Sa 210
Sa 210
Contents
Paragraph(s)
Introduction
Scope of this SA............... ........................................................................ 1
Effective Date............................................................................................ 2
Objective .................................................................................................. 3
Definitions ............................................................................................ 4-5
Requirements
Preconditions for an Audit ..................................................................... 6-8
Agreement on Audit Engagement Terms ........................................... 9-12
Recurring Audits ..................................................................................... 13
Acceptance of a Change in the Terms of the Audit Engagement ..... 14-17
Additional Considerations in Engagement Acceptance ..................... 18-21
Application and Other Explanatory Material
Scope of this SA .....................................................................................A1
Preconditions for an Audit .............................................................. A2-A19
Agreement on Audit Engagement Terms .................................... A20-A26
Recurring Audits ...................................................................................A27
Acceptance of a Change in the Terms of the Audit Engagement A28-A32
Additional Considerations in Engagement Acceptance ............... A33-A36
SA 210 2
Agreeing the Terms of Audit Engagements
Introduction
Scope of this SA
1. This Standard on Auditing (SA) deals with the auditor’s responsibilities in
agreeing the terms of the audit engagement with management and, where
appropriate, those charged with governance. This includes establishing that
certain preconditions for an audit, responsibility for which rests with management
and, where appropriate, those charged with governance, are present. SA 220 3
deals with those aspects of engagement acceptance that are within the control of
the auditor. (Ref: Para. A1)
Effective Date
2. This SA is effective for audits of financial statements for periods beginning
on or after April 1, 2010.
Objective
3. The objective of the auditor is to accept or continue an audit engagement
only when the basis upon which it is to be performed has been agreed, through:
(a) Establishing whether the preconditions for an audit are present; and
(b) Confirming that there is a common understanding between the auditor and
management and, where appropriate, those charged with governance of
the terms of the audit engagement.
Definitions
4. For purposes of the SAs, the following term has the meaning attributed
below:
Preconditions for an audit – The use by management of an acceptable financial
reporting framework4 in the preparation of the financial statements and the
agreement of management and, where appropriate, those charged with
governance to the premise5 on which an audit is conducted.
5. For the purposes of this SA, references to “management” should be read
hereafter as “management and, where appropriate, those charged with governance”.
3 SA 220, “Quality Control for an Audit of Financial Statements”, published in March, 2010 issue of
the Journal.
4 SA 200, “Overall Objectives of the Independent Auditor and the Conduct of an Audit in
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Requirements
Preconditions for an Audit
6. In order to establish whether the preconditions for an audit are present,
the auditor shall:
(a) Determine whether the financial reporting framework to be applied in the
preparation of the financial statements is acceptable; and (Ref: Para. A2-
A9)
(b) Obtain the agreement of management that it acknowledges and
understands its responsibility: (Ref: Para A10-A13, A19)
(i) For the preparation of the financial statements in accordance with the
applicable financial reporting framework, including where relevant
their fair presentation; (Ref: Para. A14)
(ii) For such internal control as management determines is necessary to
enable the preparation of financial statements that are free from
material misstatement, whether due to fraud or error; and (Ref: Para.
A15-A18)
(iii) To provide the auditor with:
a. Access to all information of which management is aware that is
relevant to the preparation of the financial statements such as
records, documentation and other matters;
b. Additional information that the auditor may request from
management for the purpose of the audit; and
c. Unrestricted access to persons within the entity from whom the
auditor determines it necessary to obtain audit evidence.
Limitation on Scope Prior to Audit Engagement Acceptance
7. If management or those charged with governance impose a limitation on
the scope of the auditor’s work in the terms of a proposed audit engagement
such that the auditor believes the limitation will result in the auditor disclaiming
an opinion on the financial statements, the auditor shall not accept such a limited
engagement as an audit engagement, unless required by law or regulation to do
so.
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Agreeing the Terms of Audit Engagements
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in effect to those set out in that paragraph. For such responsibilities that are
equivalent, the auditor may use the wording of the law or regulation to describe
them in the written agreement. For those responsibilities that are not prescribed
by law or regulation such that their effect is equivalent, the written agreement
shall use the description in paragraph 6(b). (Ref: Para. A25)
Recurring Audits
13. On recurring audits, the auditor shall assess whether circumstances
require the terms of the audit engagement to be revised and whether there is a
need to remind the entity of the existing terms of the audit engagement. (Ref:
Para. A27)
Acceptance of a Change in the Terms of the Audit Engagement
14. The auditor shall not agree to a change in the terms of the audit
engagement where there is no reasonable justification for doing so. (Ref: Para.
A28-A30)
15. If, prior to completing the audit engagement, the auditor is requested to
change the audit engagement to an engagement that conveys a lower level of
assurance, the auditor shall determine whether there is reasonable justification
for doing so. (Ref: Para. A31-A32)
16. If the terms of the audit engagement are changed, the auditor and
management shall agree on and record the new terms of the engagement in an
engagement letter or other suitable form of written agreement.
17. If the auditor is unable to agree to a change of the terms of the audit
engagement and is not permitted by management to continue the original audit
engagement, the auditor shall:
(a) Withdraw from the audit engagement where possible under applicable law
or regulation; and
(b) Determine whether there is any obligation, either contractual or otherwise,
to report the circumstances to other parties, such as those charged with
governance, owners or regulators.
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Agreeing the Terms of Audit Engagements
6 Accounting Standards issued by the ICAI or Accounting Standards, notified by the Central
Government by publishing the same as the Companies (Accounting Standards) Rules, 2006, or the
Accounting Standards for Local Bodies issued by the ICAI, as may be applicable.
7 Standard on Auditing (SA) 705, “Modifications to the Opinion in the Independent Auditor’s
the Independent Auditor’s Report”, published in February, 2010 issue of the Journal.
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(a) Evaluate the effect of the misleading nature of the financial statements on
the auditor’s report; and
(b) Include appropriate reference to this matter in the terms of the audit
engagement.
Auditor’s Report Prescribed by Law or Regulation
21. In some cases, the law or regulation applicable to the entity prescribes the
layout or wording of the auditor’s report in a form or in terms that are significantly
different from the requirements of SAs. In these circumstances, the auditor shall
evaluate:
(a) Whether users might misunderstand the assurance obtained from the audit
of the financial statements and, if so,
(b) Whether additional explanation in the auditor’s report can mitigate possible
misunderstanding9.
If the auditor concludes that additional explanation in the auditor’s report cannot
mitigate possible misunderstanding, the auditor shall not accept the audit
engagement, unless required by law or regulation to do so. An audit conducted in
accordance with such law or regulation does not comply with SAs. Accordingly,
the auditor shall not include any reference within the auditor’s report to the audit
having been conducted in accordance with SAs10. (Ref: Para. A35-A36)
***
9 SA 706.
10 SA 700, “Forming an Opinion and Reporting on Financial Statements”, paragraph 43.
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Agreeing the Terms of Audit Engagements
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SA 210 10
Agreeing the Terms of Audit Engagements
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Agreeing the Terms of Audit Engagements
provide the written representations, the auditor will be unable to obtain sufficient
appropriate audit evidence17. In such circumstances, it would not be appropriate
for the auditor to accept the audit engagement, unless law or regulation requires
the auditor to do so. In cases where the auditor is required to accept the audit
engagement, the auditor may need to explain to management the importance of
these matters, and the implications for the auditor’s report.
Preparation of the Financial Statements (Ref: Para. 6(b)(i))
A14. Most financial reporting frameworks include requirements relating to the
presentation of the financial statements; for such frameworks, preparation of the
financial statements in accordance with the financial reporting framework
includes presentation. In the case of a fair presentation framework the
importance of the reporting objective of fair presentation is such that the premise
agreed with management includes specific reference to fair presentation, or to
the responsibility to ensure that the financial statements will “give a true and fair
view” in accordance with the financial reporting framework.
Internal Control (Ref: Para. 6(b)(ii))
A15. Management maintains such internal control as it determines is necessary
to enable the preparation of financial statements that are free from material
misstatement, whether due to fraud or error. Internal control, no matter how
effective, can provide an entity with only reasonable assurance about achieving
the entity’s financial reporting objectives due to the inherent limitations of internal
control18.
A16. An independent audit conducted in accordance with the SAs does not act
as a substitute for the maintenance of internal control necessary for the
preparation of financial statements by management. Accordingly, the auditor is
required to obtain the agreement of management that it acknowledges and
understands its responsibility for internal control. However, the agreement
required by paragraph 6(b)(ii) does not imply that the auditor will find that internal
control maintained by management has achieved its purpose or will be free of
deficiencies.
A17. It is for management to determine what internal control is necessary to
enable the preparation of the financial statements. The term “internal control”
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Agreeing the Terms of Audit Engagements
Audit Engagement Letter or Other Form of Written Agreement20 (Ref: Para. 10-
11)
A21. It is in the interests of both the entity and the auditor that the auditor sends
an audit engagement letter before the commencement of the audit to help avoid
misunderstandings with respect to the audit. In some entities, however, the
objective and scope of an audit and the responsibilities of management and of
the auditor may be sufficiently established by law, that is, they prescribe the
matters described in paragraph 10. Although in these circumstances paragraph
11 permits the auditor to include in the engagement letter only reference to the
fact that relevant law or regulation applies and that management acknowledges
and understands its responsibilities as set out in paragraph 6(b), the auditor may
nevertheless consider it appropriate to include the matters described in
paragraph 10 in an engagement letter for the information of management.
Form and Content of the Audit Engagement Letter
A22. The form and content of the audit engagement letter may vary for each
entity. Information included in the audit engagement letter on the auditor’s
responsibilities may be based on SA 20021. Paragraphs 6(b) and 12 of this SA
deal with the description of the responsibilities of management. In addition to
including the matters required by paragraph 10, an audit engagement letter may
make reference to, for example:
● Elaboration of the scope of the audit, including reference to applicable
legislation, regulations, SAs, and ethical and other pronouncements of
professional bodies to which the auditor adheres.
● The form of any other communication of results of the audit engagement.
● The fact that because of the inherent limitations of an audit, together with
the inherent limitations of internal control, there is an unavoidable risk that
some material misstatements may not be detected, even though the audit
is properly planned and performed in accordance with SAs.
● Arrangements regarding the planning and performance of the audit,
including the composition of the audit team.
● The expectation that management will provide written representations (see
also paragraph A13).
20 In the paragraphs that follow, any reference to an audit engagement letter is to be taken as a
reference to an audit engagement letter or other suitable form of written agreement.
21 SA 200, paragraph 3-9.
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Agreeing the Terms of Audit Engagements
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(b) Any procedures that may have been performed in the original audit
engagement, except where the audit engagement is changed to an engagement
to undertake agreed- upon procedures and thus reference to the procedures
performed is a normal part of the report.
Additional Considerations in Engagement Acceptance
Financial Reporting Standards Supplemented by Law or Regulation (Ref: Para.
18)
A33. In case of some entities, law or regulation may supplement the financial
reporting standards established by an authorised or recognised standards setting
organization with additional requirements relating to the preparation of financial
statements. In such cases, the applicable financial reporting framework for the
purposes of applying the SAs encompasses both the identified financial reporting
framework and such additional requirements provided they do not conflict with
the identified financial reporting framework. This may, for example, be the case
when law or regulation prescribes disclosures in addition to those required by the
financial reporting standards or when they narrow the range of acceptable
choices that can be made within the financial reporting standards22.
Financial Reporting Framework Prescribed by Law or Regulation—Other Matters
Affecting Acceptance (Ref: Para. 19)
A34. Law or regulation may prescribe that the wording of the auditor’s opinion
use the phrases “present fairly, in all material respects” or “give a true and fair
view” in a case where the auditor concludes that the applicable financial
reporting framework prescribed by law or regulation would otherwise have been
unacceptable. In this case, the terms of the prescribed wording of the auditor’s
report are significantly different from the requirements of SAs (see paragraph
21).
Auditor’s Report Prescribed by Law or Regulation (Ref: Para. 21)
A35. SAs require that the auditor shall not represent compliance with SAs unless
the auditor has complied with all of the SAs relevant to the audit23. When law or
regulation prescribes the layout or wording of the auditor’s report in a form or in
terms that are significantly different from the requirements of SAs and the auditor
concludes that additional explanation in the auditor’s report cannot mitigate
possible misunderstanding, the auditor may consider including a statement in the
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auditor’s report that the audit is not conducted in accordance with SAs. The
auditor is, however, encouraged to apply SAs, including the SAs that address the
auditor’s report, to the extent practicable, notwithstanding that the auditor is not
permitted to refer to the audit being conducted in accordance with SAs.
A36. In case of certain entities, such as, Central/State governments and related
government entities (for example, agencies, boards, commissions), specific
requirements may exist within the legislation governing the audit mandate; for
example, the auditor may be required to report directly to a regulator or the
legislative body or the stakeholders if the entity attempts to limit the scope of the
audit.
Material Modifications to ISA 210, “Agreeing the Terms of
Audit Engagements”
Addition
Paragraph A8 of ISA 210 provides the examples of the financial reporting
standards, which can be used for the preparation and presentation of general
purpose financial statements. Since in India, financial reporting standards, used
for the preparation and presentation of financial statements, can be ‘Accounting
Standards issued by the Institute of Chartered Accountants of India or
Accounting Standards, notified under Companies (Accounting Standards) Rules,
2006’ or ‘Accounting Standards for Local Bodies issued by the Institute of
Chartered Accountants of India (ICAI)’, these have been added in the list of
examples of financial reporting standards. References have accordingly been
changed.
Deletions
1. Paragraph A10 of the ISA 210 deals with situations where the entity
operates in a jurisdiction that does not have a standard setting organization or a
prescribed financial reporting framework. Since in India, this kind of situation
does not exist, paragraph A10 has been deleted. However, the reference to
Appendix 2, Determining Acceptability of General Purpose Frameworks, has
been shifted to paragraph A9.
2. Paragraph A27 of ISA 210 deals with the condition where the law or
regulation governs the operations of public sector audits, and also prescribes the
public sector auditor’s responsibilities and powers. Paragraph A37 of ISA 210
deals with the specific reporting requirements within the legislation governing the
audit which may mandate; for example, the auditor may be required to report
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Agreeing the Terms of Audit Engagements
directly to a minister or the legislature or to public if the entity attempts to limit the
scope of the audit in case of public sector entities. 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. However, since it is also possible that such situations
may also exist in case of certain non-public entities pursuant to a requirement
under the statute or regulation under which they operate the spirit of erstwhile
A27 and A37 has been retained.
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Appendix 1
(Ref: Paras. A22-A23)
Example of an Audit Engagement Letter
The following is an example of an audit engagement letter for an audit of general
purpose financial statements prepared in accordance with Financial Reporting
Standards24 of a company registered under the Companies Act, 1956. This letter is
not authoritative but is intended only to be a guide that may be used in conjunction
with the considerations outlined in this SA. It will need to be varied according to
individual requirements and circumstances. It is drafted to refer to the audit of
financial statements for a single reporting period and would require adaptation if
intended or expected to apply to recurring audits (see paragraph 13 of this SA). It
may be appropriate to seek legal advice that any proposed letter is suitable.
***
To the Board of Directors of ABC Company Limited:25
[The objective and scope of the audit]
You26 have requested that we audit the financial statements of ABC Company
Limited, which comprise the Balance Sheet as at March 31, 20X1, and the
Statement of Profit & Loss, and Cash Flow Statement for the year then ended,
and a summary of significant accounting policies and other explanatory
information. We are pleased to confirm our acceptance and our understanding of
this audit engagement by means of this letter. Our audit will be conducted with
the objective of our expressing an opinion on the financial statements. 27
24 Refer footnote 6.
25 The addressees and references in the letter would be those that are appropriate in the
circumstances of the engagement, including the relevant jurisdiction. It is important to refer to the
appropriate persons – see paragraph A21.
26 Throughout this letter, references to “you”, “we”, “us”, “management”, “those charged with
component(s) which have been audited by another auditor/ auditors, the engagement letter may be
modified as under:
“You have requested that we audit the financial statements of ABC Company Limited,
which comprise the Balance Sheet as at March 31, 20X1, and the Statement of Profit &
Loss, and Cash Flow Statement for the year then ended, and a summary of significant
accounting policies and other explanatory information. We are pleased to confirm our
acceptance and our understanding of this audit engagement by means of this letter. Our
audit will be conducted with the objective of our expressing an opinion on the financial
statements.
Further, as informed by you, the financial statements of the components of ABC Company Limited,
viz., PQR Company Limited and XYZ Company Pvt Limited, whose financial information/ financial
statements have been included in the financial statements of ABC Company would be/ have been
SA 210 22
Agreeing the Terms of Audit Engagements
audited by another auditor/ auditors. However, we expect to be furnished the reports of such other
auditor(s) before the date of our audit report so as to enable us to deal with such reports in
accordance with the principles enunciated in the Standard on Auditing (SA) 600, Using the Work of
Another Auditor, issued by the Institute of Chartered Accountants of India”.
28 Use terminology as appropriate in the circumstances.
29 Or, if appropriate, “For the preparation and fair presentation of the financial statements in
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SA 210 24
Agreeing the Terms of Audit Engagements
[Insert other information, such as fee arrangements, billings30 and other specific
terms, as appropriate.]
[Reporting]
[Insert appropriate reference to the expected form and content of the auditor’s
report.]
The form and content of our report may need to be amended in the light of our
audit findings.
Please sign and return the attached copy of this letter to indicate your
acknowledgement of, and agreement with, the arrangements for our audit of the
financial statements including our respective responsibilities.
XYZ & Co.
Chartered Accountants
Firm’s Registration Number
(Signature)
Date : (Name of the Member)
Place : (Designation31)
Acknowledged on behalf of ABC Company by
(Signature)
Name and Designation
Date
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Appendix 2
(Ref: Para. A9)
Determining the Acceptability of General Purpose
Frameworks
1. Acceptable financial reporting frameworks normally exhibit the following
attributes that result in information provided in financial statements that is useful
to the intended users:
(a) Relevance, in that the information provided in the financial statements is
relevant to the nature of the entity and the purpose of the financial
statements. For example, in the case of a business enterprise that prepares
general purpose financial statements, relevance is assessed in terms of the
information necessary to meet the common financial information needs of a
wide range of users in making economic decisions. These needs are
ordinarily met by presenting the financial position, financial performance
and cash flows of the business enterprise.
(b) Completeness, in that transactions and events, account balances and
disclosures that could affect conclusions based on the financial statements
are not omitted.
(c) Reliability, in that the information provided in the financial statements:
(i) Where applicable, reflects the economic substance of events and
transactions and not merely their legal form; and
(ii) Results in reasonably consistent evaluation, measurement,
presentation and disclosure, when used in similar circumstances.
(d) Neutrality, in that it contributes to information in the financial statements
that is free from bias.
(e) Understandability, in that the information in the financial statements is clear
and comprehensive and not subject to significantly different interpretation.
2. The auditor may decide to compare the accounting conventions to the
requirements of an existing financial reporting framework considered to be
acceptable. For example, the auditor may compare the accounting conventions
to IFRSs. For an audit of a small entity, the auditor may decide to compare the
accounting conventions to a financial reporting framework specifically developed
for such entities by an authorised or recognised standards setting organization.
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When the auditor makes such a comparison and differences are identified, the
decision as to whether the accounting conventions adopted in the preparation
and presentation of the financial statements constitute an acceptable financial
reporting framework includes considering the reasons for the differences and
whether application of the accounting conventions, or the description of the
financial reporting framework in the financial statements, could result in financial
statements that are misleading.
3. A conglomeration of accounting conventions devised to suit individual
preferences is not an acceptable financial reporting framework for general
purpose financial statements. Similarly, a compliance framework will not be an
acceptable financial reporting framework, unless it is generally accepted in the
industry to which the entity belongs by preparers and users.
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