Advanced Audit and Assurance (International) · Subsequent events and going concern

ISA 580 Written Representations and Audit Completion Procedures

Updated 11 October 2026 · Fact-checked

Written representations are statements from management, usually in a letter, confirming matters the auditor relies on. Under ISA 580 they support other evidence but never replace it. Completion procedures bring together subsequent events, going concern, misstatements and representations to decide whether the audit opinion is safe to sign.

Understand Written Representations and Completion Procedures

Written representations are formal statements from management and, where appropriate, those charged with governance (TCWG). They confirm that management has met its responsibilities, or support other audit evidence. They are usually in a letter addressed to the auditor, dated as near as practicable to the date of the auditor's report, but not after it.

The key point under ISA 580 is that representations are necessary but not sufficient. They are evidence, but they do not replace evidence you could reasonably expect to obtain. If management says there are no related parties, you still test for related parties. A representation also cannot fix a weakness in the underlying evidence. Good exam answers say this clearly.

Some representations are required. Management must confirm it has fulfilled its responsibility for preparing the financial statements in line with the framework, and that it has given you all relevant information and access, as set out in the audit engagement terms. Other ISAs require specific ones too, for example on fraud, laws and regulations, related parties, going concern plans, subsequent events and uncorrected misstatements. You may also request extra ones where the scenario calls for it, such as management's intent on a restructuring.

The risk is reliability. If representations are inconsistent with other evidence, or you doubt the competence, integrity or ethical values of management, you must reconsider the reliability of all representations and the audit evidence. If management refuses to provide a required representation, you discuss it with management, reassess integrity, and consider the effect on the opinion. If the doubts about integrity are serious enough, you disclaim an opinion. Refusal of the responsibility representations also leads to a disclaimer.

Completion procedures are the final review before you sign. You update subsequent events work to the report date, review going concern again, evaluate uncorrected misstatements against materiality, perform final analytical review, check disclosures, obtain representations, and complete the file review and any engagement quality review. Then you decide the opinion and communicate with TCWG. The aim is to show that all evidence, including late evidence, supports one consistent conclusion.

Key rules to remember

Status of representations: Written representations = supporting evidence only; they do not replace other sufficient appropriate evidence; Say this whenever a scenario relies on management's word alone.
Timing of the letter: Date of representation letter ≈ date of auditor's report, and not after it; It should cover all periods referred to in the report. Update if the signing date is delayed.
Required responsibility representations: Management confirms: (1) preparation and fair presentation of the financial statements in line with the framework, (2) provision of all relevant information and access, with all transactions recorded and reflected in the financial statements; If management does not provide these, the auditor disclaims an opinion.
Unreliable representations: Doubt over integrity or inconsistency with evidence ⇒ reconsider reliability of all representations and other evidence. Serious doubt over integrity ⇒ disclaim an opinion. A requested representation refused and not resolved ⇒ take appropriate action, including modifying the opinion under ISA 705; Serious integrity doubts lead to a disclaimer.
Final decision test: Uncorrected misstatements (individually and in aggregate) vs materiality, plus qualitative factors; Also consider the effect on prior periods and the risk of further undetected error.

How to solve Written Representations and Completion Procedures questions

Use this order for any question on representations or completion. It keeps your answer tied to the scenario and the opinion.

1Identify what the requirement asks: the content of a letter, reliability of representations, completion procedures, or the effect on the report.
2Pick out the scenario facts that create risk: late events, doubtful going concern, management pressure, uncorrected errors, or new related parties.
3State the rule. Representations support but do not replace evidence, and the letter is dated close to the report date.
4Apply it. Say which matters need a representation, and what other evidence you must still obtain for each one.
5Assess reliability. Check consistency with other evidence, management integrity, and any refusals or changes in wording.
6Link to completion work. Update subsequent events and going concern, evaluate misstatements, and check disclosures.
7Conclude on the opinion: unmodified, qualified, adverse or disclaimer, and whether an emphasis or material uncertainty paragraph is needed.
8Add professional skills: clear wording, sceptical tone, and a practical recommendation, such as escalating to TCWG.

Quickest way: Evidence, reliability, opinion

When to use it: Use in Section B questions or short parts of a case study when you have little time.

Write one line: representations are supporting evidence only.
List the two or three specific matters in the scenario that need a representation.
For each, name the other evidence you still need.
Flag any inconsistency or refusal and say what it means for integrity.
Finish with the effect on the opinion and communication to TCWG.

Common mistakes in Written Representations and Completion Procedures

Treating a representation letter as enough evidence on its own.
Students see management confirming a matter and think the issue is closed.
Fix: Always pair a representation with other procedures, such as inspecting contracts, board minutes or post year-end documents.
Dating the letter after the auditor's report or well before it.
Students forget the letter must cover events up to the report date.
Fix: State that the letter is dated as near as practicable to the report date, and updated if signing is delayed.
Saying the auditor should simply accept a refusal and sign an unmodified report.
Students underestimate the effect on integrity and evidence.
Fix: Describe the steps: discuss with management and reassess integrity and reliability. If the refusal is not resolved, modify the opinion under ISA 705. If integrity is in serious doubt, disclaim an opinion.
Listing completion procedures as a generic checklist with no link to the scenario.
Students memorise headings instead of applying them.
Fix: Tie each procedure to a named fact, such as a post year-end loan default or an unadjusted inventory error.
Ignoring uncorrected misstatements that are small individually but material together.
Students compare each item to materiality separately.
Fix: Aggregate them, consider qualitative factors such as covenants or trends, and ask management to correct them.
Forgetting to update subsequent events and going concern work to the report date.
Students treat these as year-end tasks only.
Fix: State that you perform further procedures up to the report date and ask for updated representations on both.

Worked examples

Example 1

During the audit of Zenith Ltd, management refuses to sign a representation that all related party relationships have been disclosed. You have found no undisclosed relationships, but a large sale to a company owned by a director's relative looks unusual. Explain the audit implications.

Show the solution

State the rule: representations on related parties support other evidence, but a refusal casts doubt on management's integrity.
Apply it: the unusual sale suggests a possible undisclosed related party, so the refusal increases risk, not reduces it.
Recommended work: enquire of management and TCWG, inspect contracts and legal ownership records, and confirm terms with the counterparty.
Reassess reliability: consider whether other representations and management explanations can still be relied on.
Conclude on the opinion: if discussion does not resolve the refusal, take appropriate action, including modifying the opinion under ISA 705. If your doubts about management's integrity are serious enough that the representations are unreliable, disclaim an opinion.
Communicate the matter to TCWG before concluding.

Answer: The refusal is a red flag. You must discuss it with management, investigate the transaction and reassess management's integrity and the reliability of all representations. If the refusal is not resolved, you modify the opinion under ISA 705. If integrity is in serious doubt, you disclaim an opinion. You cannot simply rely on the absence of other findings.

Example 2

Your audit report on Apex plc is due to be signed on 20 March. On 15 March a major customer, representing most of Apex's sales, goes into liquidation. Management's draft going concern note says there are no material uncertainties. Explain the completion procedures you should perform.

Show the solution

Identify the event: the customer failure after the year end is a subsequent event that may indicate a going concern issue and affects year-end receivables.
Subsequent events: ask whether it gives evidence of conditions at the reporting date, such as receivables recoverability, and whether it requires adjustment or only disclosure. A customer's liquidation soon after the year end often shows the receivable was already impaired at the reporting date, so it may be an adjusting event. Check whether the balance needs to be written down.
Going concern: obtain updated cash flow forecasts and test assumptions, review available finance and covenant compliance, and check management's plans to replace the revenue.
Evaluate disclosure: assess whether the going concern note describes the material uncertainty if there is one.
Obtain updated written representations on plans, subsequent events and the recoverability of the balance.
Conclude, depending on the outcome of the going concern assessment: if no material uncertainty exists once management's plans are assessed, the opinion is unmodified with no going concern section; if a material uncertainty exists and is adequately disclosed, the opinion is unmodified with a 'Material uncertainty related to going concern' section; if a material uncertainty exists but disclosure is inadequate, the opinion is qualified or adverse. If the going concern basis is inappropriate, the opinion is adverse.
Communicate the findings to TCWG.

Answer: You extend subsequent events and going concern work to the signing date, consider whether the liquidation is an adjusting event, test updated forecasts and plans, request updated representations, and decide the opinion on the outcome of your going concern assessment and the adequacy of disclosure. The draft note saying there are no material uncertainties needs challenge.

Exam tips

Always state that representations are not a substitute for other evidence. Markers look for this point.
Link each representation to a scenario fact. Generic lists of letter contents earn few marks.
In completion questions, show the order: update subsequent events and going concern, evaluate misstatements, obtain the letter, then conclude on the opinion.
Use your professional skills marks: give a clear recommendation on what to do next, such as escalating to TCWG or modifying the opinion.

Practice questions from Subsequent events and going concern

Written Representations and Completion Procedures 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 and Completion Procedures: frequently asked questions

Can the auditor rely only on a management representation letter?

No. ISA 580 says representations do not replace other sufficient appropriate audit evidence. They corroborate evidence and confirm management's responsibilities. Where better evidence should exist, you must obtain it.

What date should the representation letter carry?

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

What if management will not give a requested representation?

Discuss it with management and reassess their integrity and the reliability of other representations. If it cannot be resolved, take appropriate action, including modifying the opinion under ISA 705. If integrity is in serious doubt, or management will not give the responsibility representations, you disclaim an opinion.

How do completion procedures link subsequent events and going concern to the opinion?

You extend those procedures to the report date, assess whether new information changes the financial statements or disclosures, and get updated representations. The result decides whether the opinion is unmodified or modified and whether a material uncertainty section is needed.