THE NEED TO CLOSE THE GAP - Between expectations and regulation is becoming clearer and more urgent - IRBA
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ISSUE 46 | APRIL - JUNE 2019
THE NEED TO CLOSE THE GAP
Between expectations and regulation is becoming clearer
and more urgent
IN THIS ISSUE: 2 From the CEO’s Desk 13 Inspections 22 Communications
4 Standards 15 Legal 23 General News
9 Ethics 17 Registry
11 Investigations 19 Education and Transformation
1 Issue 46 | April - June 2019
FROM THE CEO’S DESK
The past three months have been a significant period for the country, In a combined assurance model, an organisation relies on its
with the nation going to the polls on 8 May for the national general governance processes and structures to prevent fraud, ensure
election that led to President Cyril Ramaphosa being elected as the the accuracy of financial accounts and manage organisational
president of the republic. risk. In theory, these checks and balances allow those charged
with governance to hold management to account and ensure that
At his inauguration two-and-a-half weeks later he said: “It is a time massive fraud and corruption are not perpetrated.
for us to make the future we yearn for. It is through our actions now
that we will determine our destiny. South Africans want action and There are many safeguards that are required and ought to be there
not just words and promises – and there will be action. It is through and implemented by boards, audit committees and directors before
our actions now that we will give form to the society for which so the financial results get to the external audit stage. The external
many have fought and sacrificed, and for which all of us yearn.” auditors come into the financial reporting process as the last line of
defence to determine whether the financial statements fairly present
His promises of a clean government, an end to the culture of and comply with relevant laws.
impunity and the establishment of strong anti-corruption machinery
are needed to enable the country to arrest the misappropriation of However, how many organisations use governance and oversight
public funds in the private and public sectors and attempt to recoup as a mere checklist so they can produce financial statements? How
the losses. many give any thought to developing the spirit of good governance
throughout the organisation? It shouldn’t be an exercise, but a
The public, however, is all too aware that promises are empty if mind-set. If management and governance structures are not driven
there is no action or delivery that follows them. Consequently, by good governance thinking, businesses will continue to fail.
without action, confidence in our ability to change gets weakened.
A case in point is Steinhoff which, after a 15-month wait for the
The auditing profession has also been tainted by a string of high- forensic report into its collapse, revealed that its troubles were
profile corruption, fraud and corporate collapse cases that have precipitated by a widespread fraud perpetrated by a small group
cost the country, citizens and pensioners dearly. These include the of senior executives. It has since discovered that its options for
Gupta-linked Linkway Trading (Pty) Ltd, which first shone the light recourse against directors, board members, internal auditors
on the misappropriation of funds from state projects; the mighty and others are scant. The reality is that there is no regulation,
Steinhoff collapse under the weight of a lengthy and complex no professional regulatory oversight; therefore, there are few
management fraud; the VBS Bank collapse, as a result of executive opportunities to take action. As a result, the Steinhoff case is
looting; and now Tongaat Hulett, the 127-year-old company that a prime example for supporting the need for the comprehensive
has suspended trade in its shares due to accounting irregularities. regulation of the financial reporting eco-system.
In each case the public response has been to look to the auditors
for answers. This need was first recommended to the Minister of Finance by the
World Bank in 2013. Comprehensive regulation would lead to the
Recently, a journalist asked me whether the auditing profession has broader accounting profession and those involved in the financial
a future; adding that as the loss of confidence in the opinions of reporting chain being brought under one regulatory framework
external auditors is significant, I would have to do something about to ensure adequate oversight and accountability throughout the
it. The journalist also noted that with audit and business failures financial reporting chain.
happening almost daily, it can’t be easy.
The recommendation is not unusual. The UK’s Financial Reporting
It does seem to be a prevailing view that if the auditors were doing Council (FRC) and its Mauritius counterpart have mandates extending
their job, this fraud and corruption would not be perpetuated. to directors, audit committees, company directors, boards, financial
statements and auditors. While the FRC in Mauritius is backed by
While I stressed that not every business failure is an audit failure, it is legislation, the UK has just concluded several reviews of its FRC, the
becoming clear that auditors and the audit product must evolve to profession, audit firms and the risks of lack of market competition.
meet the expectation gap of the market. However, it is obvious that Subsequently, it has resolved that the FRC must be transformed
we also need to recognise that the financial reporting system and into an independent regulator that is supported by legislation and
corporate governance are not working as they ought to. has the powers and resources to take action.
Corporate governance seems to be a tick box exercise for many Last year, National Treasury asked the IRBA to do research into
corporate governance structures. While companies set out their other regulators and then outline a proposal for South Africa to
commitments to good governance in great detail and say that move towards a comprehensive regulation model for the broader
they comply, this appears to be merely lip service. In the words of accounting and financial reporting environment. The IRBA Board
President Ramaphosa: “South Africans want action and not just recently approved the detailed research, which will be submitted
words and promises.” to Treasury.
Issue 46 | April - June 2019 2
FROM THE CEO’S DESK cont. The fight against corruption and President Ramaphosa’s intention to turn words into action can be spurred on by regulating accountants across the financial reporting and governance eco-system. By holding all those accountable through regulatory oversight and allowing for speedy consequences for failure to execute good governance, we will be able to move from lip service to embedding a spirit of good governance at our entities – an action that is vital for Bernard Peter Agulhas business to succeed and for our economy to grow. Chief Executive Officer 3 Issue 46 | April - June 2019
STANDARDS
THE FOLLOWING TOPICS ARE DISCUSSED IN THIS The exposure drafts are:
ISSUE: • Overall Explanatory Memorandum, The IAASB’s Exposure
Drafts for Quality Management at the Firm and Engagement
• Standards: Level, Including Engagement Quality Reviews.
o Quality Management for Firms and Engagements. • Proposed International Standard on Quality Management 1,
o Risks and concerns relating to the audit of schools. Quality Management for Firms that Perform Audits or Reviews
of Financial Statements, or Other Assurance or Related
o The ISA 540 (Revised) Implementation Working Group
Services Engagements (previously ISQC 1).
Provides Implementation Support on the Revised
• Proposed International Standard on Quality Management 2,
Standard.
Engagement Quality Reviews.
o Guide for Registered Auditors: Assurance • Proposed International Standard on Auditing 220 (Revised),
Engagements on the Fresh Produce Agents’ Trust Quality Management for an Audit of Financial Statements.
Accounts.
o Revised Guide for Registered Auditors: Assurance The proposals bring important changes to the way professional
Engagements on Financial Service Providers’ accountancy firms are expected to manage quality for audits,
Separate Accounts (Section 19(3)) and Reporting reviews and other assurance and related services engagements.
Requirements (Section 19(4)) of the Financial Advisory
and Intermediary Services Act. The proposed standards include a new proactive risk-based
o Engagements on Attorneys’ Trust Accounts. approach to effective quality management systems within firms that
establishes the foundation for consistent engagement quality. The
o The IRBA issues the South African Auditing Practice
new approach improves the scalability of the standards because it
Statement (SAAPS) 3 (Revised May 2019), Illustrative
promotes a system tailored to the nature and circumstances of the
Reports.
firm and its engagements.
o Illustrative Banks Act Regulatory Auditor’s Reports.
o Reminder: IRBA seeks feedback on implementing The IAASB proposals are intended to improve engagement quality
SAAEPS 1. through:
o Exposure Draft: Proposed Revised Guide for • Modernising the standards for an evolving and increasingly
Registered Auditors: Auditing in the Public Sector. complex environment, including addressing the impact of
o Audits of Less Complex Entities: Furthering the Debate technology, networks and use of external service providers;
on Applying the ISAs in Audits of Less Complex • Increasing firm leadership responsibilities and accountability,
Entities. and improving firm governance;
• More rigorous monitoring of quality management systems and
o IAASB projects in progress.
remediating deficiencies;
• Ethics: • Enhancing the engagement partner’s responsibility for audit
o IRBA Rules Regarding Improper Conduct (Revised engagement leadership and audit quality; and
2019). • Addressing the robustness of engagement quality reviews,
o Final Amendments to the IRBA Code of Professional including engagement selection, documentation and
Conduct for Registered Auditors in respect of Second performance.
Opinions.
o Implementation Support Resources relating to the Given the significance of the changes and the need for firms to
IRBA Code of Professional Conduct for Registered adjust how they manage quality, the IAASB has also developed
Auditors (Revised November 2018). draft guidance and tools, such as examples and frequently asked
questions. These resources will help firms understand the proposals,
o IESBA Proposes Revisions to Part 4B of the Code
including how to apply them in different circumstances.
to Reflect Terms and Concepts Used in ISAE 3000
(Revised).
Audit firms are urged to begin preparations for the transition to the
o IESBA projects in progress. new quality management system, well before the expected effective
dates.
QUALITY MANAGEMENT FOR FIRMS AND
ENGAGEMENTS Copies of the exposure drafts are available in PDF format and
may be downloaded from the exposure drafts page on the IRBA
Registered auditors (auditors) are reminded that the International website.
Auditing and Assurance Standards Board (IAASB) recently issued
on exposure three interrelated standards that address quality
management, with the comment period closing on 1 July 2019.
Issue 46 | April - June 2019 4
STANDARDS cont.
RISKS AND CONCERNS RELATING TO THE AUDIT A project page, ISA 540 (Revised) Implementation, has been
OF SCHOOLS added to the IAASB website as a repository for such implementation
support. It contains links to useful materials and will continue to be
updated.
The Minister of Basic Education recently contacted the IRBA
regarding risks and concerns relating to the audits of schools. The
Please continue to visit the ISA 540 (Revised) Implementation
following concerns have been identified:
project page to check if any new implementation support has been
• Persons holding themselves out to be auditors are not issued by the Working Group.
registered auditors.
• The auditor is performing bookkeeping, accounting, preparation Guide for Registered Auditors: Assurance
of the financial statements and auditing, in other words, the Engagements on the Fresh Produce Agents’ Trust
auditor is not independent. Accounts
• The financial statements are not prepared in accordance with a
recognised accounting framework. The CFAS approved the release of the Guide for Registered
• The audit is not performed in compliance with International Auditors: Assurance Engagements on the Fresh Produce Agents’
Standards on Auditing. Trust Accounts (this Guide) in May 2019 for issue.
• Material misstatements are often not detected, meaning the
The guidance relates to understanding the nature and characteristics
audit opinion is incorrect.
of an agricultural produce agent, and the nature and extent of
• Alleged collusion between principals of schools, school
assurance work on the engagement. As a consequence, this Guide
governing bodies and auditors.
emphasises professional competence and professional scepticism.
• Tender corruption (accountants/auditors appointed to schools
without the proper tender process being followed).
This Guide provides certain practical guidance to be considered
• Poor audit quality.
in developing audit programmes. It, however, does not override
• Perceived lack of integrity on the part of auditors.
the requirements of the International Standards on Assurance
Engagements (ISAEs), nor does it purport to deal with all special
The Department of Basic Education has indicated that auditors who
considerations that may be relevant in the circumstances of the
are suspected of any transgressions will be referred to the IRBA for
engagement. As such, it should not be regarded as a checklist.
investigation.
This Guide is authoritative and includes:
Auditors are reminded that they should comply with the IRBA Code
of Professional Conduct and apply the International Standards on • Guidance to a registered auditor on conducting an assurance
Auditing when performing audits of schools. engagement in accordance with ISAE 3000 (Revised),
Assurance Engagements Other than Audits or Reviews of
Historical Financial Information, on a fresh produce agents’
COMMITTEE FOR AUDITING STANDARDS (CFAS)
trust accounts in terms of the Agricultural Produce Agents Act
12 of 1992;
The ISA 540 (Revised) Implementation Working Group • An illustrative engagement letter and representation letter; and
Provides Implementation Support on the Revised • Illustrative interim and annual auditor’s reports based on ISAE
Standard 3000 (Revised).
As previously communicated by the IRBA on 8 November 2018:
The abovementioned ISAE is effective for assurance reports dated
• The International Auditing and Assurance Standards Board
on or after 15 December 2015.
(IAASB) issued the International Standard on Auditing (ISA)
540 (Revised), Auditing Accounting Estimates and Related
Effective Date
Disclosures, on 3 October 2018.
• At its meeting on 6 November 2018, the IRBA Board approved This Guide is effective for assurance engagements on trust accounts
ISA 540 (Revised) for adoption, issue and prescription for use of financial year-ends ending on or after 31 December 2020. Early
by auditors in South Africa. adoption is permitted.
ISA 540 (Revised) becomes effective for financial statement audits Also, this Guide is available in PDF and Word formats, and may be
for periods beginning on or after 15 December 2019. Early adoption downloaded from the IRBA website.
of ISA 540 (Revised) is permissible and is encouraged by the IRBA.
ISA 540 (Revised) may be downloaded from the IRBA website.
This communique also noted that the IAASB will provide
implementation support to help auditors navigate and apply the
revised standard.
5 Issue 46 | April - June 2019
STANDARDS cont.
Revised Guide for Registered Auditors: Assurance It is likely that the proposed Revised Guide will be issued on
Engagements on Financial Service Providers’ exposure during the latter part of this year.
Separate Accounts (Section 19(3)) and Reporting
Requirements (Section 19(4)) of the Financial Advisory
CFAS REGULATED INDUSTRIES AND REPORTS
and Intermediary Services Act
STANDING COMMITTEE (RIRSC)
The CFAS, at its meeting on 28 May 2019, approved the issue of the
Revised Guide for Registered Auditors: Assurance Engagements on The IRBA Issues the South African Auditing Practice
Financial Service Providers’ Separate Accounts (Section 19(3)) and Statement (SAAPS) 3 (Revised May 2019), Illustrative
Reporting Requirements (Section 19(4)) of the Financial Advisory Reports
and Intermediary Services Act (this Revised Guide) for use by The CFAS approved the issue of the South African Auditing Practice
auditors. Statement (SAAPS) 3 (Revised May 2019), Illustrative Reports,
(SAAPS 3 (Revised May 2019)) for use by auditors in May 2019.
This Revised Guide provides guidance to auditors on various
matters relating to the audit, limited assurance engagement and SAAPS 3 (Revised May 2019) is aimed at providing practical
other reporting obligations for authorised financial services providers guidance to auditors who report on financial statements, both for
(Providers), in compliance with the requirements of the Financial compliance with the International Standards on Auditing (ISAs) or
Advisory and Intermediary Services Act, 2002 (Act No. 37 of 2002) the International Standards on Review Engagements (ISREs), as
as amended (the Act), and its subordinate legislation. applicable, and the legal and regulatory requirements applicable
to auditors and auditor reporting in South Africa, as related to the
The purpose of this Revised Guide is to provide assistance to content and format of the auditor’s report. For the purpose of SAAPS
auditors of Providers with respect to the auditor’s responsibilities: 3 (Revised May 2019), the main legal and regulatory requirements
• To report to the Provider in terms of Section 19(3) of the Act; addressed are the Auditing Profession Act, 2005 (No. 26 of 2005)
• To report to the Financial Sector Conduct Authority in terms of (the APA); the Rule in terms of Sections 9 and 10, read with Sections
Section 19(4) of the Act; and 1, 2 and 3 of the APA, published in Government Gazette No. 39475
• Relating to his/her other reporting obligations. on 4 December 2015; the Companies Act, 2008 (Act No. 71 of
2008); and the Public Audit Act, 2004 (Act No. 25 of 2004).
This Revised Guide has been updated for the following:
• Clarifying that the limited assurance engagement (Section SAAPS 3 (Revised May 2019) has been updated as a result of
19(3)) is conducted in accordance with ISAE 3000 (Revised), the amendments to the International Ethics Standards Board for
Assurance Engagements Other than Audits or Reviews of Accountants (IESBA) Code of Ethics for Professional Accountants
Historical Financial Information; (now the IESBA International Code of Ethics for Professional
• Changes to legislation and the IRBA Code of Professional Accountants (including International Independence Standards)
Conduct for Registered Auditors (Revised November 2018); (IESBA Code)) and the amendments to the IRBA Code of
• Assurance related guidance in this regard; and Professional Conduct for Registered Auditors (now the IRBA Code
• The auditor’s other reporting responsibilities. of Professional Conduct for Registered Auditors (Revised November
2018) (IRBA Code)). Due to the different effective dates of the parts
Effective Date in both the IRBA Code and the IESBA Code, SAAPS 3 (Revised
May 2019) makes provision for two options in the illustrative
This Revised Guide is effective for engagements commencing on or auditor’s reports where references are made to the Codes, and
after 1 July 2019. Early adoption is permitted. clearly distinguishes between the two options as follows:
• Transitional period: Auditors who sign off auditor’s reports
It is available for downloading in both PDF and Word formats from issued on or after 15 June 2019 in respect of the audits for
the IRBA website. financial periods beginning before or on 14 June 2019; and
• Periods going forward: Auditors who sign off auditor’s reports
Engagements on Attorneys’ Trust Accounts for audits of financial statements for periods beginning on or
Work is progressing on the revision of the Revised Guide for after 15 June 2019.
Registered Auditors: Engagements on Attorneys’ Trust Accounts
(the proposed Revised Guide). In addition, SAAPS 3 (Revised May 2019) has been updated to:
• Incorporate the guidance contained in the IRBA Staff Audit
The proposed Revised Guide will be updated for: Practice Alert: Determining Other Information as Defined in
• The Legal Practice Act, No. 28 of 2014 (LPA) that replaced the ISA 720 (Revised) in the South African Context. As a result,
Attorneys Act 53 of 1979 in its entirety; the IRBA will withdraw the Staff Audit Practice Alert as at the
• The South African Legal Practice Council Rules made under effective date of SAAPS 3 (Revised May 2019).
the authority of Sections 95(1), 95(3) and 109(2) of the LPA that • Recognise that, in the public sector environment, other
replaced the Uniform Rules; and information does not include those selected objectives
• Other issues identified by the Task Group. presented in the annual performance report that have been
Issue 46 | April - June 2019 6
STANDARDS cont.
specifically audited and reported on in the auditor’s report. Background
The CFAS approved the issuing of SAAEPS 1 in August 2018 for
The format of SAAPS 3 (Revised May 2019) has also been updated
use by practitioners.
to enhance navigation and use.
SAAEPS 1 is aimed at providing practical assistance to practitioners
Effective Date on certain preconditions that need to be present when requested
SAAPS 3 (Revised May 2019) is effective for auditors’ or independent to accept a sustainability assurance engagement in accordance
reviewers’ reports issued on or after 15 June 2019. with the requirements of the International Standards on Assurance
Engagements (ISAE) 3000 (Revised), Assurance Engagements
It is available for downloading in both PDF and Word formats Other than Audits or Reviews of Historical Financial Information. The
from the IRBA website. characteristics dealt with in SAAEPS 1 are whether the sustainability
assurance engagement exhibits:
Illustrative Banks Act Regulatory Auditor’s Reports • A rational purpose;
• That the underlying subject matter is appropriate; and
The CFAS approved the issue of the following illustrative Banks Act
• That the criteria that the practitioner expects to be applied in
regulatory auditor’s reports on the Banks Act Returns (illustrative
the preparation of the subject matter information are suitable
regulatory reports) for use by auditors for banks with year-ends on
for the engagement circumstances.
or after 28 February 2019:
• The revised Illustrative Macro-Prudential Foreign Exposure
The preparation of appropriate engagement documentation is
Limit Return (MPL) reports;
emphasised.
• The new Illustrative Mutual Banks Act (MBA) reports; and
• The new Illustrative BA 501 report.
The guidance is supplemented by a series of questions that the
practitioner may ask. After receiving feedback from the reporting
In terms of Regulation 46 of the Banks Act (No. 94 of 1990), the
entity, the practitioner may consider the responses collectively
external auditor of a bank is required to report to the Prudential
to determine whether the sustainability assurance engagement
Authority at the South African Reserve Bank (specifically to the
exhibits the characteristics set out in the objective paragraph of
Prudential Authority and the Financial Surveillance Department) on
SAAEPS 1.
various regulatory matters.
Effective Date
Furthermore, in terms of Regulation 46(6) of the Banks Act, these
illustrative reports have been rendered in accordance with the SAAEPS 1 is effective for the Acceptance and Continuance
wording and practices that the Prudential Authority, the South – Preconditions for the Assurance Engagement phase of the
African Institute of Chartered Accountants and the IRBA agree to sustainability assurance engagement for reporting periods beginning
from time to time. on or after 15 December 2020. Early adoption is permitted.
These illustrative reports are available in both PDF and Word formats Two years were provided to allow time for practitioners to prepare for
and may be downloaded from the IRBA website. and implement the guidance, receive training and provide feedback
to the IRBA on any implementation lessons. This timeframe also
allowed for preparers of sustainability reports to receive training on
CFAS SUSTAINABILITY STANDING COMMITTEE the content of SAAEPS 1, as it relates to them.
(SSC)
Feedback on Implementing SAAEPS 1
Reminder: IRBA Seeks Feedback on Implementing
SAAEPS 1 Should you have any comments on implementing SAAEPS 1, please
contact the Standards Department by email at standards@irba.co.za.
The above titled communique was issued by the IRBA during
Please provide your feedback by 15 December 2019.
June 2019, reminding interested parties to provide feedback on
the implementation of the South African Assurance Engagements
To assist you with providing feedback on implementing SAAEPS
Practice Statement (SAAEPS) 1, Sustainability Assurance
1, the communique contains a set of four questions that you may
Engagements: Rational Purpose, Appropriateness of Underlying
consider answering in providing your feedback.
Subject Matter and Suitability of Criteria (SAAEPS 1).
7 Issue 46 | April - June 2019
STANDARDS cont.
CFAS PUBLIC SECTOR STANDING COMMITTEE Auditing (ISAs) in audits of less complex entities and the views
(PSSC) about possible actions to address those challenges.
Exposure Draft: Proposed Revised Guide for Registered The IAASB recognises the global call for action to address issues of
Auditors: Auditing in the Public Sector complexity, length, understandability, scalability and proportionality
in relation to using the ISAs. Continuing the debate on these
The CFAS approved the release of the Proposed Revised Guide for
strategic issues, the Discussion Paper explores how the IAASB,
Registered Auditors: Auditing in the Public Sector (this proposed
and others, could further support auditors working in increasingly
Revised Guide) in March 2019 for exposure for public comment until
evolving environments. The South African landscape for the
7 June 2019. The exposure draft is available on the IRBA website.
audit of companies is influenced by the role of the so-called “PIS
score”. However, audits are also mandated for entities other than
This proposed Revised Guide helps to improve the understanding
companies, which may differ vastly in complexity. This Discussion
and enhance the performance of quality public sector audits by
Paper, therefore, is relevant to regulators, preparers, those charged
registered auditors in public practice (registered with the IRBA),
with governance, other stakeholders and auditors across a wide
who are contracted by the Auditor-General South Africa (AGSA) or
range of industries.
appointed as auditors of public institutions where the AGSA has
opted not to perform the audit, in accordance with Section 4(3) and
Request for Comments
4(3A) of the Public Audit Act, 2004 (Act No. 25 of 2004) (PAA).
The IRBA welcomes comments regarding the Discussion Paper
Section 12(3)(a) of the PAA requires the AGSA to determine “the for consideration, as we prepare our response to the IAASB.
minimum qualifications, experience and competence for authorised Comments should be submitted by 29 August 2019 via email to
auditors”. Auditors performing public sector engagements need to standards@irba.co.za in Word and PDF formats. All comments will
ensure that they have the professional competence to perform such be considered as a public record.
audit engagements, in accordance with the applicable professional
standards, additional extensive legal and regulatory requirements as Alternatively, we invite registered auditors and other interested parties
well as the unique circumstances of the public sector. The guidance to submit comments directly to the IAASB via the IAASB website
herein is intended to assist auditors to meet these requirements. by 12 September 2019. Respondents are asked to submit their
comments electronically (as both PDF and Word files).
This proposed Revised Guide has been updated for the following:
• Changes made to the AGSA’s audit methodology; Copies of the exposure draft are available in PDF format and may be
• Guidance on how political governance structures in the public downloaded from the exposure drafts page on the IRBA website.
sector should be dealt with;
• Expanding/enhancing the sections dealing with legislation, IAASB Projects in Progress
guidance and key stakeholders/role players in the public sector;
• Technology
• A new section on the role and powers of the Auditor-General;
o IAASB’s Technology Working Group issued Tech Talk:
• Changes to the financial reporting frameworks applicable to
Technology and the Future Ready Auditor in May 2019.
the public sector;
The publication is available on the IAASB website.
• Enhancing referencing to the International Standards of
• Quality management at firm level (ISQM 1).
Supreme Audit Institutions (ISSAIs); and
• Engagement quality review (ISQM 2).
• Amendments arising from the revision of the PAA.
• Quality management at engagement level (ISA 220).
The PSSC is considering and will thereafter prepare responses to • Group audits (ISA 600).
the comment letters received. The final proposed Revised Guide • Agreed-upon procedures engagements (ISRS 4400).
will be presented to the CFAS in August 2019 for its review and • Extended external reporting (EER) assurance.
approval to issue as final. • Audits of less complex entities (LCE).
• Professional scepticism.
• Auditor risk assessments (ISA 315 (Revised)).
INTERNATIONAL AUDIT AND ASSURANCE • Audit evidence.
STANDARDS BOARD (IAASB)
More information on these projects is available on the IAASB website.
Audits of Less Complex Entities: Furthering the Debate
on Applying the ISAs in Audits of Less Complex Entities
The IAASB has published a Discussion Paper, Audits of Less
Complex Entities: Exploring Possible Options to Address the
Challenges in Applying the International Standards on Auditing
(ISAs). Through the Discussion Paper, the IAASB seeks to further
understand the challenges of using International Standards on
Issue 46 | April - June 2019 8ETHICS
Final Amendments to the IRBA Code of Professional
COMMITTEE FOR AUDITOR ETHICS (CFAE)
Conduct for Registered Auditors in respect of Second
IRBA Rules Regarding Improper Conduct (Revised Opinions
2019) The IRBA approved and issued changes to the IRBA Code of
The IRBA approved and issued changes to the IRBA Rules Professional Conduct for Registered Auditors (Revised November
Regarding Improper Conduct (IRBA Rules) (Revised 2019). 2018) (IRBA Code) in respect of Second Opinions in June 2019.
It adopted these amendments following their issue on exposure for It adopted these local amendments following their issue on
public comment in Government Gazette No. 42304 on 15 March exposure for public comment via Government Gazette No. 42092
2019 (Board Notice No. 30 of 2019). on 7 December 2018 (Board Notice No.179 of 2018).
Changes in Substance Changes in Substance
The IRBA Rules (Revised 2019), which regulate the conduct of an Amendments to the IRBA Code Section 321 include the following:
investigation and the disciplinary process, were revised due to the • Incorporate practical and relevant guidance from Circular
following reasons: 01/2006, Giving Second Opinions (the Circular), issued in
November 2006 by the Committee for Auditing Standards;
• Recent IRBA disciplinary hearings have brought to light the
• Align the guidance, where applicable, with South African
need for potential improvements in the wording of certain IRBA
amendments made elsewhere in the IRBA Code;
Rules.
• Further strengthen the guidance by elevating certain application
• Certain IRBA Rules are outdated or no longer required.
material to a requirement paragraph; and
• The IRBA Rules required certain alignment amendments in light
• Include additional safeguards mentioned in other Sections of
of the release of the IRBA Code (Revised November 2018).
the IRBA Code that might be relevant in addressing a possible
• The APA, as amended in 2015, included the regulation of
self-interest threat when an auditor is engaged to provide a
registered candidate auditors. An update to the IRBA Rules
second opinion.
was required to consider the potential investigation of these
individuals.
Effective Date
Auditors need to note that the deletion of certain IRBA Rules To facilitate the implementation of the amendments to the IRBA
should not be read as a condonation of that conduct. Rather, Code, including their impact on the investigations and disciplinary
these deletions are due to changes in laws and regulations, or the functions of the IRBA, the amendments will be effective for
particular conduct is covered by the conceptual framework in the engagements commencing on or after 15 January 2020.
IRBA Code (Revised November 2018).
A Board Notice will be published in the Government Gazette,
Effective Date advising on the publication of the amendments to the IRBA Code
pursuant to the provisions of Section 10(1)(a) of the APA.
The IRBA Rules (Revised 2019) repeal and replace the IRBA Rules
Regarding Improper Conduct issued in June 2010, referred to in
The amendments to the IRBA Code may be downloaded from the
Section 10(1) read with Section 21(2) of the APA.
IRBA website.
The IRBA Rules (Revised 2019) have been prescribed by the Board
under Section 4(1)(c) with effect from 1 January 2020. IMPLEMENTATION SUPPORT RESOURCES
RELATING TO THE IRBA CODE OF PROFESSIONAL
Until the effective date of the IRBA Rules (Revised 2019), as CONDUCT FOR REGISTERED AUDITORS (REVISED
mentioned above, the IRBA Rules Regarding Improper Conduct NOVEMBER 2018)
issued in June 2010 and effective from 1 January 2011 will remain
in force. Daily Reminders
The IRBA has been running a 30-day daily reminder series to
A Board Notice will be published in the Government Gazette,
assist auditors to become familiar with the new IRBA Code. These
advising of the publication of the amendments to the IRBA Rules
daily alerts are available free of charge to all interested parties that
pursuant to the provisions of Section 10(1)(a) of the APA.
subscribed.
The IRBA Rules (Revised 2019) may be downloaded from the
At the end of the series, the 30 daily reminders will be made available
IRBA website.
on the IRBA website.
9 Issue 46 | April - June 2019ETHICS cont.
SAICA/IRBA Workshop The IRBA Code of Professional Conduct for Registered Auditors
The South African Institute of Chartered Accountants (SAICA) and (Revised November 2018) (IRBA Code) adopted the IESBA Code,
the IRBA held an Ethics Workshop on the IRBA Code on 3 April 2019. issued during 2018, following the issue of proposed amendments
The recording of this interactive workshop as well as the handouts on exposure in South Africa, together with South African
are available on the SAICA website. To access these, follow these enhancements. All amendments to the IRBA Code are in line with
steps: Login on the SAICA website >Membership >Click2start the IESBA Code. It is expected that these amendments will be
>Click here to go to online training >Elearning platform >webinars incorporated in the IRBA Code.
>Ethics >2019 Code of Professional Conduct for auditors’ seminar.
In accordance with the provisions of Section 10(1)(a) of the APA,
IESBA Webinar the IRBA may, by notice in the Government Gazette and pursuant
to the provisions of Section 4(1)(c) of the Act, publish, for public
The International Ethics Standards Board for Accountants (IESBA) information and comment, an amendment to the IRBA Code.
held two webinars that included an introduction to the substantive Accordingly, a Board Notice to the same effect will be published in
revisions to the International Code of Ethics for Professional the Government Gazette for public comment for a minimum period
Accountants (including International Independence Standards) of 30 days.
(IESBA Code).
Comments to the IESBA closed on 26 June 2019.
The IRBA Code adopted the amendments made to the IESBA
Code, issued during 2018, following the issue of proposed IESBA Projects in Progress
amendments on exposure in South Africa, together with South
• Non-assurance services.
African enhancements. All amendments to the IRBA Code are in
• Fees.
line with the IESBA Code.
• Role and mind-set expected of professional accountants
For a recording of the IESBA webinar, click here. (formerly professional scepticism).
• Technology.
• E-Code.
INTERNATIONAL ETHICS STANDARDS BOARD FOR
ACCOUNTANTS (IESBA) More information on these projects is available on the IESBA website.
IESBA Proposes Revisions to Part 4B of the Code Should you have any further queries, please email standards@irba.
to Reflect Terms and Concepts Used in ISAE 3000 co.za.
(Revised)
The IESBA released for public comment the Exposure Draft,
Proposed Revisions to Part 4B of the Code to Reflect Terms and
Concepts Used in ISAE 3000 (Revised), on 27 March 2019.
This exposure draft proposed revisions to Part 4B, Independence
for Assurance Engagements Other than Audit and Review
Engagements, of the revised and restructured International Code Imran Vanker
of Ethics for Professional Accountants (including International Director Standards
Independence Standards) (IESBA Code) to reflect terms and
concepts used in International Standard on Assurance Engagements Telephone: (087) 940-8838
(ISAE) 3000 (Revised), Assurance Engagements other than Audits Fax: (086) 575-6535
or Reviews of Historical Financial Information.
E-mail: standards@irba.co.za
The proposals in the Exposure Draft include:
• Changes in key terminology, including a revised definition of the
term “assurance client”;
• Enhanced and clarified independence requirements for
attestation engagements;
• Clarification of the types of assurance engagement addressed
in Part 4B; and
• Simplified guidance on assurance engagements that refers
to the definitive source of explanatory material on such
engagements in IAASB literature.
Issue 46 | April - June 2019 10INVESTIGATIONS
INVESTIGATING COMMITTEE The respondent was sentenced to a fine of R80 000, of which
R40 000 has been suspended for three years, on condition that
the respondent is not found guilty of unprofessional conduct
The Investigating Committee met once during this period and
relating to work done during the period of suspension; no cost
referred 22 matters to the Disciplinary Advisory Committee with
order; and publication by the IRBA in general terms.
recommendations.
Matter 4
DISCIPLINARY ADVISORY COMMITTEE The matter was a referral from the Inspections Committee. A
consultant of the audit firm prepared the client’s annual financial
The Disciplinary Advisory Committee met once during this period statements while the firm was engaged to perform the audit.
and concluded on 14 matters. Furthermore, the network firm of the audit firm was appointed as
the company secretary of the company for the same period that
Decisions not to charge the respondent was engaged to perform the audit of the annual
Two matters in terms of Disciplinary Rule 3.5.1.1 – the respondent financial statements of the company. As a result, the respondent
was not guilty of improper conduct. breached Section 90(2) of the Companies Act.
Two matters in terms of Disciplinary Rule 3.5.1.2 – there is a The respondent was sentenced to a fine of R80 000, of which R40 000
reasonable explanation for the respondent’s conduct. has been suspended for three years, on condition that the respondent
is not found guilty of unprofessional conduct relating to work done
Decisions to charge and matters finalised by consent during the period of suspension; no cost order; and publication by the
order IRBA in general terms.
Ten matters were finalised by consent order. Matter 5
The matter was a referral from the Inspections Committee. The
Matter 1 respondent failed to obtain sufficient appropriate audit evidence
Mr Paul Richard Badrick, the respondent, failed to identify material regarding property, plant and equipment. Land was revalued, which
misstatements in the financial statements, which resulted in restated resulted in a contravention of the International Financial Reporting
financial statements in the subsequent year. As a result, the audit Standard for Small and Medium-sized Entities. As a result, the
opinion issued by the respondent was inappropriate. respondent issued an inappropriate audit opinion. Furthermore, the
respondent onward invoiced the company for the preparation of the
The respondent was sentenced to a fine of R150 000, of which financial statements.
R75 000 has been suspended for three years, on condition that the
respondent is not found guilty of unprofessional conduct relating The respondent was sentenced to a fine of R80 000, of which R40 000
to work done during the period of suspension; no cost order; and has been suspended for three years, on condition that the respondent
publication by the IRBA of the respondent’s name, the findings of is not found guilty of unprofessional conduct relating to work done
the investigation and the sanction imposed. during the period of suspension; no cost order; and publication by the
IRBA in general terms.
Matter 2
Ms Serena Ho, the respondent, failed to identify material Matter 6
misstatements in the financial statements, which resulted in restated The matter was a referral from the Inspections Committee. The
financial statements in the subsequent year. As a result, the audit respondent’s working papers reflected missing documents relating
opinion issued by the respondent was inappropriate. to the occurrence assertion for revenue, constituting a scope
limitation. Furthermore, the respondent tested an insufficient
The respondent was sentenced to a fine of R150 000, of which sample size of source documents for the completeness assertion
R75 000, has been suspended for three years, on condition that for revenue. In addition, the respondent did not modify the audit
the respondent is not found guilty of unprofessional conduct relating opinion due to a limitation of scope as revenue was not tested
to work done during the period of suspension; no cost order; and sufficiently and appropriately.
publication by the IRBA of the respondent’s name, the findings of
the investigation and the sanction imposed. The respondent was sentenced to a fine of R80 000, of which R40 000
has been suspended for three years, on condition that the respondent
Matter 3 is not found guilty of unprofessional conduct relating to work done
The matter was a referral from the Inspections Committee. A during the period of suspension; no cost order; and publication by the
manager of the audit firm prepared the client’s annual financial IRBA in general terms.
statements while the firm was engaged to perform the audit. As a
result, the respondent breached Section 90(2) of the Companies
Act.
11 Issue 46 | April - June 2019INVESTIGATIONS cont.
Matter 7 The respondent was sentenced to a fine of R150 000, of which
The matter was a referral from the Inspections Committee. The R75 000 has been suspended for five years, on condition that the
respondent did not have policies and procedures in place that respondent is not found guilty of unprofessional conduct relating
complied with the International Standard on Quality Control 1 to work done during the period of suspension; no cost order; and
regarding certain ethical requirements, client acceptance and publication by the IRBA in general terms. In addition, the respondent
continuance procedures, human resource procedures, and must arrange and ensure that external training on the practical
engagement performance procedures. application of auditing standards is attended by the respondent and
their audit staff within 60 days of the imposition of the sentence, and
The respondent was sentenced to a fine of R100 000, of which must provide evidence of compliance to the IRBA.
R50 000 has been suspended for five years, on condition that the
respondent is not found guilty of unprofessional conduct relating Decision to charge and matters referred for a
to work done during the period of suspension; no cost order; disciplinary hearing
and publication by the IRBA in general terms. In addition, the
No matter was referred to the Legal Department for a disciplinary
respondent must arrange and ensure that external training on the
hearing.
implementation of the International Standard on Quality Control 1
is attended by the respondent and their audit staff within 60 days
of the imposition of the sentence, and must provide evidence of REGISTERED AUDITORS NEED TO CHECK THE
compliance to the IRBA. CIPC RECORDS
A previous practice existed whereby auditors agreed to be
Matter 8
registered as the auditor of “shelf” companies. While their intention
The respondent failed to modify the audit opinion on the financial
may have been for the person who purchased the “shelf” company
statements in respect of the inability to obtain sufficient appropriate
to then select an auditor of their choice and ask the previous auditor
audit evidence on certain aspects of the financial statements.
to resign, this did not often occur in practice.
The respondent was sentenced to a fine of R50 000, of which R25 000
It is critical that auditors are aware of the companies of which they
has been suspended for three years, on condition that the respondent
are the auditors, as per the Companies and Intellectual Property
is not found guilty of unprofessional conduct relating to work done
Commission (CIPC) records. If the CIPC records do not correlate
during the period of suspension; no cost order; and publication by the
with the auditors’ client listing, the auditor must follow the process
IRBA in general terms.
required by the CIPC to correct the discrepancies.
Matter 9
The respondent did not apply due care and skill while issuing share
certificates. Furthermore, the respondent’s firm issued an audit
report without performing an audit. As a result, an inappropriate
audit opinion was issued on the company.
The respondent was sentenced to a fine of R100 000, of which
R50 000 has been suspended for five years, on condition that the Jillian Bailey
respondent is not found guilty of unprofessional conduct relating
Director Investigations
to work done during the period of suspension; no cost order; and
publication by the IRBA in general terms. In addition, the respondent Telephone: (087) 940-8800
must arrange and ensure that external training on the practical E-mail: investigations@irba.co.za
application of auditing standards is attended by the respondent and
their audit staff within 60 days of the imposition of the sentence, and
must provide evidence of compliance to the IRBA.
Matter 10
The matter was a referral from the Inspections Committee. The
respondent did not document sufficient appropriate evidence
regarding risk assessment, response and sampling. Furthermore, the
respondent did not adequately evaluate the accounting framework
that was applicable to the client. In addition, the engagement team
did not design and perform audit procedures that were appropriate
for the purpose of obtaining sufficient appropriate audit evidence
on certain items.
Issue 46 | April - June 2019 12INSPECTIONS
THE TOP ENGAGEMENT INSPECTIONS THEMES 3. Completion of the assembly of final engagement files
Many instances were identified and reported where
Deliberations at the IRBA Inspections Committee meeting held in the engagement files selected for inspection were not
May 2019 highlighted the top five engagement inspections themes assembled in accordance with the prescribed time limits
for the quarter, and these are briefly discussed below. Some of of the audit firm’s policies and procedures; ISQC 1,
the themes are emerging while others are regrettably recurring. paragraph 45 (application paragraph 54); and ISA 230,
Individual auditors and those responsible for firm quality control are paragraph 14.
urged to proactively address these themes on their audits.
Furthermore, there were ongoing instances where the
IRBA identified modifications to the audit file after the
1. Documenting sufficient appropriate audit evidence and
auditor’s report had already been signed off, or after the
procedures on the audit file
file assembly period had passed. However, there was no
Following numerous public communications and inspection documented audit evidence on the audit file to support
reports issued to auditors over the past years, the IRBA the modification, as required by ISA 230, paragraphs
continues to identify and report deficiencies related to no 13 and 16. This cast significant doubt on the integrity of
or poor documentation of sufficient appropriate evidence the audit file and the firm. Such practice undermines the
on the audit file (International Standard on Auditing (ISA) effectiveness of the IRBA’s inspection process and poses
230, paragraphs 8 and 9). In the absence of sufficient a significant risk to the public due to the actual quality of
and appropriate audit evidence documented on the audit the audit being obscured.
file, the IRBA is limited in its ability to understand and
There were also still modifications made to selected audit
assess the nature, timing, extent and results of the audit
files in connection with an inspection, which is seen in a
procedures that would have detected misstatements; and
very serious light and may result in a disciplinary referral.
to understand and assess professional judgments made
by the engagement team in reaching conclusions.
4. Statement of cash flows
As sufficient and appropriate documented audit evidence
Numerous reportable deficiencies that relate to the
on the archived audit file is the only acceptable proof
inclusion of non-cash flow items in the statement of cash
that the relevant audit work was performed and the audit
flows were identified and reported. It was further noted
evidence existed and had been considered at the time of
that audit files contained insufficient audit procedures and
the audit opinion, the IRBA applies the principle of “if it is
evidence supporting the classification of cash flows as
not documented, it is deemed not done”.
either operating, investing or financing activities.
This is a recurring inspections theme that requires much
closer attention from auditors as it underpins most 5. Reliance on information systems
deficiencies reported by the IRBA.
The IRBA continues to identify and report deficiencies
Auditors are referred to the “How a lack of documented where engagement teams placed undue reliance on
evidence can trip you up” information session held in reports obtained from the auditee’s information systems,
June 2018. The slide presentation is available on the without performing either appropriate tests on the
IRBA website. information system or alternative procedures to verify the
completeness and the accuracy of such reports (ISA 500,
2. Fraud risk related to revenue recognition paragraph 9).
The IRBA continues to identify and report deficiencies
on inappropriately documented risk assessments The IRBA urges all stakeholders to take cognisance of the above themes
related to revenue recognition (ISA 240, paragraph 26). and to note that the list discussed here is not exhaustive. We encourage
These reportable deficiencies include the inadequate stakeholders to analyse our previous Public Inspections reports for
documentation related to the rebuttal of the presumed risk a more comprehensive summary of the themes, most of which are
of fraud in revenue recognition (ISA 240, paragraph 47) recurring. Stakeholders are also referred to the latest Inspections Findings
to enable the IRBA to understand and assess the basis Survey Report issued by the International Forum of Independent Audit
of the rebuttal and arrive at the same conclusion as the Regulators (IFIAR), as seen below.
engagement team. Auditors are encouraged to consider
the information contained in the SAICA Frequently Asked IFIAR SURVEY OF AUDIT INSPECTION FINDINGS
Questions (FAQs): Application of the requirements of the
ISAs in relation to matters arising from monitoring findings In May 2019 IFIAR released a report on the results of its seventh
and other in-practice challenges. annual survey of inspection findings arising from its member
The FAQs document is available on the SAICA website. regulators’ individual inspections of audit firms affiliated with the six
largest global audit firm networks. It collected information about two
categories of activities: inspections performed on firm-wide systems
of quality control and inspections of individual audit engagements.
13 Issue 46 | April - June 2019INSPECTIONS cont.
IFIAR members reported in the 2018 survey that 37% of audit To augment the survey’s information about inspection findings, in
engagements inspected had at least one finding, compared to 40% the 2018 survey IFIAR collected information about its members’
in the 2017 survey and to 47% in the first survey capturing this practices with respect to reporting the results of inspections to
percentage (2014 survey). While the downward trend is encouraging, the inspected audit firms, audit committees/those charged with
the recurrence and level of findings reflected in the survey indicate governance and the public. The 2018 survey also includes data
a lack of consistency in the execution of high-quality audits and the about certain initiatives, beyond inspections, pursued by IFIAR
need for a sustained focus on continuing improvement. members individually that are designed to contribute to improving
audit quality. Forty-five IFIAR members contributed to the 2018
The survey results do not measure precisely – and are not the survey.
sole factor when considering developments in – firms’ progress in
improving audit quality. Members’ inspection processes follow a
risk-based methodology and are not necessarily intended to select
a representative sample of all firms, firms’ quality control elements
or all assurance work throughout the year. A comprehensive
evaluation of audit quality involves consideration of various factors Imre Nagy
beyond numerical information about deficiencies identified and
Director Inspections
reported over the course of an inspection.
Telephone: (087) 940-8800
While responsibility for improving audit quality rests with audit firms, Fax: (087) 940-8874
IFIAR seeks to influence progress towards consistent, high-quality E-mail: inspections@irba.co.za
audits globally through various activities. It also encourages audit
firms to execute on an ongoing cycle of continuous improvement, a
topic that has been – and will remain – a prominent aspect of IFIAR’s
dialogue with the GPPC networks and knowledge sharing among
IFIAR members.
Issue 46 | April - June 2019 14LEGAL
DISCIPLINARY COMMITTEE
The Disciplinary Committee sat once during the period to hear a part-heard matter that had commenced in 2017. The matter was heard on
11 June 2019 and sanction is reserved.
REPORTABLE IRREGULARITIES
Reportable Irregularities (RIs) for the quarter 1 January 2019 to 31
March 2019:
(Note that RIs are reported on quarterly in arrears)
163 second reports were received, of which:
RIs were continuing 108
RIs were not continuing 55
RIs did not exist 0
Of the 108 continuing RIs received, the top six types of RIs most frequently reported, categorised by nature, were:
(Note that in many cases a second report received would identify more than one RI)
Unlawful Act or Ommission Reporting Frequency Regulator(s) Informed
The South African Revenue Service
-
Financial statements not prepared/not approved within (SARS), the Financial Sector Conduct
41.01%
the alloted timeframe. Authority (FSCA) and the Companies and
Intellectual Property Commission (CIPC).
-
Tax and VAT-related contraventions, e.g. non-submission
of tax returns, failure to register for tax, non-payment of 32.37% SARS.
PAYE, etc.
-
Various Companies Act Contraventions, e.g. reckless
trading, breach of directors’ fiduciary duties, irregular
12.95% CIPC.
financial assistance to directors, AGM-related
irregularities, etc.
-
Suspected fraud and/or theft, and contravention of the The Directorate for Priority Crime
Prevention and Combatting of Corrupt Activities Act 4.32% Investigation and the Financial Intelligence
(PRECCA). Centre.
-
Contravention of the Pension Funds Act – i.e. fund
not responding to FSCA queries, breaches in fiduciary 2.16% FSCA.
duties, etc.
-
Contravention of the Trust Property Control Act – i.e.
number of trustees falling below stipulated minimum, 1.44% Master of the High Court.
trustees acting negligently, etc.
-
Other, e.g. contraventions of the Johannesburg Stock
The Johannesburg Stock Exchange, the
Exchange Listing Requirements, the Sectional Title
5.75% Community Schemes Ombud Service,
Schemes Management Act, the Compensation for
the Compensation Fund, etc.
Occupational Injuries and Diseases Act.
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