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17. If management does not take the necessary steps to ensure that anyone in receipt of the previously issued financial statements is informed of the situation and does not amend the financial statements in circumstances where the auditor believes they need to be amended, the auditor shall notify management and, unless all of those charged with governance6 are involved in managing the entity, those charged with governance, that the auditor will seek to prevent future reliance on the auditor’s report. If, despite such notification, management or those charged with governance do not take these necessary steps, the auditor shall take appropriate action to seek to prevent reliance on the auditor’s report. (Ref: Para. A20) ***
Application and Other Explanatory Material
Introduction (Ref: Para. 1)
A1. When the audited financial statements are included in other documents subsequent to the issuance of the financial statements (other than annual reports that would be within the scope of SA 720(Revised)), the auditor may have additional responsibilities relating to subsequent events that the auditor may need to consider, such as legal or regulatory requirements involving the offering of securities to the public in jurisdictions in which the securities are being offered. For example, the auditor may be required to perform additional audit procedures to the date of the final offering document. These procedures may include those referred to in paragraphs 6 and 7 performed up to a date at or near the effective date of the final offering document, and reading the offering document to assess whether the other information in the offering document is consistent with the financial information with which the auditor is associated.
Definitions
Date of Approval of the Financial Statements (Ref: Para. 5(b))
A2. In some entities, the applicable law or regulation identifies the individuals or bodies (for example, management or those charged with governance) that are responsible for concluding that all the statements that comprise the financial statements, including the related notes, have been prepared, and specifies the necessary approval process. In some other entities, the approval process is not prescribed in law or regulation and the entity follows its own procedures in preparing and finalising its financial statements in view of its management and 6 SA 260(Revised), paragraph 16(c). governance structures. In some cases, final approval of the financial statements by shareholders is required. In such cases, final approval by shareholders is not necessary for the auditor to conclude that sufficient appropriate audit evidence on which to base the auditor’s opinion on the financial statements has been obtained. The date of approval of the financial statements for purposes of the SAs is the earlier date on which those with the recognised authority determine that all the statements that comprise the financial statements, including the related notes, have been prepared and that those with the recognised authority have asserted that they have taken responsibility for those financial statements.
Date of the Auditor’s Report (Ref: Para. 5(c))
A3. The auditor’s report cannot be dated earlier than the date on which the auditor has obtained sufficient appropriate audit evidence on which to base the opinion on the financial statements, including evidence that all the statements that comprise the financial statements, including the related notes, have been prepared and that those with the recognised authority have asserted that they have taken responsibility for those financial statements.7 Consequently, the date of the auditor’s report cannot be earlier than the date of approval of the financial statements as defined in paragraph 5(b). A time period may elapse due to administrative issues between the date of the auditor’s report as defined in paragraph 5(c) and the date the auditor’s report is provided to the entity.
Date the Financial Statements are Issued (Ref: Para. 5(d))
A4. The date the financial statements are issued generally depends on the regulatory environment of the entity. In some circumstances, the date the financial statements are issued may be the date that they are filed with a regulatory authority. Since audited financial statements cannot be issued without an auditor’s report, the date that the audited financial statements are issued must not only be at or later than the date of the auditor’s report, but must also be at or later than the date the auditor’s report is provided to the entity.
A5. In the case of certain entities, such as, Central/State governments and related government entities (for example, agencies, boards, commissions), the date the financial statements are issued may be the date the audited financial statements and the auditor’s report thereon are presented to the legislature or otherwise made public.
Events Occurring Between the Date of the Financial Statements and
the Date of the Auditor’s Report (Ref: Para. 6-9)
A6. Depending on the auditor’s risk assessment, the audit procedures required by paragraph 6 may include procedures, necessary to obtain sufficient 7 SA 700(Revised), paragraph 48. appropriate audit evidence, involving the review or testing of accounting records or transactions occurring between the date of the financial statements and the date of the auditor’s report. The audit procedures required by paragraphs 6 and 7 are in addition to procedures that the auditor may perform for other purposes that, nevertheless, may provide evidence about subsequent events (for example, to obtain audit evidence for account balances as at the date of the financial statements, such as cut-off procedures or procedures in relation to subsequent receipts of accounts receivable).
A7. Paragraph 7 stipulates certain audit procedures in this context that the auditor is required to perform pursuant to paragraph 6. The subsequent events procedures that the auditor performs may, however, depend on the information that is available and, in particular, the extent to which the accounting records have been prepared since the date of the financial statements. When the accounting records are not up-to-date, and accordingly no interim financial statements (whether for internal or external purposes) have been prepared, or minutes of meetings of management or those charged with governance have not been prepared, relevant audit procedures may take the form of inspection of available books and records, including bank statements. Paragraph A8 gives examples of some of the additional matters that the auditor may consider in the course of these inquiries.
A8. In addition to the audit procedures required by paragraph 7, the auditor may consider it necessary and appropriate to: Read the entity’s latest available budgets, cash flow forecasts and other related management reports for periods after the date of the financial statements; Inquire, or extend previous oral or written inquiries, of the entity’s legal counsel concerning litigation and claims; or Consider whether written representations covering particular subsequent events may be necessary to support other audit evidence and thereby obtain sufficient appropriate audit evidence.
Inquiry (Ref: Para. 7(b))
A9. In inquiring of management and, where appropriate, those charged with governance, as to whether any subsequent events have occurred that might affect the financial statements, the auditor may inquire as to the current status of items that were accounted for on the basis of preliminary or inconclusive data and may make specific inquiries about the following matters:
Whether new commitments, borrowings or guarantees have been entered
into. Whether sales or acquisitions of assets have occurred or are planned. Whether there have been increases in capital or issuance of debt instruments, such as the issue of new shares or debentures, or an agreement to merge or liquidate has been made or is planned. Whether any assets have been appropriated by government or destroyed, for example, by fire or flood. Whether there have been any developments regarding contingencies.
Whether any unusual accounting adjustments have been made or are
contemplated. Whether any events have occurred or are likely to occur that will bring into question the appropriateness of accounting policies used in the financial statements, as would be the case, for example, if such events call into question the validity of the going concern assumption. Whether any events have occurred that are relevant to the measurement of estimates or provisions made in the financial statements. Whether any events have occurred that are relevant to the recoverability of assets.
Reading Minutes (Ref: Para. 7(c))
A10. In case of certain entities, such as, Central/State governments and related government entities (for example, agencies, boards, commissions), the auditor may read the official records of relevant proceedings of the legislature and inquire about matters addressed in proceedings for which official records are not yet available. Facts Which Become Known to the Auditor After the Date of the
Auditor’s Report but Before the Date the Financial Statements are
Issued
Implications of Other Information Obtained after the Date of the Auditor’s
Report (Ref: Para. 10)
A11. While the auditor has no obligation to perform any audit procedures regarding the financial statements after the date of the auditor’s report but before the date the financial statements are issued, SA 720(Revised) contains requirements and guidance with respect to other information obtained after the date of the auditor’s report, which might include other information obtained after the date of the auditor’s report, but before the date the financial statements are issued.
Management Responsibility Towards Auditor (Ref: Para. 10)
A12. As explained in SA 210, the terms of the audit engagement include the agreement of management to inform the auditor of facts that may affect the financial statements, of which management may become aware during the period from the date of the auditor’s report to the date the financial statements are issued.8
Dual Dating (Ref: Para. 12(a))
A13. When, in the circumstances described in paragraph 12(a), the auditor amends the auditor’s report to include an additional date restricted to that amendment, the date of the auditor’s report on the financial statements prior to their subsequent amendment by management remains unchanged because this date informs the reader as to when the audit work on those financial statements was completed. However, an additional date is included in the auditor’s report to inform users that the auditor’s procedures subsequent to that date were restricted to the subsequent amendment of the financial statements. The following is an illustration of such an additional date: “(Date of auditor’s report), except as to Note Y, which is as of (date of completion of audit procedures restricted to amendment described in Note Y)”.
No Amendment of Financial Statements by Management (Ref: Para. 13)
A14. In some entities, management may not be required by the applicable law, regulation or the financial reporting framework to issue amended financial statements. This is often the case when issuance of the financial statements for the following period is imminent, provided appropriate disclosures are made in such statements.
A15. In case of certain entities, such as, Central/State governments and related government entities (for example, agencies, boards, commissions), the actions taken in accordance with paragraph 13 when management does not amend the financial statements may also include reporting separately to the legislature, or other relevant body in the reporting hierarchy, on the implications of the subsequent event for the financial statements and the auditor’s report. Auditor Action to Seek to Prevent Reliance on Auditor’s Report (Ref: Para. 13(b))
A16. The auditor may need to fulfill additional legal obligations even when the auditor has notified management not to issue the financial statements and management has agreed to this request.
A17. When management has issued the financial statements despite the auditor’s notification not to issue the financial statements to third parties, the auditor’s course of action to prevent reliance on the auditor’s report on the financial statements depends upon the auditor’s legal rights and obligations. Consequently, the auditor may consider it appropriate to seek legal advice. 8 SA 210, “Agreeing the Terms of Audit Engagements”, paragraph A23.
Facts Which Become Known to the Auditor After the Financial
Statements have been Issued
Implications of Other Information Received after the Financial Statements
Have Been Issued (Ref: Para. 14)
A18. The auditor’s obligations regarding other information received after the date of the auditor’s report are addressed in SA 720(Revised). While the auditor has no obligation to perform any audit procedures regarding the financial statements after the financial statements have been issued, SA 720(Revised) contains requirements and guidance with respect to other information obtained after the date of the auditor’s report.
No Amendment of Financial Statements by Management (Ref: Para. 15)
A19. In some circumstances, the entities, such as, Central/State governments and related government entities (for example, agencies, boards, commissions) may be prevented from issuing amended financial statements by law or regulation. In such circumstances, the appropriate course of action for the auditor may be to report to the appropriate statutory body. Auditor Action to Seek to Prevent Reliance on Auditor’s Report (Ref: Para. 17)
A20. When the auditor believes that management, or those charged with governance, have failed to take the necessary steps to prevent reliance on the auditor’s report on financial statements previously issued by the entity despite the auditor’s prior notification that the auditor will take action to seek to prevent such reliance, the auditor’s course of action depends upon the auditor’s legal rights and obligations. Consequently, the auditor may consider it appropriate to seek legal advice.
Material Modifications to ISA 560, “Subsequent Events”
Deletion
1. Paragraph A5 of ISA 560 (A5 of SA 560) provides that in the case of public sector entities, the date the financial statements are issued may be the date the audited financial statements and the auditor’s report thereon are presented to the legislature or otherwise made public. Paragraph A10 of ISA 560 (A10 of SA 560) provides that in the case of public sector, the auditor may read the official records of relevant proceedings of the legislature and inquire about matters addressed in proceedings for which official records are not yet available. Paragraph A15 of ISA 560 (A15 of SA 560) provides that in the case of public sector, the actions taken in accordance with paragraph 13 of ISA when management does not amend the financial statements may also include reporting separately to the legislature, or other relevant body in the reporting hierarchy, on the implications of the subsequent event for the financial statements and the auditor’s report. Paragraph A19 of ISA 560 (A19 of SA 560) provides that in some circumstances, the entities in the public sector may be prevented from issuing amended financial statements by law or regulation. In such circumstances, the appropriate course of action for the auditor may be to report to the appropriate statutory body. Since as mentioned in the “Preface to the Standards on Quality Control, Auditing, Review, Other Assurance and
Related Services”, the Standards issued by the Auditing and Assurance
Standards Board, apply equally to all entities, irrespective of their form, nature and size, a specific reference to applicability of the Standard to public sector entities has been deleted. Further, it is also possible that such situations may also exist in case of certain entities pursuant to a requirement under the statute or regulation under which they operate. Accordingly, the spirit of Paragraphs A5, A10, A15 and A19 in ISA 560, highlighting such fact, has been retained though a specific reference to public sector entities has been deleted.
