Revised Auditor’s Report [SA 700 (R) / SA 705 / SA706]

This time we all have to prepare Audit Report in a Revised Format. In the recent times, there has been an increased focus on role of auditor due to some wrong and some ‘right’ reasons.

Audit consists of 3 major activities:

1) Conduct of the audit (using SAs)

2) Ensuring compliance of AS

3) Ensuring adequate disclosure as per statute, AS, etc.

Since last several years, the focus of audit has shifted to (2) and (3) ignoring (1).

Standards on Auditing (SA) are issued by Auditing and Assurance Standards Board (AASB) under the authority of the Council of the ICAI. ICAI is one of the founder members of the International Federation of Accountants (IFAC). The Standards developed and promulgated by the AASB under the authority of the Council of the ICAI are required to be in conformity with the corresponding International Standards issued by the International Auditing and Assurance Standards Board (IAASB), established by the IFAC.

SA 700 was originally issued in the year 2003 by the ICAI and was then known as Auditing & Assurance Standard (AS) 28 corresponding to the International Standard on Auditing (ISA) 700. The 2008 crisis shook the confidence of the users of financial statements and brought to light, the need for greater transparency and information in the auditor’s report. Responding to the above needs, IASSB revised its ISA 700 and split it into three standards, namely –

ISA 700 (Revised)	Forming an Opinion on Financial Statements
ISA 705	Modifications to the Opinion in the Independent Auditor’s Report
ISA 706	Emphasis of Matter Paragraphs in the Independent Auditor’s Report

Correspondingly, ICAI revised its SA 700 (AAS 28) in the year 2010 and issued three separate Standards on Auditing (SA) to deal with the form and content of an independent auditor’s report as also the various types of opinion that may be included in the auditor’s report corresponding to the aforementioned ISAs. The standards are:

EFFECTIVE DATE/APPLICABILITY:-

These standards, when issued in 2010, were supposed to be effective for all audits relating to accounting periods beginning on or after April 1, 2011. However, the Council later decided that the effective date/applicability of these standards viz SA 700 (Revised), SA 705 and SA 706 be postponed by one year and consequently the said Standards are now effective/applicable for audits of financial statements for periods beginning on or after 1st April, 2012.

Given below is a brief highlight of SA 700(Revised), SA 705 and SA 706 for easy understanding and reference. Readers are requested to refer to the complete text of the respective SAs to understand them in totality.

SA 700 (REVISED) – FORMING AN OPINION AND REPORTING ON FS:-

• SA 700 (Revised) deals with the auditor’s responsibility to form an opinion on the financial statements (FS) and also with the form and content of the auditor’s report issued as a result of an audit of FS.

• SA 700(R) requires the auditor to form an opinion on whether the FS are prepared in all material respects in according with the applicable Financial Reporting Framework.

• In order to form that opinion, auditor has to conclude, whether reasonable assurance has been obtained that the FS as a whole are free from material misstatement, whether due to fraud or error.

The conclusions shall take into account

• whether sufficient appropriate audit evidence (SAAE) has been obtained in accordance with SA 330;
• whether uncorrected misstatements are material, individually or in aggregate in accordance with SA 450

While forming an opinion of the FS, the auditor shall consider whether, in view of the requirements of the applicable Financial Reporting Framework:

• The FS adequately disclose significant accounting policies selected and applied;
• The accounting policies selected and applied are consistent with the applicable FRF and are appropriate;
• The accounting estimates made by the management are reasonable;
• The information presented in the FS is relevant, reliable, comparable and understandable;
• The FS provide adequate disclosures to enable the intended users to understand the effect of material transactions and events on the information conveyed in the FS and
• The terminology used in the FS including the title is appropriate.

The auditor shall express an unmodified opinion when the auditor concludes that the FS are prepared, in all material respects, in accordance with the applicable FRF.

The auditor shall modify the opinion in the auditor’s report in accordance with SA 705 if he:

• concludes that, based on the audit evidence obtained, the FS as a whole are not free from material misstatement; or
• is unable to obtain sufficient appropriate audit evidence to conclude that the financial statements as a whole are free from material misstatement.

The main highlights of this SA are:

• The Auditors report shall be in writing – hard Copy or report using electronic format.
• It shall have a title that clearly indicates that it is the report of an independent auditor.
• The introductory paragraph of the report shall contain the name of the entity, name and period of each statement that comprises the FS, refer to the summary of significant accounting policies and other explanatory information and state that the FS have been audited.
• The Auditor’s report shall include sections and headings as under
  • Report on the FS (if other reporting responsibilities have been addressed)
  • Management’s [or other appropriate term] Responsibility for the FS
  • Auditor’s Responsibility
  • Opinion
  • Report on Other Legal and Regulatory Requirements (wherever applicable)(eg. CARO)
• The Auditor’s report shall be signed and dated and shall also contain the place of signature along with membership number of the auditor signing the report and the FRN of the firm, as applicable.
  

SA 705 – MODIFICATIONS TO THE OPINION IN THE INDEPENDENT AUDITOR’S REPORT:-

SA 705 deals with the auditor’s responsibility to issue an appropriate report in circumstances when, in forming an opinion in accordance with SA 700 (Revised), the auditor concludes that a modification to the auditor’s opinion on the FS is necessary.

It establishes three types of modifications to the opinion, as discussed below.

Qualified Opinion

Where the auditor, either on the basis of evidence obtained or otherwise, concludes that misstatements are MATERIAL BUT NOT PERVASIVE to the FS

Adverse Opinion – The auditor, having obtained sufficient appropriate audit evidence, concludes that misstatements are BOTH MATERIAL AND PERVASIVE to the FS

Disclaimer of Opinion – The auditor is unable to obtain sufficient appropriate audit evidence on which to base the opinion and concludes that possible effects of such undetected misstatements, if any, on the FS could be BOTH MATERIAL AND PERVASIVE

Illustration on Types of Modified Opinion

The table below illustrates how the auditor’s judgment about the nature of the matter giving rise to the modification and the pervasiveness of its effects or possible effects on the FS, affects the type of opinion to be expressed:

Nature of Matter Giving Rise to the Modification	Auditor’s Judgment about the Pervasiveness of the Effects or Possible Effects on the Financial Statements
	Material but Not Pervasive	Material and Pervasive
FS are materially misstated	Qualified opinion	Adverse opinion
Inability to obtain sufficient appropriate audit evidence	Qualified opinion	Disclaimer of opinion

Form and Content of the Auditor’s Report When the Opinion Is Modified

• When the auditor modifies the opinion on the FS, the auditor shall, in addition to the specific elements required by the SA 700 (Revised), include a paragraph in the auditor’s report that provides a description of the matter giving rise to the modification. The auditor shall place this paragraph immediately before the opinion paragraph in the auditor’s report and use the heading “Basis for Qualified Opinion”, “Basis for Adverse Opinion”, or “Basis for Disclaimer of Opinion”, as appropriate.
• When the auditor modifies the audit opinion, the auditor shall use the heading “Qualified Opinion”, “Adverse Opinion”, or “Disclaimer of Opinion”, as appropriate, for the opinion paragraph.
• The financial effect of the misstatement shall be quantified as far as practicable, else the auditor needs to specify that same in the report.

Further as required under Section 227(3)(e) of the Companies Act, 1956, the basis for qualification and the qualified opinion paragraphs should be in bold or italics.

SA 706 – EMPHASIS OF MATTER PARAGRAPHS AND OTHER MATTER PARAGRAPHS IN THE INDEPENDENT AUDITOR’S REPORT:-

SA 706 deals with additional communication in the auditor’s report when the auditor considers it necessary to:

• Draw users’ attention to a matter or matters presented or disclosed in the financial statements that are of such importance that they are fundamental to users’ understanding of the financial statements; or
• Draw users’ attention to any matter or matters other than those presented or disclosed in the financial statements that are relevant to users’ understanding of the audit, the auditor’s responsibilities or the auditor’s report.

Meaning of “Emphasis of Matter” and “Other Matter”

EMPHASIS OF MATTER	A matter appropriately presented or disclosed in the FS that, in the auditor’s judgement, is of such importance that it is fundamental to user’s understanding of the FS.
OTHER MATTER	A matter other than those presented or disclosed in the FS that, in the auditor’s judgement, is relevant to user’s understanding of the audit, the auditor’s responsibilities or the auditor’s report.

Form and Content of the Auditor’s Report with “EMPHASIS OF MATTER” Paragraphs in the Auditor’s Report

• Emphasis of Matter paragraph shall be included in the auditor’s report immediately after the Opinion paragraph under the heading “Emphasis of Matter”, or other appropriate heading.
• A clear reference to the matter being emphasized and where the same can be found in the financial statements shall be given in the report.
• The Auditor shall indicate that auditor’s opinion is not modified in respect of the matter emphasized.

Form and Content of the Auditor’s Report with “OTHER MATTER” Paragraphs in the Auditor’s Report
Other Matter paragraph shall be included in the auditor’s report immediately after the Opinion paragraph and any Emphasis of Matter paragraph, or elsewhere in the auditor’s report if the content of the Other Matter paragraph is relevant to the Other Reporting Responsibilities section.

COMPARATIVE ILLUSTRATION OF FORMAT OF AUDITOR’S REPORT (NON-MODIFIED) BEFORE AND AFTER APPLICABILITY OF SA 700 (REVISED):-

Illustrative format of Audit Report applicable till 31.03.2012 [Before application of SA 700 (revised)]

Illustrative format of Audit Report applicable from 01.04.2012 [After application of SA 700 (Revised)]

AUDITORS’ REPORT To the Members of ABC Company Limited We have audited the attached balance sheet of ABC Company Limited (“the Company”) as at 31 March 20XX and the statement of profit and loss for the period ….. annexed thereto. These financial statements are the responsibility of the Company’s management. Our responsibility is to express an opinion on these financial statements based on our audit. We conducted our audit in accordance with auditing standards generally accepted in India. Those Standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. An audit includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements. An audit also includes assessing the accounting principles used and significant estimates made by management, as well as evaluating the overall financial statement presentation. We believe that our audit provides a reasonable basis for our opinion. As required by the Companies (Auditor’s Report) Order, 2003, as amended, issued by the Central Government of India in terms of sub-section (4A) of Section 227 of the Companies Act, 1956, (“the Act”) we enclose in the Annexure a statement on the matters specified in paragraphs 4 and 5 of the said Order. Further to our comments in the annexure referred to above, we report that: (a) we have obtained all the information and explanations which to the best of our knowledge and belief were necessary for the purpose of our audit; (b) in our opinion proper books of account as required by law have been kept by the Company so far as appears from our examination of those books [and proper returns adequate for the purposes of our audit have been received from branches not visited by us]; (c) the Balance Sheet, Statement of Profit and Loss, and Cash Flow Statement dealt with by this Report are in agreement with the books of account [and with the returns received from branches not visited by us; (d) in our opinion, the Balance Sheet, Statement of Profit and Loss, and Cash Flow Statement comply with the Accounting Standards referred to in subsection (3C) of section 211 of the Companies Act, 1956; (e) on the basis of written representations received from the directors as on March 31, 20XX, and taken on record by the Board of Directors, none of the directors is disqualified as on March 31, 20XX, from being appointed as a director in terms of clause (g) of sub-section (1) of section 274 of the Companies Act, 1956. (f) in our opinion and to the best of our information and according to the explanations given to us, the said accounts give the information required by the Act in the manner so required, and give a true and fair view, in conformity with the accounting principles generally accepted in India: (a) in the case of the Balance Sheet, of the state of affairs of the Company as at March 31, 20XX; (b) in the case of the Profit and Loss Account, of the profit/ loss for the year ended on that date; and (c) in the case of the Cash Flow Statement, of the cash flows for the year ended on that date. For XYZ and Co. Chartered Accountants Firm’s Registration Number Signature (Name of the Member Signing the Audit Report) (Designation) Membership Number Place of Signature Date

INDEPENDENT AUDITOR’S REPORT To the Members of ABC Company Limited Report on the Financial Statements We have audited the accompanying financial statements of ABC Company Limited (“the Company”), which comprise the Balance Sheet as at March 31, 20XX, and the Statement of Profit and Loss and Cash Flow Statement for the year then ended, and a summary of significant accounting policies and other explanatory information. Management’s Responsibility for the Financial Statements Management is responsible for the preparation of these financial statements that give a true and fair view of the financial position, financial performance and cash flows of the Company in accordance with the Accounting Standards referred to in sub-section (3C) of section 211 of the Companies Act, 1956 (“the Act”). This responsibility includes the design, implementation and maintenance of internal control relevant to the preparation and presentation of the financial statements that give a true and fair view and are free from material misstatement, whether due to fraud or error. Auditor’s Responsibility Our responsibility is to express an opinion on these financial statements based on our audit. We conducted our audit in accordance with the Standards on Auditing issued by the Institute of Chartered Accountants of India. Those Standards require that we comply with ethical requirements and plan and perform the audit to obtain reasonable assurance about whether the financial statements are free from material misstatement. An audit involves performing procedures to obtain audit evidence about the amounts and disclosures in the financial statements. The procedures selected depend on the auditor’s judgment, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error. In making those risk assessments, the auditor considers internal control relevant to the Company’s preparation and fair presentation of the financial statements in order to design audit procedures that are appropriate in the circumstances. An audit also includes evaluating the appropriateness of accounting policies used and the reasonableness of the accounting estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion. Opinion In our opinion and to the best of our information and according to the explanations given to us, the financial statements give the information required by the Act in the manner so required and give a true and fair view in conformity with the accounting principles generally accepted in India: (a) in the case of the Balance Sheet, of the state of affairs of the Company as at March 31, 20XX; (b) in the case of the Profit and Loss Account, of the profit/ loss for the year ended on that date; and (c) in the case of the Cash Flow Statement, of the cash flows for the year ended on that date. Report on Other Legal and Regulatory Requirements 1. As required by the Companies (Auditor’s Report) Order, 2003 (“the Order”) issued by the Central Government of India in terms of sub-section (4A) of section 227 of the Act, we give in the Annexure a statement on the matters specified in paragraphs 4 and 5 of the Order. 2. As required by section 227(3) of the Act, we report that: a. we have obtained all the information and explanations which to the best of our knowledge and belief were necessary for the purpose of our audit; b. in our opinion proper books of account as required by law have been kept by the Company so far as appears from our examination of those books [and proper returns adequate for the purposes of our audit have been received from branches not visited by us]; c. the Balance Sheet, Statement of Profit and Loss, and Cash Flow Statement dealt with by this Report are in agreement with the books of account [and with the returns received from branches not visited by us; d. in our opinion, the Balance Sheet, Statement of Profit and Loss, and Cash Flow Statement comply with the Accounting Standards referred to in subsection (3C) of section 211 of the Companies Act, 1956; e. on the basis of written representations received from the directors as on March 31, 20XX, and taken on record by the Board of Directors, none of the directors is disqualified as on March 31, 20XX, from being appointed as a director in terms of clause (g) of sub-section (1) of section 274 of the Companies Act, 1956. For XYZ and Co. Chartered Accountants Firm’s Registration Number Signature (Name of the Member Signing the Audit Report) (Designation) Membership Number Place of Signature Date

COMPARATIVE ILLUSTRATION OF FORMAT OF AUDITOR’S REPORT AS PER SA 700 (REVISED) AND SA (REVISED) WITH SA 705 AND SA 706:-

Illustrative format of Audit Report as per SA 700 (Revised)

Illustrative format of Audit Report As per SA 700 (Revised), SA 705 & SA 706

INDEPENDENT AUDITOR’S REPORT To the Members of ABC Company Limited Report on the Financial Statements We have audited the accompanying financial statements of ABC Company Limited (“the Company”), which comprise the Balance Sheet as at March 31, 20XX, and the Statement of Profit and Loss and Cash Flow Statement for the year then ended, and a summary of significant accounting policies and other explanatory information. Management’s Responsibility for the Financial Statements Management is responsible for the preparation of these financial statements that give a true and fair view of the financial position, financial performance and cash flows of the Company in accordance with the Accounting Standards referred to in sub-section (3C) of section 211 of the Companies Act, 1956 (“the Act”). This responsibility includes the design, implementation and maintenance of internal control relevant to the preparation and presentation of the financial statements that give a true and fair view and are free from material misstatement, whether due to fraud or error. Auditor’s Responsibility Our responsibility is to express an opinion on these financial statements based on our audit. We conducted our audit in accordance with the Standards on Auditing issued by the Institute of Chartered Accountants of India. Those Standards require that we comply with ethical requirements and plan and perform the audit to obtain reasonable assurance about whether the financial statements are free from material misstatement. An audit involves performing procedures to obtain audit evidence about the amounts and disclosures in the financial statements. The procedures selected depend on the auditor’s judgment, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error. In making those risk assessments, the auditor considers internal control relevant to the Company’s preparation and fair presentation of the financial statements in order to design audit procedures that are appropriate in the circumstances. An audit also includes evaluating the appropriateness of accounting policies used and the reasonableness of the accounting estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion. Opinion In our opinion and to the best of our information and according to the explanations given to us, the financial statements give the information required by the Act in the manner so required and give a true and fair view in conformity with the accounting principles generally accepted in India: (a) in the case of the Balance Sheet, of the state of affairs of the Company as at March 31, 20XX; (b) in the case of the Profit and Loss Account, of the profit/ loss for the year ended on that date; and (c) in the case of the Cash Flow Statement, of the cash flows for the year ended on that date. Report on Other Legal and Regulatory Requirements 1. As required by the Companies (Auditor’s Report) Order, 2003 (“the Order”) issued by the Central Government of India in terms of sub-section (4A) of section 227 of the Act, we give in the Annexure a statement on the matters specified in paragraphs 4 and 5 of the Order. 2. As required by section 227(3) of the Act, we report that: a. we have obtained all the information and explanations which to the best of our knowledge and belief were necessary for the purpose of our audit; b. in our opinion proper books of account as required by law have been kept by the Company so far as appears from our examination of those books [and proper returns adequate for the purposes of our audit have been received from branches not visited by us]; c. the Balance Sheet, Statement of Profit and Loss, and Cash Flow Statement dealt with by this Report are in agreement with the books of account [and with the returns received from branches not visited by us; d. in our opinion, the Balance Sheet, Statement of Profit and Loss, and Cash Flow Statement comply with the Accounting Standards referred to in subsection (3C) of section 211 of the Companies Act, 1956; e. on the basis of written representations received from the directors as on March 31, 20XX, and taken on record by the Board of Directors, none of the directors is disqualified as on March 31, 20XX, from being appointed as a director in terms of clause (g) of sub-section (1) of section 274 of the Companies Act, 1956. For XYZ and Co. Chartered Accountants Firm’s Registration Number Signature (Name of the Member Signing the Audit Report) (Designation) Membership Number Place of Signature Date

INDEPENDENT AUDITOR’S REPORT To the Members of ABC Company Limited Report on the Financial Statements We have audited the accompanying financial statements of ABC Company Limited (“the Company”), which comprise the Balance Sheet as at March 31, 20XX, and the Statement of Profit and Loss and Cash Flow Statement for the year then ended, and a summary of significant accounting policies and other explanatory information. Management’s Responsibility for the Financial Statements Management is responsible for the preparation of these financial statements that give a true and fair view of the financial position, financial performance and cash flows of the Company in accordance with the Accounting Standards referred to in sub-section (3C) of section 211 of the Companies Act, 1956 (“the Act”). This responsibility includes the design, implementation and maintenance of internal control relevant to the preparation and presentation of the financial statements that give a true and fair view and are free from material misstatement, whether due to fraud or error. Auditor’s Responsibility Our responsibility is to express an opinion on these financial statements based on our audit. We conducted our audit in accordance with the Standards on Auditing issued by the Institute of Chartered Accountants of India. Those Standards require that we comply with ethical requirements and plan and perform the audit to obtain reasonable assurance about whether the financial statements are free from material misstatement. An audit involves performing procedures to obtain audit evidence about the amounts and disclosures in the financial statements. The procedures selected depend on the auditor’s judgment, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error. In making those risk assessments, the auditor considers internal control relevant to the Company’s preparation and fair presentation of the financial statements in order to design audit procedures that are appropriate in the circumstances. An audit also includes evaluating the appropriateness of accounting policies used and the reasonableness of the accounting estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion. *Basis for Qualified Opinion The Company’s inventories are carried in the Balance Sheet at Rs. XXX. Management has not stated the inventories at the lower of cost and net realisable value but has stated them solely at cost, which constitutes a departure from the accounting standards referred to in sub-section (3C) of section 211 of the Act…………………………………. *Qualified Opinion In our opinion and to the best of our information and according to the explanations given to us, except for the effects of the matter described in the Basis for Qualified Opinion paragraph, the financial statements give the information required by the Act in the manner so required and give a true and fair view in conformity with the accounting principles generally accepted in India: (a) in the case of the Balance Sheet, of the state of affairs of the Company as at March 31, 20XX; (b) in the case of the Profit and Loss Account, of the profit/ loss for the year ended on that date; and (c) in the case of the Cash Flow Statement, of the cash flows for the year ended on that date. Emphasis of Matter We draw attention to Note X to the financial statements which describe the uncertainty related to the outcome of the lawsuit filed against the Company by XYZ Company. Our opinion is not qualified in respect of this matter. Report on Other Legal and Regulatory Requirements 1. As required by the Companies (Auditor’s Report) Order, 2003 (“the Order”) issued by the Central Government of India in terms of sub-section (4A) of section 227 of the Act, we give in the Annexure a statement on the matters specified in paragraphs 4 and 5 of the Order. 2. As required by section 227(3) of the Act, we report that: a. we have obtained all the information and explanations which to the best of our knowledge and belief were necessary for the purpose of our audit; b. in our opinion proper books of account as required by law have been kept by the Company so far as appears from our examination of those books [and proper returns adequate for the purposes of our audit have been received from branches not visited by us]; c. the Balance Sheet, Statement of Profit and Loss, and Cash Flow Statement dealt with by this Report are in agreement with the books of account [and with the returns received from branches not visited by us; *d. Except for the effects of the matter described in the Basis for Qualified Opinion paragraph, the Balance Sheet, Statement of Profit and Loss, and Cash Flow Statement comply with the Accounting Standards referred to in subsection (3C) of section 211 of the Companies Act, 1956; e. on the basis of written representations received from the directors as on March 31, 20XX, and taken on record by the Board of Directors, none of the directors is disqualified as on March 31, 20XX, from being appointed as a director in terms of clause (g) of sub-section (1) of section 274 of the Companies Act, 1956. For XYZ and Co. Chartered Accountants Firm’s Registration Number Signature (Name of the Member Signing the Audit Report) (Designation) Membership Number Place of Signature Date

* “Basis for Qualified Opinion” and “Qualified Opinion” paragraphs are in italics as required under Sec. 227(3)(e) of the Companies Act.
Changes in the formats have been highlighted by means of underlining the text which has got modified (added/deleted)
AUDITOR’S ROLE AND REPORTING – INDIAN SCENARIO AND GLOBAL DEVELOPMENTS:-

• Companies Bill 2012 lays down several additional restrictions, responsibilities and penalties for an auditor
• Globally also, auditor’s role and reporting is undergoing a change
• The IFAC is proposing to introduce in the IAASB Report – paragraphs on Going Concern, Auditor commentary on Audit strategy and Involvement of other Auditors, etc.
• Since the Indian SAs have to be in conformity with the ISAs; the above propositions might also get included in future in the Independent Auditor’s Reports issued in India
• Audits are becoming very challenging
• Adequate and advanced planning has become necessary for proper conduct of audit
• If proper audits are not done, auditor will have to face FRRB, QRB, NFRA, etc.