Audit and Assurance · Audit finalisation and the final review

Written Representations (ISA 580) for ACCA Audit and Assurance

Updated 11 October 2026 · Fact-checked

Written representations are statements from management, given to the auditor in writing, confirming matters or supporting other audit evidence. Under ISA 580 you request them near the date of the auditor's report. They never replace other evidence. If management refuses, you discuss it, reassess integrity, and consider a modified opinion or withdrawal.

Understand Written Representations (ISA 580)

A written representation is a written statement from management (and, where appropriate, those charged with governance) given to the auditor. It confirms certain matters or supports other audit evidence. It is usually a letter of representation, but it can also be a letter from the auditor that management confirms.

The auditor asks for it for three main reasons. First, to confirm that management has fulfilled its responsibilities for preparing the financial statements and for providing the auditor with all relevant information and access. Second, to support other audit evidence where the evidence needed is not available from other sources, such as management's intentions. Third, to record in writing what management has said orally, so management cannot later deny it.

The key point is that written representations are not sufficient appropriate audit evidence on their own. They are produced by management, who are not independent of the financial statements. They cannot replace evidence you would reasonably expect to be available. If you cannot obtain that other evidence, a representation does not fix the gap. This may lead to a limitation on scope.

Timing matters. The letter is dated as near as practicable to, but not after, the date of the auditor's report. It covers all the financial statements and periods referred to in the report. It is signed by people with appropriate responsibility and knowledge, usually the senior executive and the senior financial officer.

You must also judge reliability. If representations conflict with other evidence, or you doubt the competence, integrity or ethical values of management, you reconsider the reliability of all representations. If management refuses to provide required representations, you discuss the matter, reevaluate integrity, take appropriate action, and consider the effect on the opinion.

Key rules to remember

Required representation: responsibilities: Management confirms it has fulfilled its responsibility for the preparation of the financial statements and for providing information and access; ISA 580 requires these. The auditor requests them whatever the engagement.
Role as evidence: Written representations ≠ sufficient appropriate audit evidence on their own; They support, never replace, other evidence that could reasonably be expected to exist.
Date of the letter: Date of representations ≤ date of auditor's report, and as near as practicable to it; It cannot be dated after the report. Later events need updated representations if relevant.
Contradiction or doubt: Inconsistency with evidence or doubts about management integrity → reconsider reliability of all representations; Also consider the effect on other evidence obtained.
Refusal outcome: Refusal on responsibilities, or integrity too doubtful → disclaim an opinion (or withdraw where possible); Refusal on other matters: assess the effect and consider modifying the opinion.

How to solve Written Representations (ISA 580) questions

Use this method for any question on written representations, whether it asks for contents, reliability or refusal.

1Read the scenario and identify what is being asked: purpose, contents, timing, reliability or refusal.
2State what a written representation is and why the auditor needs it, linked to the scenario.
3Separate the matters. Responsibility representations are always required. Other representations support specific evidence, such as intentions, completeness of related parties or subsequent events.
4Check timing and signatories. The letter is dated at or just before the report date and signed by senior management and those charged with governance as appropriate.
5Ask whether other evidence exists. If the matter is one where audit evidence should be available, a representation alone is not enough.
6If there is a refusal or doubt, apply the sequence: discuss with management, reassess integrity and reliability, then decide on the opinion or withdrawal.
7Link to the audit opinion in the final sentence: unmodified, qualified or disclaimer, and why.
8Write in short, numbered points that match the marks available.

Quickest way: Purpose, evidence, refusal in three checks

When to use it: Use this for objective test questions and for short written parts where time is tight.

Ask: is this about confirming management responsibilities? If yes, the representation is required and refusal is very serious.
Ask: could the auditor get better evidence elsewhere? If yes, a letter alone is not enough.
Ask: is management refusing or contradicting other evidence? If yes, discuss, reassess integrity, then consider modifying the opinion or withdrawing.
Check the date. The letter cannot be dated after the auditor's report.

Common mistakes in Written Representations (ISA 580)

Treating the representation letter as sufficient evidence for a material balance.
Students see a signed confirmation from management and assume it settles the matter.
Fix: Say that representations are weaker evidence because management is not independent. Other evidence must still be obtained where it should exist.
Dating the letter after the auditor's report or on a different date from the financial statements.
Students link the letter to the date of approval of the statements, not to the report date.
Fix: Date the letter as near as practicable to, but not after, the date of the auditor's report.
Saying the auditor should simply accept refusal and move on.
Students forget refusal signals an integrity or scope problem.
Fix: Write the sequence: discuss, reassess integrity and reliability of other representations, take appropriate action, consider the opinion.
Giving the same opinion consequence for every refusal.
Students memorise one outcome and ignore the matter refused.
Fix: Distinguish refusal on management responsibilities or serious integrity doubts (disclaimer or withdrawal) from refusal on a specific matter (assess effect, possibly qualified or disclaimer).
Listing contents with no link to the scenario.
Students recite a generic list from memory.
Fix: Pick the representations that fit the facts, such as intentions to dispose of assets, related party completeness, litigation or subsequent events.
Confusing the letter of representation with the engagement letter.
Both are letters between auditor and client and both mention responsibilities.
Fix: The engagement letter is agreed at the start and sets terms. The representation letter is obtained at the end and supports the evidence.

Worked examples

Example 1

During the final review of Kiran Co, the auditor asks management to sign a letter of representation. The finance director says that she will sign confirmation that all related parties have been disclosed, but the directors refuse to confirm that they have provided the auditor with all relevant information. Explain what the auditor should do and the possible effect on the audit report. (6 marks)

Show the solution

State the issue: the refused representation is about management's responsibility to provide all relevant information and access. This is a required representation.
Discuss the matter with management and those charged with governance, and ask for the reason for the refusal.
Reevaluate the integrity of management. A refusal here casts doubt on how reliable all other representations and evidence are.
Consider the effect on other evidence. The related parties confirmation now carries less weight, so the auditor should seek other evidence.
Take appropriate action. If concerns cannot be resolved, consider the effect on the opinion and, where possible, withdrawal from the engagement.
Conclude on the opinion: because the refusal goes to management's responsibilities and integrity, the auditor would disclaim an opinion if the issue is not resolved.

Answer: The auditor should discuss the refusal with management, reassess their integrity and the reliability of all other representations, and gather further evidence. If the directors still refuse to confirm they provided all relevant information, the auditor should disclaim an opinion, or withdraw where law allows.

Example 2

Zed Co plans to sell a factory after the year end. Management says in a meeting that the sale is certain. The auditor has no documents on the plans. Explain how written representations help and their limitation. (4 marks)

Show the solution

Identify that management's intentions are a matter where written representations are commonly used, because other evidence may be limited.
Explain the benefit: a written statement confirming the plan records management's position and prevents later denial.
Explain the limitation: the representation is not independent evidence, so the auditor should still seek board minutes, contracts, offers or correspondence with buyers.
Conclude that if such evidence could be expected to exist but is not available, the representation alone does not make the evidence sufficient and appropriate.

Answer: The auditor should obtain a written representation on management's intentions, as it confirms and records what was said orally. It is weak evidence, so the auditor must also look for board minutes and sale documents. Without those, the evidence is insufficient and the auditor may need to consider a limitation on scope.

Exam tips

Always state that written representations are not sufficient on their own. Examiners look for this point in almost every answer.
For refusal questions, write the sequence in order: discuss, reassess integrity, take action, consider the opinion.
Match the contents to the scenario. Name the specific facts, such as intentions, litigation or related parties, instead of listing a general letter.
In objective test questions, check the date. A letter dated after the auditor's report is wrong.
Link the final point to the audit report, saying whether the opinion is modified and why.

Written Representations (ISA 580) in other exams

The same ground in other exams, if you are preparing for more than one or want another angle on it.

Written Representations (ISA 580): frequently asked questions

What is the purpose of a letter of representation in an audit?

It confirms that management has met its responsibilities, supports other audit evidence on matters such as intentions, and records oral statements in writing. It is obtained near the date of the auditor's report. It does not replace other evidence.

What if management refuses to provide written representations?

The auditor discusses the matter with management, reassesses their integrity and the reliability of other representations, and takes appropriate action. If the refusal concerns management's responsibilities or integrity cannot be relied on, the auditor disclaims an opinion or withdraws where possible. For other matters, the auditor considers the effect on the opinion.

Are written representations reliable audit evidence?

They are less reliable than evidence from independent sources, because management has a direct interest in the financial statements. They support other evidence but cannot replace it. Contradictions with other evidence reduce their reliability further.

When should the representation letter be dated?

As near as practicable to, but not after, the date of the auditor's report. It should cover all financial statements and periods referred to in the report.