ACCA and CA ANZ joint response supports the notion that the guidance needs to be practical and should not conflict with current standards. To this end, we suggest that framework neutrality be taken into account when making use of examples, including examples on both qualitative and quantitative information. Also, the new concept of ‘materiality process’ has a different meaning than ‘materiality’ in ISAE 3000, which could create confusion. The guidance should therefore be clear on the differences. Similarly, it is also important that the differences between limited and reasonable assurance are set out clearly.
Although the guidance is developing in the right direction, it already seems long. Given the fact that this is only Phase 1, it is only expected to get even longer. We appreciate the scope of work involved in the development of the guidance and hence it was divided into two phases; however, some of the questions might have been better answered if we had seen all the guidance at once. We would support revisiting some of the consultation if necessary going forward.
To read in full, please download the consultation response.