Document ID: chunk:federal_register_of_legislation:F2023C00330:reg:10:p8
Version: federal_register_of_legislation:F2023C00330
Segment Type: reg
Provision Reference: reg 10 (pt 8/14)
Character Range: 29529–32514

a threshold above which misstatements cannot be regarded as clearly trivial.  In the same way, the auditor may consider communicating to management a threshold for purposes of the requested written representations.

Date of and Period(s) Covered by Written Representations (Ref: Para. 14)

A15.         Because written representations are necessary audit evidence, the auditor's opinion cannot be expressed, and the auditor's report cannot be dated, before the date of the written representations.  Furthermore, because the auditor is concerned with events occurring up to the date of the auditor's report that may require adjustment to or disclosure in the financial report, the written representations are dated as near as practicable to, but not after, the date of the auditor's report on the financial report.

A16.         In some circumstances, it may be appropriate for the auditor to obtain a written representation about a specific assertion in the financial report during the course of the audit.  Where this is the case, it may be necessary to request an updated written representation.

A17.         The written representations are for all periods referred to in the auditor's report because management needs to reaffirm that the written representations it previously made with respect to the prior periods remain appropriate.  The auditor and management may agree to a form of written representation that updates written representations relating to the prior periods by addressing whether there are any changes to such written representations and, if so, what they are.

A18.         Situations may arise where current management were not present during all periods referred to in the auditor's report.  Such persons may assert that they are not in a position to provide some or all of the written representations because they were not in place during the period.  This fact, however, does not diminish such persons' responsibilities for the financial report as a whole.  Accordingly, the requirement for the auditor to request from them written representations that cover the whole of the relevant period(s) still applies.

Form of Written Representations (Ref: Para. 15)

A19.         Written representations are required to be included in a representation letter addressed to the auditor.  In some jurisdictions, however, management may be required by law or regulation to make a written public statement about its responsibilities.  Although such a statement is a representation to the users of the financial report, or to relevant authorities, the auditor may determine that it is an appropriate form of written representation in respect of some or all of the representations required by paragraph 10 or 11.  Consequently, the relevant matters covered by such a statement need not be included in the representation letter.  Factors that may affect the auditor's determination include:

           * Whether the statement includes confirmation of the fulfilment of the