Comments from ACCA
ACCA is pleased to respond to the exposure draft of proposed International Standard on Assurance Engagements 3000 Assurance Engagements Other than Audits or Reviews of Historical Financial Information issued by the International Auditing and Assurance Standards Board (IAASB).
We support the updating of the extant standard to reflect experience of its use and allow improvements, such as adoption of a Clarity style of drafting. We believe, however, that, rather than seeking to address many different subject matters, proposed ISAE 3000 should focus on the assurance engagement process, which would allow it to differentiate better between assurance on information separately measured or evaluated and those engagements where the practitioner directly measures or evaluates information.
If the standard is not refocused, we disagree with its proposed scope; instead, to recognise that most assurance engagements are commissioned voluntarily, we suggest conformity with other recent IAASB proposals for non-assurance engagements, whereby the deciding factor for its use is the need of the engaging party to have a report under a high quality international standard.
Our comments reflect the current circumstance that the IAASB is updating several pronouncements relevant to assurance and we call for consistency between them. We renew our calls for work on the fundamental principles of assurance as we feel that difficulties in several of the exposure drafts could have been averted had there been a proper theoretical underpinning for standard setting. Continuing piecemeal updating of standards has now resulted in a pressing need to achieve consistency of terminology. This might best be addressed in a wide-reaching IAASB project that also includes revision of the International Framework for Assurance Engagements but, as much of the terminology is also used by other standard-setting boards of the International Federation of Accountants, an IFAC-wide project is indicated.
The exposure draft includes proposed consequential amendments to the International Framework for Assurance Engagements. They are extensive and would introduce differences between it and International Standards on Auditing. If the Framework is to be made non-authoritative, we argue that it should encompass all engagements under IAASB standards. As an authoritative document it might better serve as a standard for concepts and terminology. We suggest, therefore, that a separate and properly argued exposure draft is needed for the Framework in due course.
See Related Documents for the full submission in PDF.