Document ID: chunk:federal_register_of_legislation:F2023C01136:reg:9:p21
Version: federal_register_of_legislation:F2023C01136
Segment Type: reg
Provision Reference: reg 9 (pt 21/24)
Character Range: 61369–64370

communicating are limited to specific aspects relating to the matter, such that certain information about the matter may be less sensitive and could be communicated.

    The auditor also may consider it necessary to obtain a written representation from management as to why public disclosure about the matter is not appropriate, including management's view about the significance of the adverse consequences that may arise as a result of such communication.

A55.         It may also be necessary for the auditor to consider the implications of communicating about a matter determined to be a key audit matter in light of relevant ethical requirements.  In addition, the auditor may be required by law or regulation to communicate with applicable regulatory, enforcement or supervisory authorities in relation to the matter, regardless of whether the matter is communicated in the auditor's report.  Such communication may also be useful to inform the auditor's consideration of the adverse consequences that may arise from communicating about the matter.

A56.         The issues considered by the auditor regarding a decision to not communicate a matter are complex and involve significant auditor judgement.  Accordingly, the auditor may consider it appropriate to obtain legal advice.

Form and Content of the Key Audit Matters Section in Other Circumstances (Ref: Para. 16)

A57.         The requirement in paragraph 16 applies in three circumstances:

(i)                 The auditor determines in accordance with paragraph 10 that there are no key audit matters (see paragraph A59).

(ii)               The auditor determines in accordance with paragraph 14 that a key audit matter will not be communicated in the auditor's report and no other matters have been determined to be key audit matters.

(iii)             The only matters determined to be key audit matters are those communicated in accordance with paragraph 15.

A58.         The following illustrates the presentation in the auditor's report if the auditor has determined there are no key audit matters to communicate:

    Key Audit Matters

     [Except for the matter described in the Basis for Qualified (Adverse) Opinion section or Material Uncertainty Related to Going Concern section,] We have determined that there are no [other] key audit matters to communicate in our report.

A59.         The determination of key audit matters involves making a judgement about the relative importance of matters that required significant auditor attention.  Therefore, it may be rare that the auditor of a general purpose financial report of a listed entity would not determine at least one key audit matter from the matters communicated with those charged with governance to be communicated in the auditor's report.  However, in certain limited circumstances (e.g., for a listed entity that has very limited operations), the auditor may determine that there are no key audit matters in accordance with paragraph 10 because there are