The New Auditor’s Report: Speech to the 6th Brazilian Conference on Accounting and Independent Auditing
James Gunn | Managing Director, Professional Standards
Jun 13, 2016 | at 6th Brazilian Conference on Accounting and Independent Auditing | Sao Paolo, Brazil | English
Thank you, President Coelho, for the warm welcome, and good morning ladies and gentlemen, esteemed colleagues.
It is really a pleasure for me to visit Brazil again. My last visit was some years ago, simply too long. But no matter the time between visits, I never feel disconnected from Brazil. One simple, symbolic reason is that for the last seven years Brazil has been an adopter of the International Standards on Auditing "ISAs" – so, a very valued stakeholder of the output of work of the International Auditing and Assurance Standards Board (IAASB).
There is also of course the fact that many of your colleagues from Brazil sit now, and in the past, around the tables of the IAASB and the International Ethics Standards Board for Accountants (IESBA), in these Board’s National Standards Setter Liaison Groups, and on the Board and various committees of IFAC.
There is also Brazil’s strong institutional involvement through actively commenting on our new standards proposals. And also, much outreach: past visits by the former Presidents of the Federal Accounting Council (CFC) and the Brazilian Institute (IBRACON) to our offices; also invitations to IAASB to speak at important events in Brazil with the IAASB Deputy Chair here in São Paulo in 2013 and the IAASB Chairman at IBRACON’s 40th anniversary event in June 2011. Basically, lots of valued interactions and opportunities to hear your voice.
So, personally, I found preparing for this morning pretty easy. But "easy" also because I learned that your national motto ("lema") on your flag is "Ordem e Progresso."
For me, "order and progress" is a theme that also very much underlines how IAASB goes about its own work. So, perhaps there is a bit of shared philosophy.
Interestingly, I also learned that the man credited with creating the national motto and flag was a Brazilian philosopher named Raimundo Teixeira Mandes; there is an impressive statue of him in Rio de Janeiro. And I learned that as a philosopher he was heavily influenced by the study of "Positivism." Now that is a complex area, I am no expert, but among others it suggests a theory that connect laws to their "value to society." This struck me because auditing itself is connected very much to society, and we have to continue to challenge the relevance and value of auditing and its societal role. And this is what the new Auditor’s Report helps demonstrate.
Also, a simple English translation of the word positivism is "the state or quality of being positive" – and, basically, this is how auditors and society are reacting to the new Auditor Report. And there is much to be positive about. We are in the midst of one of the biggest transformations in the auditing profession globally in recent years, which for me is exciting. But I am not alone. I recently heard a front-line auditor partner say that this new report has "renewed his energy" – So, we seem to be igniting some inspiration and enthusiasm within the profession itself!
Why change the auditor’s report?
So, why did we decide to change the auditor’s report?
The topic had been on our agenda for some time, since 2006. We started with commissioning academic research about how users feel about the auditor report. We learned that the only thing in an auditor’s report that was read is the audit opinion – a one-liner that tells you whether the financial statements are OK or not.
Important? Yes. But we heard from a variety of stakeholders, in particular users, that more was needed. It was asked why auditors don’t share more – about the audit, what they did, and why is it that none of that is made transparent – except the valued audit opinion? Well, they had a point. And all this even before the financial crisis. But that then heightened the demand for more communication from auditors. To illustrate the why, let me quote from the 2012 letter to IAASB from IBRACON:
"The global financial crisis and other related events have undermined investor confidence in corporate financial reporting and challenged the usefulness of the auditor’s report and, more broadly, the relevance of the financial statement audit. We support the IAASB’s initiative to explore options to enhance the quality, relevance and value of auditor reporting….[and] We believe the suggestions presented herein will improve the auditor’s communication, making it more informative and significant to users… this will represent a significant advance."
Further, here is a quote from the letter to IAASB from the Brazilian Institute of Corporate Governance:
"There is a belief that current auditors' reports need to change. There is a sense that current reports are incomplete and very similar to one another, therefore they are unable to clearly differentiate diverse situations at different companies using the same type of report. The IFRS is highly dependent on estimates, fair values, judgments and substance taking precedence over the format of information and whether it can be understood. Reports should assure users that the auditor did indeed take all these issues into account and how he or she did so. …It would seem that the current model does need to change."
And other voices then began talking about the potential benefits of a new style reporting: Might it not stimulate even more robust interactions and communications between auditor and entity? Could it also have the potential to improve audit quality – because if a matter is going to be discussed in the auditor’s report, then greater focus by management especially on their own disclosures, and also even greater attention and scepticism by the auditor, might result? And indeed, from a user perspective, the audit is perhaps the least understood service -- so, we also heard: tell us clearly what your responsibilities are, but not boilerplate – rather, communicate what really you have been focusing on.
The Global Journey So Far
So, a lot of early interest and promising thinking. How has that translated, what’s been the global journey so far? Simply, the world is moving ahead, with speed.
Now, the reality is that the journey was not always easy. There were skeptics, with the views that today’s standardized audit report is what it is for good reason. Also, I read an article in your news, Valor Economico, on Friday: much support for the new standard by the profession, but some concerns from the Business community: Will the new reporting be interpreted as saying a company is having problems? Will it impact audit costs more than benefit? Fair concerns, but today I think we are seeing that a different reality is possible.
The United Kingdom, through its Financial Reporting Council, is now heading into its third year of enhanced reporting in the auditor’s report and the response from investors has certainly been promising. We have also seen the Netherlands adopt new style auditor’s reports in 2014, stimulated by a strongly engaged Finance minister and Parliament. Those rules were basically drawn from the new ISAs as they developed, but with some additions.
Then, the IAASB finalized its new international standards in 2014 and these come into effect, basically, for 2016 audits. But not many are waiting. It is fascinating that we see more and more "early birds" – applying Key Audit Matters and voluntarily adopting the new reporting. In Poland, the law still has to come – but some auditors could not wait. And similarly ‘early birds’ applying KAM in Germany, in Switzerland. For the rest of Europe, enhanced auditor’s reports will be required for Public Interest Entities starting for June 2017 year ends.
But it is more than Europe and UK. In South Africa, where the national regulator IRBA needed to hurry up as auditors wanted to start as soon as possible. In Zimbabwe, all listed entities and a number of other promulgated public-interest entities are having a "dry-run" of the new auditors report. In Australia, also progress. Only a few years ago IAASB Chairman Prof. Arnold Schilder and I were grilled in public seminars – how ridiculous could we be with these plans? And now – early birds there as well. And in recent visits to Tokyo and Moscow – where we were warned for skeptical audiences - this revolution was received with surprising warmth.
And also now last month, the US Public Company Accounting Oversight Board (PCAOB) just released re-proposed standards which have many similarities in key areas with the international standards. I should say indeed that this is a major step forward towards changing the global landscape, certainly given the characteristics of the US marketplace including from a litigation perspective.
What is really interesting is that this is not only investor, auditor or regulatory driven demand, but in a few cases driven by the entity and audit committee. Before this conference I spoke with a Board Director of one of Brazil’s listed companies -- She herself has recently asked her auditors to also do a dry-run, to take their 2015 report and model it under the new style reporting.
Why is that? Why are auditors almost voluntarily agreeing to tell much more to shareholders than in the past, with the support of CFOs and audit committees? Because that is the new feature: "key audit matters" – what I believe is the center piece of the new auditor report.
Key Audit Matters (or KAM)
To explain KAM very simply: auditors now describe in their public reports what they saw as the matters of most significance in the audit, and how those matters were addressed in the audit.
Let me be clear here: it is the auditor’s story about the audit, not the auditor’s story about the entity. We listened carefully to feedback – and this was specifically noted in the Brazil letters - to be careful to respect the division of responsibility between management and auditors, and for auditors to not be the provider of original information about the entity. So, it is really about the auditor doing their job and explaining what was actually done.
The framework in ISA 701 provides auditors with a decision-making process to determine KAM, and it is about judgement, about what is relevant to communicate. The process is intuitive: start with essentially what already is being discussed with the audit committees. That focuses the lens on the salient matters. Then, further focus on matters requiring significant auditor attention – it could be areas of higher risk, or areas of significant auditor judgment. And then, think about what is really unique and relevant in this particular audit for this particular entity – that is, what is the matters of most significance. Again from the letter from the Brazilian Institute of Corporate Governance: “The report should concentrate on essential issues.”
The new standard is required for listed entity audits. Why? Well, the public market investor community has been the most vocal. But we also listened to feedback – again a message from Brazil and others – that perhaps now is not yet so critical for smaller audits. So it is voluntary for them and others, but encouraged, as well for audits of public interest entities.
What are the basics of communicating KAM? Essentially:
i) Why the auditor judged a matter to be of most significance in the audit;
ii) how that matter was addressed in the audit; and
iii) reference to any related financial statement disclosures.
And some auditors at the forefront of writing KAM are being bold in experimenting – which, for me, is more indication of positive enthusiasm. For example, some are describing the procedures they have carried out, or how they modified their audit approach. I will mention more later, but the point is: auditors are thinking now in terms of the lens of the reader, the investors, the users. And this is exactly the reason former IFAC president Warren Allen called the new Auditor Report "a step change."
KAM – Delivering Entity Specific Information
In summary then: the intention, design and flexibility that the new standard allows is intended to enable auditors to be as entity-specific and audit-specific as possible in describing each KAM so that they continue to be relevant and useful to investors and other users.
Let’s reflect: the old way was to achieve consistency and comparability – standardized language, basically. But now: what’s relevant, what’s useful, what is this specific audit about, what was in this entity that really mattered from an audit perspective. It makes much sense.
Other Key Features of the New AR
Now, I don’t have time to go into detail, but let me briefly mention a few other features of the new reports under ISAs.
We heard that the audit opinion is valued. So, it is now presented first. Why? Basically, users have told us: tell us first what your conclusion is, that is what we are still interested in. Then, through key audit matters, tell us how you got to that conclusion.
Going Concern – In essence not much has actually changed on this. We have listened to commentators – including from Brazil – to think more about how best to deal with this. But there is now clearer signaling when there is a going concern issue. And in the specific ISA 570 on Going Concern, there is a clearer imperative for auditors to be satisfied with management’s disclosure of their judgements around going concern, in particular in "close call" situations.
We have created a new section to clearly explain the auditor’s work effort with regards to other information and exactly what information the auditor has looked at.
And finally, among others, there is also a new requirement to name the engagement partner, which many jurisdictions globally were already doing – thus, further modernizing the international reporting model.
What We Are Hearing About the Experience
Now, here we are with the new standards, or equivalent; some already have them required for use; some others are "early birds" now reporting ahead of time. So, what are we hearing from these experiences? Basically, the effects of enhanced auditor reporting are seen as quite positive.
From the user and investor perspective: innovation in reporting is particularly welcomed. There has been praise for visually appealing reports, with information clearly signposted, and presented in a clear and logical structure. Some investors have also confirmed they are seeing some new relevance. Here, in my slides: "A valuable new source of complementary information."
Let me further illustrate -- one institutional investor from Blackrock said (I paraphrase):
It is a dramatic step forward. It helps us know what to be looking at over time. Also, without KAM, the only other validation of the audit (audit quality) was how much did the audit cost – so, a proxy for quality or of the nature and extent of underlying issues, was whether there was a significant increase in cost from the prior year. But now we can understand better.
And investors do understand the intent and scope: let me share another illustrative quote: "The auditor is telling us about the job that was done, not telling more about the financial statements."
To be fair, I think investors and others will always want even more: more detail, more insight of ‘what is not being told’, auditor assessment of conservatism or aggressiveness in reporting, etc. Nevertheless, I have heard from some investors: "Is it everything we want? No. But it is about the best we could have hoped for. And it will lead to better dialogue between investors and the finance function."
We are also hearing from some audit committees that it has been positive for the company’s corporate governance. Look at some video interviews that are being shared: in one video, an auditor and Audit Committee chair, and in another, an auditor and CFO; both sharing the floor, talking about positive experiences in moving towards improved communications about the audit.
In the UK there have even been Investor Awards for the most informative and innovative auditor’s reports. Three years ago, this was unimaginable. Now, a reality with positive effects in society!
Even more: The international audit regulators group IFIAR has said that audits become more observable for the public. And the auditors themselves? They are proud of showing the world what a great profession they have – how they have to tackle complex and at times sensitive issues.
So, we see it being approached with enthusiasm. Some experiment and have chosen to include conclusions and observations, even a reference to the auditor assessment of whether management’s judgements were "mildly optimistic." Not required, so why? Because they are writing with the audience in mind!
The Relationship: Enhanced Auditor Reporting and Audit Quality
Now, briefly, let me link to Audit Quality.
We have published our Framework for Audit Quality two years ago, and in my slides you will see the key diagram in that. One category is the inputs that go into the audit process, but these of course are not very well-observable for users, who look to the output. Then we emphasize the importance of interactions between the various stakeholders (auditors, management, those charged with governance, regulators and users) – and now with the new auditor reporting, much more output and interaction.
Some say, negatively, there will be more costs with the new auditors report because there will be more senior partner and senior executive time spent. Well, perhaps that is not a bad thing? So, we are seeing this framework being put in practice, giving context and stimulating even more focus on audit quality.
Of course, firms, preparers, audit committees all need support during this time. The IAASB has many resources available on its webpage, and over the course of the next few months will continue to develop and share guidance material.
Helpful? Well, when I spoke recently with a Board Director of one of your listed entities, she spontaneously noted that she already found two particular documents listed in my slides as highly relevant to share with her Board, specifically the "Illustrative Examples of KAM," and the publication "What Audit Committees and Finance Executives Need to Know."
Beginning of a Journey
For some, they are already on the New Reporting journey. For many others, they are soon to embark. But basically we are all facing a new reality and we must collectively share responsibility for success.
From the standard setter perspective I think there are two main responsibilities. Firstly: "Stay close, help, and share." The IAASB is very committed to this. For the first time, we have established an implementation support working group – lead by the former chair of the IAASB Auditor Reporting Task Force and the former Executive Director, Professional Standards and External Relations, to help develop guidance material. So, we want to hear about your experiences and challenges, and where you need support. We are counting on that, because we can feedback but also share so others can benefit.
Secondly: "Listen, learn, improve" – With this spirit, the IAASB is committed to undertaking a post-implementation review of the new reporting standards; not immediately but after a reasonable period of experience. We have opened auditing up, and sparked interest. Maybe more will come. Maybe what we have needs improvement. Here, we are also counting on you. Please be active, and let us know the Brazil experience by preparers, audit committees, investors, of course – from front-line auditors.
Continuing Improvements to Meet the Public Interest
So, there is now a new way for auditors to communicate what they have done. But what then about the quality of what is being done – that is, the quality of the underlying audit? The inputs, so to say.
The IAASB has done a lot to enhance audit quality with its work on Clarified ISAs, but that does not mean we can stand still. We learned from the post-implementation review of the clarified ISAs, we learned from inspection findings, we learned from all the dialogues that we have, that more can be done through the standards to help support audit quality.
We also see that the global landscape is changing, and that we need to keep seeing that ISAs remain fit for purpose. In that regard, we also see in particular the importance of the auditor having an independent and challenging skeptical mindset. Other areas of focus include challenging whether firms need to have a more proactive quality management approach, as well as actions related to transparency and monitoring and remediation. And then of course the need for reinforcing robust communication during the audit.
Each of these areas feature in the IAASB’s current strategy and work plan, which has started with a global consultation paper on enhancing audit quality. I encourage all of you to consider and discuss the issues raised in that paper.
In the end it should result and continue to result in the auditor being a very critical challenger of what he or she is confronted with. That is the profile of tomorrow’s auditor - a critical challenger, supported by a regime focused on the public interest and quality audits, all of which should be able to be better observed by stakeholders.
I have mentioned the concept of "a journey" several times. In closing, let me again come back to it, and ask "What kind of journey is it?" I must also mention the Olympics, which this summer will be great for Brazil.
So, is the journey like a 100-meter sprint? Some do feel the urgency to get to the finish line. Or is it perhaps like the 400-meter hurdles? Some would say everything worthwhile has obstacles to leap over.
Well, one of our former public interest oversight board members gave some perspective when we were developing the new Auditor Report standard. Let me paraphrase what he said: "This is a major change, in some uncharted waters. You need not have all the answer to all the possible ideas; rather, focus on a few key areas and make progress. There will be a second stage, at some future point, and it is then to see what further evolution makes sense."
So, perhaps the journey is like a marathon. Where you find the packs, set a pace, take a measured approach, continuous pulse checks, but nevertheless moving forward. For me, that is the path we are all travelling, with a broad horizon.
I also hear more and more: the auditor is stepping out the "black box." Auditors are back at the public forum, where they belong. The future relevancy of audit – would one need more proof?
Thank you for listening.