(Ref: Para. 7)

Preparing sufficient and appropriate audit documentation on a timely basis helps to enhance the quality of the audit and facilitates the effective review and evaluation of the audit evidence obtained and conclusions reached before the auditor’s report is finalised.  Documentation prepared after the audit work has been performed is likely to be less accurate than documentation prepared at the time such work is performed. 

Form, Content and Extent of Audit Documentation (Ref: Para. 8)

The form, content and extent of audit documentation depend on factors such as: 

• The size and complexity of the entity. 
• The nature of the audit procedures to be performed. 
• The identified risks of material misstatement. 
• The significance of the audit evidence obtained. 
• The nature and extent of exceptions identified. 
• The need to document a conclusion or the basis for a conclusion not readily determinable from the documentation of the work performed or audit evidence obtained. 
• The audit methodology and tools used.

Audit documentation may be recorded on paper or on electronic or other media.  Examples of audit documentation include: 

• Audit programs. 
• Analyses. 
• Issues memoranda. 
• Summaries of significant matters. 
• Letters of confirmation and representation. 
• Checklists. 
• Correspondence (including e‑mail) concerning significant matters.  

The auditor may include abstracts or copies of the entity’s records (for example, significant and specific contracts and agreements) as part of audit documentation.  Audit documentation, however, is not a substitute for the entity’s accounting records.

The auditor need not include in audit documentation superseded drafts of working papers and financial reports, notes that reflect incomplete or preliminary thinking, previous copies of documents corrected for typographical or other errors, and duplicates of documents.

Oral explanations by the auditor, on their own, do not represent adequate support for the work the auditor performed or conclusions the auditor reached, but may be used to explain or clarify information contained in the audit documentation.

Documentation of Compliance with Australian Auditing Standards (Ref: Para. 8(a))

In principle, compliance with the requirements of this Auditing Standard will result in the audit documentation being sufficient and appropriate in the circumstances.  Other Australian Auditing Standards contain specific documentation requirements that are intended to clarify the application of this Auditing Standard in the particular circumstances of those other Australian Auditing Standards.  The specific documentation requirements of other Australian Auditing Standards do not limit the application of this Auditing Standard.  Furthermore, the absence of a documentation requirement in any particular Auditing Standard is not intended to suggest that there is no documentation that will be prepared as a result of complying with that Auditing Standard.

Audit documentation provides evidence that the audit complies with the Australian Auditing Standards.  However, it is neither necessary nor practicable for the auditor to document every matter considered, or professional judgement made, in an audit.  Further, it is unnecessary for the auditor to document separately (as in a checklist, for example) compliance with matters for which compliance is demonstrated by documents included within the audit file.  For example:  

• The existence of an adequately documented audit plan demonstrates that the auditor has planned the audit. 
• The existence of a signed engagement letter in the audit file demonstrates that the auditor has agreed the terms of the audit engagement with management or, where appropriate, those charged with governance. 
• An auditor’s report containing an appropriately qualified opinion on the financial report demonstrates that the auditor has complied with the requirement to express a qualified opinion under the circumstances specified in the Australian Auditing Standards.  
• In relation to requirements that apply generally throughout the audit, there may be a number of ways in which compliance with them may be demonstrated within the audit file: 
  • For example, there may be no single way in which the auditor’s professional scepticism is documented.  But the audit documentation may nevertheless provide evidence of the auditor’s exercise of professional scepticism in accordance with the Australian Auditing Standards.  For example, in relation to accounting estimates, when the audit evidence obtained includes evidence that both corroborates and contradicts management’s assertions, documenting how the auditor evaluated that evidence, including the professional judgements made in forming a conclusion as to the sufficiency and appropriateness of the audit evidence obtained.
  • Similarly, that the engagement partner has taken responsibility for the direction, and supervision of the engagement team and the review of their work ^[5] may be evidenced in a number of ways within the audit documentation. This may include documentation that evidences the engagement partner’s sufficient and appropriate involvement in the audit, such as participation in engagement team discussions.

Documentation of Significant Matters and Related Significant Professional Judgements (Ref: Para. 8(c))

Judging the significance of a matter requires an objective analysis of the facts and circumstances.  Examples of significant matters include: 

• Matters that give rise to significant risks (as defined in ASA 315). ^[6]
• Results of audit procedures indicating (a) that the financial report could be materially misstated, or (b) a need to revise the auditor’s previous assessment of the risks of material misstatement and the auditor’s responses to those risks. 
• Circumstances that cause the auditor significant difficulty in applying necessary audit procedures. 
• Findings that could result in a modification to the audit opinion or the inclusion of an Emphasis of Matter paragraph in the auditor’s report.

An important factor in determining the form, content and extent of audit documentation of significant matters is the extent of professional judgement exercised in performing the work and evaluating the results.  Documentation of the professional judgements made, where significant, serves to explain the auditor’s conclusions and to reinforce the quality of the judgement.  Such matters are of particular interest to those responsible for reviewing audit documentation, including those carrying out subsequent audits when reviewing matters of continuing significance (for example, when performing a retrospective review of accounting estimates). 

Some examples of circumstances in which, in accordance with paragraph 8, it is appropriate to prepare audit documentation relating to the use of professional judgement include, where the matters and judgements are significant: 

• The rationale for the auditor’s conclusion when a requirement provides that the auditor ‘shall consider’ certain information or factors, and that consideration is significant in the context of the particular engagement. 
• The basis for the auditor’s conclusion on the reasonableness of areas of subjective judgements made by management. 
• The basis for the auditor’s evaluation of whether an accounting estimate and related disclosures are reasonable in the context of the applicable financial reporting framework, or are misstated. The basis for the auditor’s conclusions about the authenticity of a document when further investigation (such as making appropriate use of an expert or of confirmation procedures) is undertaken in response to conditions identified during the audit that caused the auditor to believe that the document may not be authentic.  
• When ASA 701 applies,^[7] the auditor’s determination of the key audit matters or the determination that there are no key audit matters to be communicated.

The auditor may consider it helpful to prepare and retain as part of the audit documentation a summary (sometimes known as a completion memorandum) that describes the significant matters identified during the audit and how they were addressed, or that includes cross‑references to other relevant supporting audit documentation that provides such information.  Such a summary may facilitate effective and efficient reviews and inspections of the audit documentation, particularly for large and complex audits.  Further, the preparation of such a summary may assist the auditor’s consideration of the significant matters.  It may also help the auditor to consider whether, in light of the audit procedures performed and conclusions reached, there is any individual relevant Auditing Standard objective that the auditor cannot achieve that would prevent the auditor from achieving the overall objectives of the auditor.

Identification of Specific Items or Matters Tested, and of the Preparer and Reviewer (Ref: Para. 9)

Recording the identifying characteristics serves a number of purposes.  For example, it enables the engagement team to be accountable for its work and facilitates the investigation of exceptions or inconsistencies.  Identifying characteristics will vary with the nature of the audit procedure and the item or matter tested.  For example: 

• For a detailed test of entity‑generated purchase orders, the auditor may identify the documents selected for testing by their dates and unique purchase order numbers. 
• For a procedure requiring selection or review of all items over a specific amount from a given population, the auditor may record the scope of the procedure and identify the population (for example, all journal entries over a specified amount from the journal register). 
• For a procedure requiring systematic sampling from a population of documents, the auditor may identify the documents selected by recording their source, the starting point and the sampling interval (for example, a systematic sample of shipping reports selected from the shipping log for the period from April 1 to September 30, starting with report number 12345 and selecting every 125th report).  
• For a procedure requiring enquiries of specific entity personnel, the auditor may record the dates of the enquiries and the names and job designations of the entity personnel. 
• For an observation procedure, the auditor may record the process or matter being observed, the relevant individuals, their respective responsibilities, and where and when the observation was carried out.

ASA 220 contains requirements and guidance on the review of audit documentation.^[8] The requirement to document who reviewed the audit work performed does not imply a need for each specific working paper to include evidence of review.  The requirement, however, means documenting what audit work was reviewed, who reviewed such work, and when it was reviewed. 

Documentation of Discussions of Significant Matters with Management, Those Charged with Governance, and Others (Ref: Para. 10)

The documentation is not limited to records prepared by the auditor but may include other appropriate records such as minutes of meetings prepared by the entity’s personnel and agreed by the auditor.  Others with whom the auditor may discuss significant matters may include other personnel within the entity, and external parties, such as persons providing professional advice to the entity.

Documentation of How Inconsistencies have been Addressed (Ref: Para. 11)

The requirement to document how the auditor addressed inconsistencies in information does not imply that the auditor needs to retain documentation that is incorrect or superseded.

Considerations Specific to Smaller Entities (Ref: Para. 8)

The audit documentation for the audit of a smaller entity is generally less extensive than that for the audit of a larger entity.  Further, in the case of an audit where the engagement partner performs all the audit work, the documentation will not include matters that might have to be documented solely to inform or instruct members of an engagement team, or to provide evidence of review by other members of the team (for example, there will be no matters to document relating to team discussions or supervision).  Nevertheless, the engagement partner complies with the overriding requirement in paragraph 8 to prepare audit documentation that can be understood by an experienced auditor, as the audit documentation may be subject to review by external parties for regulatory or other purposes.

When preparing audit documentation, the auditor of a smaller entity may also find it helpful and efficient to record various aspects of the audit together in a single document, with cross‑references to supporting working papers as appropriate.  Examples of matters that may be documented together in the audit of a smaller entity include the understanding of the entity and its environment, the applicable financial reporting framework, and the entity's system of internal control, the overall audit strategy and audit plan, materiality determined in accordance with ASA 320,^[9] assessed risks, significant matters noted during the audit, and conclusions reached.

Documentation of Inability to Comply with Relevant Requirements (Ref: Para. Aus 12.1)

The requirements of the Australian Auditing Standards are designed to enable the auditor to achieve the objectives specified in the Australian Auditing Standards, and thereby the overall objectives of the auditor.  Accordingly, other than in rare and exceptional circumstances, the Australian Auditing Standards call for compliance with each requirement that is relevant in the circumstances of the audit.

ASA 200^[*] contains a requirement regarding the situation, where, in rare and exceptional circumstances, factors outside the auditor’s control prevent the auditor from complying with an essential procedure contained within a relevant requirement. 

The documentation requirement applies only to requirements that are relevant in the circumstances.  A requirement is not relevant^[10] only in the cases where: 

1. The entire Auditing Standard is not relevant (for example, if an entity does not have an internal audit function, nothing in ASA 610^[11] is relevant); or 
2. The requirement is conditional and the condition does not exist (for example, the requirement to modify the auditor’s opinion where there is an inability to obtain sufficient appropriate audit evidence, and there is no such inability).

Matters Arising after the Date of the Auditor’s Report (Ref: Para. 13)

Examples of exceptional circumstances include facts which become known to the auditor after the date of the auditor’s report but which existed at that date and which, if known at that date, might have caused the financial report to be amended or the auditor to modify the opinion in the auditor’s report.^[12]  The resulting changes to the audit documentation are reviewed in accordance with the review responsibilities set out in ASA 220^.[13]

(Ref: Para. 14‑16)

ASQM 1 requires firms’ system of quality management to establish a quality objective that addresses the assembly of engagement documentation on a timely basis after the date of the engagement reports.^[14] An appropriate time limit within which to complete the assembly of the final audit file is ordinarily not more than 60 days after the date of the auditor’s report.^[15]

The completion of the assembly of the final audit file after the date of the auditor’s report is an administrative process that does not involve the performance of new audit procedures or the drawing of new conclusions.  Changes may, however, be made to the audit documentation during the final assembly process if they are administrative in nature.  Examples of such changes include: 

• Deleting or discarding superseded documentation. 
• Sorting, collating and cross‑referencing working papers. 
• Signing off on completion checklists relating to the file assembly process. 
• Documenting audit evidence that the auditor has obtained, discussed and agreed with the relevant members of the engagement team before the date of the auditor’s report.

ASQM 1 requires firms’ systems of quality management to establish a quality objective to address the appropriate maintenance and retention of engagement documentation to meet the needs of the firm and to comply with law, regulation, relevant ethical requirements, or AUASB Standards.^[16] The retention period for audit engagements ordinarily is no shorter than five years from the date of the auditor’s report, or, if later, the date of the auditor’s report on the group financial reports, when applicable.^[17]

Under section 307B of the Corporations Act 2001, the auditor or member of an audit firm is required to retain all audit working papers prepared by or for, or considered or used by, the auditor in accordance with the requirements of the Australian Auditing Standards until:

1. The end of seven years after the date of the audit report prepared in relation to the audit or review to which the audit working papers relate; or 
2. An earlier date determined by the Australian Securities and Investments Commission for the audit working papers.

Relevant legislation or regulation, other than the Corporations Act 2001, may require the retention of audit working papers for specified periods.

An example of a circumstance in which the auditor may find it necessary to modify existing audit documentation or add new audit documentation after file assembly has been completed is the need to clarify existing audit documentation arising from comments received during monitoring activities or external inspections.