News


Herbert M Chain
Herbert M. Chain
Shareholder, Mayer Hoffman McCann P.C, Deputy Technical Director, Global Audit Group, Kreston Global

Join Herbert M. Chain on LinkedIn

www.mhmcpa.com

Herbert M. Chain is a highly experienced auditor and is a financial expert with over 45 years of experience in business, accounting, and audit, having served as a Senior Audit Partner at Deloitte. He holds certifications from the National Association of Corporate Directors and the Private Directors Association, with knowledge of private company governance and effective risk management. He has extensive knowledge in the financial services sector, including asset management and insurance.

Contact Herbert here


A focus on group audits

April 12, 2024

Group audits have become a focus of standard setting and regulatory bodies based on the potential risks arising from deficient oversight, communications and risk assessment.

  • In April 2022, the IAASB published a revised standard on ISA 600 Audits of Group Financial Statements (Including the Work of Component Auditors). This introduced significant changes to the audit of groups for periods commencing on or after December 15, 2023 (with early adoption permitted).  The UK’s FRC followed suit and published ISA (UK) 600 (Revised September 2022).
  • In June 2022, the US Public Company Accounting Oversight Board adopted  AS 1206:  Dividing Responsibility for the Audit with Another Accounting Firm, which will be effective for fiscal years ending on or after December 15, 2024.
  • In March 2023, the US Auditing Standards Board issued a new standard for group audits (SAS No. 149, Special Considerations — Audits of Group Financial Statements (Including the Work of Component Auditors and Audits of Referred-to Auditors) effective for periods ending on or after December 25, 2026.

The new and revised requirements are generally similar, with the objectives of strengthening the auditor’s responsibilities related to professional skepticism, planning and performing a group audit, enhancing two-way communications between the group auditor and component (or “referred to”) auditors, and enhancing auditor documentation.

This article will focus on the new US standard. We recommend reading the standard itself to gain a fuller understanding.

SAS No. 149 addresses special considerations that apply to a group audit, including in circumstances in which component auditors are involved or when the group auditor makes reference to the audit of a referred-to auditor.  It adopts the terminology contained in ISA 600, some of which is new to GAAS in the United States and some of which replaces certain terms previously used in US GAAS (i.e., in AU 543).  For example, the term “group auditor” replaces the term “principal auditor”.[1]

SAS No. 149 covers the use of “component” auditors as well as “referred-to” auditors. A component auditor is a part of the engagement team.  Accordingly, the group auditor takes responsibility for the component auditor’s or auditors’ work and, accordingly, must perform certain procedures in relation to the component auditor such as understanding the willingness to comply with ethical requirements (including those relating to independence), the professional competence and capabilities, the ability of the group auditor to be involved in the component auditor’s work (i.e., review the component auditor’s working papers), and the regulatory environment that the component auditor operates in. Component auditors are part of the engagement team and may include a network firm, a firm that is not a network firm, or the group auditor’s firm (for example, another office within the group auditor’s firm).

A referred-to auditor is an auditor who performs an audit of the financial statements of a component to which the group auditor determines to make reference in the auditor’s report on the group financial statements. A referred-to auditor is not a component auditor, and accordingly, is not a part of the engagement team for a group audit.  In such cases, the group auditor should make the referred-to auditor aware of the relevant ethical requirements and should confirm whether the referred-to auditors understand and will comply with the ethical requirements (including those related to independence).  The group auditor should also determine that the referred-to auditors have the appropriate competence and capabilities, and should obtain sufficient appropriate audit evidence relating to the work to be performed at the component if the referred-to auditor does not comply with the relevant ethical requirements or the group auditor has “serious concerns” about these matters.

One principal difference between SAS No. 149 and ISA 600 is that the US standard permits the group auditor to refer to component auditors in the audit report, thus not taking responsibility for the component auditors’ work on component financial statements.[2] Another is a shift in the auditor’s approach from identifying “significant components” to using professional judgment based on assessed risk. ISA 600 focuses on the concept of a “significant component”, which requires a full scope audit.

Global audit engagements (i.e., group audits) bring with them unique risks and requirements, whether the involved firms are from the same network or not.  For Kreston Global group audits, the Global Audit Group is working toward a consistency of approach and service levels, including standardising communication templates and requirements.

If you would like to speak to one of our experts about a group audit, please get in touch.


[1] It should be noted that the PCAOB refers to the group audit partner as the “lead” auditor.

[2] ISA 600 does not permit the auditor’s report on the group financial statements to make reference to a component auditor unless required by law or regulation to include such reference.