Requirements

Management from whom Written Representations are Requested

9

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

10

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‑A9A14A22)

Information Provided and Completeness of Transactions

11

The auditor shall request management to provide a written representation that: 

  1. It has provided the auditor with all relevant information and access as agreed in the terms of the audit engagement;[3] and 
  2. All transactions have been recorded and are reflected in the financial report.  (Ref: Para. A7‑A9A14A22)

Description of Management’s Responsibilities in the Written Representations

12

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

13

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‑A14A22)

Date of and Period(s) Covered by Written Representations

14

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

15

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

16

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)

17

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)

18

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

19

If management does not provide one or more of the requested written representations, the auditor shall: 

  1. Discuss the matter with management; 
  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 
  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. 

Written Representations about Management’s Responsibilities

20

The auditor shall disclaim an opinion on the financial report in accordance with ASA 705 if: 

  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 
  2. Management does not provide the written representations required by paragraphs 10 and 11 of this Auditing Standard.  (Ref: Para. A26‑A27)

2

See ASA 210 Agreeing the Terms of Audit Engagements, paragraph 6(b)(i).

4

See ASA 705 Modifications to the Opinion in the Independent Auditor’s Report.