INTOSAI Auditing Standards Bridging Document
(Adopted by the INTOSAI Committee on Auditing Standards in September,
2003)
| This document which attempts to forge a bridge
between the private sector ISAs and INTOSAI Auditing Standards lays
down a framework for harmonizing private and public sector auditing
practices. |
Introduction
- The original INTOSAI Auditing Standards were issued by the
INTOSAI Auditing Standards Committee in June 1992, with INTOSAI code
of Ethics being approved at the XVIth Congress of INCOSAI held at
Montevideo in 1998. These Auditing Standards were subsequently
restructured, and the current INTOSAI Code of Ethics and Auditing
Standards were approved by the XVIIth Congress of INTOSAI in Seoul
2001. Both take the Lima Declaration of Guidelines on Auditing
Precepts as their foundation. The XVth Congress of INCOSAI in
Montevideo also sanctioned the Auditing Standards Committee to
develop guidelines for implementing auditing standards.
- In parallel with these developments, the International
Federation of Accountants, under the aegis of its newly created
constituent bodies the International Auditing and Assurance
Standards Board, has been developing global auditing standards
covering financial audit work through the publication of
International Standards on Auditing (ISAs). In response to this, the
INTOSAI Auditing Standards Committee, using INTOSAI Auditing
Standards as its starting point, agreed to take forward a project
for the development of implementation guidelines for financial audit
work that incorporate the guidance contained in ISAs. Further, the
Auditing Standards Committee also committed to developing additional
guidance in those areas specific to Supreme Audit Institution audit
work (e.g. compliance or regularity audit) which are not otherwise
covered by ISAs.
Purpose of the Bridging Document
- The purpose of this INTOSAI Auditing Standards Bridging Document
is to provide a link between INTOSAI Auditing Standards and
International Standards on Auditing (ISAs) issued by the
International Auditing and Assurance Standards Board (IAASB).
- In presenting this Bridging Document, the International
Organisation of Supreme Audit Institutions (INTOSAI) recognises that
INTOSAI Auditing Standards will continue to provide the necessary
framework and overriding principles for the performance of financial
audit work by Supreme Audit Institutions (SAIs). By design, however,
they do not carry the degree of detailed and specific guidance
contained in ISAs, insofar as it is relevant to the work of SAIs,
and by building upon it with the development of its own
implementation guidelines, or ‘Practice Notes”, INTOSAI aims to
provide a comprehensive suite of guidance which can be drawn upon by
all SAIs in all institutional settings and audit environments.
- While the Bridging Document provides the context for the
application of ISAs within the INTOSAI public sector context, it is
the function of the Practice Note to provide the detailed guidance
on the specific application of each ISA. There will be a separate
Practice Note for each ISA, and these will be issued on an ongoing
basis as and when the IAASB amends existing, or issues new, ISAs.
Additional practice notes will be developed to provide detailed
guidance in areas specific to the financial audit work of SAIs which
are not adequately covered by ISAs.
INTOSAI Auditing Standards
- The current INTOSAI Code of Ethics and Auditing Standards were
approved by the XVIIth Congress of INTOSAI in Seoul 2001. INTOSAI
Auditing Standards contain the basic postulates and principles for
the carrying out of audit work by SAIs. While it is the
responsibility of each SAI to judge the extent to which the
standards are compatible with the achievement of its mandate, viewed
in the particular constitutional, legal and other circumstances of
the SAI, one of the principles outlined in the Code of Ethics is the
auditor’s obligation to apply generally accepted auditing standards.
- The INTOSAI Auditing Standards consist of four elements, being
Basic Principles, General Standards, Field Standards, and Reporting
Standards. Each element is explained in detail in the original
document.
- Basic Principles are the basic assumptions, consistent premises,
logical principles, and necessary requirements designed to underpin
the development of auditing standards. They are designed to serve
the auditors in forming their opinions and reports, particularly in
cases where no specific standards apply. Each SAI should consider
compliance with the INTOSAI Auditing Standards in all matters which
are deemed material, although this must be compatible with the SAI’s
fulfillment of its own particular audit mandate. Each SAI should
establish a policy on which INTOSAI standards, or other specific
standards, should be followed in carrying out the various types of
work that the organization conducts to ensure that the work and the
products are of the highest quality.
- General Standards are concerned with the qualifications of the
auditor and/or auditing institution so that they may carry out the
tasks related to field and reporting standards in a competent and
effective manner and cover issues such as recruitment, training and
development, provision of suitable guidance, planning and
supervision of audits, and the review of the efficiency and
effectiveness of the SAI’s internal standards and procedures. The
General Standards are also concerned with Independence, conflicts of
interest, competence, and due care. Taken as a whole, these provide
effective guidance for each SAI’s internal quality control
procedures.
- Field Standards are designed to establish the framework for
conducting and managing audit work. They concern the need to plan,
review, supervise, study and evaluate internal control, and provide
advice and guidance on regularity audit, audit evidence, and
analysis of financial statements. While these standards contain a
degree of detailed guidance, the emphasis is still to provide a
framework of reference for the auditor. It is predominantly in the
audit area covered by the Field Standards that ISAs will provide
additional detailed guidance.
- Reporting Standards are concerned with the auditor’s formal
audit opinion and provide guidance in respect of report format and
modified opinions. The standards also refer to other reports that
the auditor may make, such as regularity and performance audit
remarks and reporting. Again, the emphasis of the Reporting
Standards is on providing a necessary framework within which
auditors should meet their reporting responsibilities, and as a
result the standards do not contain the degree of detail contained
in the relevant ISAs.
- INTOSAI firmly believes that INTOSAI Auditing Standards should
remain the primary source of audit guidance for INTOSAI members, and
the authority of the INTOSAI Auditing Standards is in no way
diminished by the publication of this Bridging Document or the
Practice Notes. While INTOSAI Auditing Standards provide the
necessary recommended framework within which INTOSAI members should
continue to carry out their audits, however, INTOSAI does recognize
that this framework would benefit from further guidance in a number
of areas. The remainder of this document sets out the relevance of
International Standards on Auditing (ISAs) and explains how the
Practice Notes developed by the INTOSAI Auditing Standards Committee
and endorsed by INTOSAI as a whole will provide the detailed
implementation guidelines first envisaged at the XVIth INCOSAI in
Montevideo.
IAASB and International Standards on Auditing
- The objective of the International Auditing and Assurance
Standards Board (IAASB), on behalf of the International Federation
of Accountants (IFAC), is to improve auditing and assurance
standards and the quality and uniformity of practice throughout the
world, thereby strengthening public confidence in the global
auditing profession and serving the public interest.
- The prime means by which the IAASB attempts to achieve this goal
is by establishing International Standards on Auditing (ISAs)
containing guidance covering the audit of financial statements that
is of such high quality that they are acceptable to investors,
auditors, governments, regulators and other key stakeholders across
the world. In this respect, the aims of the IAASB can be viewed
within the wider context of international harmonization of
accounting and auditing practice in general, and it is within this
context that INTOSAI is seeking to encourage adoption of the
guidance contained within ISAs. Indeed, as ISAs gain increasing
recognition within the international community, it is important that
INTOSAI Auditing Standards are seen to be consistent with what are
an increasingly recognized global set of standards.
- ISAs contain basic principles and essential procedures
(identified in bold type black lettering) together with related
guidance in the form of explanatory and other material. These basic
principles and essential procedures will in most respects be
consistent with existing INTOSAI Auditing Standards, albeit covering
a wider range of circumstances. The related guidance and explanatory
material, however, goes into greater detail than the INTOSAI
Auditing Standards.
- While the Bridging Document and Practice Notes aim to support
INTOSAI members in the application of ISAs, it will be the
responsibility of each SAI to consider the relevance of each ISA to
its own particular circumstances. Indeed, the authority attaching to
the Bridging Document and Practice Notes is the same as that
applying to the wider INTOSAI Auditing Standards within which the
detailed guidance of the ISAs is to be applied. The additional
guidance does not have mandatory application, but rather it reflects
a best practice consensus developed by members of the INTOSAI
Auditing Standards Committee. Each SAI must judge the extent to
which this additional guidance is compatible with the achievement of
its mandate.
The INTOSAI Auditing Standards Committee
17. The adoption of ISAs, suitably interpreted to reflect the work
of SAIs, is part of a wider move towards closer working between IFAC
and INTOSAI. Following a meeting of the INTOSAI Auditing Standards
Committee (ASC) in April 2003, a Memorandum of Understanding has
been developed and agreed between the ASC and the IAASB, determining
INTOSAI involvement in the future drafting of ISAs.
18. Under the terms of this Memorandum of Understanding the ASC will
nominate reference panel experts drawn from the wider INTOSAI
membership to participate in IAASB working groups responsible for
revising existing ISAs and drawing up new ones.
19. It is envisaged that participation of reference panel experts
will help ensure that all new or revised ISAs reflect appropriately
the public sector context, and help to ensure that the related
guidance is as applicable as possible to the public sector context
within which INTOSAI members operate. It is envisaged that the
direct involvement of the ASC in the ISA drafting process should
ensure that the separate Public Sector Perspectives previously
appended to each ISA are no longer required.
Practice Notes
20. Although the involvement of ASC nominated reference panel
experts should help ensure that new and revised ISAs are relevant
and applicable to the particular environment within which INTOSAI
members audit, it would be unrealistic to expect the majority of
ISAs to be directly applicable to the public sector without the need
for further guidance interpreting the ISAs in an SAI context. Each
ISA is written to have the widest possible applicability to all
industry sectors, and cannot therefore be expected to include any
substantial degree of detail in respect of the public sector
context.
21. The ASC has therefore undertaken to produce a suite of
additional interpretative guidance in the form of Practice Notes.
The Practice Note is the fundamental mechanism for facilitating the
link between INTOSAI Auditing Standards and ISAs, with each Practice
Note providing detailed guidance on the specific application of each
ISA to the SAI context, highlighting any special consideration that
need to be born in mind when applying the ISA and clearly setting
out links back to the INTOSAI Auditing Standards.
22. Each Practice Note will have a standard format, consisting of
the following constituent sections:
• Summary of the main guidance contained in the ISA and reference to
relevant sections and paragraphs where applicable.
• Reconciliation of the ISA to the wider framework of INTOSAI Auditing
Standards.
• Detailed supplementary guidance for auditors where there are specific
SAI considerations and impacts in relation to the guidance contained in
the ISA.
• Further explanation of matters with legal implication where not fully
addressed by the ISA.
• The provision of illustrative procedures, reports, letters and other
relevant extracts and documents.
• An overt statement that no additional guidance is required where this
is relevant.
23. There may also be occasions where audit issues specific to the SAI
context are not covered by the extant suite of ISAs. Where this is the
case, additional Practice Notes will be appended to the Bridging
Document providing additional guidance in these areas. A pertinent
example would be the need for detailed guidance in the area of
compliance or regularity audit, which is not covered by either existing
or planned ISAs.
The Role of the SAI
- The role and responsibilities of a SAI differ quite considerably
from those of a private sector auditor. These differences stem both from
the specific responsibilities of the SAI, as well as from the different
context in terms of legislation and accountability within which the SAI
operates.
- Public sector bodies who are responsible for the conduct of public
finance and for spending public money are generally accountable for
ensuring that public business is conducted in accordance with the law,
that public money is safeguarded and properly accounted for, and is used
economically, efficiently and effectively.
- The external audit role carried out by the SAI is an essential
element in the process of accountability and makes an important
contribution to the stewardship of public money.
- SAIs act and report in accordance with the mandates that govern
their activities and provide the authority for them to carry out and
report the results of their work. These mandates are embodied in
legislation and, in some circumstances, set out in codes of audit
practice established in accordance with legislation.
- The mandates of SAIs vary in accordance with the requirements laid
down in the legislation relevant to the each particular jurisdiction and
geographical area. Typically however, these mandates will include some
or all of the following responsibilities:
- The audit of financial statements;
- The audit of the state budget;
- Compliance with legislative and other authorities (also referred to as
regularity audit);
- Economy, efficiency and effectiveness (also referred to as performance
or value for money audit); and
- Other review and reporting assignments such as performance
information, grant claims, corporate governance, and standards of
financial conduct.
- The legislative framework governing public sector bodies will
typically set out the requirements on the public bodies in relation to
the preparation of financial statements, both in terms of necessary
format and timetable. In addition, the requirements on the public sector
auditor will also be set out, determining amongst other matters, who
that auditor is, their remit, the format of their audit opinion (whether
the financial statements give a true and fair view, present fairly, or
properly present the entity’s transactions and balances), and the
certification timetable.
- The remit of the SAI even simply in relation to the audit of
financial statements will differ from that of the private sector
counterpart. For example, the remit in respect of fraud and corruption
is likely to extend beyond simply the potential impact on the financial
statements, both in terms of identification and reporting
responsibilities. Similarly, SAIs are likely to have a wider regard to
law and regulations beyond the impact that non-compliance may have on
the financial statements. It is clear also, that consideration of the
going concern principle in the preparation of financial statements has a
very different context within the public sector. It is in areas such as
these where Practice Notes will provide the necessary SAI
interpretation.
- Perhaps the biggest difference between private and public sector
auditing however, is the requirement to report on compliance with
regulations (e.g. a “regularity Opinion”) as part of the audit report.
For may public sector bodies, public sector auditors express an opinion
on whether transactions included in the financial statements conform,
where appropriate, with the legislation that authorizes them. Even where
there is no requirement for auditors to express an opinion on the
regularity of transactions, it is common for the auditor to be required
to be alert to the question of legality and compliance with authorities,
and to review the arrangements set in place by the audited body to
ensure the legality of transactions. Where such transactions or events
come to the auditors’ attention they are often empowered under
legislation to report to the appropriate authorities. And in those
jurisdictions where SAIs carry out a quasi-legal function, their powers
in these areas will extend even further.
- Key to the responsibility to report on public bodies’ arrangements
to secure economy, efficiency and effectiveness in the use of resources
is the performance audit. The INTOSAI Auditing Standards Committee is
completing a separate project to develop implementation guidelines
governing performance audit, and auditors should refer to this for
guidance in carrying out performance audits. However, relevant aspects
of economy, efficiency and effectiveness to financial auditing will be
incorporated in the Practice Notes to provide guidance to the
performance of work in this area.