SA 610 (Revised)

Using the Work of Internal Auditors

(Effective for all audits relating to accounting periods beginning on or after April 1, 2010)

Standard on Auditing (SA) 610 (Revised), “Using the Work of Internal Auditors” should be read in the context of the “Preface to the Standards on Quality Control, Auditing, Review, Other Assurance and Related Services¹,” which sets out the authority of SAs and proposed SA 200 (Revised), “Overall Objectives of the Independent Auditor and the Conduct of an Audit in Accordance with Standards on Auditing” ².

Introduction

Scope of this SA

1. This Standard on Auditing (SA) deals with the external auditor’s responsibilities regarding the work of internal auditors when the external auditor has determined, in accordance with SA 315,³ that the internal audit function is likely to be relevant to the audit. (Ref: Para. A1-A2)

2. This SA does not deal with instances when individual internal auditors provide direct assistance to the external auditor in carrying out audit procedures or where, in terms of the applicable legal and regulatory framework, it is not permissible for the internal auditor to provide access to his working papers to the third parties.

Relationship between the Internal Audit Function and the External Auditor

3. The role and objectives of the internal audit function are determined by management and, where applicable, those charged with governance. While the objectives of the internal audit function and the external auditor are different, some of the ways in which the internal audit function and the external auditor achieve their respective objectives may be similar. (Ref: Para. A3)

4. Irrespective of the degree of autonomy and objectivity of the internal audit function, such function is not independent of the entity as is required of the external auditor when expressing an opinion on financial statements. The external auditor has sole responsibility for the audit opinion expressed, and that responsibility is not reduced by the external auditor’s use of the work of the internal auditors.

Effective Date

5. This SA is effective for audits of financial statements for periods beginning on or after April 1, 2010.

Objectives

6. The objectives of the external auditor, where the entity has an internal audit function that the external auditor has determined is likely to be relevant to the audit, are to determine:

1. Whether, and to what extent, to use specific work of the internal auditors; and
    
2. If so, whether such work is adequate for the purposes of the audit.
    

Definitions

7. For purposes of the SAs, the following terms have the meanings attributed below:

1. Internal audit function – An appraisal activity established or provided as a service to the entity. Its functions include, amongst other things, examining, evaluating and monitoring the adequacy and effectiveness of internal control. The Preface to the Standards on Internal Audit, issued by the Institute of Chartered Accountants of India, issued in November 2004 describes internal audit as “an independent management function, which involves a continuous and critical appraisal of the functioning of an entity with a view to suggest improvements thereto and add value to and strengthen the overall governance mechanism of the entity, including the entity’s strategic risk management and internal control system. Internal audit, therefore, provides assurance that there is transparency in reporting, as a part of good governance.”
    
2. Internal auditors – Those individuals who perform the activities of the internal audit function. Internal auditors may belong to an internal audit department or equivalent function.
    

Requirements

Determining Whether and to What Extent to Use the Work of the Internal Auditors

8. The external auditor shall determine:

1. Whether the work of the internal auditors is likely to be adequate for purposes of the audit; and
    
2. If so, the planned effect of the work of the internal auditors on the nature, timing or extent of the external auditor’s procedures.
    

9. In determining whether the work of the internal auditors is likely to be adequate for purposes of the audit, the external auditor shall evaluate:

1. The objectivity of the internal audit function;
    
2. The technical competence of the internal auditors;
    
3. Whether the work of the internal auditors is likely to be carried out with due professional care; and
    
4. Whether there is likely to be effective communication between the internal auditors and the external auditor. (Ref: Para. A4)
    

10. In determining the planned effect of the work of the internal auditors on the nature, timing or extent of the external auditor’s procedures, the external auditor shall consider:

1. The nature and scope of specific work performed, or to be performed, by the internal auditors;
    
2. The assessed risks of material misstatement at the assertion level for particular classes of transactions, account balances, and disclosures; and
    
3. The degree of subjectivity involved in the evaluation of the audit evidence gathered by the internal auditors in support of the relevant assertions. (Ref: Para. A5)
    

Using Specific Work of the Internal Auditors

11. In order for the external auditor to use specific work of the internal auditors, the external auditor shall evaluate and perform audit procedures on that work to determine its adequacy for the external auditor’s purposes. (Ref: Para. A6)

12. To determine the adequacy of specific work performed by the internal auditors for the external auditor’s purposes, the external auditor shall evaluate whether:

1. The work was performed by internal auditors having adequate technical training and proficiency;
    
2. The work was properly supervised, reviewed and documented;
    
3. Adequate audit evidence has been obtained to enable the internal auditors to draw reasonable conclusions;
    
4. Conclusions reached are appropriate in the circumstances and any reports prepared by the internal auditors are consistent with the results of the work performed; and
    
5. Any exceptions or unusual matters disclosed by the internal auditors are properly resolved.
    

Documentation

13. When the external auditor uses specific work of the internal auditors, the external auditor shall document conclusions regarding the evaluation of the adequacy of the work of the internal auditors, and the audit procedures performed by the external auditor on that work, in accordance with paragraph 11.

***

Application and Other Explanatory Material

Scope of this SA (Ref: Para. 1)

A1. As described in SA 315⁴, the entity’s internal audit function is likely to be relevant to the audit if the nature of the internal audit function’s responsibilities and activities are related to the entity’s financial reporting, and the auditor expects to use the work of the internal auditors to modify the nature or timing, or reduce the extent, of audit procedures to be performed.

A2. Carrying out procedures in accordance with this SA may cause the external auditor to re-evaluate the external auditor’s assessment of the risks of material misstatement. Consequently, this may affect the external auditor’s determination of the relevance of the internal audit function to the audit. Similarly, the external auditor may decide not to otherwise use the work of the internal auditors to affect the nature, timing or extent of the external auditor’s procedures. In such circumstances, the external auditor’s further application of this SA may not be necessary.

Scope and Objectives of the Internal Audit Function (Ref: Para. 3)

A3. The objectives of internal audit functions vary widely and depend on the size and structure of the entity and the requirements of management and, where applicable, those charged with governance. The activities of the internal audit function may include one or more of the following:

• Monitoring of internal control. The internal audit function may be assigned specific responsibility for reviewing controls, monitoring their operation and recommending improvements thereto.
   
• Examination of financial and operating information. The internal audit function may be assigned to review the means used to identify, measure, classify and report financial and operating information, and to make specific inquiry into individual items, including detailed testing of transactions, balances and procedures.
   
• Review of operating activities. The internal audit function may be assigned to review the economy, efficiency and effectiveness of operating activities, including non- financial activities of an entity.
   
• Review of compliance with laws and regulations. The internal audit function may be assigned to review compliance with laws, regulations and other external requirements, and with management policies and directives and other internal requirements.
   
• Risk management. The internal audit function may assist the organization by identifying and evaluating significant exposures to risk and contributing to the improvement of risk management and control systems.
   
• Governance. The internal audit function may assess the governance process in its accomplishment of objectives on ethics and values, performance management and accountability, communicating risk and control information to appropriate areas of the organization and effectiveness of communication among those charged with governance, external and internal auditors, and management.
   

Determining Whether and to What Extent to Use the Work of the Internal Auditors

Whether the Work of the Internal Auditors Is Likely to Be Adequate for Purposes of the Audit (Ref: Para. 9)

A4. Factors that may affect the external auditor’s determination of whether the work of the internal auditors is likely to be adequate for the purposes of the audit include:

Objectivity

• The status of the internal audit function within the entity and the effect such status has on the ability of the internal auditors to be objective.
   
• Whether the internal audit function reports to those charged with governance or an officer with appropriate authority, and whether the internal auditors have direct access to those charged with governance.
   
• Whether the internal auditors are free of any conflicting responsibilities.
   
• Whether those charged with governance oversee employment decisions related to the internal audit function.
   
• Whether there are any constraints or restrictions placed on the internal audit function by management or those charged with governance.
   
• Whether, and to what extent, management acts on the recommendations of the internal audit function, and how such action is evidenced.
   

Technical competence

• Whether the internal auditors are members of relevant professional bodies.
   
• Whether the internal auditors have adequate technical training and proficiency as internal auditors.
   
• Compliance with the mandatory/ recommendatory Standards on Internal Audit (SIAs) issued by Internal Audit Standards Board of the Institute of Chartered Accountants of India (ICAI).
   
• Whether there are established policies for hiring and training internal auditors.
   

Due professional care

• Whether activities of the internal audit function are properly planned, supervised, reviewed and documented.
   
• The existence and adequacy of audit manuals or other similar documents, work programs and internal audit documentation.
   

Communication

Communication between the external auditor and the internal auditors may be most effective when the internal auditors are free to communicate openly with the external auditors, and:

• Meetings are held at appropriate intervals throughout the period;
   
• The external auditor is advised of and has access to relevant internal audit reports and is informed of any significant matters that come to the attention of the internal auditors when such matters may affect the work of the external auditor; and
   
• The external auditor informs the internal auditors of any significant matters that may affect the internal audit function.
   

Planned Effect of the Work of the Internal Auditors on the Nature, Timing or Extent of the External Auditor’s Procedures (Ref: Para. 10)

A5. Where the work of the internal auditors is to be a factor in determining the nature, timing or extent of the external auditor’s procedures, it may be useful to agree in advance the following matters with the internal auditors:

• The timing of such work;
   
• The extent of audit coverage;
   
• Materiality for the financial statements as a whole (and, if applicable, materiality level or levels for particular classes of transactions, account balances or disclosures), and performance materiality;
   
• Proposed methods of item selection;
   
• Documentation of the work performed; and
   
• Review and reporting procedures.
   

Using Specific Work of the Internal Auditors (Ref: Para. 11)

A6. The nature, timing and extent of the audit procedures performed on specific work of the internal auditors will depend on the external auditor’s assessment of the risk of material misstatement, the evaluation of the internal audit function, and the evaluation of the specific work of the internal auditors. Such audit procedures may include:

• Examination of items already examined by the internal auditors;
• Examination of other similar items; and
• Observation of procedures performed by the internal auditors.

Material Modifications to ISA 610, “Using the Work of Internal Auditors”

Addition

Paragraph 2 of ISA 610 deals with the situations where this ISA would not be applicable. In India, clause 1 of Part I of the Second Schedule to the Code of Ethics provides that a Chartered Accountant in Practice shall be deemed to be guilty of professional misconduct if he discloses information acquired in the course of his professional engagement to any person other than his client, an auditor cannot provide access to his working paper to the another auditor. Therefore, keeping in view the requirements of Code of Ethics, the situation, “where, in terms of the applicable legal and regulatory framework, it is not permissible for the internal auditor to provide access to his working papers to the third parties” has been added.

Limited Revision Consequential to issuance of the Standard on Auditing (SA) 610 (Revised), “Using the Work of Internal Auditors”

The amendments to Standard on Auditing (SA) 315 have been shown in track change mode.

SA 315, “Identifying and Assessing the Risks of Material Misstatement Through Understanding the Entity and Its Environment”

22. The auditor shall obtain an understanding of the major activities that the entity uses to monitor internal control over financial reporting, including those related to those control activities relevant to the audit, and how the entity initiates corrective actions to its controls. (Ref: Para. A94-A96)

22a. If the entity has an internal audit function,^* the auditor shall obtain an understanding of the following in order to determine whether the internal audit function is likely to be relevant to the audit:

1. The nature of the internal audit function’s responsibilities and how the internal audit function fits in the entity’s organisational structure; and
    
2. The activities performed, or to be performed, by the internal audit function. (Ref: Para. A96a - A96c)
    

23. The auditor shall obtain an understanding of the sources of the information used in the entity’s monitoring activities, and the basis upon which management considers the information to be sufficiently reliable for that purpose. (Ref: Para. A97)

[When the conforming amendments are included in SA 315, paragraph 22a will become paragraph 23 and the SA will be re-numbered accordingly.]

Components of Internal Control-Monitoring of Controls (Ref: Para. 22)

A94. Monitoring of controls is a process to assess the effectiveness of internal control performance over time. It involves assessing the effectiveness of controls on a timely basis and taking necessary corrective actions. Management accomplishes monitoring of controls through ongoing activities, separate evaluations, or a combination of the two. Ongoing monitoring activities are often built into the normal recurring activities of an entity and include regular management and supervisory activities.

A95. In many entities, internal auditor or personnel performing similar
functions contribute to the monitoring of an entity’s activities. [Proposed] SA 610 (Revised) establishes requirements and provides guidance on the auditor’s consideration of the work of internal auditing. Management’s monitoring activities may also include using information from communications from external parties such as customer complaints and regulator comments that may indicate problems or highlight areas in need of improvement.

Considerations Specific to Smaller Entities

A96. Management’s monitoring of control is often accomplished by management’s or the owner-manager’s close involvement in operations. This involvement often will identify significant variances from expectations and inaccuracies in financial data leading to corrective action to the control.

Internal Audit Functions (Ref: Para 22a)

A96a. The entity’s internal audit function is likely to be relevant to the
audit if the nature of the internal audit function’s responsibilities and
activities are related to the entity’s financial reporting, and the auditor expects to use the work of the internal auditors to modify the nature or timing, or reduce the extent, of audit procedures to be performed. When the auditor determines that the internal audit function is likely to be relevant to the audit, SA 610 (Revised) applies.

A96b. The objectives of an internal audit function, and therefore the
nature of its responsibilities and its status within the organisation, vary
widely and depend on the size and structure of the entity and the requirements of management and, where applicable, those charged with governance. The responsibilities of an internal audit function may include, for example, monitoring of internal control, risk management, and review of compliance with laws and regulations. On the other hand, the responsibilities of the internal audit function may be limited to the review of the economy, efficiency and effectiveness of operations, for example, and accordingly, may not relate to the entity’s financial reporting.

A96c. If the nature of the internal audit function’s responsibilities are
related to the entity’s financial reporting, the external auditor’s consideration
of the activities performed, or to be performed by, the internal audit function
may include review of the internal audit function’s audit plan for the period,
if any, and discussion of that plan with the internal auditors.

[When the conforming amendments are included in SA 315, paragraphs A96a-A96c will become paragraphs A97-A99 and the SA will be re-numbered accordingly.]

1 Published in the July, 2007 issue of the Journal.

2 Presently, SA 200, “Basic Principles Governing an Audit” and SA 200A, “Objective and Scope of an Audit of Financial Statements” correspond to International Standard on Auditing (ISA) 200 (Revised and Redrafted). Both the SAs are currently being revised in the light of the ISA 200 (Revised and Redrafted). Post revision, the principles covered by SA 200 (AAS 1) and SA 200A (AAS 2) will be merged into one Standard, i.e., SA 200.

3 SA 315, “Identifying and Assessing the Risks of Material Misstatement Through Understanding the Entity and Its Environment,” paragraph 22a.

4 SA 315, paragraph A96a.

* The term “internal audit function” is defined in SA 610 (Revised), “Using the Work of Internal Auditors”, paragraph 7(a).

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