Audit and Assurance · Written representations

Doubts About Reliability and Refusal of Written Representations

Updated 11 October 2026

If management's integrity is in doubt, or it refuses to give requested written representations, the auditor discusses the matter, reassesses integrity and the reliability of other evidence, and takes action. Under ISA 580, if management will not confirm its responsibilities, or integrity doubts make representations unreliable, the auditor considers withdrawing where permitted, otherwise disclaims an opinion (ISA 705).

Understand Doubts About Reliability and Refusal to Provide Representations

A written representation is a statement from management, given to the auditor, to confirm certain matters or to support other audit evidence. It is normally a letter of representation. ISA 580 sets out what the auditor does with it.

The key point is that a written representation is not sufficient appropriate audit evidence on its own. It does not replace evidence the auditor could reasonably expect to obtain. If management says inventory is fully recorded, you still do your inventory work. The letter supports that work. It does not stand in for it.

The letter also confirms that management has fulfilled its responsibilities. These are preparing the financial statements in line with the framework, and giving the auditor all relevant information and access. If management will not confirm these, the basis of the audit is in question.

Two problems arise. First, doubts about reliability: representations may be inconsistent with other evidence, or you may doubt management's competence, integrity, ethical values or diligence. Second, refusal: management does not provide one or more requested representations.

In both cases you discuss the matter with management, reconsider the integrity of management and how reliable its other representations and evidence are, and take appropriate action. That action may include a modified opinion.

Under ISA 580, if management does not provide the representations on its responsibilities, or integrity doubts are so serious that the representations are unreliable, the auditor first considers withdrawing from the engagement, where permitted by law or regulation. If the auditor does not withdraw, or cannot, the auditor disclaims an opinion in line with ISA 705.

Key rules to remember

Status of representations: Written representations ≠ sufficient appropriate audit evidence on their own; They support other evidence. They never replace procedures the auditor should perform.
Doubts about reliability: Doubt → discuss → reconsider integrity and other evidence → take action; If representations are inconsistent with other evidence, perform procedures to resolve the inconsistency.
Serious integrity concern: Integrity doubts so serious that representations are unreliable → consider withdrawing where permitted by law or regulation; if not withdrawing (or unable to) → disclaim an opinion (ISA 580, ISA 705); ISA 580 requires the auditor to consider withdrawal first. The disclaimer applies where the auditor does not withdraw or cannot.
Refusal on responsibilities: Management will not confirm its responsibilities → consider withdrawing where permitted by law or regulation; if not withdrawing (or unable to) → disclaim an opinion (ISA 580, ISA 705); Applies to responsibility for the financial statements and for providing information and access.
Refusal on other matters: Other representation not provided → discuss, reassess integrity, assess effect on reliability of evidence, consider the effect on the opinion; Opinion may be qualified or disclaimed depending on materiality and pervasiveness.
Modified opinion type: Inability to obtain evidence: material but not pervasive → qualified ('except for'); material and pervasive → disclaimer. Material misstatement: material but not pervasive → qualified; material and pervasive → adverse; First decide whether the problem is missing evidence or a misstatement. Then apply pervasiveness.

How to solve Doubts About Reliability and Refusal to Provide Representations questions

Use this method for any question on refusal or unreliable representations. It keeps your answer in a logical order and earns marks for each stage.

1Identify the problem: is it a refusal, or a doubt about reliability such as inconsistency with other evidence?
2State that representations are not sufficient evidence on their own, so other evidence must be considered.
3Say the auditor should discuss the matter with management and those charged with governance.
4Reassess management's integrity and how reliable its other representations and evidence are.
5Perform extra procedures where evidence is inconsistent, and consider whether the issue is isolated or widespread.
6Decide whether the matter is about management's responsibilities and integrity (ISA 580 requires a disclaimer of opinion) or a specific item (qualify, disclaim or give an adverse opinion, depending on whether it is missing evidence or a misstatement).
7Conclude with the opinion or action, using material and pervasive to justify it, and note communication with those charged with governance.

Quickest way: Refusal triage in four lines

When to use it: Use in Section A or OT case questions and for short Section C parts when time is tight.

Ask: what was refused, or what is doubted?
If it is management's responsibilities, or integrity doubts make the representations unreliable: disclaim an opinion (ISA 580, ISA 705).
If it is one specific matter: assess the effect on evidence. Missing evidence gives qualified or disclaimer. A misstatement gives qualified or adverse.
Add the discussion and reassessment of integrity as the first action.

Common mistakes in Doubts About Reliability and Refusal to Provide Representations

Treating the representation letter as enough audit evidence.
The letter looks formal and signed, so it feels strong.
Fix: Say it supports other evidence but cannot replace it. Always state this.
Jumping straight to a disclaimer for every refusal.
Students remember the word disclaimer and apply it to all cases.
Fix: For refusal on responsibilities, or integrity doubts that make the representations unreliable, ISA 580 requires a disclaimer. For refusal on a single other matter, first assess the effect on evidence and on the opinion.
Forgetting to reassess management's integrity.
Students focus on the opinion and skip the step before it.
Fix: Include discussion with management and reassessment of integrity and other evidence before the opinion.
Mixing up qualified, adverse and disclaimer.
Students link pervasive to disclaimer in every case.
Fix: If evidence cannot be obtained: material but not pervasive is qualified; material and pervasive is a disclaimer. If there is a misstatement: material but not pervasive is qualified; material and pervasive is adverse.
Ignoring those charged with governance.
Students think only management matters.
Fix: Mention discussion or communication with those charged with governance, as management may not be the right contact.
Dating or accepting a letter signed after the report date.
Students confuse the timing of signing with the timing of the audit work.
Fix: The letter should be dated as near as practicable to, but not after, the date of the auditor's report.

Worked examples

Example 1

During the audit of Zeta Co, the finance director refuses to sign the representation letter confirming that management has provided the auditor with all relevant information and access. Explain the auditor's response.

Show the solution

The refusal relates to a core management responsibility, not a minor item.
Discuss the refusal with the finance director and those charged with governance to understand the reason.
Reassess the integrity of management and the reliability of other representations and evidence given.
Without the confirmation, the auditor cannot be sure all information has been provided, so the representations cannot be relied on.
Because management has not provided the representations on its responsibilities, ISA 580 requires the auditor to consider withdrawing from the engagement, where permitted by law or regulation.
If the auditor does not withdraw, or cannot, the auditor disclaims an opinion in accordance with ISA 705.

Answer: Discuss with management and those charged with governance, and reassess integrity and other evidence. Because management will not confirm its responsibilities, the auditor considers withdrawing where law or regulation permits. If the auditor does not withdraw, or cannot, the auditor disclaims an opinion (ISA 580, ISA 705).

Example 2

Alpha Co's management states in its representation letter that all related party transactions have been disclosed. The auditor finds an unrecorded sale to a company owned by a director's family. Explain the implications and response.

Show the solution

The representation is inconsistent with other audit evidence, so its reliability is in doubt.
Discuss the inconsistency with management and perform further procedures to identify any other undisclosed related parties.
Reconsider management's integrity and the reliability of all other representations, as the error may indicate wider concealment.
Representations alone cannot be relied on for related parties, so obtain other evidence.
The unrecorded sale is a misstatement (non-disclosure) shown by other evidence. If it is material and not corrected, the opinion is modified: qualified if material but not pervasive, or adverse if material and pervasive.
If integrity doubts are so serious that the representations are unreliable overall, ISA 580 requires the auditor to consider withdrawing where permitted, and otherwise to disclaim an opinion (ISA 705).

Answer: Treat the representation as unreliable, perform further procedures and reassess integrity. The uncorrected misstatement gives a qualified opinion (material, not pervasive) or an adverse opinion (material and pervasive). If integrity doubts make the representations unreliable overall, the auditor considers withdrawing, and if not withdrawing (or unable to), disclaims an opinion.

Exam tips

Always state that representations are not sufficient evidence on their own. It is a frequent source of marks.
Link the action to the cause: refusal on responsibilities or integrity doubts that make representations unreliable point to a disclaimer of opinion under ISA 580; a single item points to a modified opinion, with the type set by missing evidence or misstatement.
In OT questions, read for words like refuses, inconsistent and integrity. They signal the exact ISA 580 response.
For written answers, set out discuss, reassess, extra procedures, then opinion. Each stage can score.
Do not invent section numbers or extra rules. Stick to what ISA 580 requires.

Doubts About Reliability and Refusal to Provide Representations: frequently asked questions

What if management refuses to sign the representation letter?

The auditor discusses the refusal, reassesses management's integrity and the reliability of other evidence, and considers the effect on the opinion. If the refusal concerns management's responsibilities, ISA 580 requires the auditor to consider withdrawing where permitted by law or regulation, and otherwise to disclaim an opinion.

What is the difference between written representations and audit evidence?

Written representations are a type of audit evidence, but they are not sufficient on their own. They confirm or support other evidence and cannot replace procedures the auditor should perform.

When does refusal lead to a disclaimer of opinion?

A disclaimer arises when management will not confirm its responsibilities, or doubts about integrity are so serious that representations cannot be relied on, and the auditor does not withdraw or cannot. A disclaimer can also arise where the auditor cannot obtain evidence and the effect is material and pervasive.

Can the auditor withdraw instead of disclaiming?

Yes. Where management does not provide the responsibilities representations, or integrity doubts make the representations unreliable, ISA 580 requires the auditor to consider withdrawing from the engagement where law or regulation permits. If the auditor does not withdraw, or cannot, the auditor disclaims an opinion under ISA 705. The auditor should discuss the matter with those charged with governance.