":"division","heading":"Written Representations","content":"Auditing Standard ASA 580\n\nThe Auditing and Assurance Standards Board (AUASB) made Auditing Standard ASA 580 Written Representations pursuant to section 227B of the Australian Securities and Investments Commission Act 2001 and section 336 of the Corporations Act 2001, on 27 October 2009.\n\nThis compiled version of ASA 580 incorporates subsequent amendments contained in other Auditing Standards made by the AUASB up to and including 15 March 2023 (see Compilation Details).\n\n## Auditing Standard ASA 580\n\n### Written Representations\n\n##### Application\n\nAus 0.1 This Auditing Standard applies to:\n\n(a) an audit of a financial report for a financial year, or an audit of a financial report for a half‑year, in accordance with the Corporations Act 2001; and\n\n(b) an audit of a financial report, or a complete set of financial statements, for any other purpose.\n\nAus 0.2 This Auditing Standard also applies, as appropriate, to an audit of other historical financial information.\n\n##### Operative Date\n\nAus 0.3 This Auditing Standard is operative for financial reporting periods commencing on or after 1 January 2010. \\[Note: For operative dates of paragraphs changed or added by an Amending Standard, see Compilation Details.\\]\n\n##### Introduction\n\n###### Scope of this Auditing Standard\n\n1.  This Auditing Standard deals with the auditor’s responsibility to obtain written representations from management and, where appropriate, those charged with governance in an audit of a financial report.\n2.  Appendix 1 lists other Australian Auditing Standards containing subject‑matter specific requirements for written representations. The specific requirements for written representations of other Australian Auditing Standards do not limit the application of this Auditing Standard.\n\n###### Written Representations as Audit Evidence\n\n1.  Audit evidence is the information used by the auditor in arriving at the conclusions on which the auditor’s opinion is based.[\\[1\\]](#_ftn2) Written representations are necessary information that the auditor requires in connection with the audit of the entity’s financial report. Accordingly, similar to responses to enquiries, written representations are audit evidence. (Ref: Para. A1)\n2.  Although written representations provide necessary audit evidence, they do not provide sufficient appropriate audit evidence on their own about any of the matters with which they deal. Furthermore, the fact that management has provided reliable written representations does not affect the nature or extent of other audit evidence that the auditor obtains about the fulfilment of management’s responsibilities, or about specific assertions.\n\n###### Effective Date\n\n1.  \\[Deleted by the AUASB. Refer Aus 0.3\\]\n\n##### Objectives\n\n1.  The objectives of the auditor are:\n    1.  To obtain written representations from management and, where appropriate, those charged with governance that they believe that they have fulfilled their responsibility for the preparation of the financial report and for the completeness of the information provided to the auditor;\n    2.  To support other audit evidence relevant to the financial report or specific assertions in the financial report by means of written representations if determined necessary by the auditor or required by other Australian Auditing Standards; and\n    3.  To respond appropriately to written representations provided by management and, where appropriate, those charged with governance, or if management or, where appropriate, those charged with governance do not provide the written representations requested by the auditor.\n\n##### Definitions\n\n1.  For the purposes of this Auditing Standard, the following terms have the meanings attributed below:\n\nWritten representation means a written statement by management provided to the auditor to confirm certain matters or to support other audit evidence. Written representations in this context do not include the financial report, the assertions therein, or supporting books and records.\n\n1.  For purposes of this Auditing Standard, references to “management” should be read as “management and, where appropriate, those charged with governance.” Furthermore, in the case of a fair presentation framework, management is responsible for the preparation and fair presentation of the financial report in accordance with the applicable financial reporting framework; or the preparation of a financial report that gives a true and fair view in accordance with the applicable financial reporting framework.\n\n##### Requirements\n\n###### Management from whom Written Representations are Requested\n\n1.  The auditor shall request written representations from management with appropriate responsibilities for the financial report and knowledge of the matters concerned. (Ref: Para. A2‑A6)\n\n###### Written Representations about Management’s Responsibilities\n\nPreparation of the Financial report\n\n1.  The auditor shall request management to provide a written representation that it has fulfilled its responsibility for the preparation of the financial report in accordance with the applicable financial reporting framework, and other statutory reporting requirements, including where relevant their fair presentation, as set out in the terms of the audit engagement.[\\[2\\]](#_ftn3) (Ref: Para. A7‑A9, A14, A22)\n\nInformation Provided and Completeness of Transactions\n\n1.  The auditor shall request management to provide a written representation that:\n    1.  It has provided the auditor with all relevant information and access as agreed in the terms of the audit engagement;[\\[3\\]](#_ftn4) and\n    2.  All transactions have been recorded and are reflected in the financial report. (Ref: Para. A7‑A9, A14, A22)\n\nDescription of Management’s Responsibilities in the Written Representations\n\n1.  Management’s responsibilities shall be described in the written representations required by paragraphs 10 and 11 of this Auditing Standard in the manner in which these responsibilities are described in the terms of the audit engagement.\n\n###### Other Written Representations\n\n1.  Other Auditing Standards require the auditor to request written representations. If, in addition to such required representations, the auditor determines that it is necessary to obtain one or more written representations to support other audit evidence relevant to the financial report or one or more specific assertions in the financial report, the auditor shall request such other written representations. (Ref: Para. A10‑A14, A22)\n\n###### Date of and Period(s) Covered by Written Representations\n\n1.  The date of the written representations shall be as near as practicable to, but not after, the date of the auditor’s report on the financial report. The written representations shall be for all the financial report(s) and period(s) referred to in the auditor’s report. (Ref: Para. A15‑A18)\n\n###### Form of Written Representations\n\n1.  The written representations shall be in the form of a representation letter addressed to the auditor. If law or regulation requires management to make written public statements about its responsibilities, and the auditor determines that such statements provide some or all of the representations required by paragraphs 10 or 11 of this Auditing Standard, the relevant matters covered by such statements need not be included in the representation letter. (Ref: Para. A19‑A21)\n\n###### Doubt as to the Reliability of Written Representations and Requested Written Representations Not Provided\n\nDoubt as to the Reliability of Written Representations\n\n1.  If the auditor has concerns about the competence, integrity, ethical values or diligence of management, or about its commitment to or enforcement of these, the auditor shall determine the effect that such concerns may have on the reliability of representations (oral or written) and audit evidence in general. (Ref: Para. A24‑A25)\n2.  In particular, if written representations are inconsistent with other audit evidence, the auditor shall perform audit procedures to attempt to resolve the matter. If the matter remains unresolved, the auditor shall reconsider the assessment of the competence, integrity, ethical values or diligence of management, or of its commitment to or enforcement of these, and shall determine the effect that this may have on the reliability of representations (oral or written) and audit evidence in general. (Ref: Para. A23)\n3.  If the auditor concludes that the written representations are not reliable, the auditor shall take appropriate actions, including determining the possible effect on the opinion in the auditor’s report in accordance with ASA 705,[\\[4\\]](#_ftn5) having regard to the requirement in paragraph 20 of this Auditing Standard.\n\nRequested Written Representations Not Provided\n\n1.  If management does not provide one or more of the requested written representations, the auditor shall:\n    1.  Discuss the matter with management;\n    2.  Re‑evaluate the integrity of management and evaluate the effect that this may have on the reliability of representations (oral or written) and audit evidence in general; and\n    3.  Take appropriate actions, including determining the possible effect on the opinion in the auditor’s report in accordance with ASA 705, having regard to the requirement in paragraph 20 of this Auditing Standard.\n\nWritten Representations about Management’s Responsibilities\n\n1.  The auditor shall disclaim an opinion on the financial report in accordance with ASA 705 if:\n    1.  The auditor concludes that there is sufficient doubt about the integrity of management such that the written representations required by paragraphs 10 and 11 of this Auditing Standard are not reliable; or\n    2.  Management does not provide the written representations required by paragraphs 10 and 11 of this Auditing Standard. (Ref: Para. A26‑A27)\n\n\\* \\* \\*\n\n##### Application and Other Explanatory Material\n\n###### Written Representations as Audit Evidence (Ref: Para. 3)\n\n1.  Written representations are an important source of audit evidence. If management modifies or does not provide the requested written representations, it may alert the auditor to the possibility that one or more significant issues may exist. Further, a request for written, rather than oral, representations in many cases may prompt management to consider such matters more rigorously, thereby enhancing the quality of the representations.\n\n###### Management from whom Written Representations are Requested (Ref: Para. 9)\n\n1.  Written representations are requested from those responsible for the preparation of the financial report. Those individuals may vary depending on the governance structure of the entity, and relevant law or regulation; however, management (rather than those charged with governance) is often the responsible party. Written representations may therefore be requested from the entity’s chief executive officer and chief financial officer, or other equivalent persons in entities that do not use such titles. In some circumstances, however, other parties, such as those charged with governance, are also responsible for the preparation of the financial report.\n2.  Due to its responsibility for the preparation of the financial report, and its responsibilities for the conduct of the entity’s business, management would be expected to have sufficient knowledge of the process followed by the entity in preparing and presenting the financial report and the assertions therein on which to base the written representations.\n3.  In some cases, however, management may decide to make enquiries of others who participate in preparing and presenting the financial report and assertions therein, including individuals who have specialised knowledge relating to the matters about which written representations are requested. Such individuals may include:\n\n-   An actuary responsible for actuarially determined accounting measurements.\n-   Staff engineers who may have responsibility for and specialised knowledge about environmental liability measurements.\n-   Internal counsel who may provide information essential to provisions for legal claims.\n\n1.  In some cases, management may include in the written representations qualifying language to the effect that representations are made to the best of its knowledge and belief. It is reasonable for the auditor to accept such wording if the auditor is satisfied that the representations are being made by those with appropriate responsibilities and knowledge of the matters included in the representations.\n2.  To reinforce the need for management to make informed representations, the auditor may request that management include in the written representations confirmation that it has made such enquiries as it considered appropriate to place it in the position to be able to make the requested written representations. It is not expected that such enquiries would usually require a formal internal process beyond those already established by the entity.\n\n###### Written Representations about Management’s Responsibilities (Ref: Para. 10‑11)\n\n1.  Audit evidence obtained during the audit that management has fulfilled the responsibilities referred to in paragraphs 10 and 11 is not sufficient without obtaining confirmation from management that it believes that it has fulfilled those responsibilities. This is because the auditor is not able to judge solely on other audit evidence whether management has prepared and presented the financial report and provided information to the auditor on the basis of the agreed acknowledgement and understanding of its responsibilities. For example, the auditor could not conclude that management has provided the auditor with all relevant information agreed in the terms of the audit engagement without asking it whether, and receiving confirmation that, such information has been provided.\n2.  The written representations required by paragraphs 10 and 11 draw on the agreed acknowledgement and understanding of management of its responsibilities in the terms of the audit engagement by requesting confirmation that it has fulfilled them. The auditor may also ask management to reconfirm its acknowledgement and understanding of those responsibilities in written representations. This is common in certain jurisdictions, but in any event may be particularly appropriate when:\n\n-   Those who signed the terms of the audit engagement on behalf of the entity no longer have the relevant responsibilities;\n-   The terms of the audit engagement were prepared in a previous year;\n-   There is any indication that management misunderstands those responsibilities; or\n-   Changes in circumstances make it appropriate to do so.\n-   Consistent with the requirement of ASA 210,[\\[5\\]](#_ftn6) such reconfirmation of management’s acknowledgement and understanding of its responsibilities is not made subject to the best of management’s knowledge and belief (as discussed in paragraph A5).\n\nConsiderations Specific to Public Sector Entities\n\n1.  The mandates for audits of financial reports of public sector entities may be broader than those of other entities. As a result, the premise, relating to management’s responsibilities, on which an audit of the financial report of a public sector entity is conducted may give rise to additional written representations. These may include written representations confirming that transactions and events have been carried out in accordance with law, regulation or other authority.\n\n###### Other Written Representations (Ref: Para. 13)\n\nAdditional Written Representations about the Financial Report\n\n1.  In addition to the written representation required by paragraph 10, the auditor may consider it necessary to request other written representations about the financial report. Such written representations may supplement, but do not form part of, the written representation required by paragraph 10. They may include representations about the following:\n\n-   Whether the selection and application of accounting policies are appropriate; and\n-   Whether matters such as the following, where relevant under the applicable financial reporting framework, have been recognised, measured, presented or disclosed in accordance with that framework:\n    -   Plans or intentions that may affect the carrying value or classification of assets and liabilities;\n    -   Liabilities, both actual and contingent;\n    -   Title to, or control over, assets, the liens or encumbrances on assets, and assets pledged as collateral; and\n    -   Aspects of laws, regulations and contractual agreements that may affect the financial report, including non‑compliance.\n\nAdditional Written Representations about Information Provided to the Auditor\n\n1.  In addition to the written representation required by paragraph 11, the auditor may consider it necessary to request management to provide a written representation that it has communicated to the auditor all deficiencies in internal control of which management is aware.\n\nWritten Representations about Specific Assertions\n\n1.  When obtaining evidence about, or evaluating, judgements and intentions, the auditor may consider one or more of the following:\n\n-   The entity’s past history in carrying out its stated intentions.\n-   The entity’s reasons for choosing a particular course of action.\n-   The entity’s ability to pursue a specific course of action.\n-   The existence or lack of any other information that might have been obtained during the course of the audit that may be inconsistent with management’s judgement or intent.\n\n1.  In addition, the auditor may consider it necessary to request management to provide written representations about specific assertions in the financial report; in particular, to support an understanding that the auditor has obtained from other audit evidence of management’s judgement or intent in relation to, or the completeness of, a specific assertion. For example, if the intent of management is important to the valuation basis for investments, it may not be possible to obtain sufficient appropriate audit evidence without a written representation from management about its intentions. Although such written representations provide necessary audit evidence, they do not provide sufficient appropriate audit evidence on their own for that assertion.\n\n###### Communicating a Threshold Amount (Ref: Para. 10‑11, 13)\n\n1.  ASA 450 requires the auditor to accumulate misstatements identified during the audit, other than those that are clearly trivial.[\\[6\\]](#_ftn7) The auditor may determine a threshold above which misstatements cannot be regarded as clearly trivial. In the same way, the auditor may consider communicating to management a threshold for purposes of the requested written representations.\n\n###### Date of and Period(s) Covered by Written Representations (Ref: Para. 14)\n\n1.  Because written representations are necessary audit evidence, the auditor’s opinion cannot be expressed, and the auditor’s report cannot be dated, before the date of the written representations. Furthermore, because the auditor is concerned with events occurring up to the date of the auditor’s report that may require adjustment to or disclosure in the financial report, the written representations are dated as near as practicable to, but not after, the date of the auditor’s report on the financial report.\n2.  In some circumstances, it may be appropriate for the auditor to obtain a written representation about a specific assertion in the financial report during the course of the audit. Where this is the case, it may be necessary to request an updated written representation.\n3.  The written representations are for all periods referred to in the auditor’s report because management needs to reaffirm that the written representations it previously made with respect to the prior periods remain appropriate. The auditor and management may agree to a form of written representation that updates written representations relating to the prior periods by addressing whether there are any changes to such written representations and, if so, what they are.\n4.  Situations may arise where current management were not present during all periods referred to in the auditor’s report. Such persons may assert that they are not in a position to provide some or all of the written representations because they were not in place during the period. This fact, however, does not diminish such persons’ responsibilities for the financial report as a whole. Accordingly, the requirement for the auditor to request from them written representations that cover the whole of the relevant period(s) still applies.\n\n###### Form of Written Representations (Ref: Para. 15)\n\n1.  Written representations are required to be included in a representation letter addressed to the auditor. In some jurisdictions, however, management may be required by law or regulation to make a written public statement about its responsibilities. Although such a statement is a representation to the users of the financial report, or to relevant authorities, the auditor may determine that it is an appropriate form of written representation in respect of some or all of the representations required by paragraph 10 or 11. Consequently, the relevant matters covered by such a statement need not be included in the representation letter. Factors that may affect the auditor’s determination include:\n\n-   Whether the statement includes confirmation of the fulfilment of the responsibilities referred to in paragraphs 10 and 11.\n-   Whether the statement has been given or approved by those from whom the auditor requests the relevant written representations.\n-   Whether a copy of the statement is provided to the auditor as near as practicable to, but not after, the date of the auditor’s report on the financial report (see paragraph 14).\n\n1.  A formal statement of compliance with law or regulation, or of approval of the financial report, would not contain sufficient information for the auditor to be satisfied that all necessary representations have been consciously made. The expression of management’s responsibilities in law or regulation is also not a substitute for the requested written representations.\n2.  Appendix 2 provides an illustrative example of a representation letter.\n\n###### Communication with Those Charged with Governance (Ref: Para. 10‑11, 13)\n\n1.  ASA 260 requires the auditor to communicate with those charged with governance the written representations which the auditor has requested from management.[\\[7\\]](#_ftn8)\n\n###### Doubt as to the Reliability of Written Representations and Requested Written Representations Not Provided\n\nDoubt as to the Reliability of Written Representations (Ref: Para. 16‑17)\n\n1.  In the case of identified inconsistencies between one or more written representations and audit evidence obtained from another source, the auditor may consider whether the risk assessment remains appropriate and, if not, revise the risk assessment and determine the nature, timing and extent of further audit procedures to respond to the assessed risks.\n2.  Concerns about the competence, integrity, ethical values or diligence of management, or about its commitment to or enforcement of these, may cause the auditor to conclude that the risk of management misrepresentation in the financial report is such that an audit cannot be conducted. In such a case, the auditor may consider withdrawing from the engagement, where withdrawal is possible under applicable law or regulation, unless those charged with governance put in place appropriate corrective measures. Such measures, however, may not be sufficient to enable the auditor to issue an unmodified audit opinion.\n3.  ASA 230 requires the auditor to document significant matters arising during the audit, the conclusions reached thereon, and significant professional judgements made in reaching those conclusions.[\\[8\\]](#_ftn9) The auditor may have identified significant issues relating to the competence, integrity, ethical values or diligence of management, or about its commitment to or enforcement of these, but concluded that the written representations are nevertheless reliable. In such a case, this significant matter is documented in accordance with ASA 230.\n\nWritten Representations about Management’s Responsibilities (Ref: Para. 20)\n\n1.  As explained in paragraph A7, the auditor is not able to judge solely on other audit evidence whether management has fulfilled the responsibilities referred to in paragraphs 10 and 11. Therefore, if, as described in paragraph 20(a), the auditor concludes that the written representations about these matters are unreliable, or if management does not provide those written representations, the auditor is unable to obtain sufficient appropriate audit evidence. The possible effects on the financial report of such inability are not confined to specific elements, accounts or items of the financial report and are hence pervasive. ASA 705 requires the auditor to disclaim an opinion on the financial report in such circumstances.[\\[9\\]](#_ftn10)\n\nIf Management do not Provide Written Representations\n\nAus A26.1 If management do not provide written representations, the auditor would ordinarily:\n\n(a) draw to the attention of those charged with governance any relevant regulatory requirements which give the auditor a right of access to any requested information, explanations or assistance for the purposes of the audit;[\\[\\*\\]](#_ftn11)\n\n(b) consider any other implications of the refusal that may have any effect on the auditor’s report;[\\[#\\]](#_ftn12) and\n\n(c) consider whether the auditor has any regulatory obligation to report that management has not provided a written representation.[\\[†\\]](#_ftn13)\n\n1.  A written representation that has been modified from that requested by the auditor does not necessarily mean that management did not provide the written representation. However, the underlying reason for such modification may affect the opinion in the auditor’s report. For example:\n\n-   The written representation about management’s fulfilment of its responsibility for the preparation of the financial report may state that management believes that, except for material non‑compliance with a particular requirement of the applicable financial reporting framework, the financial report is prepared in accordance with that framework. The requirement in paragraph 20 does not apply because the auditor concluded that management has provided reliable written representations. However, the auditor is required to consider the effect of the non‑compliance on the opinion in the auditor’s report in accordance with ASA 705.\n-   The written representation about the responsibility of management to provide the auditor with all relevant information agreed in the terms of the audit engagement may state that management believes that, except for information destroyed in a fire, it has provided the auditor with such information. The requirement in paragraph 20 does not apply because the auditor concluded that management has provided reliable written representations. However, the auditor is required to consider the effects of the pervasiveness of the information destroyed in the fire on the financial report and the effect thereof on the opinion in the auditor’s report in accordance with ASA 705.","sortOrder":11},{"sectionNumber":"Application","sectionType":"section","heading":"Application","content":"##### Application\n\nAus 0.1 This Auditing Standard applies to:\n\n(a) an audit of a financial report for a financial year, or an audit of a financial report for a half‑year, in accordance with the Corporations Act 2001; and\n\n(b) an audit of a financial report, or a complete set of financial statements, for any other purpose.\n\nAus 0.2 This Auditing Standard also applies, as appropriate, to an audit of other historical financial information.","sortOrder":12},{"sectionNumber":"Operative Date","sectionType":"section","heading":"Operative Date","content":"##### Operative Date\n\nAus 0.3 This Auditing Standard is operative for financial reporting periods commencing on or after 1 January 2010. \\[Note: For operative dates of paragraphs changed or added by an Amending Standard, see Compilation Details.\\]","sortOrder":13},{"sectionNumber":"Introduction","sectionType":"section","heading":"Introduction","content":"Auditing Standard ASA 580\n\nThe Auditing and Assurance Standards Board (AUASB) made Auditing Standard ASA 580 Written Representations pursuant to section 227B of the Australian Securities and Investments Commission Act 2001 and section 336 of the Corporations Act 2001, on 27 October 2009.\n\nThis compiled version of ASA 580 incorporates subsequent amendments contained in other Auditing Standards made by the AUASB up to and including 15 March 2023 (see Compilation Details).\n\n## Auditing Standard ASA 580\n\n### Written Representations\n\n##### Application\n\nAus 0.1 This Auditing Standard applies to:\n\n(a) an audit of a financial report for a financial year, or an audit of a financial report for a half‑year, in accordance with the Corporations Act 2001; and\n\n(b) an audit of a financial report, or a complete set of financial statements, for any other purpose.\n\nAus 0.2 This Auditing Standard also applies, as appropriate, to an audit of other historical financial information.\n\n##### Operative Date\n\nAus 0.3 This Auditing Standard is operative for financial reporting periods commencing on or after 1 January 2010. \\[Note: For operative dates of paragraphs changed or added by an Amending Standard, see Compilation Details.\\]\n\n##### Introduction\n\n###### Scope of this Auditing Standard\n\n1.  This Auditing Standard deals with the auditor’s responsibility to obtain written representations from management and, where appropriate, those charged with governance in an audit of a financial report.\n2.  Appendix 1 lists other Australian Auditing Standards containing subject‑matter specific requirements for written representations. The specific requirements for written representations of other Australian Auditing Standards do not limit the application of this Auditing Standard.\n\n###### Written Representations as Audit Evidence\n\n1.  Audit evidence is the information used by the auditor in arriving at the conclusions on which the auditor’s opinion is based.[\\[1\\]](#_ftn2) Written representations are necessary information that the auditor requires in connection with the audit of the entity’s financial report. Accordingly, similar to responses to enquiries, written representations are audit evidence. (Ref: Para. A1)\n2.  Although written representations provide necessary audit evidence, they do not provide sufficient appropriate audit evidence on their own about any of the matters with which they deal. Furthermore, the fact that management has provided reliable written representations does not affect the nature or extent of other audit evidence that the auditor obtains about the fulfilment of management’s responsibilities, or about specific assertions.\n\n###### Effective Date\n\n1.  \\[Deleted by the AUASB. Refer Aus 0.3\\]\n\n##### Objectives\n\n1.  The objectives of the auditor are:\n    1.  To obtain written representations from management and, where appropriate, those charged with governance that they believe that they have fulfilled their responsibility for the preparation of the financial report and for the completeness of the information provided to the auditor;\n    2.  To support other audit evidence relevant to the financial report or specific assertions in the financial report by means of written representations if determined necessary by the auditor or required by other Australian Auditing Standards; and\n    3.  To respond appropriately to written representations provided by management and, where appropriate, those charged with governance, or if management or, where appropriate, those charged with governance do not provide the written representations requested by the auditor.\n\n##### Definitions\n\n1.  For the purposes of this Auditing Standard, the following terms have the meanings attributed below:\n\nWritten representation means a written statement by management provided to the auditor to confirm certain matters or to support other audit evidence. Written representations in this context do not include the financial report, the assertions therein, or supporting books and records.\n\n1.  For purposes of this Auditing Standard, references to “management” should be read as “management and, where appropriate, those charged with governance.” Furthermore, in the case of a fair presentation framework, management is responsible for the preparation and fair presentation of the financial report in accordance with the applicable financial reporting framework; or the preparation of a financial report that gives a true and fair view in accordance with the applicable financial reporting framework.\n\n##### Requirements\n\n###### Management from whom Written Representations are Requested\n\n1.  The auditor shall request written representations from management with appropriate responsibilities for the financial report and knowledge of the matters concerned. (Ref: Para. A2‑A6)\n\n###### Written Representations about Management’s Responsibilities\n\nPreparation of the Financial report\n\n1.  The auditor shall request management to provide a written representation that it has fulfilled its responsibility for the preparation of the financial report in accordance with the applicable financial reporting framework, and other statutory reporting requirements, including where relevant their fair presentation, as set out in the terms of the audit engagement.[\\[2\\]](#_ftn3) (Ref: Para. A7‑A9, A14, A22)\n\nInformation Provided and Completeness of Transactions\n\n1.  The auditor shall request management to provide a written representation that:\n    1.  It has provided the auditor with all relevant information and access as agreed in the terms of the audit engagement;[\\[3\\]](#_ftn4) and\n    2.  All transactions have been recorded and are reflected in the financial report. (Ref: Para. A7‑A9, A14, A22)\n\nDescription of Management’s Responsibilities in the Written Representations\n\n1.  Management’s responsibilities shall be described in the written representations required by paragraphs 10 and 11 of this Auditing Standard in the manner in which these responsibilities are described in the terms of the audit engagement.\n\n###### Other Written Representations\n\n1.  Other Auditing Standards require the auditor to request written representations. If, in addition to such required representations, the auditor determines that it is necessary to obtain one or more written representations to support other audit evidence relevant to the financial report or one or more specific assertions in the financial report, the auditor shall request such other written representations. (Ref: Para. A10‑A14, A22)\n\n###### Date of and Period(s) Covered by Written Representations\n\n1.  The date of the written representations shall be as near as practicable to, but not after, the date of the auditor’s report on the financial report. The written representations shall be for all the financial report(s) and period(s) referred to in the auditor’s report. (Ref: Para. A15‑A18)\n\n###### Form of Written Representations\n\n1.  The written representations shall be in the form of a representation letter addressed to the auditor. If law or regulation requires management to make written public statements about its responsibilities, and the auditor determines that such statements provide some or all of the representations required by paragraphs 10 or 11 of this Auditing Standard, the relevant matters covered by such statements need not be included in the representation letter. (Ref: Para. A19‑A21)\n\n###### Doubt as to the Reliability of Written Representations and Requested Written Representations Not Provided\n\nDoubt as to the Reliability of Written Representations\n\n1.  If the auditor has concerns about the competence, integrity, ethical values or diligence of management, or about its commitment to or enforcement of these, the auditor shall determine the effect that such concerns may have on the reliability of representations (oral or written) and audit evidence in general. (Ref: Para. A24‑A25)\n2.  In particular, if written representations are inconsistent with other audit evidence, the auditor shall perform audit procedures to attempt to resolve the matter. If the matter remains unresolved, the auditor shall reconsider the assessment of the competence, integrity, ethical values or diligence of management, or of its commitment to or enforcement of these, and shall determine the effect that this may have on the reliability of representations (oral or written) and audit evidence in general. (Ref: Para. A23)\n3.  If the auditor concludes that the written representations are not reliable, the auditor shall take appropriate actions, including determining the possible effect on the opinion in the auditor’s report in accordance with ASA 705,[\\[4\\]](#_ftn5) having regard to the requirement in paragraph 20 of this Auditing Standard.\n\nRequested Written Representations Not Provided\n\n1.  If management does not provide one or more of the requested written representations, the auditor shall:\n    1.  Discuss the matter with management;\n    2.  Re‑evaluate the integrity of management and evaluate the effect that this may have on the reliability of representations (oral or written) and audit evidence in general; and\n    3.  Take appropriate actions, including determining the possible effect on the opinion in the auditor’s report in accordance with ASA 705, having regard to the requirement in paragraph 20 of this Auditing Standard.\n\nWritten Representations about Management’s Responsibilities\n\n1.  The auditor shall disclaim an opinion on the financial report in accordance with ASA 705 if:\n    1.  The auditor concludes that there is sufficient doubt about the integrity of management such that the written representations required by paragraphs 10 and 11 of this Auditing Standard are not reliable; or\n    2.  Management does not provide the written representations required by paragraphs 10 and 11 of this Auditing Standard. (Ref: Para. A26‑A27)\n\n\\* \\* \\*\n\n##### Application and Other Explanatory Material\n\n###### Written Representations as Audit Evidence (Ref: Para. 3)\n\n1.  Written representations are an important source of audit evidence. If management modifies or does not provide the requested written representations, it may alert the auditor to the possibility that one or more significant issues may exist. Further, a request for written, rather than oral, representations in many cases may prompt management to consider such matters more rigorously, thereby enhancing the quality of the representations.\n\n###### Management from whom Written Representations are Requested (Ref: Para. 9)\n\n1.  Written representations are requested from those responsible for the preparation of the financial report. Those individuals may vary depending on the governance structure of the entity, and relevant law or regulation; however, management (rather than those charged with governance) is often the responsible party. Written representations may therefore be requested from the entity’s chief executive officer and chief financial officer, or other equivalent persons in entities that do not use such titles. In some circumstances, however, other parties, such as those charged with governance, are also responsible for the preparation of the financial report.\n2.  Due to its responsibility for the preparation of the financial report, and its responsibilities for the conduct of the entity’s business, management would be expected to have sufficient knowledge of the process followed by the entity in preparing and presenting the financial report and the assertions therein on which to base the written representations.\n3.  In some cases, however, management may decide to make enquiries of others who participate in preparing and presenting the financial report and assertions therein, including individuals who have specialised knowledge relating to the matters about which written representations are requested. Such individuals may include:\n\n-   An actuary responsible for actuarially determined accounting measurements.\n-   Staff engineers who may have responsibility for and specialised knowledge about environmental liability measurements.\n-   Internal counsel who may provide information essential to provisions for legal claims.\n\n1.  In some cases, management may include in the written representations qualifying language to the effect that representations are made to the best of its knowledge and belief. It is reasonable for the auditor to accept such wording if the auditor is satisfied that the representations are being made by those with appropriate responsibilities and knowledge of the matters included in the representations.\n2.  To reinforce the need for management to make informed representations, the auditor may request that management include in the written representations confirmation that it has made such enquiries as it considered appropriate to place it in the position to be able to make the requested written representations. It is not expected that such enquiries would usually require a formal internal process beyond those already established by the entity.\n\n###### Written Representations about Management’s Responsibilities (Ref: Para. 10‑11)\n\n1.  Audit evidence obtained during the audit that management has fulfilled the responsibilities referred to in paragraphs 10 and 11 is not sufficient without obtaining confirmation from management that it believes that it has fulfilled those responsibilities. This is because the auditor is not able to judge solely on other audit evidence whether management has prepared and presented the financial report and provided information to the auditor on the basis of the agreed acknowledgement and understanding of its responsibilities. For example, the auditor could not conclude that management has provided the auditor with all relevant information agreed in the terms of the audit engagement without asking it whether, and receiving confirmation that, such information has been provided.\n2.  The written representations required by paragraphs 10 and 11 draw on the agreed acknowledgement and understanding of management of its responsibilities in the terms of the audit engagement by requesting confirmation that it has fulfilled them. The auditor may also ask management to reconfirm its acknowledgement and understanding of those responsibilities in written representations. This is common in certain jurisdictions, but in any event may be particularly appropriate when:\n\n-   Those who signed the terms of the audit engagement on behalf of the entity no longer have the relevant responsibilities;\n-   The terms of the audit engagement were prepared in a previous year;\n-   There is any indication that management misunderstands those responsibilities; or\n-   Changes in circumstances make it appropriate to do so.\n-   Consistent with the requirement of ASA 210,[\\[5\\]](#_ftn6) such reconfirmation of management’s acknowledgement and understanding of its responsibilities is not made subject to the best of management’s knowledge and belief (as discussed in paragraph A5).\n\nConsiderations Specific to Public Sector Entities\n\n1.  The mandates for audits of financial reports of public sector entities may be broader than those of other entities. As a result, the premise, relating to management’s responsibilities, on which an audit of the financial report of a public sector entity is conducted may give rise to additional written representations. These may include written representations confirming that transactions and events have been carried out in accordance with law, regulation or other authority.\n\n###### Other Written Representations (Ref: Para. 13)\n\nAdditional Written Representations about the Financial Report\n\n1.  In addition to the written representation required by paragraph 10, the auditor may consider it necessary to request other written representations about the financial report. Such written representations may supplement, but do not form part of, the written representation required by paragraph 10. They may include representations about the following:\n\n-   Whether the selection and application of accounting policies are appropriate; and\n-   Whether matters such as the following, where relevant under the applicable financial reporting framework, have been recognised, measured, presented or disclosed in accordance with that framework:\n    -   Plans or intentions that may affect the carrying value or classification of assets and liabilities;\n    -   Liabilities, both actual and contingent;\n    -   Title to, or control over, assets, the liens or encumbrances on assets, and assets pledged as collateral; and\n    -   Aspects of laws, regulations and contractual agreements that may affect the financial report, including non‑compliance.\n\nAdditional Written Representations about Information Provided to the Auditor\n\n1.  In addition to the written representation required by paragraph 11, the auditor may consider it necessary to request management to provide a written representation that it has communicated to the auditor all deficiencies in internal control of which management is aware.\n\nWritten Representations about Specific Assertions\n\n1.  When obtaining evidence about, or evaluating, judgements and intentions, the auditor may consider one or more of the following:\n\n-   The entity’s past history in carrying out its stated intentions.\n-   The entity’s reasons for choosing a particular course of action.\n-   The entity’s ability to pursue a specific course of action.\n-   The existence or lack of any other information that might have been obtained during the course of the audit that may be inconsistent with management’s judgement or intent.\n\n1.  In addition, the auditor may consider it necessary to request management to provide written representations about specific assertions in the financial report; in particular, to support an understanding that the auditor has obtained from other audit evidence of management’s judgement or intent in relation to, or the completeness of, a specific assertion. For example, if the intent of management is important to the valuation basis for investments, it may not be possible to obtain sufficient appropriate audit evidence without a written representation from management about its intentions. Although such written representations provide necessary audit evidence, they do not provide sufficient appropriate audit evidence on their own for that assertion.\n\n###### Communicating a Threshold Amount (Ref: Para. 10‑11, 13)\n\n1.  ASA 450 requires the auditor to accumulate misstatements identified during the audit, other than those that are clearly trivial.[\\[6\\]](#_ftn7) The auditor may determine a threshold above which misstatements cannot be regarded as clearly trivial. In the same way, the auditor may consider communicating to management a threshold for purposes of the requested written representations.\n\n###### Date of and Period(s) Covered by Written Representations (Ref: Para. 14)\n\n1.  Because written representations are necessary audit evidence, the auditor’s opinion cannot be expressed, and the auditor’s report cannot be dated, before the date of the written representations. Furthermore, because the auditor is concerned with events occurring up to the date of the auditor’s report that may require adjustment to or disclosure in the financial report, the written representations are dated as near as practicable to, but not after, the date of the auditor’s report on the financial report.\n2.  In some circumstances, it may be appropriate for the auditor to obtain a written representation about a specific assertion in the financial report during the course of the audit. Where this is the case, it may be necessary to request an updated written representation.\n3.  The written representations are for all periods referred to in the auditor’s report because management needs to reaffirm that the written representations it previously made with respect to the prior periods remain appropriate. The auditor and management may agree to a form of written representation that updates written representations relating to the prior periods by addressing whether there are any changes to such written representations and, if so, what they are.\n4.  Situations may arise where current management were not present during all periods referred to in the auditor’s report. Such persons may assert that they are not in a position to provide some or all of the written representations because they were not in place during the period. This fact, however, does not diminish such persons’ responsibilities for the financial report as a whole. Accordingly, the requirement for the auditor to request from them written representations that cover the whole of the relevant period(s) still applies.\n\n###### Form of Written Representations (Ref: Para. 15)\n\n1.  Written representations are required to be included in a representation letter addressed to the auditor. In some jurisdictions, however, management may be required by law or regulation to make a written public statement about its responsibilities. Although such a statement is a representation to the users of the financial report, or to relevant authorities, the auditor may determine that it is an appropriate form of written representation in respect of some or all of the representations required by paragraph 10 or 11. Consequently, the relevant matters covered by such a statement need not be included in the representation letter. Factors that may affect the auditor’s determination include:\n\n-   Whether the statement includes confirmation of the fulfilment of the responsibilities referred to in paragraphs 10 and 11.\n-   Whether the statement has been given or approved by those from whom the auditor requests the relevant written representations.\n-   Whether a copy of the statement is provided to the auditor as near as practicable to, but not after, the date of the auditor’s report on the financial report (see paragraph 14).\n\n1.  A formal statement of compliance with law or regulation, or of approval of the financial report, would not contain sufficient information for the auditor to be satisfied that all necessary representations have been consciously made. The expression of management’s responsibilities in law or regulation is also not a substitute for the requested written representations.\n2.  Appendix 2 provides an illustrative example of a representation letter.\n\n###### Communication with Those Charged with Governance (Ref: Para. 10‑11, 13)\n\n1.  ASA 260 requires the auditor to communicate with those charged with governance the written representations which the auditor has requested from management.[\\[7\\]](#_ftn8)\n\n###### Doubt as to the Reliability of Written Representations and Requested Written Representations Not Provided\n\nDoubt as to the Reliability of Written Representations (Ref: Para. 16‑17)\n\n1.  In the case of identified inconsistencies between one or more written representations and audit evidence obtained from another source, the auditor may consider whether the risk assessment remains appropriate and, if not, revise the risk assessment and determine the nature, timing and extent of further audit procedures to respond to the assessed risks.\n2.  Concerns about the competence, integrity, ethical values or diligence of management, or about its commitment to or enforcement of these, may cause the auditor to conclude that the risk of management misrepresentation in the financial report is such that an audit cannot be conducted. In such a case, the auditor may consider withdrawing from the engagement, where withdrawal is possible under applicable law or regulation, unless those charged with governance put in place appropriate corrective measures. Such measures, however, may not be sufficient to enable the auditor to issue an unmodified audit opinion.\n3.  ASA 230 requires the auditor to document significant matters arising during the audit, the conclusions reached thereon, and significant professional judgements made in reaching those conclusions.[\\[8\\]](#_ftn9) The auditor may have identified significant issues relating to the competence, integrity, ethical values or diligence of management, or about its commitment to or enforcement of these, but concluded that the written representations are nevertheless reliable. In such a case, this significant matter is documented in accordance with ASA 230.\n\nWritten Representations about Management’s Responsibilities (Ref: Para. 20)\n\n1.  As explained in paragraph A7, the auditor is not able to judge solely on other audit evidence whether management has fulfilled the responsibilities referred to in paragraphs 10 and 11. Therefore, if, as described in paragraph 20(a), the auditor concludes that the written representations about these matters are unreliable, or if management does not provide those written representations, the auditor is unable to obtain sufficient appropriate audit evidence. The possible effects on the financial report of such inability are not confined to specific elements, accounts or items of the financial report and are hence pervasive. ASA 705 requires the auditor to disclaim an opinion on the financial report in such circumstances.[\\[9\\]](#_ftn10)\n\nIf Management do not Provide Written Representations\n\nAus A26.1 If management do not provide written representations, the auditor would ordinarily:\n\n(a) draw to the attention of those charged with governance any relevant regulatory requirements which give the auditor a right of access to any requested information, explanations or assistance for the purposes of the audit;[\\[\\*\\]](#_ftn11)\n\n(b) consider any other implications of the refusal that may have any effect on the auditor’s report;[\\[#\\]](#_ftn12) and\n\n(c) consider whether the auditor has any regulatory obligation to report that management has not provided a written representation.[\\[†\\]](#_ftn13)\n\n1.  A written representation that has been modified from that requested by the auditor does not necessarily mean that management did not provide the written representation. However, the underlying reason for such modification may affect the opinion in the auditor’s report. For example:\n\n-   The written representation about management’s fulfilment of its responsibility for the preparation of the financial report may state that management believes that, except for material non‑compliance with a particular requirement of the applicable financial reporting framework, the financial report is prepared in accordance with that framework. The requirement in paragraph 20 does not apply because the auditor concluded that management has provided reliable written representations. However, the auditor is required to consider the effect of the non‑compliance on the opinion in the auditor’s report in accordance with ASA 705.\n-   The written representation about the responsibility of management to provide the auditor with all relevant information agreed in the terms of the audit engagement may state that management believes that, except for information destroyed in a fire, it has provided the auditor with such information. The requirement in paragraph 20 does not apply because the auditor concluded that management has provided reliable written representations. However, the auditor is required to consider the effects of the pervasiveness of the information destroyed in the fire on the financial report and the effect thereof on the opinion in the auditor’s report in accordance with ASA 705.","sortOrder":14},{"sectionNumber":"Scope of this Auditing Standard","sectionType":"section","heading":"Scope of this Auditing Standard","content":"###### Scope of this Auditing Standard\n\n1.  This Auditing Standard deals with the auditor’s responsibility to obtain written representations from management and, where appropriate, those charged with governance in an audit of a financial report.\n2.  Appendix 1 lists other Australian Auditing Standards containing subject‑matter specific requirements for written representations. The specific requirements for written representations of other Australian Auditing Standards do not limit the application of this Auditing Standard.","sortOrder":15},{"sectionNumber":"Written Representations as Audit Evidenc","sectionType":"section","heading":"Written Representations as Audit Evidence","content":"###### Written Representations as Audit Evidence\n\n1.  Audit evidence is the information used by the auditor in arriving at the conclusions on which the auditor’s opinion is based.[\\[1\\]](#_ftn2) Written representations are necessary information that the auditor requires in connection with the audit of the entity’s financial report. Accordingly, similar to responses to enquiries, written representations are audit evidence. (Ref: Para. A1)\n2.  Although written representations provide necessary audit evidence, they do not provide sufficient appropriate audit evidence on their own about any of the matters with which they deal. Furthermore, the fact that management has provided reliable written representations does not affect the nature or extent of other audit evidence that the auditor obtains about the fulfilment of management’s responsibilities, or about specific assertions.","sortOrder":16},{"sectionNumber":"Effective Date","sectionType":"section","heading":"Effective Date","content":"###### Effective Date\n\n1.  \\[Deleted by the AUASB. Refer Aus 0.3\\]","sortOrder":17},{"sectionNumber":"Objectives","sectionType":"section","heading":"Objectives","content":"##### Objectives\n\n1.  The objectives of the auditor are:\n    1.  To obtain written representations from management and, where appropriate, those charged with governance that they believe that they have fulfilled their responsibility for the preparation of the financial report and for the completeness of the information provided to the auditor;\n    2.  To support other audit evidence relevant to the financial report or specific assertions in the financial report by means of written representations if determined necessary by the auditor or required by other Australian Auditing Standards; and\n    3.  To respond appropriately to written representations provided by management and, where appropriate, those charged with governance, or if management or, where appropriate, those charged with governance do not provide the written representations requested by the auditor.","sortOrder":18},{"sectionNumber":"Definitions","sectionType":"section","heading":"Definitions","content":"##### Definitions\n\n1.  For the purposes of this Auditing Standard, the following terms have the meanings attributed below:\n\nWritten representation means a written statement by management provided to the auditor to confirm certain matters or to support other audit evidence. Written representations in this context do not include the financial report, the assertions therein, or supporting books and records.\n\n1.  For purposes of this Auditing Standard, references to “management” should be read as “management and, where appropriate, those charged with governance.” Furthermore, in the case of a fair presentation framework, management is responsible for the preparation and fair presentation of the financial report in accordance with the applicable financial reporting framework; or the preparation of a financial report that gives a true and fair view in accordance with the applicable financial reporting framework.","sortOrder":19},{"sectionNumber":"Requirements","sectionType":"section","heading":"Requirements","content":"Auditing Standard ASA 580\n\nThe Auditing and Assurance Standards Board (AUASB) made Auditing Standard ASA 580 Written Representations pursuant to section 227B of the Australian Securities and Investments Commission Act 2001 and section 336 of the Corporations Act 2001, on 27 October 2009.\n\nThis compiled version of ASA 580 incorporates subsequent amendments contained in other Auditing Standards made by the AUASB up to and including 15 March 2023 (see Compilation Details).\n\n## Auditing Standard ASA 580\n\n### Written Representations\n\n##### Application\n\nAus 0.1 This Auditing Standard applies to:\n\n(a) an audit of a financial report for a financial year, or an audit of a financial report for a half‑year, in accordance with the Corporations Act 2001; and\n\n(b) an audit of a financial report, or a complete set of financial statements, for any other purpose.\n\nAus 0.2 This Auditing Standard also applies, as appropriate, to an audit of other historical financial information.\n\n##### Operative Date\n\nAus 0.3 This Auditing Standard is operative for financial reporting periods commencing on or after 1 January 2010. \\[Note: For operative dates of paragraphs changed or added by an Amending Standard, see Compilation Details.\\]\n\n##### Introduction\n\n###### Scope of this Auditing Standard\n\n1.  This Auditing Standard deals with the auditor’s responsibility to obtain written representations from management and, where appropriate, those charged with governance in an audit of a financial report.\n2.  Appendix 1 lists other Australian Auditing Standards containing subject‑matter specific requirements for written representations. The specific requirements for written representations of other Australian Auditing Standards do not limit the application of this Auditing Standard.\n\n###### Written Representations as Audit Evidence\n\n1.  Audit evidence is the information used by the auditor in arriving at the conclusions on which the auditor’s opinion is based.[\\[1\\]](#_ftn2) Written representations are necessary information that the auditor requires in connection with the audit of the entity’s financial report. Accordingly, similar to responses to enquiries, written representations are audit evidence. (Ref: Para. A1)\n2.  Although written representations provide necessary audit evidence, they do not provide sufficient appropriate audit evidence on their own about any of the matters with which they deal. Furthermore, the fact that management has provided reliable written representations does not affect the nature or extent of other audit evidence that the auditor obtains about the fulfilment of management’s responsibilities, or about specific assertions.\n\n###### Effective Date\n\n1.  \\[Deleted by the AUASB. Refer Aus 0.3\\]\n\n##### Objectives\n\n1.  The objectives of the auditor are:\n    1.  To obtain written representations from management and, where appropriate, those charged with governance that they believe that they have fulfilled their responsibility for the preparation of the financial report and for the completeness of the information provided to the auditor;\n    2.  To support other audit evidence relevant to the financial report or specific assertions in the financial report by means of written representations if determined necessary by the auditor or required by other Australian Auditing Standards; and\n    3.  To respond appropriately to written representations provided by management and, where appropriate, those charged with governance, or if management or, where appropriate, those charged with governance do not provide the written representations requested by the auditor.\n\n##### Definitions\n\n1.  For the purposes of this Auditing Standard, the following terms have the meanings attributed below:\n\nWritten representation means a written statement by management provided to the auditor to confirm certain matters or to support other audit evidence. Written representations in this context do not include the financial report, the assertions therein, or supporting books and records.\n\n1.  For purposes of this Auditing Standard, references to “management” should be read as “management and, where appropriate, those charged with governance.” Furthermore, in the case of a fair presentation framework, management is responsible for the preparation and fair presentation of the financial report in accordance with the applicable financial reporting framework; or the preparation of a financial report that gives a true and fair view in accordance with the applicable financial reporting framework.\n\n##### Requirements\n\n###### Management from whom Written Representations are Requested\n\n1.  The auditor shall request written representations from management with appropriate responsibilities for the financial report and knowledge of the matters concerned. (Ref: Para. A2‑A6)\n\n###### Written Representations about Management’s Responsibilities\n\nPreparation of the Financial report\n\n1.  The auditor shall request management to provide a written representation that it has fulfilled its responsibility for the preparation of the financial report in accordance with the applicable financial reporting framework, and other statutory reporting requirements, including where relevant their fair presentation, as set out in the terms of the audit engagement.[\\[2\\]](#_ftn3) (Ref: Para. A7‑A9, A14, A22)\n\nInformation Provided and Completeness of Transactions\n\n1.  The auditor shall request management to provide a written representation that:\n    1.  It has provided the auditor with all relevant information and access as agreed in the terms of the audit engagement;[\\[3\\]](#_ftn4) and\n    2.  All transactions have been recorded and are reflected in the financial report. (Ref: Para. A7‑A9, A14, A22)\n\nDescription of Management’s Responsibilities in the Written Representations\n\n1.  Management’s responsibilities shall be described in the written representations required by paragraphs 10 and 11 of this Auditing Standard in the manner in which these responsibilities are described in the terms of the audit engagement.\n\n###### Other Written Representations\n\n1.  Other Auditing Standards require the auditor to request written representations. If, in addition to such required representations, the auditor determines that it is necessary to obtain one or more written representations to support other audit evidence relevant to the financial report or one or more specific assertions in the financial report, the auditor shall request such other written representations. (Ref: Para. A10‑A14, A22)\n\n###### Date of and Period(s) Covered by Written Representations\n\n1.  The date of the written representations shall be as near as practicable to, but not after, the date of the auditor’s report on the financial report. The written representations shall be for all the financial report(s) and period(s) referred to in the auditor’s report. (Ref: Para. A15‑A18)\n\n###### Form of Written Representations\n\n1.  The written representations shall be in the form of a representation letter addressed to the auditor. If law or regulation requires management to make written public statements about its responsibilities, and the auditor determines that such statements provide some or all of the representations required by paragraphs 10 or 11 of this Auditing Standard, the relevant matters covered by such statements need not be included in the representation letter. (Ref: Para. A19‑A21)\n\n###### Doubt as to the Reliability of Written Representations and Requested Written Representations Not Provided\n\nDoubt as to the Reliability of Written Representations\n\n1.  If the auditor has concerns about the competence, integrity, ethical values or diligence of management, or about its commitment to or enforcement of these, the auditor shall determine the effect that such concerns may have on the reliability of representations (oral or written) and audit evidence in general. (Ref: Para. A24‑A25)\n2.  In particular, if written representations are inconsistent with other audit evidence, the auditor shall perform audit procedures to attempt to resolve the matter. If the matter remains unresolved, the auditor shall reconsider the assessment of the competence, integrity, ethical values or diligence of management, or of its commitment to or enforcement of these, and shall determine the effect that this may have on the reliability of representations (oral or written) and audit evidence in general. (Ref: Para. A23)\n3.  If the auditor concludes that the written representations are not reliable, the auditor shall take appropriate actions, including determining the possible effect on the opinion in the auditor’s report in accordance with ASA 705,[\\[4\\]](#_ftn5) having regard to the requirement in paragraph 20 of this Auditing Standard.\n\nRequested Written Representations Not Provided\n\n1.  If management does not provide one or more of the requested written representations, the auditor shall:\n    1.  Discuss the matter with management;\n    2.  Re‑evaluate the integrity of management and evaluate the effect that this may have on the reliability of representations (oral or written) and audit evidence in general; and\n    3.  Take appropriate actions, including determining the possible effect on the opinion in the auditor’s report in accordance with ASA 705, having regard to the requirement in paragraph 20 of this Auditing Standard.\n\nWritten Representations about Management’s Responsibilities\n\n1.  The auditor shall disclaim an opinion on the financial report in accordance with ASA 705 if:\n    1.  The auditor concludes that there is sufficient doubt about the integrity of management such that the written representations required by paragraphs 10 and 11 of this Auditing Standard are not reliable; or\n    2.  Management does not provide the written representations required by paragraphs 10 and 11 of this Auditing Standard. (Ref: Para. A26‑A27)\n\n\\* \\* \\*\n\n##### Application and Other Explanatory Material\n\n###### Written Representations as Audit Evidence (Ref: Para. 3)\n\n1.  Written representations are an important source of audit evidence. If management modifies or does not provide the requested written representations, it may alert the auditor to the possibility that one or more significant issues may exist. Further, a request for written, rather than oral, representations in many cases may prompt management to consider such matters more rigorously, thereby enhancing the quality of the representations.\n\n###### Management from whom Written Representations are Requested (Ref: Para. 9)\n\n1.  Written representations are requested from those responsible for the preparation of the financial report. Those individuals may vary depending on the governance structure of the entity, and relevant law or regulation; however, management (rather than those charged with governance) is often the responsible party. Written representations may therefore be requested from the entity’s chief executive officer and chief financial officer, or other equivalent persons in entities that do not use such titles. In some circumstances, however, other parties, such as those charged with governance, are also responsible for the preparation of the financial report.\n2.  Due to its responsibility for the preparation of the financial report, and its responsibilities for the conduct of the entity’s business, management would be expected to have sufficient knowledge of the process followed by the entity in preparing and presenting the financial report and the assertions therein on which to base the written representations.\n3.  In some cases, however, management may decide to make enquiries of others who participate in preparing and presenting the financial report and assertions therein, including individuals who have specialised knowledge relating to the matters about which written representations are requested. Such individuals may include:\n\n-   An actuary responsible for actuarially determined accounting measurements.\n-   Staff engineers who may have responsibility for and specialised knowledge about environmental liability measurements.\n-   Internal counsel who may provide information essential to provisions for legal claims.\n\n1.  In some cases, management may include in the written representations qualifying language to the effect that representations are made to the best of its knowledge and belief. It is reasonable for the auditor to accept such wording if the auditor is satisfied that the representations are being made by those with appropriate responsibilities and knowledge of the matters included in the representations.\n2.  To reinforce the need for management to make informed representations, the auditor may request that management include in the written representations confirmation that it has made such enquiries as it considered appropriate to place it in the position to be able to make the requested written representations. It is not expected that such enquiries would usually require a formal internal process beyond those already established by the entity.\n\n###### Written Representations about Management’s Responsibilities (Ref: Para. 10‑11)\n\n1.  Audit evidence obtained during the audit that management has fulfilled the responsibilities referred to in paragraphs 10 and 11 is not sufficient without obtaining confirmation from management that it believes that it has fulfilled those responsibilities. This is because the auditor is not able to judge solely on other audit evidence whether management has prepared and presented the financial report and provided information to the auditor on the basis of the agreed acknowledgement and understanding of its responsibilities. For example, the auditor could not conclude that management has provided the auditor with all relevant information agreed in the terms of the audit engagement without asking it whether, and receiving confirmation that, such information has been provided.\n2.  The written representations required by paragraphs 10 and 11 draw on the agreed acknowledgement and understanding of management of its responsibilities in the terms of the audit engagement by requesting confirmation that it has fulfilled them. The auditor may also ask management to reconfirm its acknowledgement and understanding of those responsibilities in written representations. This is common in certain jurisdictions, but in any event may be particularly appropriate when:\n\n-   Those who signed the terms of the audit engagement on behalf of the entity no longer have the relevant responsibilities;\n-   The terms of the audit engagement were prepared in a previous year;\n-   There is any indication that management misunderstands those responsibilities; or\n-   Changes in circumstances make it appropriate to do so.\n-   Consistent with the requirement of ASA 210,[\\[5\\]](#_ftn6) such reconfirmation of management’s acknowledgement and understanding of its responsibilities is not made subject to the best of management’s knowledge and belief (as discussed in paragraph A5).\n\nConsiderations Specific to Public Sector Entities\n\n1.  The mandates for audits of financial reports of public sector entities may be broader than those of other entities. As a result, the premise, relating to management’s responsibilities, on which an audit of the financial report of a public sector entity is conducted may give rise to additional written representations. These may include written representations confirming that transactions and events have been carried out in accordance with law, regulation or other authority.\n\n###### Other Written Representations (Ref: Para. 13)\n\nAdditional Written Representations about the Financial Report\n\n1.  In addition to the written representation required by paragraph 10, the auditor may consider it necessary to request other written representations about the financial report. Such written representations may supplement, but do not form part of, the written representation required by paragraph 10. They may include representations about the following:\n\n-   Whether the selection and application of accounting policies are appropriate; and\n-   Whether matters such as the following, where relevant under the applicable financial reporting framework, have been recognised, measured, presented or disclosed in accordance with that framework:\n    -   Plans or intentions that may affect the carrying value or classification of assets and liabilities;\n    -   Liabilities, both actual and contingent;\n    -   Title to, or control over, assets, the liens or encumbrances on assets, and assets pledged as collateral; and\n    -   Aspects of laws, regulations and contractual agreements that may affect the financial report, including non‑compliance.\n\nAdditional Written Representations about Information Provided to the Auditor\n\n1.  In addition to the written representation required by paragraph 11, the auditor may consider it necessary to request management to provide a written representation that it has communicated to the auditor all deficiencies in internal control of which management is aware.\n\nWritten Representations about Specific Assertions\n\n1.  When obtaining evidence about, or evaluating, judgements and intentions, the auditor may consider one or more of the following:\n\n-   The entity’s past history in carrying out its stated intentions.\n-   The entity’s reasons for choosing a particular course of action.\n-   The entity’s ability to pursue a specific course of action.\n-   The existence or lack of any other information that might have been obtained during the course of the audit that may be inconsistent with management’s judgement or intent.\n\n1.  In addition, the auditor may consider it necessary to request management to provide written representations about specific assertions in the financial report; in particular, to support an understanding that the auditor has obtained from other audit evidence of management’s judgement or intent in relation to, or the completeness of, a specific assertion. For example, if the intent of management is important to the valuation basis for investments, it may not be possible to obtain sufficient appropriate audit evidence without a written representation from management about its intentions. Although such written representations provide necessary audit evidence, they do not provide sufficient appropriate audit evidence on their own for that assertion.\n\n###### Communicating a Threshold Amount (Ref: Para. 10‑11, 13)\n\n1.  ASA 450 requires the auditor to accumulate misstatements identified during the audit, other than those that are clearly trivial.[\\[6\\]](#_ftn7) The auditor may determine a threshold above which misstatements cannot be regarded as clearly trivial. In the same way, the auditor may consider communicating to management a threshold for purposes of the requested written representations.\n\n###### Date of and Period(s) Covered by Written Representations (Ref: Para. 14)\n\n1.  Because written representations are necessary audit evidence, the auditor’s opinion cannot be expressed, and the auditor’s report cannot be dated, before the date of the written representations. Furthermore, because the auditor is concerned with events occurring up to the date of the auditor’s report that may require adjustment to or disclosure in the financial report, the written representations are dated as near as practicable to, but not after, the date of the auditor’s report on the financial report.\n2.  In some circumstances, it may be appropriate for the auditor to obtain a written representation about a specific assertion in the financial report during the course of the audit. Where this is the case, it may be necessary to request an updated written representation.\n3.  The written representations are for all periods referred to in the auditor’s report because management needs to reaffirm that the written representations it previously made with respect to the prior periods remain appropriate. The auditor and management may agree to a form of written representation that updates written representations relating to the prior periods by addressing whether there are any changes to such written representations and, if so, what they are.\n4.  Situations may arise where current management were not present during all periods referred to in the auditor’s report. Such persons may assert that they are not in a position to provide some or all of the written representations because they were not in place during the period. This fact, however, does not diminish such persons’ responsibilities for the financial report as a whole. Accordingly, the requirement for the auditor to request from them written representations that cover the whole of the relevant period(s) still applies.\n\n###### Form of Written Representations (Ref: Para. 15)\n\n1.  Written representations are required to be included in a representation letter addressed to the auditor. In some jurisdictions, however, management may be required by law or regulation to make a written public statement about its responsibilities. Although such a statement is a representation to the users of the financial report, or to relevant authorities, the auditor may determine that it is an appropriate form of written representation in respect of some or all of the representations required by paragraph 10 or 11. Consequently, the relevant matters covered by such a statement need not be included in the representation letter. Factors that may affect the auditor’s determination include:\n\n-   Whether the statement includes confirmation of the fulfilment of the responsibilities referred to in paragraphs 10 and 11.\n-   Whether the statement has been given or approved by those from whom the auditor requests the relevant written representations.\n-   Whether a copy of the statement is provided to the auditor as near as practicable to, but not after, the date of the auditor’s report on the financial report (see paragraph 14).\n\n1.  A formal statement of compliance with law or regulation, or of approval of the financial report, would not contain sufficient information for the auditor to be satisfied that all necessary representations have been consciously made. The expression of management’s responsibilities in law or regulation is also not a substitute for the requested written representations.\n2.  Appendix 2 provides an illustrative example of a representation letter.\n\n###### Communication with Those Charged with Governance (Ref: Para. 10‑11, 13)\n\n1.  ASA 260 requires the auditor to communicate with those charged with governance the written representations which the auditor has requested from management.[\\[7\\]](#_ftn8)\n\n###### Doubt as to the Reliability of Written Representations and Requested Written Representations Not Provided\n\nDoubt as to the Reliability of Written Representations (Ref: Para. 16‑17)\n\n1.  In the case of identified inconsistencies between one or more written representations and audit evidence obtained from another source, the auditor may consider whether the risk assessment remains appropriate and, if not, revise the risk assessment and determine the nature, timing and extent of further audit procedures to respond to the assessed risks.\n2.  Concerns about the competence, integrity, ethical values or diligence of management, or about its commitment to or enforcement of these, may cause the auditor to conclude that the risk of management misrepresentation in the financial report is such that an audit cannot be conducted. In such a case, the auditor may consider withdrawing from the engagement, where withdrawal is possible under applicable law or regulation, unless those charged with governance put in place appropriate corrective measures. Such measures, however, may not be sufficient to enable the auditor to issue an unmodified audit opinion.\n3.  ASA 230 requires the auditor to document significant matters arising during the audit, the conclusions reached thereon, and significant professional judgements made in reaching those conclusions.[\\[8\\]](#_ftn9) The auditor may have identified significant issues relating to the competence, integrity, ethical values or diligence of management, or about its commitment to or enforcement of these, but concluded that the written representations are nevertheless reliable. In such a case, this significant matter is documented in accordance with ASA 230.\n\nWritten Representations about Management’s Responsibilities (Ref: Para. 20)\n\n1.  As explained in paragraph A7, the auditor is not able to judge solely on other audit evidence whether management has fulfilled the responsibilities referred to in paragraphs 10 and 11. Therefore, if, as described in paragraph 20(a), the auditor concludes that the written representations about these matters are unreliable, or if management does not provide those written representations, the auditor is unable to obtain sufficient appropriate audit evidence. The possible effects on the financial report of such inability are not confined to specific elements, accounts or items of the financial report and are hence pervasive. ASA 705 requires the auditor to disclaim an opinion on the financial report in such circumstances.[\\[9\\]](#_ftn10)\n\nIf Management do not Provide Written Representations\n\nAus A26.1 If management do not provide written representations, the auditor would ordinarily:\n\n(a) draw to the attention of those charged with governance any relevant regulatory requirements which give the auditor a right of access to any requested information, explanations or assistance for the purposes of the audit;[\\[\\*\\]](#_ftn11)\n\n(b) consider any other implications of the refusal that may have any effect on the auditor’s report;[\\[#\\]](#_ftn12) and\n\n(c) consider whether the auditor has any regulatory obligation to report that management has not provided a written representation.[\\[†\\]](#_ftn13)\n\n1.  A written representation that has been modified from that requested by the auditor does not necessarily mean that management did not provide the written representation. However, the underlying reason for such modification may affect the opinion in the auditor’s report. For example:\n\n-   The written representation about management’s fulfilment of its responsibility for the preparation of the financial report may state that management believes that, except for material non‑compliance with a particular requirement of the applicable financial reporting framework, the financial report is prepared in accordance with that framework. The requirement in paragraph 20 does not apply because the auditor concluded that management has provided reliable written representations. However, the auditor is required to consider the effect of the non‑compliance on the opinion in the auditor’s report in accordance with ASA 705.\n-   The written representation about the responsibility of management to provide the auditor with all relevant information agreed in the terms of the audit engagement may state that management believes that, except for information destroyed in a fire, it has provided the auditor with such information. The requirement in paragraph 20 does not apply because the auditor concluded that management has provided reliable written representations. However, the auditor is required to consider the effects of the pervasiveness of the information destroyed in the fire on the financial report and the effect thereof on the opinion in the auditor’s report in accordance with ASA 705.","sortOrder":20},{"sectionNumber":"Management from whom Written Representat","sectionType":"section","heading":"Management from whom Written Representations are Requested","content":"###### Management from whom Written Representations are Requested\n\n1.  The auditor shall request written representations from management with appropriate responsibilities for the financial report and knowledge of the matters concerned. (Ref: Para. A2‑A6)","sortOrder":21},{"sectionNumber":"Written Representations about Management","sectionType":"section","heading":"Written Representations about Management’s Responsibilities","content":"###### Written Representations about Management’s Responsibilities\n\nPreparation of the Financial report\n\n1.  The auditor shall request management to provide a written representation that it has fulfilled its responsibility for the preparation of the financial report in accordance with the applicable financial reporting framework, and other statutory reporting requirements, including where relevant their fair presentation, as set out in the terms of the audit engagement.[\\[2\\]](#_ftn3) (Ref: Para. A7‑A9, A14, A22)\n\nInformation Provided and Completeness of Transactions\n\n1.  The auditor shall request management to provide a written representation that:\n    1.  It has provided the auditor with all relevant information and access as agreed in the terms of the audit engagement;[\\[3\\]](#_ftn4) and\n    2.  All transactions have been recorded and are reflected in the financial report. (Ref: Para. A7‑A9, A14, A22)\n\nDescription of Management’s Responsibilities in the Written Representations\n\n1.  Management’s responsibilities shall be described in the written representations required by paragraphs 10 and 11 of this Auditing Standard in the manner in which these responsibilities are described in the terms of the audit engagement.","sortOrder":22},{"sectionNumber":"Other Written Representations","sectionType":"section","heading":"Other Written Representations","content":"###### Other Written Representations\n\n1.  Other Auditing Standards require the auditor to request written representations. If, in addition to such required representations, the auditor determines that it is necessary to obtain one or more written representations to support other audit evidence relevant to the financial report or one or more specific assertions in the financial report, the auditor shall request such other written representations. (Ref: Para. A10‑A14, A22)","sortOrder":23},{"sectionNumber":"Date of and Period(s) Covered by Written","sectionType":"section","heading":"Date of and Period(s) Covered by Written Representations","content":"###### Date of and Period(s) Covered by Written Representations\n\n1.  The date of the written representations shall be as near as practicable to, but not after, the date of the auditor’s report on the financial report. The written representations shall be for all the financial report(s) and period(s) referred to in the auditor’s report. (Ref: Para. A15‑A18)","sortOrder":24},{"sectionNumber":"Form of Written Representations","sectionType":"section","heading":"Form of Written Representations","content":"###### Form of Written Representations\n\n1.  The written representations shall be in the form of a representation letter addressed to the auditor. If law or regulation requires management to make written public statements about its responsibilities, and the auditor determines that such statements provide some or all of the representations required by paragraphs 10 or 11 of this Auditing Standard, the relevant matters covered by such statements need not be included in the representation letter. (Ref: Para. A19‑A21)","sortOrder":25},{"sectionNumber":"Doubt as to the Reliability of Written R","sectionType":"section","heading":"Doubt as to the Reliability of Written Representations and Requested Written Representations Not Provided","content":"###### Doubt as to the Reliability of Written Representations and Requested Written Representations Not Provided\n\nDoubt as to the Reliability of Written Representations\n\n1.  If the auditor has concerns about the competence, integrity, ethical values or diligence of management, or about its commitment to or enforcement of these, the auditor shall determine the effect that such concerns may have on the reliability of representations (oral or written) and audit evidence in general. (Ref: Para. A24‑A25)\n2.  In particular, if written representations are inconsistent with other audit evidence, the auditor shall perform audit procedures to attempt to resolve the matter. If the matter remains unresolved, the auditor shall reconsider the assessment of the competence, integrity, ethical values or diligence of management, or of its commitment to or enforcement of these, and shall determine the effect that this may have on the reliability of representations (oral or written) and audit evidence in general. (Ref: Para. A23)\n3.  If the auditor concludes that the written representations are not reliable, the auditor shall take appropriate actions, including determining the possible effect on the opinion in the auditor’s report in accordance with ASA 705,[\\[4\\]](#_ftn5) having regard to the requirement in paragraph 20 of this Auditing Standard.\n\nRequested Written Representations Not Provided\n\n1.  If management does not provide one or more of the requested written representations, the auditor shall:\n    1.  Discuss the matter with management;\n    2.  Re‑evaluate the integrity of management and evaluate the effect that this may have on the reliability of representations (oral or written) and audit evidence in general; and\n    3.  Take appropriate actions, including determining the possible effect on the opinion in the auditor’s report in accordance with ASA 705, having regard to the requirement in paragraph 20 of this Auditing Standard.\n\nWritten Representations about Management’s Responsibilities\n\n1.  The auditor shall disclaim an opinion on the financial report in accordance with ASA 705 if:\n    1.  The auditor concludes that there is sufficient doubt about the integrity of management such that the written representations required by paragraphs 10 and 11 of this Auditing Standard are not reliable; or\n    2.  Management does not provide the written representations required by paragraphs 10 and 11 of this Auditing Standard. (Ref: Para. A26‑A27)\n\n\\* \\* \\*","sortOrder":26},{"sectionNumber":"Application and Other Explanatory Materi","sectionType":"section","heading":"Application and Other Explanatory Material","content":"Auditing Standard ASA 580\n\nThe Auditing and Assurance Standards Board (AUASB) made Auditing Standard ASA 580 Written Representations pursuant to section 227B of the Australian Securities and Investments Commission Act 2001 and section 336 of the Corporations Act 2001, on 27 October 2009.\n\nThis compiled version of ASA 580 incorporates subsequent amendments contained in other Auditing Standards made by the AUASB up to and including 15 March 2023 (see Compilation Details).\n\n## Auditing Standard ASA 580\n\n### Written Representations\n\n##### Application\n\nAus 0.1 This Auditing Standard applies to:\n\n(a) an audit of a financial report for a financial year, or an audit of a financial report for a half‑year, in accordance with the Corporations Act 2001; and\n\n(b) an audit of a financial report, or a complete set of financial statements, for any other purpose.\n\nAus 0.2 This Auditing Standard also applies, as appropriate, to an audit of other historical financial information.\n\n##### Operative Date\n\nAus 0.3 This Auditing Standard is operative for financial reporting periods commencing on or after 1 January 2010. \\[Note: For operative dates of paragraphs changed or added by an Amending Standard, see Compilation Details.\\]\n\n##### Introduction\n\n###### Scope of this Auditing Standard\n\n1.  This Auditing Standard deals with the auditor’s responsibility to obtain written representations from management and, where appropriate, those charged with governance in an audit of a financial report.\n2.  Appendix 1 lists other Australian Auditing Standards containing subject‑matter specific requirements for written representations. The specific requirements for written representations of other Australian Auditing Standards do not limit the application of this Auditing Standard.\n\n###### Written Representations as Audit Evidence\n\n1.  Audit evidence is the information used by the auditor in arriving at the conclusions on which the auditor’s opinion is based.[\\[1\\]](#_ftn2) Written representations are necessary information that the auditor requires in connection with the audit of the entity’s financial report. Accordingly, similar to responses to enquiries, written representations are audit evidence. (Ref: Para. A1)\n2.  Although written representations provide necessary audit evidence, they do not provide sufficient appropriate audit evidence on their own about any of the matters with which they deal. Furthermore, the fact that management has provided reliable written representations does not affect the nature or extent of other audit evidence that the auditor obtains about the fulfilment of management’s responsibilities, or about specific assertions.\n\n###### Effective Date\n\n1.  \\[Deleted by the AUASB. Refer Aus 0.3\\]\n\n##### Objectives\n\n1.  The objectives of the auditor are:\n    1.  To obtain written representations from management and, where appropriate, those charged with governance that they believe that they have fulfilled their responsibility for the preparation of the financial report and for the completeness of the information provided to the auditor;\n    2.  To support other audit evidence relevant to the financial report or specific assertions in the financial report by means of written representations if determined necessary by the auditor or required by other Australian Auditing Standards; and\n    3.  To respond appropriately to written representations provided by management and, where appropriate, those charged with governance, or if management or, where appropriate, those charged with governance do not provide the written representations requested by the auditor.\n\n##### Definitions\n\n1.  For the purposes of this Auditing Standard, the following terms have the meanings attributed below:\n\nWritten representation means a written statement by management provided to the auditor to confirm certain matters or to support other audit evidence. Written representations in this context do not include the financial report, the assertions therein, or supporting books and records.\n\n1.  For purposes of this Auditing Standard, references to “management” should be read as “management and, where appropriate, those charged with governance.” Furthermore, in the case of a fair presentation framework, management is responsible for the preparation and fair presentation of the financial report in accordance with the applicable financial reporting framework; or the preparation of a financial report that gives a true and fair view in accordance with the applicable financial reporting framework.\n\n##### Requirements\n\n###### Management from whom Written Representations are Requested\n\n1.  The auditor shall request written representations from management with appropriate responsibilities for the financial report and knowledge of the matters concerned. (Ref: Para. A2‑A6)\n\n###### Written Representations about Management’s Responsibilities\n\nPreparation of the Financial report\n\n1.  The auditor shall request management to provide a written representation that it has fulfilled its responsibility for the preparation of the financial report in accordance with the applicable financial reporting framework, and other statutory reporting requirements, including where relevant their fair presentation, as set out in the terms of the audit engagement.[\\[2\\]](#_ftn3) (Ref: Para. A7‑A9, A14, A22)\n\nInformation Provided and Completeness of Transactions\n\n1.  The auditor shall request management to provide a written representation that:\n    1.  It has provided the auditor with all relevant information and access as agreed in the terms of the audit engagement;[\\[3\\]](#_ftn4) and\n    2.  All transactions have been recorded and are reflected in the financial report. (Ref: Para. A7‑A9, A14, A22)\n\nDescription of Management’s Responsibilities in the Written Representations\n\n1.  Management’s responsibilities shall be described in the written representations required by paragraphs 10 and 11 of this Auditing Standard in the manner in which these responsibilities are described in the terms of the audit engagement.\n\n###### Other Written Representations\n\n1.  Other Auditing Standards require the auditor to request written representations. If, in addition to such required representations, the auditor determines that it is necessary to obtain one or more written representations to support other audit evidence relevant to the financial report or one or more specific assertions in the financial report, the auditor shall request such other written representations. (Ref: Para. A10‑A14, A22)\n\n###### Date of and Period(s) Covered by Written Representations\n\n1.  The date of the written representations shall be as near as practicable to, but not after, the date of the auditor’s report on the financial report. The written representations shall be for all the financial report(s) and period(s) referred to in the auditor’s report. (Ref: Para. A15‑A18)\n\n###### Form of Written Representations\n\n1.  The written representations shall be in the form of a representation letter addressed to the auditor. If law or regulation requires management to make written public statements about its responsibilities, and the auditor determines that such statements provide some or all of the representations required by paragraphs 10 or 11 of this Auditing Standard, the relevant matters covered by such statements need not be included in the representation letter. (Ref: Para. A19‑A21)\n\n###### Doubt as to the Reliability of Written Representations and Requested Written Representations Not Provided\n\nDoubt as to the Reliability of Written Representations\n\n1.  If the auditor has concerns about the competence, integrity, ethical values or diligence of management, or about its commitment to or enforcement of these, the auditor shall determine the effect that such concerns may have on the reliability of representations (oral or written) and audit evidence in general. (Ref: Para. A24‑A25)\n2.  In particular, if written representations are inconsistent with other audit evidence, the auditor shall perform audit procedures to attempt to resolve the matter. If the matter remains unresolved, the auditor shall reconsider the assessment of the competence, integrity, ethical values or diligence of management, or of its commitment to or enforcement of these, and shall determine the effect that this may have on the reliability of representations (oral or written) and audit evidence in general. (Ref: Para. A23)\n3.  If the auditor concludes that the written representations are not reliable, the auditor shall take appropriate actions, including determining the possible effect on the opinion in the auditor’s report in accordance with ASA 705,[\\[4\\]](#_ftn5) having regard to the requirement in paragraph 20 of this Auditing Standard.\n\nRequested Written Representations Not Provided\n\n1.  If management does not provide one or more of the requested written representations, the auditor shall:\n    1.  Discuss the matter with management;\n    2.  Re‑evaluate the integrity of management and evaluate the effect that this may have on the reliability of representations (oral or written) and audit evidence in general; and\n    3.  Take appropriate actions, including determining the possible effect on the opinion in the auditor’s report in accordance with ASA 705, having regard to the requirement in paragraph 20 of this Auditing Standard.\n\nWritten Representations about Management’s Responsibilities\n\n1.  The auditor shall disclaim an opinion on the financial report in accordance with ASA 705 if:\n    1.  The auditor concludes that there is sufficient doubt about the integrity of management such that the written representations required by paragraphs 10 and 11 of this Auditing Standard are not reliable; or\n    2.  Management does not provide the written representations required by paragraphs 10 and 11 of this Auditing Standard. (Ref: Para. A26‑A27)\n\n\\* \\* \\*\n\n##### Application and Other Explanatory Material\n\n###### Written Representations as Audit Evidence (Ref: Para. 3)\n\n1.  Written representations are an important source of audit evidence. If management modifies or does not provide the requested written representations, it may alert the auditor to the possibility that one or more significant issues may exist. Further, a request for written, rather than oral, representations in many cases may prompt management to consider such matters more rigorously, thereby enhancing the quality of the representations.\n\n###### Management from whom Written Representations are Requested (Ref: Para. 9)\n\n1.  Written representations are requested from those responsible for the preparation of the financial report. Those individuals may vary depending on the governance structure of the entity, and relevant law or regulation; however, management (rather than those charged with governance) is often the responsible party. Written representations may therefore be requested from the entity’s chief executive officer and chief financial officer, or other equivalent persons in entities that do not use such titles. In some circumstances, however, other parties, such as those charged with governance, are also responsible for the preparation of the financial report.\n2.  Due to its responsibility for the preparation of the financial report, and its responsibilities for the conduct of the entity’s business, management would be expected to have sufficient knowledge of the process followed by the entity in preparing and presenting the financial report and the assertions therein on which to base the written representations.\n3.  In some cases, however, management may decide to make enquiries of others who participate in preparing and presenting the financial report and assertions therein, including individuals who have specialised knowledge relating to the matters about which written representations are requested. Such individuals may include:\n\n-   An actuary responsible for actuarially determined accounting measurements.\n-   Staff engineers who may have responsibility for and specialised knowledge about environmental liability measurements.\n-   Internal counsel who may provide information essential to provisions for legal claims.\n\n1.  In some cases, management may include in the written representations qualifying language to the effect that representations are made to the best of its knowledge and belief. It is reasonable for the auditor to accept such wording if the auditor is satisfied that the representations are being made by those with appropriate responsibilities and knowledge of the matters included in the representations.\n2.  To reinforce the need for management to make informed representations, the auditor may request that management include in the written representations confirmation that it has made such enquiries as it considered appropriate to place it in the position to be able to make the requested written representations. It is not expected that such enquiries would usually require a formal internal process beyond those already established by the entity.\n\n###### Written Representations about Management’s Responsibilities (Ref: Para. 10‑11)\n\n1.  Audit evidence obtained during the audit that management has fulfilled the responsibilities referred to in paragraphs 10 and 11 is not sufficient without obtaining confirmation from management that it believes that it has fulfilled those responsibilities. This is because the auditor is not able to judge solely on other audit evidence whether management has prepared and presented the financial report and provided information to the auditor on the basis of the agreed acknowledgement and understanding of its responsibilities. For example, the auditor could not conclude that management has provided the auditor with all relevant information agreed in the terms of the audit engagement without asking it whether, and receiving confirmation that, such information has been provided.\n2.  The written representations required by paragraphs 10 and 11 draw on the agreed acknowledgement and understanding of management of its responsibilities in the terms of the audit engagement by requesting confirmation that it has fulfilled them. The auditor may also ask management to reconfirm its acknowledgement and understanding of those responsibilities in written representations. This is common in certain jurisdictions, but in any event may be particularly appropriate when:\n\n-   Those who signed the terms of the audit engagement on behalf of the entity no longer have the relevant responsibilities;\n-   The terms of the audit engagement were prepared in a previous year;\n-   There is any indication that management misunderstands those responsibilities; or\n-   Changes in circumstances make it appropriate to do so.\n-   Consistent with the requirement of ASA 210,[\\[5\\]](#_ftn6) such reconfirmation of management’s acknowledgement and understanding of its responsibilities is not made subject to the best of management’s knowledge and belief (as discussed in paragraph A5).\n\nConsiderations Specific to Public Sector Entities\n\n1.  The mandates for audits of financial reports of public sector entities may be broader than those of other entities. As a result, the premise, relating to management’s responsibilities, on which an audit of the financial report of a public sector entity is conducted may give rise to additional written representations. These may include written representations confirming that transactions and events have been carried out in accordance with law, regulation or other authority.\n\n###### Other Written Representations (Ref: Para. 13)\n\nAdditional Written Representations about the Financial Report\n\n1.  In addition to the written representation required by paragraph 10, the auditor may consider it necessary to request other written representations about the financial report. Such written representations may supplement, but do not form part of, the written representation required by paragraph 10. They may include representations about the following:\n\n-   Whether the selection and application of accounting policies are appropriate; and\n-   Whether matters such as the following, where relevant under the applicable financial reporting framework, have been recognised, measured, presented or disclosed in accordance with that framework:\n    -   Plans or intentions that may affect the carrying value or classification of assets and liabilities;\n    -   Liabilities, both actual and contingent;\n    -   Title to, or control over, assets, the liens or encumbrances on assets, and assets pledged as collateral; and\n    -   Aspects of laws, regulations and contractual agreements that may affect the financial report, including non‑compliance.\n\nAdditional Written Representations about Information Provided to the Auditor\n\n1.  In addition to the written representation required by paragraph 11, the auditor may consider it necessary to request management to provide a written representation that it has communicated to the auditor all deficiencies in internal control of which management is aware.\n\nWritten Representations about Specific Assertions\n\n1.  When obtaining evidence about, or evaluating, judgements and intentions, the auditor may consider one or more of the following:\n\n-   The entity’s past history in carrying out its stated intentions.\n-   The entity’s reasons for choosing a particular course of action.\n-   The entity’s ability to pursue a specific course of action.\n-   The existence or lack of any other information that might have been obtained during the course of the audit that may be inconsistent with management’s judgement or intent.\n\n1.  In addition, the auditor may consider it necessary to request management to provide written representations about specific assertions in the financial report; in particular, to support an understanding that the auditor has obtained from other audit evidence of management’s judgement or intent in relation to, or the completeness of, a specific assertion. For example, if the intent of management is important to the valuation basis for investments, it may not be possible to obtain sufficient appropriate audit evidence without a written representation from management about its intentions. Although such written representations provide necessary audit evidence, they do not provide sufficient appropriate audit evidence on their own for that assertion.\n\n###### Communicating a Threshold Amount (Ref: Para. 10‑11, 13)\n\n1.  ASA 450 requires the auditor to accumulate misstatements identified during the audit, other than those that are clearly trivial.[\\[6\\]](#_ftn7) The auditor may determine a threshold above which misstatements cannot be regarded as clearly trivial. In the same way, the auditor may consider communicating to management a threshold for purposes of the requested written representations.\n\n###### Date of and Period(s) Covered by Written Representations (Ref: Para. 14)\n\n1.  Because written representations are necessary audit evidence, the auditor’s opinion cannot be expressed, and the auditor’s report cannot be dated, before the date of the written representations. Furthermore, because the auditor is concerned with events occurring up to the date of the auditor’s report that may require adjustment to or disclosure in the financial report, the written representations are dated as near as practicable to, but not after, the date of the auditor’s report on the financial report.\n2.  In some circumstances, it may be appropriate for the auditor to obtain a written representation about a specific assertion in the financial report during the course of the audit. Where this is the case, it may be necessary to request an updated written representation.\n3.  The written representations are for all periods referred to in the auditor’s report because management needs to reaffirm that the written representations it previously made with respect to the prior periods remain appropriate. The auditor and management may agree to a form of written representation that updates written representations relating to the prior periods by addressing whether there are any changes to such written representations and, if so, what they are.\n4.  Situations may arise where current management were not present during all periods referred to in the auditor’s report. Such persons may assert that they are not in a position to provide some or all of the written representations because they were not in place during the period. This fact, however, does not diminish such persons’ responsibilities for the financial report as a whole. Accordingly, the requirement for the auditor to request from them written representations that cover the whole of the relevant period(s) still applies.\n\n###### Form of Written Representations (Ref: Para. 15)\n\n1.  Written representations are required to be included in a representation letter addressed to the auditor. In some jurisdictions, however, management may be required by law or regulation to make a written public statement about its responsibilities. Although such a statement is a representation to the users of the financial report, or to relevant authorities, the auditor may determine that it is an appropriate form of written representation in respect of some or all of the representations required by paragraph 10 or 11. Consequently, the relevant matters covered by such a statement need not be included in the representation letter. Factors that may affect the auditor’s determination include:\n\n-   Whether the statement includes confirmation of the fulfilment of the responsibilities referred to in paragraphs 10 and 11.\n-   Whether the statement has been given or approved by those from whom the auditor requests the relevant written representations.\n-   Whether a copy of the statement is provided to the auditor as near as practicable to, but not after, the date of the auditor’s report on the financial report (see paragraph 14).\n\n1.  A formal statement of compliance with law or regulation, or of approval of the financial report, would not contain sufficient information for the auditor to be satisfied that all necessary representations have been consciously made. The expression of management’s responsibilities in law or regulation is also not a substitute for the requested written representations.\n2.  Appendix 2 provides an illustrative example of a representation letter.\n\n###### Communication with Those Charged with Governance (Ref: Para. 10‑11, 13)\n\n1.  ASA 260 requires the auditor to communicate with those charged with governance the written representations which the auditor has requested from management.[\\[7\\]](#_ftn8)\n\n###### Doubt as to the Reliability of Written Representations and Requested Written Representations Not Provided\n\nDoubt as to the Reliability of Written Representations (Ref: Para. 16‑17)\n\n1.  In the case of identified inconsistencies between one or more written representations and audit evidence obtained from another source, the auditor may consider whether the risk assessment remains appropriate and, if not, revise the risk assessment and determine the nature, timing and extent of further audit procedures to respond to the assessed risks.\n2.  Concerns about the competence, integrity, ethical values or diligence of management, or about its commitment to or enforcement of these, may cause the auditor to conclude that the risk of management misrepresentation in the financial report is such that an audit cannot be conducted. In such a case, the auditor may consider withdrawing from the engagement, where withdrawal is possible under applicable law or regulation, unless those charged with governance put in place appropriate corrective measures. Such measures, however, may not be sufficient to enable the auditor to issue an unmodified audit opinion.\n3.  ASA 230 requires the auditor to document significant matters arising during the audit, the conclusions reached thereon, and significant professional judgements made in reaching those conclusions.[\\[8\\]](#_ftn9) The auditor may have identified significant issues relating to the competence, integrity, ethical values or diligence of management, or about its commitment to or enforcement of these, but concluded that the written representations are nevertheless reliable. In such a case, this significant matter is documented in accordance with ASA 230.\n\nWritten Representations about Management’s Responsibilities (Ref: Para. 20)\n\n1.  As explained in paragraph A7, the auditor is not able to judge solely on other audit evidence whether management has fulfilled the responsibilities referred to in paragraphs 10 and 11. Therefore, if, as described in paragraph 20(a), the auditor concludes that the written representations about these matters are unreliable, or if management does not provide those written representations, the auditor is unable to obtain sufficient appropriate audit evidence. The possible effects on the financial report of such inability are not confined to specific elements, accounts or items of the financial report and are hence pervasive. ASA 705 requires the auditor to disclaim an opinion on the financial report in such circumstances.[\\[9\\]](#_ftn10)\n\nIf Management do not Provide Written Representations\n\nAus A26.1 If management do not provide written representations, the auditor would ordinarily:\n\n(a) draw to the attention of those charged with governance any relevant regulatory requirements which give the auditor a right of access to any requested information, explanations or assistance for the purposes of the audit;[\\[\\*\\]](#_ftn11)\n\n(b) consider any other implications of the refusal that may have any effect on the auditor’s report;[\\[#\\]](#_ftn12) and\n\n(c) consider whether the auditor has any regulatory obligation to report that management has not provided a written representation.[\\[†\\]](#_ftn13)\n\n1.  A written representation that has been modified from that requested by the auditor does not necessarily mean that management did not provide the written representation. However, the underlying reason for such modification may affect the opinion in the auditor’s report. For example:\n\n-   The written representation about management’s fulfilment of its responsibility for the preparation of the financial report may state that management believes that, except for material non‑compliance with a particular requirement of the applicable financial reporting framework, the financial report is prepared in accordance with that framework. The requirement in paragraph 20 does not apply because the auditor concluded that management has provided reliable written representations. However, the auditor is required to consider the effect of the non‑compliance on the opinion in the auditor’s report in accordance with ASA 705.\n-   The written representation about the responsibility of management to provide the auditor with all relevant information agreed in the terms of the audit engagement may state that management believes that, except for information destroyed in a fire, it has provided the auditor with such information. The requirement in paragraph 20 does not apply because the auditor concluded that management has provided reliable written representations. However, the auditor is required to consider the effects of the pervasiveness of the information destroyed in the fire on the financial report and the effect thereof on the opinion in the auditor’s report in accordance with ASA 705.","sortOrder":27},{"sectionNumber":"Other Written Representations (Ref: Para","sectionType":"section","heading":"Other Written Representations (Ref: Para. 13)","content":"###### Other Written Representations (Ref: Para. 13)\n\nAdditional Written Representations about the Financial Report\n\n1.  In addition to the written representation required by paragraph 10, the auditor may consider it necessary to request other written representations about the financial report. Such written representations may supplement, but do not form part of, the written representation required by paragraph 10. They may include representations about the following:\n\n-   Whether the selection and application of accounting policies are appropriate; and\n-   Whether matters such as the following, where relevant under the applicable financial reporting framework, have been recognised, measured, presented or disclosed in accordance with that framework:\n    -   Plans or intentions that may affect the carrying value or classification of assets and liabilities;\n    -   Liabilities, both actual and contingent;\n    -   Title to, or control over, assets, the liens or encumbrances on assets, and assets pledged as collateral; and\n    -   Aspects of laws, regulations and contractual agreements that may affect the financial report, including non‑compliance.\n\nAdditional Written Representations about Information Provided to the Auditor\n\n1.  In addition to the written representation required by paragraph 11, the auditor may consider it necessary to request management to provide a written representation that it has communicated to the auditor all deficiencies in internal control of which management is aware.\n\nWritten Representations about Specific Assertions\n\n1.  When obtaining evidence about, or evaluating, judgements and intentions, the auditor may consider one or more of the following:\n\n-   The entity’s past history in carrying out its stated intentions.\n-   The entity’s reasons for choosing a particular course of action.\n-   The entity’s ability to pursue a specific course of action.\n-   The existence or lack of any other information that might have been obtained during the course of the audit that may be inconsistent with management’s judgement or intent.\n\n1.  In addition, the auditor may consider it necessary to request management to provide written representations about specific assertions in the financial report; in particular, to support an understanding that the auditor has obtained from other audit evidence of management’s judgement or intent in relation to, or the completeness of, a specific assertion. For example, if the intent of management is important to the valuation basis for investments, it may not be possible to obtain sufficient appropriate audit evidence without a written representation from management about its intentions. Although such written representations provide necessary audit evidence, they do not provide sufficient appropriate audit evidence on their own for that assertion.","sortOrder":31},{"sectionNumber":"Communicating a Threshold Amount (Ref: P","sectionType":"section","heading":"Communicating a Threshold Amount (Ref: Para. 10‑11, 13)","content":"###### Communicating a Threshold Amount (Ref: Para. 10‑11, 13)\n\n1.  ASA 450 requires the auditor to accumulate misstatements identified during the audit, other than those that are clearly trivial.[\\[6\\]](#_ftn7) The auditor may determine a threshold above which misstatements cannot be regarded as clearly trivial. In the same way, the auditor may consider communicating to management a threshold for purposes of the requested written representations.","sortOrder":32},{"sectionNumber":"Form of Written Representations (Ref: Pa","sectionType":"section","heading":"Form of Written Representations (Ref: Para. 15)","content":"###### Form of Written Representations (Ref: Para. 15)\n\n1.  Written representations are required to be included in a representation letter addressed to the auditor. In some jurisdictions, however, management may be required by law or regulation to make a written public statement about its responsibilities. Although such a statement is a representation to the users of the financial report, or to relevant authorities, the auditor may determine that it is an appropriate form of written representation in respect of some or all of the representations required by paragraph 10 or 11. Consequently, the relevant matters covered by such a statement need not be included in the representation letter. Factors that may affect the auditor’s determination include:\n\n-   Whether the statement includes confirmation of the fulfilment of the responsibilities referred to in paragraphs 10 and 11.\n-   Whether the statement has been given or approved by those from whom the auditor requests the relevant written representations.\n-   Whether a copy of the statement is provided to the auditor as near as practicable to, but not after, the date of the auditor’s report on the financial report (see paragraph 14).\n\n1.  A formal statement of compliance with law or regulation, or of approval of the financial report, would not contain sufficient information for the auditor to be satisfied that all necessary representations have been consciously made. The expression of management’s responsibilities in law or regulation is also not a substitute for the requested written representations.\n2.  Appendix 2 provides an illustrative example of a representation letter.","sortOrder":34},{"sectionNumber":"Communication with Those Charged with Go","sectionType":"section","heading":"Communication with Those Charged with Governance (Ref: Para. 10‑11, 13)","content":"###### Communication with Those Charged with Governance (Ref: Para. 10‑11, 13)\n\n1.  ASA 260 requires the auditor to communicate with those charged with governance the written representations which the auditor has requested from management.[\\[7\\]](#_ftn8)","sortOrder":35},{"sectionNumber":"List of Australian Auditing Standards Co","sectionType":"section","heading":"List of Australian Auditing Standards Containing Requirements for Written Representations","content":"##### List of Australian Auditing Standards Containing Requirements for Written Representations\n\nThis appendix identifies paragraphs in other Auditing Standards that require subject‑matter specific written representations. The list is not a substitute for considering the requirements and related application and other explanatory material in the Australian Auditing Standards.\n\nASA 240 The Auditor’s Responsibilities Relating to Fraud in an Audit of the Financial Report – paragraph 40\n\nASA 250 Consideration of Laws and Regulations in an Audit of a Financial Report – paragraph 17\n\nASA 450 Evaluation of Misstatements Identified during the Audit – paragraph 14\n\nASA 502 Audit Evidence—Specific Considerations for Litigation and Claims – paragraph 7\n\nASA 540 Auditing Accounting Estimates and Related Disclosures – paragraph 37\n\nASA 550 Related Parties – paragraph 26\n\nASA 560 Subsequent Events – paragraph 9\n\nASA 570 Going Concern – paragraph 16(e)\n\nASA 710 Comparative Information—Corresponding Figures and Comparative Financial Reports – paragraph 9\n\nASA 720 The Auditor’s Responsibilities Relating to Other Information, paragraph 13(c)","sortOrder":37},{"sectionNumber":"Illustrative Representation Letter","sectionType":"section","heading":"Illustrative Representation Letter","content":"##### Illustrative Representation Letter\n\nThe following illustrative letter includes written representations that are required by this and other Auditing Standards, in effect for audits of financial reports for periods beginning on or after 1 January 2010. It is assumed in this illustration that the applicable financial reporting framework is the Australian Accounting Standards and the Corporations Act 2001; the requirement of ASA 570[\\[10\\]](#_ftn14) and ASA 710# to obtain a written representation is not relevant; and that there are no exceptions to the requested written representations. If there were exceptions, the representations would need to be modified to reflect the exceptions.\n\n(Entity Letterhead)\n\n(To Auditor)\n\n(Date)\n\nThis representation letter is provided in connection with your audit of the financial report of ABC Company Ltd for the year ended 30 June 20XX[\\[11\\]](#_ftn15) \\[or period covered by the auditor’s report\\] for the purpose of expressing an opinion as to whether the financial report gives a true and fair view in accordance with the Australian Accounting Standards and the Corporations Act 2001.\n\nWe confirm that (to the best of our knowledge and belief, having made such enquiries as we considered necessary for the purpose of appropriately informing ourselves):\n\nFinancial Report\n\n-   We have fulfilled our responsibilities, as set out in the terms of the audit engagement dated \\[insert date\\], for the preparation of the financial report in accordance with Australian Accounting Standards and the Corporations Act 2001; in particular the financial report gives a true and fair view in accordance therewith.\n-   The methods, the data, and the significant assumptions used in making accounting estimates, and their related disclosures are appropriate to achieve recognition, measurement or disclosure that is reasonable in the context of the applicable financial reporting framework. (ASA 540)\n-   Related party relationships and transactions have been appropriately accounted for and disclosed in accordance with the requirements of Australian Accounting Standards. (ASA 550)\n-   All events subsequent to the date of the financial report and for which Australian Accounting Standards require adjustment or disclosure have been adjusted or disclosed. (ASA 560)\n-   The effects of uncorrected misstatements are immaterial, both individually and in the aggregate, to the financial report as a whole. A list of the uncorrected misstatements is attached to the representation letter. (ASA 450)\n-   \\[Any other matters that the auditor may consider appropriate (see paragraph A10).\\]\n\n  \n\nInformation Provided[\\[12\\]](#_ftn16)\n\n-   We have provided you with:\n    -   Access to all information of which we are aware that is relevant to the preparation of the financial report such as records, documentation and other matters;\n    -   Additional information that you have requested from us for the purpose of the audit; and\n    -   Unrestricted access to persons within the entity from whom you determined it necessary to obtain audit evidence.\n-   All transactions have been recorded in the accounting records and are reflected in the financial report.\n-   We acknowledge our responsibility for the design, implementation and maintenance of internal control to prevent and detect fraud.\n-   We have disclosed to you the results of our assessment of the risk that the financial report may be materially misstated as a result of fraud. (ASA 240)\n-   We have disclosed to you all information in relation to fraud or suspected fraud that we are aware of and that affects the entity and involves:\n    -   Management;\n    -   Employees who have significant roles in internal control; or\n    -   Others where the fraud could have a material effect on the financial report. (ASA 240)\n-   We have disclosed to you all information in relation to allegations of fraud, or suspected fraud, affecting the entity’s financial report communicated by employees, former employees, analysts, regulators or others. (ASA 240)\n-   We have disclosed to you all known instances of non‑compliance or suspected non‑compliance with laws and regulations whose effects should be considered when preparing the financial report. (ASA 250)\n-   We have disclosed to you all known actual or possible litigation and claims whose effects should be considered when preparing the financial report; and accounted for and disclosed in accordance with \\[the applicable financial reporting framework\\]. (ASA 502)\n-   We have disclosed to you the identity of the entity’s related parties and all the related party relationships and transactions of which we are aware. (ASA 550)\n-   Aus In respect of other information:\n    -   We have informed you of all the documents that we expect to issue that may comprise other information;\n\nIf the other information has been provided prior to the auditor’s report date:\n\n-   \\[The financial report and any other information obtained by you prior to the date of your auditor’s report is consistent with one another, and the other information does not contain any material misstatements;\\] or\n\nIf the other information will not be provided prior to the auditor’s report date:\n\n-   \\[With regard to any other information that we have not provided to you prior to the date of the auditor’s report, that we intend to prepare and issue such other information and that we expect to issue it by \\[insert date.\\] and will provide it to you to enable you to complete your required procedures.\\]\n\n-   \\[Any other matters that the auditor may consider necessary (see paragraph A11).\\]\n-   Aus We have provided you with all requested information, explanations and assistance for the purposes of the audit.[\\[\\*\\]](#_ftn17)\n-   Aus We have provided you with all information required by the Corporations Act 2001 \\[where applicable\\].[\\[#\\]](#_ftn18)\n\n| Management |     |\n| ---------- | --- |","sortOrder":38}],"analysis":{"flash_summary":{"complexity_score":5,"scope_assessment":{"changed":false,"description":"The compiled ASA 580 retains the original core purpose — requiring auditors to obtain written representations from management — and aligns the Australian standard with ISA 580 while adding Australian‑specific paragraphs (marked Aus) and updates. Amendments since 2009 have adjusted drafting, appended illustrative material, and added cross‑references to other Australian Standards, but they do not materially broaden the standard’s subject matter beyond obtaining and handling written representations and the auditor’s responses when they are unreliable or withheld (see paras 3, 9–20; Aus additions and Compilation Details)."},"complexity_factors":["Multiple cross‑references to other AUASB Standards (Appendix 1 lists 11 Standards; paras throughout reference ASA 210, ASA 230, ASA 240, ASA 450, ASA 705, ASA 260 etc.)","Compilation includes six amending Standards and several Aus‑prefixed (Australia‑specific) paragraphs (Compilation Details and Table of Standards)","Clear conditional logic and nested responses for unreliable or absent representations (paras 16–20; Aus A26.1) — several stepwise requirements","Guidance material and examples in a long Application/Explanatory section and an illustrative representation letter (Appendix 2) increasing drafting/implementation detail","Timing constraints and coverage rules (date must be as near as practicable to, but not after, auditor’s report; covers all periods) create sequencing dependencies (para. 14; paras A15–A18)","Discretionary determinations for accepting public statements in lieu of parts of the representation letter (para. 15; paras A19–A21)","Amendments and renumbering over time (Table of Amendments) require attention when mapping historical practice to current obligations","Multiple repeating clauses and duplicated compilation text increase navigation time for a reader (compiled document repetition noted in text)"],"plain_english_summary":"**What this standard does (mechanics first)\n\n- Requires the auditor to ask management (or, where appropriate, those charged with governance) for written confirmations — normally a signed representation letter — about certain matters relevant to the audit of the financial report (see para. 9; paras 14–15).\n- Specifies the minimum topics the auditor must cover in those written representations, notably that management has met its responsibilities for preparing the financial report in accordance with the applicable framework, has given the auditor all relevant information and access, and that all transactions have been recorded (paras 10–11). Appendix 2 provides an illustrative representation letter.\n- Allows the auditor to request additional written representations where needed to support other audit evidence or particular assertions (para. 13; Appendix 1 lists other Standards that require subject‑matter specific representations).\n- Fixes timing and form rules: the representation letter should be dated as close as practicable to, but not after, the auditor’s report date and should cover all periods referred to in the auditor’s report (para. 14). It is normally addressed to the auditor (para. 15).\n- Sets out the auditor’s responses when written representations are inconsistent with other evidence, are unreliable, or are not provided: discuss with management, re‑assess management’s integrity and the reliability of evidence, perform further procedures, and if unresolved the auditor may need to qualify or disclaim an opinion in accordance with ASA 705 (paras 16–20; Aus A26.1).\n- Allows, in certain cases, acceptance of law‑ or regulation‑required public statements in place of (some of) the representation letter if the auditor is satisfied they cover the same matters and are provided timely (para. 15; para. A19).\n\nWhy the AUASB says this matters (official rationale)\n\n- The AUASB treats written representations as necessary audit evidence that help the auditor confirm management’s acknowledgement of responsibilities and certain facts or intentions (para. 3; para. A1). The standard says written reps prompt management to consider matters more rigorously and support other audit evidence (para. A1).\n\nTesting that rationale against costs, incentives and practical trade‑offs\n\n- Who pays and who decides: management must prepare, review and sign the representation letter; the auditor decides the content, timing and whether to accept any substitute public statements (paras 9, 15). That creates a modest compliance cost for the audited entity (preparing confirmations, making enquiries of specialists) and some administrative cost for the auditor (drafting, following up and documenting) (paras A2–A6; A19–A21).\n- Incentives and behaviour change: the requirement increases the chance management will consciously consider and document positions (para. A1). It also gives auditors a formal lever: an absent or modified representation is a red flag that triggers further procedures or reporting consequences (paras 16–20; Aus A26.1).\n- Substitution and reliance effects: the standard explicitly warns that written representations are necessary but not sufficient on their own — auditors must obtain other appropriate evidence (para. 3). That reduces the risk that firms will replace substantive testing with mere letters, but it leaves judgment to auditors about when additional representations are adequate (paras A10–A14).\n- Concentrated benefits, diffuse costs: benefits are concentrated (auditors obtain documented confirmations that support audit conclusions and file documentation). Costs are diffuse across audited entities (time to prepare letters, internal enquiries, potential delay to audit sign‑off) (paras 14–15; paras A15–A18).\n- Compliance and implementation risk: the auditor has discretion to accept public statements as partial substitutes, to set thresholds for misstatements communicated to management, and to decide when to perform extra procedures — those discretionary points create room for inconsistent practice across engagements (paras A14; para 15; para A14). If management refuses or supplies unreliable representations, the auditor may have to withhold or disclaim an opinion (paras 16–20), which can materially delay or affect the entity’s published results.\n- Opportunity cost and timing: because the auditor normally cannot date the audit report before receiving the representations (para. 14), late or refused letters can delay reporting deadlines and increase audit fees for extra work.\n- Risks of strategic drafting: management may attempt to qualify or limit representations (examples in Aus A26.1). The standard requires auditors to evaluate such modifications and consider their effect on the auditor’s opinion (Aus A26.1; para. 20).\n\nPractical interface with business operations and regulation\n\n- Affects all audited entities to which an audit is being conducted (financial year, half‑year or other) and also applies as appropriate to other historical financial information (Aus 0.1–0.2).\n- Has special points for public sector audits where mandates may require broader representations (para. A9).\n- Cross‑references multiple other Standards (see Appendix 1) — so in practice auditors will tailor representation requests to the subject matter of the engagement (Appendix 1).\n\nBottom line (plain):\n\n- ASA 580 makes obtaining a signed representation letter from management a standard, dated part of the audit file, sets out what it should contain and when it should be dated, requires auditors to treat missing or inconsistent representations as serious and to take defined follow‑up steps (including possibly disclaiming an opinion), and emphasises that such letters are audit evidence but not enough on their own. (paras 3, 9–20; Aus A26.1; Appendix 2.)"},"flash_summary_failed":{"failed":true,"reason":"Unauthenticated. Configure AI_GATEWAY_API_KEY or use a provider module. Learn more: https://ai-sdk.dev/unauthenticated-ai-gateway","source":"analysis-cron"},"kimi_summary":{"_metrics":{"completionTokens":659},"content_quality":"ok","complexity_score":5,"scope_assessment":{"changed":true,"description":"The standard has expanded significantly from its original 2009 form through six amending standards. Notable scope creep includes: (1) 2011 amendments adding detailed requirements for 'other information' and fraud-related disclosures; (2) 2015 amendments restructuring paragraph numbering and deleting Australian-specific guidance; (3) 2018 and 2023 amendments updating cross-references to other standards. The illustrative representation letter in Appendix 2 has grown from a simple template to a comprehensive 20-item checklist covering fraud, litigation, related parties, internal controls, and other information."},"complexity_factors":["Multiple cross-references to other Australian Auditing Standards (ASA 101, ASA 200, ASA 210, ASA 230, ASA 240, ASA 250, ASA 260, ASA 450, ASA 502, ASA 540, ASA 550, ASA 560, ASA 570, ASA 705, ASA 710, ASA 720)","Conditional requirements with nested exceptions (e.g., when public statements can substitute for representation letters)","Australian-specific additions marked with 'Aus' prefix that modify or extend the international standard","Detailed compilation history showing amendments across 6 separate standards from 2009 to 2023","Extensive application guidance (A1-A27) with multiple scenarios and examples","Appendix with illustrative representation letter containing 20+ specific representations"],"plain_english_summary":"ASA 580 requires auditors to obtain formal written confirmations from management (and sometimes those charged with governance) during a financial audit that the financial report is prepared properly, all relevant information and access have been provided, and transactions are recorded. Auditors can seek extra representations on specific risks; letters must be appropriately dated and signed.\n\nThese representations are mandatory audit evidence affecting auditors, company management/signatories, and certain public sector entities — but they don’t replace other audit evidence."}},"importantCases":[],"_links":{"self":"/api/acts/asa-580-written-representations-october-2009","history":"/api/acts/asa-580-written-representations-october-2009/history","analysis":"/api/acts/asa-580-written-representations-october-2009/analysis","conflicts":"/api/acts/asa-580-written-representations-october-2009/conflicts","importantCases":"/api/acts/asa-580-written-representations-october-2009/important-cases","documents":"/api/acts/asa-580-written-representations-october-2009/documents"}}