Draft SA 220 (Revised), Quality Management for an Audit of Financial Statements

EXPOSURE DRAFT
STANDARD ON AUDITING (SA) 220(REVISED)
QUALITY MANAGEMENT FOR AN AUDIT OF FINANCIAL STATEMENTS

Introduction

Scope of this SA

1. This Standard on Auditing (SA) deals with the specific responsibilities of the auditor regarding quality management at the engagement level for an audit of financial statements, and the related responsibilities of the engagement partner. This SA is to be read in conjunction with relevant ethical requirements. (Ref: Para. A1, A38)

The Firm’s System of Quality Management and Role of Engagement Teams

2. under proposed SQM 1, the objective of the firm is to design, implement and operate a system of quality management for audits or reviews of financial statements, or other assurance or related services engagements performed by the firm, that provides the firm with reasonable assurance that: (Ref: Para. A13–A14)

(a) The firm and its personnel fulfill their responsibilities in accordance with professional standards and applicable legal and regulatory requirements, and conduct engagements in accordance with such standards and requirements; and

(b) Engagement reports issued by the firm or engagement partners are appropriate in the circumstances.²

3. This SA is premised on the basis that the firm is subject to the SQMs. (Ref: Para. A2–A3)

4. The engagement team, led by the engagement partner, is responsible, within the context of the firm’s system of quality management and through complying with the requirements of this SA, for: (Ref: Para. A4–A11)

(a) Implementing the firm’s responses to quality risks (i.e., the firm’s policies or procedures) that are applicable to the audit engagement using information communicated by, or obtained from, the firm;

(b) Given the nature and circumstances of the audit engagement, determining whether to design and implement responses at the engagement level beyond those in the firm’s policies or procedures; and

(c) Communicating to the firm information from the audit engagement that is required to be communicated by the firm’s policies or procedures to support the design, implementation and operation of the firm’s system of quality management.

5. Complying with the requirements in other SAs may provide information that is relevant to quality management at the engagement level. (Ref: Para. A12)

6. The public interest is served by the consistent performance of quality audit engagements through achieving the objective of this standard and other SAs for each engagement. A quality audit engagement is achieved through planning and performing the engagement and reporting on it in accordance with professional standards and applicable legal and regulatory requirements. Achieving the objectives of those standards and complying with the requirements of applicable law or regulation involves exercising professional judgment and exercising professional skepticism.

7. In accordance with SA 200,³ the engagement team is required to plan and perform an audit with professional skepticism and to exercise professional judgment. Professional judgment is exercised in making informed decisions about the courses of action that are appropriate to manage and achieve quality given the nature and circumstances of the audit engagement. Professional skepticism supports the quality of judgments made by the engagement team and, through these judgments, supports the overall effectiveness of the engagement team in achieving quality at the engagement level. The appropriate exercise of professional skepticism may be demonstrated through the actions and communications of the engagement team. Such actions and communications may include specific steps to mitigate impediments that may impair the appropriate exercise of professional skepticism, such as unconscious bias or resource constraints. (Ref: Para. A33–A36)

Scalability

8. The requirements of this SA are intended to be applied in the context of the nature and circumstances of each audit. For example:

(a) When an audit is carried out entirely by the engagement partner, which may be the case for an audit of a less complex entity, some requirements in this SA are not relevant because they are conditional on the involvement of other members of the engagement team. (Ref: Para. A13– A14)

(b) When an audit is not carried out entirely by the engagement partner or in an audit of an entity whose nature and circumstances are more complex, the engagement partner may assign the design or performance of some procedures, tasks or actions to other members of the engagement team.

The Engagement Partner’s Responsibilities

9. The engagement partner remains ultimately responsible, and therefore accountable, for compliance with the requirements of this SA. The term “the engagement partner shall take responsibility for…” is used for those requirements that the engagement partner is permitted to assign the design or performance of procedures, tasks or actions to appropriately skilled or suitably experienced members of the engagement team. For other requirements, this SA expressly intends that the requirement or responsibility be fulfilled by the engagement partner and the engagement partner may obtain information from the firm or other members of the engagement team. (Ref: Para. A22–A25)

Effective Date

10. This SA is effective for audits of financial statements for periods beginning on or after…….

 Objective

11. The objective of the auditor is to manage quality at the engagement level to obtain reasonable assurance that quality has been achieved such that:

(a) The auditor has fulfilled the auditor’s responsibilities, and has conducted the audit, in accordance with professional standards and applicable legal and regulatory requirements; and

(b) The auditor’s report issued is appropriate in the circumstances.

Definitions

12. For purposes of the SAs, the following terms have the meanings attributed below:

(a) Engagement partner – The partner or other individual, appointed by the firm, who is a member of the Institute of Chartered Accountants of India and is in full time practice and is responsible for the audit engagement and its performance, and for the auditor’s report that is issued on behalf of the firm, and who, where required, has the appropriate authority from a professional, legal or regulatory body.

(b) Engagement quality review – An objective evaluation of the significant judgments made by the engagement team and the conclusions reached thereon, performed by the engagement quality reviewer and completed on or before the date of the engagement report.

(c) Engagement quality reviewer – A partner, other individual in the firm⁴, or an external individual⁵, appointed by the firm to perform the engagement quality review.

(d) Engagement team – All partners and staff performing the audit engagement, and any other individuals who perform audit procedures on the engagement, excluding an auditor’s external expert⁶ and internal auditors who provide direct assistance on an engagement.⁷ (Ref: Para. A15– A25)

(e) Firm – A sole practitioner/proprietor, partnership including limited liability partnership or any such entity of professional accountants, as may be permitted by law. (Ref: Para. A26)

(f) Network firm – A firm or entity that belongs to the firm’s network. (Ref: Para. A27)

(g) Network – A larger structure: (Ref: Para. A27)

(i) That is aimed at cooperation, and

(ii) That is clearly aimed at profit or cost-sharing or shares common ownership, control or management, common quality management policies or procedures, common business strategy, the use of a common brand name, or a significant part of professional resources.

(h) Partner – Any individual with authority to bind the firm with respect to the performance of a professional services engagement.

(i) Personnel – Partners and staff in the firm.

(j)  Professional standards – Standards on Auditing (SAs), as defined in the “Preface to the Standards on Quality Management, Auditing, Review, Other Assurance and Related Services”, and relevant ethical requirements.

(k) Relevant ethical requirements – Principles of professional ethics and ethical requirements that are applicable to professional accountants when undertaking the audit engagement. Relevant ethical requirements ordinarily comprise the provisions of the Code of Ethics issued by the Institute of Chartered Accountants of India (ICAI’s Code of Ethics) related to audits of financial statements.

(l)  Response (in relation to a system of quality management) – Policies or procedures designed and implemented by the firm to address one or more quality risk(s):

(i) Policies are statements of what should, or should not, be done to address a quality risk(s). Such statements may be documented, explicitly stated in communications or implied through actions and decisions.

(ii) Procedures are actions to implement policies.

(m) Staff – Professionals, other than partners, including any experts the firm employs.

Requirements

Leadership Responsibilities for Managing and Achieving Quality on Audits

13. The engagement partner shall take overall responsibility for managing and achieving quality on the audit engagement, including taking responsibility for creating an environment for the engagement that emphasizes the firm’s culture and expected behavior of engagement team members. In doing so, the engagement partner shall be sufficiently and appropriately involved throughout the audit engagement such that the engagement partner has the basis for determining whether the significant judgments made, and the conclusions reached, are appropriate given the nature and circumstances of the engagement. (Ref: Para. A28–A37)

14. In creating the environment described in paragraph 13, the engagement partner shall take responsibility for clear, consistent and effective actions being taken that reflect the firm’s commitment to quality and establish and communicate the expected behavior of engagement team members, including emphasizing: (Ref: Para. A30–A34)

(a) That all engagement team members are responsible for contributing to the management and achievement of quality at the engagement level;

(b) The importance of professional ethics, values and attitudes to the members of the 106 engagement team;

(c) The importance of open and robust communication within the engagement team, and supporting the ability of engagement team members to raise concerns without fear of reprisal; and

(d) The importance of each engagement team member exercising professional skepticism throughout the audit engagement.

15. If the engagement partner assigns the design or performance of procedures, tasks or actions related to a requirement of this SA to other members of the engagement team to assist the engagement partner in complying with the requirements of this SA, the engagement partner shall continue to take overall responsibility for managing and achieving quality on the audit engagement through direction and supervision of those members of the engagement team, and review of their work. (Ref: Para. 9, A37)

Relevant Ethical Requirements, Including Those Related to Independence

16. The engagement partner shall have an understanding of the relevant ethical requirements, including those related to independence, that are applicable given the nature and circumstances of the audit engagement. (Ref: Para. A38–A42, A48)

17. The engagement partner shall take responsibility for other members of the engagement team having been made aware of relevant ethical requirements that are applicable given the nature and circumstances of the audit engagement, and the firm’s related policies or procedures, including those that address: (Ref: Para. A23–A25, A40– A44)

(a) Identifying, evaluating and addressing threats to compliance with relevant ethical requirements, including those related to independence;

(b) Circumstances that may cause a breach of relevant ethical requirements, including those related to independence, and the responsibilities of members of the engagement team when they become aware of breaches; and

(c) The responsibilities of members of the engagement team when they become aware of an instance of non-compliance with laws and regulations by the entity.⁸

18. If matters come to the engagement partner’s attention that indicate that a threat to compliance with relevant ethical requirements exists, the engagement partner shall evaluate the threat through complying with the firm’s policies or procedures, using relevant information from the firm, the engagement team or other sources, and take appropriate action. (Ref: Para. A43–A44)

19. The engagement partner shall remain alert throughout the audit engagement, through observation and making inquiries as necessary, for breaches of relevant ethical requirements or the firm’s related policies or procedures by members of the engagement team. (Ref: Para. A45)

20. If matters come to the engagement partner’s attention through the firm’s system of quality management, or from other sources, that indicate that relevant ethical requirements applicable to the nature and circumstances of the audit engagement have not been fulfilled, the engagement partner, in consultation with others in the firm, shall take appropriate action. (Ref: Para. A46)

21. Prior to dating the auditor’s report, the engagement partner shall take responsibility for determining whether relevant ethical requirements, including those related to independence, have been fulfilled. (Ref: Para. A38 and A47)

Acceptance and Continuance of Client Relationships and Audit Engagements

22. The engagement partner shall determine that the firm’s policies or procedures for the acceptance and continuance of client relationships and audit engagements have been followed, and that conclusions reached in this regard are appropriate. (Ref: Para. A49–A52, A58)

23. The engagement partner shall take into account information obtained in the acceptance and continuance process in planning and performing the audit engagement in accordance with the SAs and complying with the requirements of this SA. (Ref: Para. A53–A56)

24. If the engagement team becomes aware of information that may have caused the firm to decline the audit engagement had that information been known by the firm prior to accepting or continuing the client relationship or specific engagement, the engagement partner shall communicate that information promptly to the firm, so that the firm and the engagement partner can take the necessary action. (Ref: Para. A57)

Engagement Resources

25. The engagement partner shall determine that sufficient and appropriate resources to perform the engagement are assigned or made available to the engagement team in a timely manner, taking into account the nature and circumstances of the audit engagement, the firm’s policies or procedures, and any changes that may arise during the engagement. (Ref: Para. A59–A69, A72–A73, A77)

26. The engagement partner shall determine that members of the engagement team, and any auditor’s external experts and internal auditors who provide direct assistance who are not part of the engagement team, collectively have the appropriate competence and capabilities, including sufficient time, to perform the audit engagement. (Ref: Para. A61, A70–A73)

27. If, as a result of complying with the requirements in paragraphs 25 and 26, the engagement partner determines that resources assigned or made available are insufficient or inappropriate in the circumstances of the audit engagement, the engagement partner shall take appropriate action, including communicating with appropriate individuals about the need to assign or make available additional or alternative resources to the engagement. (Ref: Para. A74‒A76)

28. The engagement partner shall take responsibility for using the resources assigned  or made available to the engagement team appropriately, given the nature and circumstances of the audit engagement. (Ref: Para. A62–A68)

Engagement Performance

Direction, Supervision and Review

29. The engagement partner shall take responsibility for the direction and supervision of the members of the engagement team and the review of their work. (Ref: Para. A78)

30. The engagement partner shall determine that the nature, timing and extent of direction, supervision and review is: (Ref: Para. A79–A87, A92–A95)

(a) Planned⁹ and performed in accordance with the firm’s policies or procedures, professional standards and applicable legal and regulatory requirements; and

(b) Responsive to the nature and circumstances of the audit engagement and the resources assigned or made available to the engagement team by the firm.

31. The engagement partner shall review audit documentation at appropriate points in time during the audit engagement, including audit documentation relating to: (Ref: Para. A88–A91)

(a) Significant matters;¹⁰

(b) Significant judgments, including those relating to difficult or contentious matters identified during the audit engagement, and the conclusions reached; and

(c) Other matters that, in the engagement partner’s professional judgment, are relevant to the engagement partner’s responsibilities.

32. On or before the date of the auditor’s report, the engagement partner shall determine, through review of audit documentation and discussion with the engagement team, that sufficient appropriate audit evidence has been obtained to support the conclusions reached and for the auditor’s report to be issued. (Ref: Para. A88–A92)

33. Prior to dating the auditor’s report, the engagement partner shall review the financial statements and the auditor’s report, including, if applicable, the description of the key audit matters¹¹ and related audit documentation, to determine that the report to be issued will be appropriate in the circumstances.¹²

34. The engagement partner shall review, prior to their issuance, formal written communications to management, those charged with governance or regulatory authorities. (Ref: Para. A96)

Consultation

35. The engagement partner shall: (Ref: Para. A97–A100)

(a) Take responsibility for the engagement team undertaking consultation on:

(i) Difficult or contentious matters and matters on which the firm’s policies or procedures require consultation; and

(ii) Other matters that, in the engagement partner’s professional judgment, require consultation;

(b) Determine that members of the engagement team have undertaken appropriate consultation during the audit engagement, both within the engagement team, and between the engagement team and others at the appropriate level within or outside the firm;

(c) Determine that the nature and scope of, and conclusions resulting from, such consultations are agreed with the party consulted; and

(d) Determine that conclusions agreed have been implemented.

Engagement Quality Review

36. For audit engagements for which an engagement quality review is required, the engagement partner shall: (Ref: Para. A101)

(a) Determine that an engagement quality reviewer has been appointed;

(b) Cooperate with the engagement quality reviewer and inform other members of the engagement team of their responsibility to do so;

(c) Discuss significant matters and significant judgments arising during the audit engagement, including those identified during the engagement quality review, with the engagement quality reviewer; and

(d) Not date the auditor’s report until the completion of the engagement quality review. (Ref: Para. A102–A104)

Differences of Opinion

37. If differences of opinion arise within the engagement team, or between the engagement team and the engagement quality reviewer or individuals performing activities within the firm’s system of quality management, including those who provide consultation, the engagement team shall follow the firm’s policies or procedures for dealing with and resolving such differences of opinion. (Ref: Para. A105–A106)

38. The engagement partner shall:

(a) Take responsibility for differences of opinion being addressed and resolved in accordance with the firm’s policies or procedures;

(b) Determine that conclusions reached are documented and implemented; and

(c) Not date the auditor’s report until any differences of opinion are resolved.

Monitoring and Remediation

39. The engagement partner shall take responsibility for: (Ref: Para. A107‒A110)

(a) Obtaining an understanding of the information from the firm’s monitoring and remediation process, as communicated by the firm including, as applicable, the information from the monitoring and remediation process of the network and across the network firms;

(b) Determining the relevance and effect on the audit engagement of the information referred to in paragraph 39(a) and take appropriate action; and

(c) Remaining alert throughout the audit engagement for information that may be relevant to the firm’s monitoring and remediation process and communicate such information to those responsible for the process.

Taking Overall Responsibility for Managing and Achieving Quality

40. Prior to dating the auditor’s report, the engagement partner shall determine that the engagement partner has taken overall responsibility for managing and achieving quality on the audit engagement. In doing so, the engagement partner shall determine that: (Ref: Para. A111–A114)

(a) The engagement partner’s involvement has been sufficient and appropriate throughout the audit engagement such that the engagement partner has the basis for determining that the significant judgments made and the conclusions reached are appropriate given the nature and circumstances of the engagement; and

(b) The nature and circumstances of the audit engagement, any changes thereto, and the firm’s related policies or procedures have been taken into account in complying with the requirements of this SA.

Documentation

41. In applying SA 230,¹³ the auditor shall include in the audit documentation: (Ref: Para. A115–A118)

(a)       Matters identified, relevant discussions with personnel, and conclusions reached with respect to:

(i) Fulfillment of responsibilities relating to relevant ethical requirements, including those related to independence.

(ii) The acceptance and continuance of the client relationship and audit engagement.

(b)       The nature and scope of, and conclusions resulting from, consultations undertaken during the audit engagement and how such conclusions were implemented.

(c)        If the audit engagement is subject to an engagement quality review, that the engagement quality review has been completed on or before the date of the auditor’s report.

***

Application and Other Explanatory Material

Scope of this SA (Ref: Para. 1)

A1. This SA applies to all audits of financial statements, including audits of group financial statements. SA 600¹⁴ deals with situations where an auditor (referred to herein as the ‘principal auditor’), reporting on the financial information of an entity, uses the work of another auditor (referred to herein as the ‘component auditor’) with respect to the financial information of one or more components included in the financial information of the entity. SA 600, adapted as necessary in the circumstances, may also be useful in an audit of financial statements when the engagement team includes individuals from another firm. For example, SA 600 may be useful when involving such an individual to attend a physical inventory count, inspect property, plant and equipment, or perform audit procedures at a shared service center at a remote location.

The Firm’s System of Quality Management and Role of Engagement Teams (Ref: Para. 2–9)

A2. Proposed SQM 1 deals with a firm’s responsibilities for designing, implementing and operating its system of quality management.

A3. Firms may use different terminology or frameworks to describe the components of the system of quality management.

The Engagement Team’s Responsibilities Relating to the Firm’s System of Quality Management (Ref: Para. 4)

A4. Quality management at the engagement level is supported by the firm’s system of quality management and informed by the specific nature and circumstances of the audit engagement. In accordance with proposed SQM 1, the firm is responsible for communicating information that enables the engagement team to understand and carry out their responsibilities relating to performing engagements. For example, such communications may cover policies or procedures to undertake consultations with designated individuals in certain situations involving complex technical or ethical matters, or to involve firm-designated experts in specific engagements to perform audit procedures related to particular matters (e.g., the firm may specify that firm-designated credit experts are to be involved in auditing expected credit loss allowances in audits of financial institutions).

A5. Firm-level responses may include policies or procedures established by a network, or by other firms, structures or organizations within the same network (network requirements or network services are described further in proposed SQM 1 within the “Network Requirements or Network Services” section).¹⁵ The requirements of this SA are based on the premise that the firm is responsible for taking the necessary action to enable engagement teams to implement or use network requirements or network services on the audit engagement (for example, a requirement to use an audit methodology developed for use by a network firm). Under proposed SQM 1, the firm is responsible for determining how network requirements or network services are relevant to, and are taken into account in, the firm’s system of quality management.¹⁶

A6. Some firm-level responses to quality risks are not performed at the engagement level but are nevertheless relevant when complying with the requirements of this SA. For example, firm-level responses that the engagement team may be able to depend on when complying with the requirements of this SA include:

• Personnel recruitment and professional training processes;
• The information technology (IT) applications that support the firm’s monitoring of independence;
• The development of IT applications that support the acceptance and continuance of client relationships and audit engagements; and
• The development of audit methodologies and related implementation tools and guidance.

A7. Due to the specific nature and circumstances of each audit engagement and changes that may occur during the audit engagement, a firm cannot identify all quality risks that may arise at the engagement level or set forth all relevant and appropriate responses. Accordingly, the engagement team exercises professional judgment in determining whether to design and implement responses, beyond those set forth in the firm’s policies or procedures, at the engagement level to meet the objective of this SA.¹⁷

A8. The engagement team’s determination of whether engagement level responses are necessary (and, if so, what those responses are) is influenced by the requirements of this SA, the engagement team’s understanding of the nature and circumstances of the engagement and any changes during the audit engagement. For example, unanticipated circumstances may arise during the engagement that may cause the engagement partner to request the involvement of appropriately experienced personnel in addition to those initially assigned or made available.

A9. The relative balance of the engagement team’s efforts to comply with the requirements of this SA (i.e., between implementing the firm’s responses and designing and implementing engagement specific responses beyond those set forth in the firm’s policies or procedures) may vary. For example, the firm may design an audit program to be used in circumstances that are applicable to the audit engagement (e.g., an industry-specific audit program). Other than determining the timing and extent of procedures to be performed, there may be little or no need for supplemental audit procedures to be added to the audit program at the engagement level. Alternatively, the engagement team’s actions in complying with the engagement performance requirements of this SA may be more focused on designing and implementing responses at the engagement level to deal with the specific nature and circumstances of the engagement (e.g., planning and performing procedures to address risks of material misstatement not contemplated by the firm’s audit programs).

A10. Ordinarily, the engagement team may depend on the firm’s policies or procedures in complying with the requirements of this SA, unless:

• The engagement team’s understanding or practical experience indicates that the firm’s policies or procedures will not effectively address the nature and circumstances of the engagement; or
• Information provided by the firm or other parties, about the effectiveness of such policies or procedures suggests otherwise (e.g., information provided by the firm’s monitoring activities, external inspections or other relevant sources, indicates that the firm’s policies or procedures are not operating effectively).

A11. If the engagement partner becomes aware (including through being informed by other members of the engagement team) that the firm’s responses to quality risks are ineffective in the context of the specific engagement or the engagement partner is unable to depend on the firm’s policies or procedures, the engagement partner communicates such information promptly to the firm in accordance with paragraph 39(c) as such information is relevant to the firm’s monitoring and remediation process. For example, if an engagement team member identifies that an audit software program has a security weakness, timely communication of such information to the appropriate personnel enables the firm to take steps to update and reissue the audit program. See also paragraph A69 in respect of sufficient and appropriate resources.

Information Relevant to Quality Management at the Engagement Level (Ref: Para. 5)

A12. Complying with the requirements in other SAs may provide information that is relevant to quality management at the engagement level. For example, the understanding of the entity and its environment required to be obtained under proposed SA 315 (Revised)¹⁸ provides information that may be relevant to complying with the requirements of this SA. Such information may be relevant to the determination of:

• The nature of resources to deploy for specific audit areas, such as the use of appropriately experienced team members for high risk areas, or the involvement of experts to deal with complex matters;
• The amount of resources to allocate to specific audit areas, such as the number of team members assigned to attend the physical inventory count at multiple locations;
• The nature, timing and extent of review of the work performed by members of the engagement team based on the assessed risks of material misstatement; or
• The allocation of the budgeted audit hours, including allocating more time, and the time of more experienced engagement team members to those areas where there are more risks of material misstatement or the identified risks are assessed as higher.

Scalability (Ref: Para. 2, 8)

A13. In a smaller firm, the firm’s policies or procedures may designate an engagement partner, on behalf of the firm, to design many of the responses to the firm’s quality risks, as doing so may be a more effective approach to designing and implementing responses as part of the firm’s system of quality management. Additionally, a smaller firm’s policies or procedures may be less formal. For example, in a very small firm with a relatively small number of audit engagements, the firm may determine that there is no need to establish a firm-wide system to monitor independence, and rather, independence will be monitored at the individual engagement level by the engagement partner.

A14. The requirements relating to direction, supervision and review of the work of other members of the engagement team are only relevant if there are members of the engagement team other than the engagement partner.

Definitions

Engagement Team (Ref: Para. 12(d))

A15. The engagement team may be organized in a variety of ways. For example, engagement team members may be located together or across different geographic locations and may be organized in groups by the activity they are performing. Regardless of how the engagement team is organized, any individual who performs audit procedures¹⁹ on the audit engagement is a member of the engagement team.

A16. The definition of an engagement team focuses on individuals who perform audit procedures on the audit engagement. Audit evidence, which is necessary to support the auditor’s opinion and report, is primarily obtained from audit procedures performed during the course of the audit.²⁰ Audit procedures comprise risk assessment procedures²¹ and further audit procedures.²² As explained in SA 500, audit procedures include inspection, observation, confirmation, recalculation, reperformance, analytical procedures and inquiry, often performed in some combination.²³ Other SAs may also include specific procedures to obtain audit evidence, for example, SA 520.²⁴

A17. Engagement teams include personnel and may also include other individuals who perform audit procedures who are from:

(a) A network firm; or

(b) A firm that is not a network firm, or another service provider.²⁵

For example, an individual from another firm may perform audit procedures on the financial information of a component in a group audit engagement, attend a physical inventory count or inspect physical fixed assets at a remote location.

A18. Engagement teams may also include individuals from service delivery centers who perform audit procedures. For example, it may be determined that specific tasks that are repetitive or specialized in nature will be performed by a group of appropriately skilled personnel and the engagement team therefore includes such individuals. Service delivery centers may be established by the firm, the network, or by other firms, structures or organizations within the same network. For example, a centralized function may be used to facilitate external confirmation procedures.

A19. Engagement teams may include individuals with expertise in a specialized area of accounting or auditing who perform audit procedures on the audit engagement, for example, individuals with expertise in accounting for income taxes, or in analyzing complex information produced by automated tools and techniques for the purpose of identifying unusual or unexpected relationships. An individual is not a member of the engagement team if that individual’s involvement with the engagement is limited to consultation. Consultations are addressed in paragraphs 35 and A97–A100.

A20. If the audit engagement is subject to an engagement quality review, the engagement quality reviewer, and any other individuals performing the engagement quality review, are not members of the engagement team. Such individuals may be subject to specific independence requirements.

A21. An internal auditor providing direct assistance and an auditor’s external expert whose work is used in the engagement are not members of the engagement team.²⁶ SA 610 (Revised) and SA 620 provide requirements and guidance for the auditor when using the work of internal auditors in a direct assistance capacity or when using the work of an external expert, respectively. Compliance with these SAs requires the auditor to obtain sufficient appropriate audit evidence on the work performed by an internal auditor providing direct assistance and perform audit procedures on the work of an auditor’s expert.

The Engagement Partner’s Responsibilities (Ref: Para. 9, 12(d))

A22. When this SA expressly intends that a requirement or responsibility be fulfilled by the engagement partner, the engagement partner may need to obtain information from the firm or other members of the engagement team to fulfil the requirement (e.g., information to make the required decision or judgment). For example, the engagement partner is required to determine that members of the engagement team collectively have the appropriate competence and capabilities to perform the audit engagement. To make a judgment on whether the competence and capabilities of the engagement team is appropriate, the engagement partner may need to use information compiled by the engagement team or from the firm’s system of quality management.

The Application of Firm Policies or Procedures by Members of the Engagement Team (Ref: Para. 9, 12(d),17)

A23. Within the context of the firm’s system of quality management, engagement team members from the firm are responsible for implementing the firm’s policies or procedures that are applicable to the audit engagement. As engagement team members from another firm are neither partners nor staff of the engagement partner’s firm, they may not be subject to the firm’s system of quality management or the firm’s policies or procedures. Further, the policies or procedures of another firm may not be similar to that of the engagement partner’s firm. For example, policies or procedures regarding direction, supervision and review may be different, particularly when the other firm is in a jurisdiction with a different legal system, language or culture than that of the engagement partner’s firm. Accordingly, if the engagement team includes individuals who are from another firm, different actions may need to be taken by the firm or the engagement partner to implement the firm’s policies or procedures in respect of the work of those individuals.

A24. In particular, the firm’s policies or procedures may require the firm or the engagement partner to take different actions from those applicable to personnel when obtaining an understanding of whether an individual from another firm:

• Has the appropriate competence and capabilities to perform the audit engagement. For example, the individual would not be subject to the firm’s recruitment and training processes and therefore the firm’s policies or procedures may state that this determination can be made through other actions such as obtaining information from the other firm or a licensing or registration body. Paragraph 11 of SA 600 contains requirement w.r.t. considering the professional competence of component auditors in the context of specific assignment, if the component auditors are not the members of the Institute of Chartered Accountants of India.
• Understands the ethical requirements that are relevant to the group audit engagement. For example, the individual would not be subject to the firm’s training in respect of the firm’s policies or procedures for relevant ethical requirements. The firm’s policies or procedures may state that this understanding is obtained through other actions such as providing information, manuals, or guides containing the provisions of the relevant ethical requirements applicable to the audit engagement to the individual.
• Will confirm independence. For example, individuals who are not personnel may not be able to complete independence declarations directly on the firm’s independence systems. The firm’s policies or procedures may state that such individuals can provide evidence of their independence in relation to the audit engagement in other ways, such as written confirmation.

A25. When firm policies or procedures require specific activities to be undertaken in certain circumstances (e.g., consultation on a particular matter), it may be necessary for the firm’s related policies or procedures to be communicated to individuals who are not personnel. Such individuals are then able to alert the engagement partner if the circumstance arises, and this enables the engagement partner to comply with the firm’s policies or procedures. For example, in a group audit engagement, if a component auditor is performing audit procedures on the financial information of a component and identifies a difficult or contentious matter or significant findings that is relevant to the group financial statements and subject to consultation²⁷ under the group auditor’s policies or procedures, the component auditor is able to alert the group engagement team about the matter.

Firm (Ref: Para. 12(e))

A26. The definition of “firm” in relevant ethical requirements may differ from the definition set out in this SA.

“Network” and “Network Firm” (Ref: Para. 12(f)–12(g))

A27. The definitions of “network” or “network firm” in relevant ethical requirements may differ from those set out in this SA. The Code of Ethics also provides guidance in relation to the terms “network” and “network firm”.

Networks and the other network firms may be structured in a variety of ways, and are in all cases external to the firm. The provisions in this SA in relation to networks also apply to any structures or organizations that do not form part of the firm, but that exist within the network.

Leadership Responsibilities for Managing and Achieving Quality on Audits (Ref: Para. 13–15)

Taking Overall Responsibility for Managing and Achieving Quality

A28. Proposed SQM 1 requires the firm to establish quality objectives that address the firm’s governance and leadership that supports the design, implementation and operation of the system of quality management. The engagement partner’s responsibility for managing and achieving quality is supported by a firm culture that demonstrates a commitment to quality. In addressing the requirements in paragraphs 13 and 14 of this SA, the engagement partner may communicate directly to other members of the engagement team and reinforce this communication through personal conduct and actions (e.g., leading by example). A culture that demonstrates a commitment to quality is further shaped and reinforced by the engagement team members as they demonstrate expected behaviors when performing the engagement.

Scalability

A29. The nature and extent of the actions of the engagement partner to demonstrate the firm’s commitment to quality may depend on a variety of factors including the size, structure, geographical dispersion and complexity of the firm and the engagement team, and the nature and circumstances of the audit engagement. With a smaller engagement team with few engagement team members, influencing the desired culture through direct interaction and conduct may be sufficient, whereas for a larger engagement team that is dispersed over many locations, more formal communications may be necessary.

Sufficient and Appropriate Involvement

A30. Being sufficiently and appropriately involved throughout the audit engagement may be demonstrated by the engagement partner in different ways, including:

• Taking responsibility for the nature, timing and extent of the direction and supervision of the members of the engagement team, and the review of their work in complying with the requirements of this SA; and
• Varying the nature, timing and extent of such direction, supervision and review in the context of the nature and circumstances of the engagement.

Communication

A31. Communication is the means through which the engagement team shares relevant information on a timely basis to comply with the requirements of this SA, thereby contributing to the achievement of quality on the audit engagement. Communication may be between or among members of the engagement team, or with:

(a) The firm, (e.g., individuals performing activities within the firm’s system of quality management, including those assigned ultimate or operational responsibility for the firm’s system of quality management);

(b) Others involved in the audit (e.g., internal auditors who provide direct assistance²⁸ or an auditor’s external expert²⁹); and

(c) Parties that are external to the firm (e.g., management, those charged with governance or regulatory authorities).

A32. The nature and circumstances of the audit engagement may affect the engagement partner’s decisions regarding the appropriate means of effective communication with the members of the engagement team. For example, to support appropriate direction, supervision and review, the firm may use IT applications to facilitate the communication between the members of the engagement team when they are performing work across different geographical locations.

Professional Skepticism (Ref: Para. 7)

A33. The engagement partner is responsible for emphasizing the importance of each engagement team member exercising professional skepticism throughout the audit engagement. Conditions inherent in some audit engagements can create pressures on the engagement team that may impede the appropriate exercise of professional skepticism when designing and performing audit procedures and evaluating audit evidence. Accordingly, when developing the overall audit strategy in accordance with SA 300, the engagement team may need to consider whether such conditions exist in the audit engagement and, if so, what actions the firm or the engagement team may need to undertake to mitigate such impediments.

A34. Impediments to the exercise of professional skepticism at the engagement level may include, but are not limited to:

• Budget constraints, which may discourage the use of sufficiently experienced or technically qualified resources, including experts, necessary for audits of entities where technical expertise or specialized skills are needed for effective understanding, assessment of and responses to risks and informed questioning of management.
• Tight deadlines, which may negatively affect the behavior of those who perform the work as well as those who direct, supervise and review. For example, external time pressures may create restrictions to analyzing complex information effectively.
• Lack of cooperation or undue pressures imposed by management, which may negatively affect the engagement team’s ability to resolve complex or contentious issues.
• Insufficient understanding of the entity and its environment, its system of internal control and the applicable financial reporting framework, which may constrain the ability of the engagement team to make appropriate judgments and an informed questioning of management’s assertions.
• Difficulties in obtaining access to records, facilities, certain employees, customers, vendors or others, which may cause the engagement team to bias the selection of sources of audit evidence and seek audit evidence from sources that are more easily accessible.
• Overreliance on automated tools and techniques, which may result in the engagement team not critically assessing audit evidence.

A35. Unconscious or conscious auditor biases may affect the engagement team’s professional judgments, including for example, in the design and performance of audit procedures, or the evaluation of audit evidence. Examples of unconscious auditor biases that may impede the exercise of professional skepticism, and therefore the reasonableness of the professional judgments made by the engagement team in complying with the requirements of this SA, may include:

• Availability bias, which is a tendency to place more weight on events or experiences that immediately come to mind or are readily available than on those that are not.
• Confirmation bias, which is a tendency to place more weight on information that corroborates an existing belief than information that contradicts or casts doubt on that belief.
• Groupthink, which is a tendency to think or make decisions as a group that discourages creativity or individual responsibility.
• Overconfidence bias, which is a tendency to overestimate one’s own ability to make accurate assessments of risk or other judgments or decisions.
• Anchoring bias, which is a tendency to use an initial piece of information as an anchor against which subsequent information is inadequately assessed.
• Automation bias, which is a tendency to favor output generated from automated systems, even when human reasoning or contradictory information raises questions as to whether such output is reliable or fit for purpose.

A36. Possible actions that the engagement team may take to mitigate impediments to the exercise of professional skepticism at the engagement level may include:

• Remaining alert to changes in the nature or circumstances of the audit engagement that necessitate additional or different resources for the engagement, and requesting additional or different resources from those individuals within the firm responsible for allocating or assigning resources to the engagement.
• Explicitly alerting the engagement team to instances or situations when vulnerability to unconscious or conscious auditor biases may be greater (e.g., areas involving greater judgment) and emphasizing the importance of seeking advice from more experienced members of the engagement team in planning and performing audit procedures.
• Changing the composition of the engagement team, for example, requesting that more experienced individuals with greater skills or knowledge or specific expertise are assigned to the engagement.
• Involving more experienced members of the engagement team when dealing with members of management who are difficult or challenging to interact with.
• Involving members of the engagement team with specialized skills and knowledge or an auditor’s expert to assist the engagement team with complex or subjective areas of the audit.
• Modifying the nature, timing and extent of direction, supervision or review by involving more experienced engagement team members, more in-person oversight on a more frequent basis or more in-depth reviews of certain working papers for:
  • Complex or subjective areas of the audit;
  • Areas that pose risks to achieving quality on the audit engagement;
  • Areas with a fraud risk; and
  • Identified or suspected non-compliance with laws or regulations.
• Setting expectations for:
  • Less experienced members of the engagement team to seek advice frequently and in a timely manner from more experienced engagement team members or the engagement partner; and
  • More experienced members of the engagement team to be available to less experienced members of the engagement team throughout the audit engagement and to respond positively and in a timely manner to their insights, requests for advice or assistance.
• Communicating with those charged with governance when management imposes undue pressure or the engagement team experiences difficulties in obtaining access to records, facilities, certain employees, customers, vendors or others from whom audit evidence may be sought.

Assigning Procedures, Tasks, or Actions to Other Members of the Engagement Team (Ref: Para. 15)

A37. Being sufficiently and appropriately involved throughout the audit engagement when procedures, tasks or actions have been assigned to other members of the engagement team may be demonstrated by the engagement partner in different ways, including:

• Informing assignees about the nature of their responsibilities and authority, the scope of the work being assigned and the objectives thereof; and to provide any other necessary instructions and relevant information.
• Direction and supervision of the assignees.
• Review of the assignees’ work to evaluate the conclusions reached, in addition to the requirements in paragraphs 29–34.

Relevant Ethical Requirements, Including Those Related to Independence (Ref: Para. 16–21)

Relevant Ethical Requirements (Ref: Para. 1, 16–21)

A38. SA 200³⁰ requires that the auditor comply with relevant ethical requirements, including those pertaining to independence, relating to financial statement audit engagements. Relevant ethical requirements may vary depending on the nature and circumstances of the engagement. For example, certain requirements related to independence may be applicable only when performing audits of listed entities.

A39. Based on the nature and circumstances of the audit engagement, certain law, regulation or aspects of relevant ethical requirements, such as those pertaining to non­compliance with laws or regulations, may be relevant to the engagement, for example laws or regulations dealing with money laundering, corruption, or bribery.

A40. The firm’s information system and the resources provided by the firm may assist the engagement team in understanding and fulfilling relevant ethical requirements applicable to the nature and circumstances of the audit engagement. For example, the firm may:

• Communicate the independence requirements to engagement teams.
• Provide training for engagement teams on relevant ethical requirements.
• Establish manuals and guides (i.e., intellectual resources) containing the provisions of the relevant ethical requirements and guidance on how they are applied in the nature and circumstances of the firm and its engagements.
• Assign personnel to manage and monitor compliance with relevant ethical requirements (e.g., Proposed SQM 1 requires that the firm obtains, at least annually, a documented confirmation of compliance with the independence requirements from all personnel required by relevant ethical requirements to be independent) or provide consultation on matters related to relevant ethical requirements.
• Establish policies or procedures for engagement team members to communicate relevant and reliable information to appropriate parties within the firm or to the engagement partner, such as policies or procedures for engagement teams to:
  •  Communicate information about client engagements and the scope of services, including non-assurance services, to enable the firm to identify threats to independence during the period of the engagement and during the period covered by the subject matter.
  • Communicate circumstances and relationships that may create a threat to independence, so that the firm can evaluate whether such a threat is at an acceptable level and if it is not, address the threat by eliminating it or reducing it to an acceptable level.
  • Promptly communicate any breaches of the relevant ethical requirements, including those related to independence.

A41. The engagement partner may take into account the information, communication, and resources described in paragraph A40 when determining whether the engagement partner may depend on the firm’s policies or procedures in complying with relevant ethical requirements.

A42. Open and robust communication between the members of the engagement team about relevant ethical requirements may also assist in:

• Drawing the attention of engagement team members to relevant ethical requirements that may be of particular significance to the audit engagement; and
• Keeping the engagement partner informed about matters relevant to the engagement team’s understanding and fulfillment of relevant ethical requirements and the firm’s related policies or procedures.

Identifying and Evaluating Threats to Compliance with Relevant Ethical Requirements (Ref: Para. 17–18)

A43. In accordance with Proposed SQM 1, the firm’s responses to address the quality risks in relation to relevant ethical requirements, including those related to independence for engagement team members, include policies or procedures for identifying, evaluating and addressing threats to compliance with the relevant ethical requirements.

 A44.  Relevant ethical requirements may contain provisions regarding the identification and evaluation of threats and how they are to be dealt with. For example, the ICAI’s Code of Ethics explains that a self-interest threat to compliance with the fundamental principle of professional competence and due care may arise if the fee quoted for an audit engagement is so low that it might be difficult to perform the engagement in accordance with applicable technical and professional standards.³¹

Breaches of Relevant Ethical Requirements (Ref: Para. 19)

A45. In accordance with Proposed SQM 1, the firm is required to establish policies or procedures for identifying, communicating, evaluating and reporting of any breaches of relevant ethical requirements and appropriately responding to the causes and consequences of the breaches in a timely manner.

Taking Appropriate Action (Ref: Para. 20)

A46. Appropriate actions may include, for example:

• Following the firm’s policies or procedures regarding breaches of relevant ethical requirements, including communicating to or consulting with the appropriate individuals so that appropriate action can be taken, including as applicable, disciplinary action(s).
• Communicating with those charged with governance.
• Communicating with regulatory authorities or professional bodies. In some circumstances, communication with regulatory authorities may be required by law or regulation.
• Seeking legal advice.
• Withdrawing from the audit engagement, when withdrawal is possible under applicable law or regulation.

Prior to Dating the Auditor’s Report (Ref: Para. 21)

A47. SA 700 (Revised) requires that the auditor’s report include a statement that the auditor is independent of the entity in accordance with the relevant ethical requirements relating to the audit, and that the auditor has fulfilled the auditor’s other ethical responsibilities in accordance with these requirements.³² Performing the procedures required by paragraphs 16–21 of this SA provides the basis for these statements in the auditor’s report.

A48. In case of certain entities, such as, Central/State governments and related government entities (for example, agencies, boards, commissions), statutory measures may provide safeguards for the independence of auditors of such entities. However, such auditors or audit firms carrying out audits of such entities on behalf of the statutory auditor may, depending on the terms of the applicable legal or regulatory framework, need to adapt their approach to promote compliance with paragraph 16. This may include, where the auditor’s applicable legal or regulatory framework does not permit withdrawal of the auditor from the audit engagement, disclosure through a public report of circumstances that have arisen that would, have otherwise, lead the auditor to withdraw.

Acceptance and Continuance of Client Relationships and Audit Engagements (Ref: Para. 22–24)

A49. Proposed SQM 1 requires the firm to establish quality objectives that address the acceptance and continuance of client relationships and specific engagements.

A50. Information such as the following may assist the engagement partner in determining whether the conclusions reached regarding the acceptance and continuance of client relationships and audit engagements are appropriate:

• The integrity and ethical values of the principal owners, key management and those charged with governance of the entity;
• Whether sufficient and appropriate resources are available to perform the engagement;
• Whether management and those charged with governance have acknowledged their responsibilities in relation to the engagement;
• Whether the engagement team has the competence and capabilities, including sufficient time, to perform the engagement; and
• Whether significant matters that have arisen during the current or previous engagement have implications for continuing the engagement.

A51. Under proposed SQM 1, for acceptance and continuance decisions, the firm is required to make judgments about the firm’s ability to perform the engagement in accordance with professional standards and applicable legal and regulatory requirements. The engagement partner may use the information considered by the firm in this regard in determining whether the conclusions reached regarding the acceptance and continuance of client relationships and audit engagements are appropriate. If the engagement partner has concerns regarding the appropriateness of the conclusions reached, the engagement partner may discuss the basis for those conclusions with those involved in the acceptance and continuance process.

A52. If the engagement partner is directly involved throughout the firm’s acceptance and continuance process, the engagement partner will be aware of the information obtained or used by the firm, in reaching the related conclusions. Such direct involvement may also provide a basis for the engagement partner’s determination that the firm’s policies or procedures have been followed and that the conclusions reached are appropriate.

A53. Information obtained during the acceptance and continuance process may assist the engagement partner in complying with the requirements of this SA and making informed decisions about appropriate courses of action. Such information may include:

• Information about the size, complexity and nature of the entity, including whether it is a group audit, the industry in which it operates and the applicable financial reporting framework;
• The entity’s timetable for reporting, such as at interim and final stages;
• In relation to group audits, the nature of the control relationships between the parent and its components; and
• Whether there have been changes in the entity or in the industry in which the entity operates since the previous audit engagement that may affect the nature of resources required, as well as the manner in which the work of the engagement team will be directed, supervised and reviewed.

A54. Information obtained during acceptance and continuance may also be relevant in complying with the requirements of other SAs, as well as this SA, for example with respect to:

• Establishing an understanding of the terms of the audit engagement, as required by SA 210;³³

• Identifying and assessing risks of material misstatement, whether due to error or fraud, in accordance with proposed SA 315 (Revised) and SA 240;³⁴
• Understanding the group, its components and their environments, in the case of an audit of group financial statements in accordance with SA 600, and reviewing the written summary of the component auditor’s procedures and findings;
• Determining whether, and how, to involve an auditor’s expert in accordance with SA 620; and
• The entity’s governance structure in accordance with SA 260(Revised)³⁵ and SA 265.³⁶

A55. Law, regulation, or relevant ethical requirements may require the successor auditor to request, prior to accepting the audit engagement, the predecessor auditor to provide known information regarding any facts or other information that, in the predecessor auditor’s opinion, the successor auditor needs to be aware of before deciding whether to accept the engagement. In some circumstances, the predecessor auditor may be required, on request by the proposed successor auditor, to provide all relevant facts and other information concerning identified or suspected non-compliance with laws and regulations to the proposed successor auditor. For example, if the predecessor auditor has withdrawn from the engagement as a result of identified or suspected non­compliance with laws and regulations, the ICAI’s Code of Ethics requires that the predecessor auditor, on request by a proposed successor auditor, provide all relevant facts and other information concerning such non-compliance that, in the predecessor auditor’s opinion, the proposed successor auditor needs to be aware of before deciding whether to accept the audit appointment.

A56. In circumstances when the firm is obligated by law or regulation to accept or continue an audit engagement, the engagement partner may take into account information obtained by the firm about the nature and circumstances of the engagement.

A57. In deciding on the necessary action, the engagement partner and the firm may conclude that it is appropriate to continue with the audit engagement and, if so, determine what additional steps are necessary at the engagement level (e.g., the assignment of more staff or staff with specific expertise). If the engagement partner has further concerns or is not satisfied that the matter has been appropriately dealt with, the firm’s policies or procedures for resolving differences of opinion may be applicable.

A58. In case of certain entities, such as, Central/State governments and related government entities (for example, agencies, boards, commissions) auditors may be appointed in accordance with statutory procedures and such auditor may not need to establish all policies or procedures regarding the acceptance and continuance of audit engagements. Nevertheless, the requirements and considerations for the acceptance and continuance of client relationships and engagements as set out in paragraphs 22– 24 and A49–A57 may be valuable to such auditors in performing risk assessments and in carrying out reporting responsibilities.

Engagement Resources (Ref: Para. 25–28)

A59. Under proposed SQM 1, the resources assigned or made available by the firm to support the performance of audit engagements include:

• Human resources;
• Technological resources; and
• Intellectual resources.

A60 A relevant consideration for the engagement partner, in complying with the requirements in paragraphs 25 and 26, may be whether the resources assigned or made available to the engagement team enable fulfillment of relevant ethical requirements, including ethical principles such as professional competence and due care.

Human Resources

A61. Human resources include members of the engagement team (see also paragraphs A5, A15–A21) and, where applicable, an auditor’s external expert and individuals from within the entity’s internal audit function who provide direct assistance on the audit.

Technological Resources

A62. The use of technological resources on the audit engagement may assist the auditor in obtaining sufficient appropriate audit evidence. Technological tools may allow the auditor to more effectively and efficiently manage the audit. Technological tools may also allow the auditor to evaluate large amounts of data more easily to, for example, provide deeper insights, identify unusual trends or more effectively challenge management’s assertions, which enhances the ability of the auditor to exercise professional skepticism. Technological tools may also be used to conduct meetings and provide communication tools to the engagement team. Inappropriate use of such technological resources may, however, increase the risk of overreliance on the information produced for decision making purposes, or may create threats to complying with relevant ethical requirements, for example, requirements related to confidentiality.

A63. The firm’s policies or procedures may include required considerations or responsibilities for the engagement team when using firm approved technological tools to perform audit procedures and may require the involvement of individuals with specialized skills or expertise in evaluating or analyzing the output.

A64. When the engagement partner requires individuals from another firm to use specific automated tools and techniques when performing audit procedures, communications with those individuals may indicate that the use of such automated tools and techniques needs to comply with the engagement team’s instructions.

A65. The firm’s policies or procedures may specifically prohibit the use of certain IT applications or features of IT applications (e.g., software that has not yet been specifically approved for use by the firm). Alternatively, the firm’s policies or procedures may require the engagement team to take certain actions before using an IT application that is not firm-approved to determine it is appropriate for use, for example by requiring:

• The engagement team to have appropriate competence and capabilities to use the IT application.
• Testing the operation and security of the IT application.
• Specific documentation to be included in the audit file.

A66. The engagement partner may exercise professional judgment in considering whether the use of an IT application on the audit engagement is appropriate in the context of the engagement, and if so, how the IT application is to be used. Factors that may be considered in determining whether a particular IT application, that has not been specifically approved for use by the firm, is appropriate for use in the audit engagement include whether:

• Use and security of the IT application complies with the firm’s policies or procedures.
• The IT application operates as intended.
• Personnel have the competence and capabilities required to use the IT application.

Intellectual Resources

A67. Intellectual resources include, for example, audit methodologies, implementation tools, auditing guides, model programs, templates, checklists or forms.

A68. The use of intellectual resources on the audit engagement may facilitate the consistent application and understanding of professional standards, law and regulation, and related firm policies or procedures. For this purpose, the engagement team may be required, in accordance with the firm’s policies or procedures, to use the firm’s audit methodology and specific tools and guidance. The engagement team may also consider whether the use of other intellectual resources is appropriate and relevant based on the nature and circumstances of the engagement, for example, an industry specific methodology or related guides and performance aids.

Sufficient and Appropriate Resources to Perform the Engagement (Ref: Para. 25)

A69. In determining whether sufficient and appropriate resources to perform the engagement have been assigned or made available to the engagement team, ordinarily the engagement partner may depend on the firm’s related policies or procedures (including resources) as described in paragraph A6. For example, based on information communicated by the firm, the engagement partner may be able to depend on the firm’s technological development, implementation and maintenance programs when using firm-approved technology to perform audit procedures.

Competence and Capabilities of the Engagement Team (Ref: Para. 26)

A70. When determining that the engagement team has the appropriate competence and capabilities, the engagement partner may take into consideration such matters as the team’s:

• Understanding of, and practical experience with, audit engagements of a similar nature and complexity through appropriate training and participation.
• Understanding of professional standards and applicable legal and regulatory requirements.
• Expertise in specialized areas of accounting or auditing.
• Expertise in IT used by the entity or automated tools or techniques that are to be used by the engagement team in planning and performing the audit engagement.
• Knowledge of relevant industries in which the entity being audited operates.
• Ability to exercise professional skepticism and professional judgment.
• Understanding of the firm’s policies or procedures.

A71. Internal auditors and an auditor’s external expert are not members of the engagement team. SA 610(Revised)³⁷ and SA 620³⁸ include requirements and guidance relating to the assessment of the competence and capabilities of internal auditors and an auditor’s external expert, respectively.

Project Management

A72. In situations where there are many engagement team members, for example in an audit of a larger or more complex entity, the engagement partner may involve an individual who has specialized skills or knowledge in project management, supported by appropriate technological and intellectual resources of the firm. Conversely, in an audit of a less complex entity with few engagement team members, project management may be achieved by a member of the engagement team through less formal means.

A73. Project management techniques and tools may support the engagement team in managing the quality of the audit engagement by, for example:

• Increasing the engagement team’s ability to exercise professional skepticism through alleviating budget or time constraints that may otherwise impede the exercise of professional skepticism;
• Facilitating timely performance of audit work to effectively manage time constraints at the end of the audit process when more difficult or contentious matters may arise;
• Monitoring the progress of the audit against the audit plan,³⁹ including the achievement of key milestones, which may assist the engagement team in being proactive in identifying the need for making timely adjustments to the audit plan and the assigned resources; or
• Facilitating communication among members of the engagement team, for example, coordinating arrangements with component auditors⁴⁰ and auditor’s experts.

Insufficient or Inappropriate Resources (Ref: Para. 27)

A74. Proposed SQM 1 addresses the firm’s commitment to quality through its culture that exists throughout the firm, which recognizes and reinforces the firm’s role in serving the public interest by consistently performing quality engagements, and the importance of quality in the firm’s strategic decisions and actions, including the firm’s financial and operational priorities. Proposed SQM 1 also addresses the firm’s responsibilities for planning for resource needs, and obtaining, allocating or assigning resources in a manner that is consistent with the firm’s commitment to quality. However, in certain circumstances, the firm’s financial and operational priorities may place constraints on the resources assigned or made available to the engagement team. In such circumstances, these constraints do not override the engagement partner’s responsibility for achieving quality at the engagement level, including for determining that the resources assigned or made available by the firm are sufficient and appropriate to perform the audit engagement.

A75. The engagement partner’s determination of whether additional engagement level resources are required is a matter of professional judgment and is influenced by the requirements of this SA and the nature and circumstances of the audit engagement. As described in paragraph A11, in certain circumstances, the engagement partner may determine that the firm’s responses to quality risks are ineffective in the context of the specific engagement, including that certain resources assigned or made available to the engagement team are insufficient. In those circumstances, the engagement partner is required to take appropriate action, including communicating such information to the appropriate individuals in accordance with paragraph 27 and paragraph 39(c). For example, if an audit software program provided by the firm has not incorporated new or revised audit procedures in respect of recently issued industry regulation, timely communication of such information to the firm enables the firm to take steps to update and reissue the software promptly or to provide an alternative resource that enables the engagement team to comply with the new regulation in the performance of the audit engagement.

A76. If the resources assigned or made available are insufficient or inappropriate in the circumstances of the engagement and additional or alternative resources have not been made available, appropriate actions may include:

• Changing the planned approach to the nature, timing and extent of direction, supervision and review (see also paragraph A92).
• Discussing an extension to reporting deadlines with management or those charged with governance, when an extension is possible under applicable law or regulation.
• Following the firm’s policies or procedures for resolving differences of opinion if the engagement partner does not obtain the necessary resources for the audit engagement.

• Following the firm’s policies or procedures for withdrawing from the audit engagement, when withdrawal is possible under applicable law or regulation.

A77. In case of certain entities, such as, Central/State governments and related government entities (for example, agencies, boards, commissions), specialized skills may be necessary to discharge the terms of the applicable legal or regulatory framework. Such skills may include an understanding of the applicable reporting arrangements, including reporting to the legislature or other governing body or reporting in the public interest. The wider scope of audit of such entities may include, for example, some aspects of performance auditing.

Engagement Performance
Scalability (Ref: Para. 29)

A78. When an audit is not carried out entirely by the engagement partner, or in an audit of an entity whose nature and circumstances are more complex, it may be necessary for the engagement partner to assign direction, supervision, and review to other members of the engagement team. However, as part of the engagement partner’s overall responsibility for managing and achieving quality on the audit engagement and to be sufficiently and appropriately involved, the engagement partner is required to determine that the nature, timing and extent of direction, supervision and review is undertaken in accordance with paragraph 30. In such circumstances, personnel or members of the engagement team may provide information to the engagement partner to enable the engagement partner to make the determination required by paragraph 30.

Direction, Supervision and Review (Ref: Para. 30)

A79. Under proposed SQM 1, the firm is required to establish a quality objective that addresses the nature, timing and extent of the direction and supervision of engagement teams and review of their work. Proposed SQM 1 also requires that such direction, supervision and review is planned and performed on the basis that the work performed by less experienced members of the engagement team is directed, supervised and reviewed by more experienced engagement team members.

A80. Direction and supervision of the engagement team and the review of the work of the engagement team are firm-level responses that are implemented at the engagement level, of which the nature, timing and extent may be further tailored by the engagement partner in managing the quality of the audit engagement. Accordingly, the approach to direction, supervision and review will vary from one engagement to the next, taking into account the nature and circumstances of the engagement. The approach will generally include a combination of addressing the firm’s policies or procedures and engagement specific responses.

A81. The approach to the direction and supervision of the members of the engagement team and the review of their work provides support for the engagement partner in fulfilling the requirements of this SA, and in concluding that the engagement partner has been sufficiently and appropriately involved throughout the audit engagement in accordance with paragraph 40.

A82. Ongoing discussion and communication among members of the engagement team allows less experienced engagement team members to raise questions with more experienced engagement team members (including the engagement partner) in a timely manner and enables effective direction, supervision and review in accordance with paragraph 30.

Direction

A83. Direction of the engagement team may involve informing the members of the engagement team of their responsibilities, such as:

• Contributing to the management and achievement of quality at the engagement level through their personal conduct, communication and actions.
• Maintaining a questioning mind and being aware of unconscious or conscious auditor biases in exercising professional skepticism when gathering and evaluating audit evidence (see paragraph A35).
• Fulfilling relevant ethical requirements.
• The responsibilities of respective partners when more than one partner is involved in the conduct of an audit engagement.
• The responsibilities of respective engagement team members to perform audit procedures and of more experienced engagement team members to direct, supervise and review the work of less experienced engagement team members.
• Understanding the objectives of the work to be performed and the detailed instructions regarding the nature, timing and extent of planned audit procedures as set forth in the overall audit strategy and audit plan.
• Addressing threats to the achievement of quality, and the engagement team’s expected response. For example, budget constraints or resource constraints should not result in the engagement team members modifying planned audit procedures or failing to perform planned audit procedures.

Supervision

A84. Supervision may include matters such as:

• Tracking the progress of the audit engagement, which includes monitoring:
  • The progress against the audit plan;
  • Whether the objective of work performed has been achieved; and
  • The ongoing adequacy of assigned resources.
• Taking appropriate action to address issues arising during the engagement, including for example, reassigning planned audit procedures to more experienced engagement team members when issues are more complex than initially anticipated.
• Identifying matters for consultation or consideration by more experienced  engagement team members during the audit engagement.

• Providing coaching and on-the-job training to help engagement team members develop skills or competencies.
• Creating an environment where engagement team members raise concerns without fear of reprisals.

Review

A85. Review of the engagement team’s work provides support for the conclusion that the requirements of this SA have been addressed.

A86. Review of the engagement team’s work consists of consideration of whether, for example:

• The work has been performed in accordance with the firm’s policies or procedures, professional standards and applicable legal and regulatory requirements;
• Significant matters have been raised for further consideration;
• Appropriate consultations have taken place and the resulting conclusions have been documented and implemented;
• There is a need to revise the nature, timing and extent of work performed;
• The work performed supports the conclusions reached and is appropriately documented;
• The evidence obtained is sufficient and appropriate to provide a basis for the auditor’s opinion; and
• The objectives of the audit procedures have been achieved.

A87. The firm’s policies or procedures may contain specific requirements regarding:

• The nature, timing and extent of review of audit documentation;
• Different types of review that may be appropriate in different situations (e.g., review of each individual working paper or selected working papers); and
• Which members of the engagement team are required to perform the different types of review.

The Engagement Partner’s Review (Ref: Para. 30–34)

A88. As required by SA 230, the engagement partner documents the date and extent of the review.⁴¹

A89. Timely review of documentation by the engagement partner at appropriate stages throughout the audit engagement enables significant matters to be resolved to the engagement partner’s satisfaction on or before the date of the auditor’s report. The engagement partner need not review all audit documentation.

A90. The engagement partner exercises professional judgment in identifying the areas of significant judgment made by the engagement team. The firm’s policies or procedures may specify certain matters that are commonly expected to be significant judgments. Significant judgments in relation to the audit engagement may include matters related to the overall audit strategy and audit plan for undertaking the engagement, the execution of the engagement and the overall conclusions reached by the engagement team, for example:

• Matters related to planning the engagement, such as matters related to determining materiality.
• The composition of the engagement team, including:
  • Personnel using expertise in a specialized area of accounting or auditing;
  • The use of personnel from service delivery centers.
• The decision to involve an auditor’s expert, including the decision to involve an external expert.
• The engagement team’s consideration of information obtained in the acceptance and continuance process and proposed responses to that information.
• The engagement team’s risk assessment process, including situations where consideration of inherent risk factors and the assessment of inherent risk requires significant judgment by the engagement team.
• The engagement team’s consideration of related party relationships and transactions and disclosures.
• Results of the procedures performed by the engagement team on significant areas of the engagement, for example, conclusions in respect of certain accounting estimates, accounting policies or going concern considerations.
• The engagement team’s evaluation of the work performed by experts and conclusions drawn therefrom.
• In group audit situations:
  • The proposed overall group audit strategy and group audit plan;
  • Decisions about the involvement of component auditors, including how to review the written summary of the component auditor’s procedures and findings.
  • The evaluation of work performed by component auditors and the conclusions drawn therefrom.
• How matters affecting the overall audit strategy and audit plan have been addressed.
• The significance and disposition of corrected and uncorrected misstatements identified during the engagement.
• The proposed audit opinion and matters to be communicated in the auditor’s report, for example, key audit matters, or a “Material Uncertainty Related to Going Concern” paragraph.

A91. The engagement partner exercises professional judgment in determining other matters to review, for example based on:

• The nature and circumstances of the audit engagement.
• Which engagement team member performed the work.
• Matters relating to recent inspection findings.
• The requirements of the firm’s policies or procedures.
  Nature, Timing and Extent

A92. The nature, timing and extent of the direction, supervision and review are required to be planned and performed in accordance with the firm’s policies or procedures, as well as professional standards and applicable legal and regulatory requirements. For example, the firm’s policies or procedures may include that:

• Work planned to be performed at an interim date is to be directed, supervised and reviewed at the same time as the performance of the procedures rather than at the end of the period, so that any necessary corrective action can be taken in a timely manner.
• Certain matters are to be reviewed by the engagement partner and the firm may specify the circumstances or engagements in which such matters are expected to be reviewed.

Scalability

A93. The approach to direction, supervision and review may be tailored depending on, for example:

• The engagement team member’s previous experience with the entity and the area to be audited. For example, if the work related to the entity’s information system is being performed by the same engagement team member who performed the work in the prior period and there are no significant changes to the information system, the extent and frequency of the direction and supervision of the engagement team member may be less and the review of the related working papers may be less detailed.
• The complexity of the audit engagement. For example, if significant events have occurred that make the audit engagement more complex, the extent and frequency of the direction and supervision of the engagement team member may be greater and the review of the related working papers may be more detailed.
• The assessed risks of material misstatement. For example, a higher assessed risk of material misstatement may require a corresponding increase in the extent and frequency of the direction and supervision of engagement team members and a more detailed review of their work.
• The competence and capabilities of the individual engagement team members performing the audit work. For example, less experienced engagement team members may require more detailed instructions and more frequent, or in-person, interactions as the work is performed.
• The manner in which the reviews of the work performed are expected to take place. For example, in some circumstances, remote reviews may not be effective in providing the necessary direction and may need to be supplemented by in-person interactions.
• The structure of the engagement team and the location of engagement team members. For example, direction and supervision of individuals located at service delivery centers and the review of their work may:
  • Be more formalized and structured than when members of the engagement team are all situated in the same location; or
  • Use IT to facilitate the communication between the members of the engagement team.

A94. Identification of changes in the engagement circumstances may warrant reevaluation of the planned approach to the nature, timing or extent of direction, supervision or review. For example, if the assessed risk of material misstatement at the financial statement level increases because of a complex transaction, the engagement partner may need to change the planned level of review of the work related to the transaction.

A95. In accordance with paragraph 30(b), the engagement partner is required to determine that the approach to direction, supervision and review is responsive to the nature and circumstances of the audit engagement. For example, if a more experienced engagement team member becomes unavailable to participate in the supervision and review of the engagement team, the engagement partner may need to increase the extent of supervision and review of the less experienced engagement team members.

Review of Communications to Management, Those Charged with Governance, or Regulatory Authorities (Ref: Para. 34)

A96. The engagement partner uses professional judgment in determining which written communications to review, taking into account the nature and circumstances of the audit engagement. For example, it may not be necessary for the engagement partner to review communications between the engagement team and management in the ordinary course of the audit.

Consultation (Ref: Para. 35)

A97. Proposed SQM 1 requires the firm to establish a quality objective that addresses consultation on difficult or contentious matters and how the conclusions agreed are implemented. Consultation may be appropriate or required, for example for:

• Issues that are complex or unfamiliar (e.g., issues related to an accounting estimate with a high degree of estimation uncertainty);
• Significant risks;
• Significant transactions that are outside the normal course of business for the entity, or that otherwise appear to be unusual;
• Limitations imposed by management; and
• Non-compliance with laws or regulations.

A98. Effective consultation on significant technical, ethical and other matters within the firm or, where applicable, outside the firm may be achieved when those consulted:

• Are given all the relevant facts that will enable them to provide informed advice; and
• Have appropriate knowledge, seniority and experience.

A99. It may be appropriate for the engagement team, in the context of the firm’s policies or procedures, to consult outside the firm, for example, where the firm lacks appropriate internal resources. The engagement team may take advantage of advisory services provided by firms, professional and regulatory bodies or commercial organizations that provide relevant quality control services.

A100. The need for consultation outside the engagement team on a difficult or contentious matter may be an indicator that the matter is a key audit matter.⁴²

Engagement Quality Review (Ref: Para. 36)

A101. Proposed SQM 1 contains requirements that the firm establish policies or procedures addressing engagement quality reviews in accordance with proposed SQM 2,⁴³ and requiring an engagement quality review for certain types of engagements.⁴⁴ proposed SQM 2 deals with the appointment and eligibility of the engagement quality reviewer and the engagement quality reviewer’s responsibilities relating to performing and documenting an engagement quality review.

Completion of the Engagement Quality Review Before Dating of the Auditor’s Report (Ref: Para. 36(d))

A102. SA 700 (Revised) requires the auditor’s report to be dated no earlier than the date on which the auditor has obtained sufficient appropriate audit evidence on which to base the auditor’s opinion on the financial statements.⁴⁵ If applicable to the audit engagement, proposed SQM 2 and this SA require that the engagement partner be precluded from dating the engagement report until notification has been received from the engagement quality reviewer that the engagement quality review is complete. For example, if the engagement quality reviewer has communicated to the engagement partner concerns about the significant judgments made by the engagement team or that the conclusions reached thereon were not appropriate then the engagement quality review is not complete.⁴⁶

A103. An engagement quality review that is conducted in a timely manner at appropriate stages during the audit engagement may assist the engagement team in promptly resolving matters raised to the engagement quality reviewer’s satisfaction on or before the date of the auditor’s report.

A104. Frequent communications between the engagement team and the engagement quality reviewer throughout the audit engagement may assist in facilitating an effective and timely engagement quality review. In addition to discussing significant matters with the engagement quality reviewer, the engagement partner may assign responsibility for coordinating requests from the engagement quality reviewer to another member of the engagement team.

Differences of Opinion (Ref: Para. 37–38)

105. Proposed SQM 1 requires the firm to establish a quality objective that addresses differences of opinion that arise within the engagement team, or between the engagement team and the engagement quality reviewer or individuals performing activities within the firm’s system of quality management. Proposed SQM 1 also requires that differences of opinion are brought to the attention of the firm and resolved.

106. In some circumstances, the engagement partner may not be satisfied with the resolution of the difference of opinion. In such circumstances, appropriate actions for the engagement partner may include, for example:

• Seeking legal advice; or
• Withdrawing from the audit engagement, when withdrawal is possible under applicable law or regulation.

Monitoring and Remediation (Ref: Para. 39)

107. Proposed SQM 1 sets out requirements for the firm’s monitoring and remediation process. Proposed SQM 1 requires the firm to communicate to engagement teams information about the firm’s monitoring and remediation process to enable them to take prompt and appropriate action in accordance with their responsibilities.⁴⁷ Further, information provided by members of the engagement team may be used by the firm in the firm’s monitoring and remediation process, and exercising professional judgment and professional skepticism while conducting the audit may assist the members of the engagement team in remaining alert for information that may be relevant to that process.

108. Information provided by the firm may be relevant to the audit engagement when, for example, it relates to findings on another engagement performed by the engagement partner or other members of the engagement team, findings from the local firm office or inspection results of previous audits of the entity.

109. In considering information communicated by the firm through its monitoring and remediation process and how it may affect the audit engagement, the engagement partner may consider the remedial actions designed and implemented by the firm to address identified deficiencies and, to the extent relevant to the nature and circumstances of the engagement, communicate accordingly to the engagement team. The engagement partner may also determine whether additional remedial actions are needed at the engagement level. For example, the engagement partner may determine that:

• An auditor’s expert is needed; or
• The nature, timing and extent of direction, supervision and review needs to be enhanced in an area of the audit where deficiencies have been identified.

If an identified deficiency does not affect the quality of the audit (e.g., if it relates to a technological resource that the engagement team did not use) then no further action may be needed.

A110. An identified deficiency in the firm’s system of quality management does not necessarily indicate that an audit engagement was not performed in accordance with professional standards and applicable legal and regulatory requirements, or that the auditor’s report was not appropriate in the circumstances.

Taking Overall Responsibility for Managing and Achieving Quality (Ref: Para. 40)

A111. Proposed SQM 1 requires the firm to establish a quality objective addressing the engagement team’s understanding and fulfillment of their responsibilities in connection with the engagement. Proposed SQM 1 further requires that the quality objective include the overall responsibility of engagement partners for managing and achieving quality on the engagement and being sufficiently and appropriately involved throughout the engagement.

A112. Relevant considerations in addressing the requirement of paragraph 40 include determining how the engagement partner has complied with the requirements of this SA, given the nature and circumstances of the audit engagement and how the audit documentation evidences the engagement partner’s involvement throughout the audit engagement, as described in paragraph A116.

A113. Indicators that the engagement partner may not have been sufficiently and appropriately involved include, for example:

• Lack of timely review by the engagement partner of the audit engagement planning, including reviewing the assessment of risks of material misstatement and the design of those responses to those risks.
• Evidence that those to whom tasks, actions or procedures have been assigned were not adequately informed about the nature of their responsibilities and authority, the scope of the work being assigned and the objectives thereof; and were not provided other necessary instructions and relevant information.
• A lack of evidence of the engagement partner’s direction and supervision of the other members of the engagement team and the review of their work.

A114. If the engagement partner’s involvement does not provide the basis for determining that the significant judgments made and the conclusions reached are appropriate, the engagement partner will not be able to reach the determination required by paragraph 40. In addition to taking account of firm policies or procedures that may set forth the required actions to be taken in such circumstances, appropriate actions that the engagement partner may take, include, for example:

• Updating and changing the audit plan;
• Reevaluating the planned approach to the nature and extent of review and modifying the planned approach to increase the involvement of the engagement partner; or

• Consulting with personnel assigned operational responsibility for the relevant aspect of the firm’s system of quality management.

Documentation (Ref: Para. 41)

A115. In accordance with SA 230,⁴⁸ audit documentation provides evidence that the audit complies with the SAs. However, it is neither necessary nor practicable for the auditor to document every matter considered, or professional judgment made, in an audit. Further, it is unnecessary for the auditor to document separately (as in a checklist, for example) compliance with matters for which compliance is demonstrated by documents included within the audit file.

A116. Documentation of the performance of the requirements of this SA, including evidencing the involvement of the engagement partner and the engagement partner’s determination in accordance with paragraph 40, may be accomplished in different ways depending on the nature and circumstances of the audit engagement. For example:

• Direction of the engagement team can be documented through signoffs of the audit plan and project management activities;
• Minutes from formal meetings of the engagement team may provide evidence of the clarity, consistency and effectiveness of the engagement partner’s communications and other actions in respect of culture and expected behaviors that demonstrate the firm’s commitment to quality;
• Agendas from discussions between the engagement partner and other members of the engagement team, and where applicable the engagement quality reviewer, and related signoffs and records of the time the engagement partner spent on the engagement, may provide evidence of the engagement partner’s involvement throughout the audit engagement and supervision of other members of the engagement team; or
• Signoffs by the engagement partner and other members of the engagement team provide evidence that the working papers were reviewed.

A117. When dealing with circumstances that may pose risks to achieving quality on the audit engagement, the exercise of professional skepticism, and the documentation of the auditor’s consideration thereof, may be important. For example, if the engagement partner obtains information that may have caused the firm to decline the engagement (see paragraph 24), the documentation may include explanations of how the engagement team dealt with the circumstance.

A118. Documentation of consultations with other professionals that involve difficult or contentious matters that is sufficiently complete and detailed contributes to an understanding of:

• The nature and scope of the issue on which consultation was sought; and
• The results of the consultation, including any decisions taken, the basis for those decisions and how they were implemented.

Material Modifications vis-à-vis ISA 220(Revised), “Quality Management for an Audit of Financial Statements”

Deletions

 1. Paragraphs A48, A58 and A79 of the Application Section of ISA 220(Revised) (paragraphs A48, A58, and A77 of SA 220(Revised)) deal with the application of the requirements of ISA 220(Revised) to the audits of public sector entities. Since as mentioned in the “Preface to the Standards on Quality Management, Auditing, Review, Other Assurance and Related Services”, the Standards on Auditing 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 these requirements may also exist in case of non-public sector entities pursuant to a requirement under the statute or regulation under which they operate. Accordingly, the spirit of paragraphs A48, A58 and A79 in ISA 220(Revised) has, accordingly, been made more generic in its application.

2. Paragraph A60 of ISA 220(Revised) contains the following guidance which is based on ISA 600, Special Considerations ― Audits of Group Financial Statements (Including the Work of Component Auditors):

“Resources for an audit engagement are primarily assigned or made available by the firm, although there may be circumstances when the engagement team directly obtains resources for the audit engagement. For example, this may be the case when a component auditor is required by statute, regulation or for another reason to express an audit opinion on the financial statements of a component, and the component auditor is also appointed by component management to perform audit procedures on behalf of the group engagement team. In such circumstances, the firm’s policies or procedures may require the engagement partner to take different actions, such as requesting information from the component auditor, to determine whether sufficient and appropriate resources are assigned or made available.”

SA 600 used in India does not contain the abovementioned guidance. Hence, paragraph A60 of ISA 220(Revised) has been deleted.

3. Paragraph A76 of ISA 220(Revised) contains the following guidance which is based on ISA 600:

“In an audit of group financial statements, when there are insufficient or inappropriate resources in relation to work being performed at a component by a component auditor, the engagement partner may discuss the matter with the component auditor, management or the firm to make sufficient and appropriate resources available.”

SA 600 used in India does not contain the abovementioned guidance. Hence, paragraph A76 of ISA 220(Revised) has been deleted.