Emphasis of Matter Paragraphs and Other Emphasis of Matter Paragraphs and Other Matter Paragraphs in the Independent Auditor's Report

Auditing Standard ASA 706

Emphasis of Matter Paragraphs and Other Matter Paragraphs in the Independent Auditor's Report

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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

1. This Auditing Standard deals with the auditor’s responsibility regarding additional communication in the auditor’s report when the auditor considers it necessary to:
   1. Draw users’ attention to a matter or matters presented or disclosed in the financial report that are of such importance that they are fundamental to users’ understanding of the financial report; or
   2. Draw users’ attention to any matter or matters other than those presented or disclosed in the financial report that are relevant to users’ understanding of the audit, the auditor’s responsibilities or the auditor’s report.
2. Appendices 1 and 2 identify Auditing Standards that contain specific requirements for the auditor to include Emphasis of Matter paragraphs or Other Matter paragraphs in the auditor’s report. In those circumstances, the requirements in this Auditing Standard regarding the form and placement of such paragraphs apply.

Effective Date

1. [Deleted by the AUASB. Refer Aus 0.3]

Objective

1. The objective of the auditor, having formed an opinion on the financial report, is to draw users’ attention, when in the auditor’s judgement it is necessary to do so, by way of clear additional communication in the auditor’s report, to:
   1. A matter, although appropriately presented or disclosed in the financial report, that is of such importance that it is fundamental to users’ understanding of the financial report; or
   2. As appropriate, any other matter that is relevant to users’ understanding of the audit, the auditor’s responsibilities or the auditor’s report.

Definitions

1. For purposes of the Australian Auditing Standards, the following terms have the meanings attributed below:
   1. Emphasis of Matter paragraph means a paragraph included in the auditor’s report that refers to a matter appropriately presented or disclosed in the financial report that, in the auditor’s judgement, is of such importance that it is fundamental to users’ understanding of the financial report.
   2. Other Matter paragraph means a paragraph included in the auditor’s report that refers to a matter other than those presented or disclosed in the financial report that, in the auditor’s judgement, is relevant to users’ understanding of the audit, the auditor’s responsibilities or the auditor’s report.

Requirements

Emphasis of Matter Paragraphs in the Auditor’s Report

1. If the auditor considers it necessary to draw users’ attention to a matter presented or disclosed in the financial report that, in the auditor’s judgement, is of such importance that it is fundamental to users’ understanding of the financial report, the auditor shall include an Emphasis of Matter paragraph in the auditor’s report provided the auditor has obtained sufficient appropriate audit evidence that the matter is not materially misstated in the financial report. Such a paragraph shall refer only to information presented or disclosed in the financial report. (Ref: Para. A1-Aus 2.1)

Aus 6.1 In addition to the requirements in paragraph 6 of this Auditing Standard, the auditor shall include an Emphasis of Matter paragraph in the auditor’s report where required by other Auditing Standards. (Ref: Appendix 1)

1. When the auditor includes an Emphasis of Matter paragraph in the auditor’s report, the auditor shall:
   1. Include it immediately after the Opinion paragraph in the auditor’s report;
   2. Use the heading “Emphasis of Matter,” or other appropriate heading;
   3. Include in the paragraph a clear reference to the matter being emphasised and to where relevant disclosures that fully describe the matter can be found in the financial report; and
   4. Indicate that the auditor’s opinion is not modified in respect of the matter emphasised. (Ref: Para. A3-A4)

Aus 7.1 When the financial report has been prepared in accordance with Australian Accounting Standards but additional disclosures have been made in the financial report:

 on the basis that, or which imply that, application of a particular Accounting Standard has resulted in the financial report being potentially misleading; or

 that, in the opinion of those charged with governance, are necessary to present a true and fair view; and

the auditor is of the opinion that:

(a) it is likely, in the absence of the additional disclosures, that users would be misled when making evaluations or decisions about the allocation of scarce resources; and

(b) the additional disclosures contain all, and only, relevant and reliable information, and are presented in such a manner as to ensure the financial report as a whole is comparable and understandable in meeting the objectives of the financial report,

the auditor shall include in the auditor’s report an Emphasis of Matter paragraph headed "Application of Australian Accounting Standard AASB ..." or an appropriate alternative which:

(i) draws attention to the additional disclosures;

(ii) where relevant, states that in the auditor's opinion application of the particular Accounting Standard has, in this instance, resulted in the financial report being potentially misleading;

(iii) states the specific reasons why the auditor believes the additional disclosures are necessary to ensure the financial report as a whole is not misleading (the auditor's reasons are to be stated in the auditor’s report itself rather than only by reference to the reasons included in the financial report); and

(iv) states that, in the auditor's opinion, the additional disclosures are relevant and reliable in meeting the objectives of the financial report. (Ref: Para. Aus A4.1)

Other Matter Paragraphs in the Auditor’s Report (Ref: Para. A5-A11)

1. If the auditor considers it necessary to communicate a matter other than those that are presented or disclosed in the financial report that, in the auditor’s judgement, is relevant to users’ understanding of the audit, the auditor’s responsibilities or the auditor’s report and this is not prohibited by law or regulation, the auditor shall do so in a paragraph in the auditor’s report, with the heading “Other Matter,” or other appropriate heading. The auditor shall include this paragraph immediately after the Opinion paragraph and any Emphasis of Matter paragraph, or elsewhere in the auditor’s report if the content of the Other Matter paragraph is relevant to the Other Reporting Responsibilities section.

Aus 8.1 In addition to the requirements in paragraph 8 of this Auditing Standard, the auditor shall include an Other Matter paragraph in the auditor’s report where required by other Auditing Standards. (Ref: Appendix 2)

Communication with Those Charged with Governance

1. If the auditor expects to include an Emphasis of Matter or an Other Matter paragraph in the auditor’s report, the auditor shall communicate with those charged with governance regarding this expectation and the proposed wording of this paragraph.
   (Ref: Para. A12)

* * *

Application and Other Explanatory Material

Emphasis of Matter Paragraphs in the Auditor’s Report

Circumstances in Which an Emphasis of Matter Paragraph May Be Necessary (Ref: Para. 6-Aus 6.1 and Aus 7.1)

1. Examples of circumstances where the auditor may consider it necessary to include an Emphasis of Matter paragraph are:

 An uncertainty relating to the future outcome of exceptional litigation or regulatory action.

 Early application (where permitted) of a new accounting standard (for example, a new Australian Accounting Standard) that has a pervasive effect on the financial report in advance of its effective date.

 A major catastrophe that has had, or continues to have, a significant effect on the entity’s financial position.

Aus A1.1 Ordinarily, an uncertainty, the resolution of which may materially affect the financial report, would warrant an Emphasis of Matter paragraph in the auditor’s report.

1. A widespread use of Emphasis of Matter paragraphs diminishes the effectiveness of the auditor’s communication of such matters. Additionally, to include more information in an Emphasis of Matter paragraph than is presented or disclosed in the financial report may imply that the matter has not been appropriately presented or disclosed; accordingly, paragraph 6 limits the use of an Emphasis of Matter paragraph to matters presented or disclosed in the financial report.

Aus A2.1 Accounting estimates are ordinarily made in connection with amounts and other disclosures appearing in the financial report. In most cases the auditor is able to be satisfied regarding the reasonableness of an accounting estimate. Requirements and application and other explanatory material on this matter are contained in ASA 540 Auditing Accounting Estimates, Including Fair Value Accounting Estimates, and Related Disclosures. Such an accounting estimate will not ordinarily be regarded as a significant uncertainty for the purposes of this Auditing Standard.

Including an Emphasis of Matter Paragraph in the Auditor’s Report
(Ref: Para. 7)

1. The inclusion of an Emphasis of Matter paragraph in the auditor’s report does not affect the auditor’s opinion. An Emphasis of Matter paragraph is not a substitute for either:
   1. The auditor expressing a qualified opinion or an adverse opinion, or disclaiming an opinion, when required by the circumstances of a specific audit engagement (see ASA 705[1]); or
   2. Disclosures in the financial report that the applicable financial reporting framework requires management to make.
2. The illustrative report (example 1) in Appendix 3 includes an Emphasis of Matter paragraph in an auditor’s report that contains a qualified opinion.

Aus A4.1 When an auditor’s report is prepared on a financial report prepared under the Corporations Act 2001 (the Act), section 308(3B) of the Act requires that if the financial report includes additional information under paragraph 295(3)(c) (additional information included to give a true and fair view of the entity’s financial position and performance), the auditor’s report includes the auditor’s opinion on whether the additional information was necessary to give a true and fair view. (Ref: Para. Aus 7.1)

Other Matter Paragraphs in the Auditor’s Report (Ref: Para. 8 – Aus 8.1)

Circumstances in Which an Other Matter Paragraph May Be Necessary

Relevant to Users’ Understanding of the Audit

1. In the rare circumstance where the auditor is unable to withdraw from an engagement even though the possible effect of an inability to obtain sufficient appropriate audit evidence due to a limitation on the scope of the audit imposed by management is pervasive,[2] the auditor may consider it necessary to include an Other Matter paragraph in the auditor’s report to explain why it is not possible for the auditor to withdraw from the engagement.

Relevant to Users’ Understanding of the Auditor’s Responsibilities or the Auditor’s Report

1. Law, regulation or generally accepted practice in a jurisdiction may require or permit the auditor to elaborate on matters that provide further explanation of the auditor’s responsibilities in the audit of the financial report or of the auditor’s report thereon. Where relevant, one or more sub-headings may be used that describe the content of the Other Matter paragraph.
2. An Other Matter paragraph does not deal with circumstances where the auditor has other reporting responsibilities that are in addition to the auditor’s responsibility under the Australian Auditing Standards to report on the financial report (see “Other Reporting Responsibilities” section in ASA 700[3]), or where the auditor has been asked to perform and report on additional specified procedures, or to express an opinion on specific matters.

Reporting on more than one financial report

1. An entity may prepare one financial report in accordance with a general purpose framework (for example, the Australian Accounting Standards) and another financial report in accordance with another general purpose framework (for example, International Financial Reporting Standards), and engage the auditor to report on both financial reports. If the auditor has determined that the frameworks are acceptable in the respective circumstances, the auditor may include an Other Matter paragraph in the auditor’s report, referring to the fact that another financial report has been prepared by the same entity in accordance with another general purpose framework and that the auditor has issued a report on that financial report.

Restriction on distribution or use of the auditor’s report

1. A financial report prepared for a specific purpose may be prepared in accordance with a general purpose framework because the intended users have determined that such a general purpose financial report meets their financial information needs. Since the auditor’s report is intended for specific users, the auditor may consider it necessary in the circumstances to include an Other Matter paragraph, stating that the auditor’s report is intended solely for the intended users, and should not be distributed to or used by other parties.

Including an Other Matter Paragraph in the Auditor’s Report

1. The content of an Other Matter paragraph reflects clearly that such other matter is not required to be presented and disclosed in the financial report. An Other Matter paragraph does not include information that the auditor is prohibited from providing by law, regulation or other professional standards, for example, ethical standards relating to confidentiality of information. An Other Matter paragraph also does not include information that is required to be provided by management.

Aus A10.1 The inclusion of an Other Matter paragraph in the auditor’s report does not affect the auditor’s opinion. An auditor needs to consider whether, in the circumstances, it is appropriate to indicate that the auditor’s opinion is not modified in respect of the Other Matter paragraph.

1. The placement of an Other Matter paragraph depends on the nature of the information to be communicated. When an Other Matter paragraph is included to draw users’ attention to a matter relevant to their understanding of the audit of the financial report, the paragraph is included immediately after the Opinion paragraph and any Emphasis of Matter paragraph. When an Other Matter paragraph is included to draw users’ attention to a matter relating to Other Reporting Responsibilities addressed in the auditor’s report, the paragraph may be included in the section sub-titled “Report on Other Legal and Regulatory Requirements.” Alternatively, when relevant to all the auditor’s responsibilities or users’ understanding of the auditor’s report, the Other Matter paragraph may be included as a separate section following the Report on the Financial Report and the Report on Other Legal and Regulatory Requirements.

Communication with Those Charged with Governance (Ref: Para. 9)

1. Such communication enables those charged with governance to be made aware of the nature of any specific matters that the auditor intends to highlight in the auditor’s report, and provides them with an opportunity to obtain further clarification from the auditor where necessary. Where the inclusion of an Other Matter paragraph on a particular matter in the auditor’s report recurs on each successive engagement, the auditor may determine that it is unnecessary to repeat the communication on each engagement.

Conformity with International Standards on Auditing

This Auditing Standard conforms with International Standard on Auditing ISA 706 Emphasis of Matter Paragraphs and Other Matter Paragraphs in the Independent Auditor's Report, issued by the International Auditing and Assurance Standards Board (IAASB), an independent standard-setting board of the International Federation of Accountants (IFAC).

Paragraphs 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”.

The following requirements are additional to ISA 706:

 In addition to the requirements in paragraph 6 of this Auditing Standard, the auditor shall include an Emphasis of Matter paragraph in the auditor’s report where required by other Auditing Standards. (Ref: Para. Aus 6.1)

 When the financial report has been prepared in accordance with Australian Accounting Standards but additional disclosures have been made in the financial report:

♦ on the basis that, or which imply that, application of a particular Accounting Standard has resulted in the financial report being potentially misleading; or

♦ that, in the opinion of those charged with governance, are necessary to present a true and fair view; and

the auditor is of the opinion that:

♦ it is likely, in the absence of the additional disclosures, that users would be misled when making evaluations or decisions about the allocation of scarce resources; and

♦ the additional disclosures contain all, and only, relevant and reliable information, and are presented in such a manner as to ensure the financial report as a whole is comparable and understandable in meeting the objectives of the financial report,

the auditor shall include in the auditor’s report an Emphasis of Matter paragraph headed "Application of Australian Accounting Standard AASB ..." or an appropriate alternative which:

♦ draws attention to the additional disclosures;

♦ where relevant, states that in the auditor's opinion application of the particular Accounting Standard has, in this instance, resulted in the financial report being potentially misleading;

♦ states the specific reasons why the auditor believes the additional disclosures are necessary to ensure the financial report as a whole is not misleading (the auditor's reasons are to be stated in the auditor’s report itself rather than only by reference to the reasons included in the financial report); and

♦ states that, in the auditor's opinion, the additional disclosures are relevant and reliable in meeting the objectives of the financial report. (Ref: Para Aus 7.1)

 In addition to the requirements in paragraph 8 of this Auditing Standard, the auditor shall include an Other Matter paragraph in the auditor’s report where required by other Auditing Standards.
(Ref: Para. Aus 8.1)

Compliance with this Auditing Standard enables compliance with ISA 706.