The auditor's report

Relevant to ACCA Qualification exams AA and AAA

The International Auditing and Assurance Standards Board (IAASB) finalised its project on auditor reporting in 2015, which resulted in a set of new and revised standards on auditor reporting as well as revised versions of ISA, 570Going Concern and a number of other International Standards on Auditing (ISAs).

Candidates attempting Audit and Assurance (AA) and Advanced Audit and Assurance (AAA) are required to have a sound understanding of these standards.

This article will focus primarily on: the requirements of ISA 701, Communicating Key Audit Matters in the Independent Auditor’s Report; how ISA 701 interacts with the other reporting standards (ISA 705 and 706); and the reporting requirements in ISA 570 (Revised), Going Concern.

Candidates often find auditor’s reports a challenging part of the syllabus and in preparation for exams it is imperative that candidates can:

  • describe the different elements of the auditor’s report (particularly relevant for AA candidates)
  • determine the most appropriate type of audit opinion in a given scenario, often through an explanation of why a certain opinion is appropriate which will test the application of the candidate’s knowledge
  • understand the issues that may arise during the course of an audit that could require an Emphasis of Matter or Other Matter paragraph to be included in the auditor’s report, and
  • identify Key Audit Matters (KAM) that are required to be disclosed in an auditor’s report.

Candidates will not be expected to draft an auditor’s report in either AA or AAA, but may be asked to present reasons for an unmodified or a modified opinion, or the inclusion of an Emphasis of Matter paragraph. Candidates attempting AA may be required to identify and describe the elements of the auditor’s report and therefore candidates should ensure that they have a sound understanding of ISA 700, Forming an Opinion and Reporting on Financial Statements. AAA questions may require a candidate to determine whether a transaction, or a series of transactions and events or other issues arising during the audit, gives rise to a KAM and should also be prepared to critique the content of a KAM section of an auditor’s report. AA candidates should be able to discuss what should be included in the KAM section to ensure the auditor’s report is compliant with ISA 701.

Candidates may also be presented with extracts from an auditor’s report and be asked to critically appraise the extracts, or challenge the proposed audit opinion. Candidates are therefore reminded to ensure they have a sound understanding of the relevant Syllabus and Study Guide and ensure the revision phase in the lead-up to the examination includes plenty of exam-standard question practise, particularly if this is an area of the syllabus which a candidate finds challenging.

Key Audit Matters (KAM)

In January 2015 the IAASB issued ISA 701, Communicating Key Audit Matters in the Independent Auditor’s Report. This standard is required to be applied to the audit of all listed entities. The objectives of ISA 701 are for the auditor to:

  • determine those matters which are to be regarded as KAM; and
  • communicate those matters in the auditor’s report.

The term ‘key audit matters’ is defined in ISA 701 as:

‘Those matters that, in the auditor’s professional judgment, were of most significance in the audit of the financial statements of the current period. Key audit matters are selected from matters communicated with those charged with governance.’ (1)

Determination of KAM

The definition in paragraph 8 of ISA 701 states that KAM are selected from matters which are communicated with those charged with governance. Matters which are discussed with those charged with governance are then evaluated by the auditor who then determines those matters which required significant auditor attention during the course of the audit. There are three matters which the ISA requires the auditor to take into account when making this determination:

  1. Areas which were considered to be susceptible to higher risks of material misstatement or which were deemed to be ‘significant risks’ in accordance with ISA 315 (Revised), Identifying and Assessing the Risks of Material Misstatement through Understanding the Entity and Its Environment.
  2. Significant auditor judgments in relation to areas of the financial statements that involved significant management judgment. This might include accounting estimates which have been identified by the auditor as having a high degree of estimation uncertainty.
  3. The effect on the audit of significant events or transactions that have taken place during the period.

The auditor must determine which matters are of most significance in the audit of the financial statements and these will be regarded as KAM.

Communicating KAM

Once the auditor has determined which matters will be included as KAM, the auditor must ensure that each matter is appropriately described in the auditor’s report including a description of:

  1. Why the matter was determined to be one of most significance and therefore a key audit matter, and
  2. How the matter was addressed in the audit (which may include a description of the auditor’s approach, a brief overview of procedures performed with an indication of their outcome and any other key observations in respect of the matter).

Reporting in line with ISA 570, Going concern

Exam questions might ask the candidate to recognise indicators that an entity may not be a going concern, or require candidates to arrive at an appropriate audit opinion depending on the circumstances presented in the scenario. It may be the case that candidates are presented with a situation where the auditor has concluded that there are material uncertainties relating to going concern and the directors have made appropriate disclosures in relation to going concern and candidates must understand the auditor reporting requirements in this respect.

The auditor’s work in relation to going concern has been enhanced in ISA 570 (Revised), Going Concern and the ISA includes additional guidance relating to the appropriateness of disclosures when a material uncertainty exists.

Under ISA 570 (Revised), if the use of the going concern basis of accounting is appropriate but a material uncertainty exists and management have included adequate disclosures relating to the material uncertainties the auditor will continue to express an unmodified opinion, but the auditor must include a separate section under the heading ‘Material Uncertainty Related to Going Concern’ and:

  • draw attention to the note in the financial statements that discloses the matters giving rise to the material uncertainty, and
  • state that these events or conditions indicate that a material uncertainty exists which may cast significant doubt on the entity’s ability to continue as a going concern and that the auditor’s opinion is not modified in respect of the matter.

The section headed ‘Material Uncertainty Related to Going Concern’ is included immediately after the Basis for Opinion paragraph but before the KAM section. It should be noted that where the uncertainty is not adequately disclosed in the financial statements the auditor would continue to modify the opinion in line with ISA 705, Modifications to the Opinion in the Independent Auditor’s Report.

Over and above the reporting requirements under ISA 570, candidates need to understand how issues identified regarding going concern interact with the requirements of ISA 701. By their very nature, issues identified relating to going concern are likely to be considered a key audit matter and hence need to be communicated in the auditor’s report. Where the auditor has identified conditions which cast doubt over going concern, but audit evidence confirms that no material uncertainty exists, this ‘close call’ can be disclosed in line with ISA 701. This is because while the auditor may conclude that no material uncertainty exists, they may determine that one, or more, matters relating to this conclusion are key audit matters. Examples include substantial operating losses, available borrowing facilities and possible debt refinancing, or non-compliance with loan agreements and related mitigating factors.

In summary if a confirmed material uncertainty exists it must be disclosed in accordance with ISA 570 and where there is a ‘close call’ over going concern which has been determined by the auditor to be a KAM it will be disclosed in line with ISA 701. This is illustrated in the following example:


Example – unmodified audit opinion but material uncertainty exists in relation to going concern and the disclosures are adequate

Report on the Audit of the Financial Statements (extract)

In our opinion, the accompanying financial statements present fairly, in all material respects, the financial position of the Company as at 31 December 20X5, and its financial performance and its cash flows for the year then ended in accordance with IFRS® Standards.

Basis for opinion
We conducted our audit in accordance with International Standards on Auditing (ISAs). Our responsibilities under those standards are further described in the Auditor’s Responsibilities for the Audit of the Financial Statements section of our report. We are independent of the Company in accordance with the ethical requirements that are relevant to our audit of the financial statements in Farland, and we have fulfilled our other ethical responsibilities in accordance with these requirements. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.

Material uncertainty related to going concern
We draw attention to Note 6 in the financial statements, which indicates that the Company incurred a net loss of $125,000 during the year ended 31 December 20X5 and, as of that date, the Company’s current liabilities exceeded its total assets by $106,000. As stated in Note 6, these events or conditions, along with other matters as set forth in Note 6, indicate that a material uncertainty exists that may cast significant doubt on the Company’s ability to continue as a going concern. Our opinion is not modified in respect of this matter.

Key audit matters
Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the financial statements of the current period. These matters were addressed in the context of our audit of the financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters. In addition to the matter described in the Material Uncertainty Related to Going Concern section, we have determined the matters described below to be the key audit matters to be communicated in our report.


[Include a description of each key audit matter]

Application of ISA 701 when a Qualified or Adverse Opinion is issued

ISA 705 (Revised), Modifications to the Opinion in the Independent Auditor’s Report outlines the requirements when the auditor concludes that the audit opinion should be modified. ISA 705 (Revised) requires that the auditor includes a Basis for Qualified/Adverse Opinion section in the auditor’s report. When the auditor expresses a qualified or adverse opinion, the requirement to communicate other KAM is still relevant and hence will still apply.

When the auditor issues an adverse opinion it means that the financial statements do not give a true and fair view (or present fairly) because the auditor has concluded that misstatements, individually and in aggregate, are both material and pervasive to the financial statements.

Depending on the significance of the matter(s) which has resulted in the auditor expressing an adverse audit opinion, the auditor might determine that no other matters are KAM. In this situation, the auditor will deal with the matter(s) in accordance with applicable ISAs and include a reference to the Basis for Qualified/Adverse Opinion or the Material Uncertainty Related to Going Concern section(s) in the KAM section of the report as illustrated below.


Example – Qualified ‘except for’ opinion issued but no key audit matters

The audit of Turquoise Industries Co has been completed and the auditor discovered a material amount of research expenditure which had been capitalised as an intangible asset in contravention of IAS 38® Intangible Assets. The finance director refused to derecognise the research expenditure as an intangible asset and include it in profit or loss and the auditor therefore issued a qualified ‘except for’ opinion on the basis of disagreement with the entity’s accounting treatment for research expenditure.

The auditor has concluded that there are no KAM which require to be communicated in the audit report. The KAM section of the report will therefore be as follows:

Key audit matters
Except for the matter described in the Basis for Qualified Opinion section, we have determined that there are no key audit matters to communicate in our report.

When the auditor has expressed an adverse opinion on the financial statements and communicates KAM, it is important that the descriptions of such KAM do not imply that the financial statements as a whole are more credible in light of the adverse opinion.

Disclaimer of Opinion issued

A disclaimer of opinion is issued when the auditor is unable to form an opinion on the financial statements. ISA 705 states that when the auditor expresses a disclaimer of opinion then the auditor’s report should not include a KAM section.

Emphasis of Matter and Other Matter paragraphs

Emphasis of Matter and Other Matter paragraphs are still retained in ISA 706 (Revised), Emphasis of Matter Paragraphs and Other Matter Paragraphs in the Independent Auditor’s Report and the concepts involved have not been overridden by the ISA 701 requirements. The IAASB have noted that in some cases, matters which the auditor considers to be KAM will relate to issues that are presented and/or disclosed in the financial statements. Therefore, communicating these as KAM under ISA 701 will serve as the most useful and meaningful mechanism for highlighting the importance of the matter.

Candidates should appreciate that when the auditor communicates matters as KAM, the intention is to provide additional information beyond that which would be included in an Emphasis of Matter paragraph. In recognition of this ISA 706 (Revised) states:

  • The auditor is prohibited from using an Emphasis of Matter paragraph or an Other Matter paragraph when the matter has been determined to be a KAM. To that end, the IAASB has emphasised that the use of an Emphasis of Matter paragraph is not a substitute for a description of individual KAM.
  • If a KAM is also determined to be fundamental to users’ understanding, the auditor may present this issue more prominently in the KAM section. Alternatively, the auditor might also include additional information in the KAM description to indicate the importance of the matter.
  • There may be a matter which is not determined to be a KAM, but which, in the auditor’s judgement is fundamental to users’ understanding and for which an Emphasis of Matter paragraph may be considered necessary.

Additional requirements for candidates attempting AAA

Candidates attempting AAA may be required to determine matters which should be treated as KAM and to discuss the content of the KAM section of the auditor’s report. Typical examples of issues which could be regarded as KAM include:

Impairment testing on goodwill

IFRS® 3, Business Combinations requires goodwill to be tested for impairment at each reporting date and the annual impairment test may be regarded as a KAM where the carrying amount of goodwill is material. Impairment tests are inherently complex and judgmental and therefore management’s assessment process may also be a KAM.


Effects of new IFRS standards

New accounting standards may be introduced by the International Accounting Standards Board (such as IFRS 15, Revenue from Contracts with Customers) that will involve a material change of accounting treatment. For example, IFRS 15 requires the application of a new framework in respect of revenue recognition, and hence the implementation of IFRS 15 may give rise to the new accounting requirements becoming a KAM as they will impact on the reporting entity’s financial position and performance.

Valuation of financial instruments, and other assets and liabilities at fair value

Significant measurement uncertainties in some financial instruments (for example those for which quoted prices are not available) may give rise to the valuation of financial instruments becoming a KAM because such valuations would invariably rely on entity-developed models. This can also apply to other assets and liabilities, particularly those measured using fair value techniques which can be complex and subjective.

Please note that the examples above are included for illustrative purposes and do not form an exhaustive list of all issues that could be identified as KAM.


The auditor’s report was significantly changed by the IAASB in response to the users of financial statements requesting a more informative auditor’s report and for the report to include more relevant information for users. Candidates attempting AA will need to be able to identify and describe the basic elements contained in the auditor’s report.

Candidates sitting either exam need to understand the requirements and responsibilities of the auditor as set out in the reporting standards, as well as be able to determine the form and content of an unmodified/modified auditor’s report or where the use of an Emphasis of Matter or Other Matter paragraph would be appropriate.

In addition, AAA candidates may be required to identify matters relating to the financial statements which should be treated as a KAM and to critically assess the content of the KAM section of a proposed auditor’s report.

(1) ISA 701 paragraph 8

Written by a member of the Audit and Assurance examining team