The 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.
This 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).
Auditing Standard ASA 580
Written Representations
Application
Aus 0.1 This Auditing Standard applies to:
(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
(b) an audit of a financial report, or a complete set of financial statements, for any other purpose.
Aus 0.2 This Auditing Standard also applies, as appropriate, to an audit of other historical financial information.
Operative Date
Aus 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.]
Introduction
Scope of this Auditing Standard
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.
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.
Written Representations as Audit Evidence
Audit evidence is the information used by the auditor in arriving at the conclusions on which the auditor’s opinion is based.[1] 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)
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.
Effective Date
[Deleted by the AUASB. Refer Aus 0.3]
Objectives
The objectives of the auditor are:
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;
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
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.
Definitions
For the purposes of this Auditing Standard, the following terms have the meanings attributed below:
Written 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.
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.
Requirements
Management from whom Written Representations are Requested
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)
Written Representations about Management’s Responsibilities
Preparation of the Financial report
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] (Ref: Para. A7‑A9, A14, A22)
Information Provided and Completeness of Transactions
The auditor shall request management to provide a written representation that:
It has provided the auditor with all relevant information and access as agreed in the terms of the audit engagement;[3] and
All transactions have been recorded and are reflected in the financial report. (Ref: Para. A7‑A9, A14, A22)
Description of Management’s Responsibilities in the Written Representations
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.
Other Written Representations
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)
Date of and Period(s) Covered by Written Representations
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)
Form of Written Representations
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)
Doubt as to the Reliability of Written Representations and Requested Written Representations Not Provided
Doubt as to the Reliability of Written Representations
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)
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)
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] having regard to the requirement in paragraph 20 of this Auditing Standard.
Requested Written Representations Not Provided
If management does not provide one or more of the requested written representations, the auditor shall:
Discuss the matter with management;
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
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.
Written Representations about Management’s Responsibilities
The auditor shall disclaim an opinion on the financial report in accordance with ASA 705 if:
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
Management does not provide the written representations required by paragraphs 10 and 11 of this Auditing Standard. (Ref: Para. A26‑A27)
* * *
Application and Other Explanatory Material
Written Representations as Audit Evidence (Ref: Para. 3)
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.
Management from whom Written Representations are Requested (Ref: Para. 9)
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.
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.
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:
An actuary responsible for actuarially determined accounting measurements.
Staff engineers who may have responsibility for and specialised knowledge about environmental liability measurements.
Internal counsel who may provide information essential to provisions for legal claims.
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.
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.
Written Representations about Management’s Responsibilities (Ref: Para. 10‑11)
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.
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:
Those who signed the terms of the audit engagement on behalf of the entity no longer have the relevant responsibilities;
The terms of the audit engagement were prepared in a previous year;
There is any indication that management misunderstands those responsibilities; or
Changes in circumstances make it appropriate to do so.
Consistent with the requirement of ASA 210,[5] 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).
Considerations Specific to Public Sector Entities
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.
Other Written Representations (Ref: Para. 13)
Additional Written Representations about the Financial Report
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:
Whether the selection and application of accounting policies are appropriate; and
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:
Plans or intentions that may affect the carrying value or classification of assets and liabilities;
Liabilities, both actual and contingent;
Title to, or control over, assets, the liens or encumbrances on assets, and assets pledged as collateral; and
Aspects of laws, regulations and contractual agreements that may affect the financial report, including non‑compliance.
Additional Written Representations about Information Provided to the Auditor
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.
Written Representations about Specific Assertions
When obtaining evidence about, or evaluating, judgements and intentions, the auditor may consider one or more of the following:
The entity’s past history in carrying out its stated intentions.
The entity’s reasons for choosing a particular course of action.
The entity’s ability to pursue a specific course of action.
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.
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.
Communicating a Threshold Amount (Ref: Para. 10‑11, 13)
ASA 450 requires the auditor to accumulate misstatements identified during the audit, other than those that are clearly trivial.[6] 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.
Date of and Period(s) Covered by Written Representations (Ref: Para. 14)
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.
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.
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.
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.
Form of Written Representations (Ref: Para. 15)
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:
Whether the statement includes confirmation of the fulfilment of the responsibilities referred to in paragraphs 10 and 11.
Whether the statement has been given or approved by those from whom the auditor requests the relevant written representations.
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).
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.
Appendix 2 provides an illustrative example of a representation letter.
Communication with Those Charged with Governance (Ref: Para. 10‑11, 13)
ASA 260 requires the auditor to communicate with those charged with governance the written representations which the auditor has requested from management.[7]
Doubt as to the Reliability of Written Representations and Requested Written Representations Not Provided
Doubt as to the Reliability of Written Representations (Ref: Para. 16‑17)
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.
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.
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] 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.
Written Representations about Management’s Responsibilities (Ref: Para. 20)
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]
If Management do not Provide Written Representations
Aus A26.1 If management do not provide written representations, the auditor would ordinarily:
(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;[*]
(b) consider any other implications of the refusal that may have any effect on the auditor’s report;[#] and
(c) consider whether the auditor has any regulatory obligation to report that management has not provided a written representation.[†]
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:
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.
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.