Audit and Assurance · Written representations

ISA 580 Required Written Representations and Management Responsibilities

Updated 11 October 2026 · Fact-checked

ISA 580 requires the auditor to ask management for written representations. The two mandatory ones confirm that management has fulfilled its responsibility for preparing the financial statements, and that it has given the auditor all relevant information and access. Other representations cover specific matters. They support, but never replace, other audit evidence.

Understand Management Responsibilities and Required Representations

A written representation is a written statement from management to the auditor. It confirms certain matters or supports other audit evidence. It is usually a letter of representation, signed by those with the right responsibility, often the chief executive and finance director.

Why is it needed? Management knows things the auditor cannot fully verify, such as its intentions or whether all related parties have been disclosed. The letter also confirms that management accepts its responsibilities. This links to the engagement letter, which sets out those responsibilities at the start.

ISA 580 requires two representations in every case. First, responsibility for the financial statements: management confirms it has fulfilled its responsibility for the preparation of the financial statements in line with the applicable framework, including fair presentation where relevant, as set out in the engagement terms. Second, information provided and completeness of transactions: management confirms it has given the auditor all relevant information and access agreed in the engagement terms, and that all transactions are recorded and reflected in the financial statements.

The auditor may also request other representations, depending on the audit. Typical examples are the completeness of related party identification and disclosure, the effect of uncorrected misstatements being immaterial, the completeness of subsequent events disclosure, plans or intentions affecting assets and liabilities, going concern assumptions, and disclosure of known or suspected fraud and non-compliance with laws.

The key limit: a representation is not sufficient appropriate audit evidence on its own for a matter. If management says inventory is fully valued, you still test it. Representations are the weakest type of evidence because they come from a party with an interest in the outcome.

Key rules to remember

Mandatory representation 1: Management confirms it has fulfilled its responsibility for preparing the financial statements, as in the engagement terms; Required by ISA 580 on every audit. It includes fair presentation where the framework requires it.
Mandatory representation 2: Management confirms it has provided all relevant information and access, and that all transactions are recorded; Covers completeness of information and of transactions. Required on every audit.
Role of representations: Written representations ≠ sufficient appropriate audit evidence on their own; They corroborate other evidence. They never replace procedures.
Date and form: Letter dated as near as practicable to, but not after, the date of the auditor's report; It covers all financial statements and periods referred to in the report.
Who signs: Those with appropriate responsibility and knowledge, usually management and, where appropriate, those charged with governance; Typically the chief executive and the finance director.

How to solve Management Responsibilities and Required Representations questions

Use this method for any question asking what a letter of representation should contain, why it is needed or how the auditor responds.

1Read the scenario and identify the entity, framework and the issues given, such as related parties, a subsequent event, a going concern doubt or a suspected fraud.
2Start with the two mandatory representations: responsibility for the financial statements and completeness of information and transactions.
3Add representations that match each issue in the scenario. Link every point to a fact in the question.
4Say that representations support but do not replace other evidence, and name the further procedures the auditor still needs.
5Cover the form: written, dated near the report date, addressed to the auditor, signed by appropriate people.
6If the question asks what to do when management refuses or the representations seem unreliable, state the consequences, including the effect on the opinion.
7Check you have answered the verb: list, explain or discuss.

Quickest way: Mandatory first, then scenario-led

When to use it: Use for Section C list questions and for objective test items asking which representation is required.

Write 'Responsibility' and 'Completeness' as your first two points.
Scan the scenario for triggers: related party, subsequent event, going concern, fraud, uncorrected errors, legal claims, plans or intentions.
Turn each trigger into one representation sentence.
Add one line: representation is not enough alone, so other evidence is also needed.
Add the date and signatory point if marks remain.

Common mistakes in Management Responsibilities and Required Representations

Treating a representation as enough evidence for a material item.
The letter feels formal and authoritative, so students rely on it.
Fix: State that it only corroborates other evidence and name the procedures still required.
Leaving out one of the two mandatory representations.
Students jump straight to specific items like related parties.
Fix: Always open with responsibility for the financial statements and completeness of information and transactions.
Listing generic representations that do not link to the scenario.
Students memorise a standard list and recite it.
Fix: Tie each point to a stated fact, such as a pending lawsuit or a post year-end event.
Saying the auditor writes and signs the letter.
Students confuse it with the auditor's report.
Fix: Remember the letter comes from management. The auditor requests it and keeps it on file.
Dating the letter after the auditor's report.
Students think it is a post-audit formality.
Fix: It must be dated as near as practicable to, but not after, the date of the auditor's report.
Ignoring what happens when management refuses.
Questions often ask only for contents, so students skip consequences.
Fix: Know that refusal on the mandatory matters leads to a disclaimer of opinion, or withdrawal where possible, as ISA 580 requires.

Worked examples

Example 1

You are the audit senior on Lotus Ltd, a manufacturer. At the year end, management disclosed a lawsuit from a customer, and you have noted that a major customer became insolvent two weeks after the year end. List the written representations you would request from management.

Show the solution

Start with the mandatory ones: management has fulfilled its responsibility for preparing financial statements in line with the applicable framework, and has given you all relevant information and access, with all transactions recorded.
Lawsuit: management confirms it has disclosed all known claims and that the provision or disclosure is appropriate.
Insolvent customer: management confirms all subsequent events needing adjustment or disclosure have been dealt with.
Related parties: management confirms it has disclosed the identity of all related parties and all related party transactions.
Uncorrected misstatements: management believes the effects of any unadjusted differences are immaterial, individually and in total.
Fraud and laws: management confirms it has disclosed any known or suspected fraud and any non-compliance with laws.
Note that these do not replace your own testing of the claim and the post year-end receivables.

Answer: Request the two mandatory representations (responsibility, and completeness of information and transactions) plus representations on the lawsuit, subsequent events, related parties, uncorrected misstatements, and fraud and non-compliance. They corroborate, not replace, other evidence.

Example 2

During the audit of Zenith Co, the finance director refuses to sign a representation that all information has been provided. Explain the implications for the auditor.

Show the solution

This is one of the mandatory representations. It concerns management's integrity and the completeness of evidence.
Discuss the matter with management and re-evaluate their integrity and the reliability of other representations and evidence.
Take appropriate action, including determining the possible effect on the opinion.
If the auditor concludes there is sufficient doubt about management's integrity so that the representations are unreliable, or management does not provide the mandatory representations, the auditor must disclaim an opinion.
Consider withdrawing from the engagement where law permits.
Consider reporting to those charged with governance.

Answer: Refusal to give a mandatory representation means the auditor cannot obtain sufficient appropriate evidence. After discussing with management and re-evaluating integrity, the auditor disclaims an opinion, or withdraws where permitted, and tells those charged with governance.

Exam tips

Always open a 'contents of the letter' answer with the two mandatory representations. These are easy marks.
Make every other representation scenario-specific. Quote the fact, then the representation.
Add a line stating that representations are not sufficient evidence alone. Examiners reward this.
For objective test questions, check who provides the letter (management) and the date rule (not after the report date).
If the scenario mentions refusal or doubts over integrity, bring in the effect on the audit opinion.

Management Responsibilities and Required Representations in other exams

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

Management Responsibilities and Required Representations: frequently asked questions

What are the required written representations under ISA 580?

There are two. Management confirms it has fulfilled its responsibility for preparing the financial statements, and that it has provided all relevant information and access, with all transactions recorded. Other representations are requested where needed.

Who signs the letter of representation?

Management signs it, usually the chief executive and the finance director, as those with appropriate responsibility and knowledge. Where relevant, those charged with governance may be involved. The auditor does not sign it.

When should the letter of representation be dated?

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

Can the auditor rely on a representation instead of testing?

No. A written representation is not sufficient appropriate audit evidence on its own. The auditor still performs other procedures on the matter.

What if management refuses to give the representations?

The auditor discusses it with management, re-evaluates their integrity and considers the effect on the opinion. If a mandatory representation is refused, the auditor disclaims an opinion, or withdraws where law allows.