Advanced Auditing, Assurance and Professional Ethics · Completion and Review

Reliability, Doubts and Refusal of Written Representations (SA 580)

Updated 5 October 2026 · Fact-checked

Under SA 580, if written representations are inconsistent with other evidence, or doubt arises about management's integrity, the auditor reconsiders reliability and, where needed, modifies the opinion. If management refuses the requested representations, the auditor discusses it, reassesses integrity, takes appropriate action and disclaims an opinion if required.

Understand Reliability, Doubts and Refusal of Written Representations

A written representation is a written statement from management to the auditor, confirming certain matters or supporting other audit evidence. It is usually a letter addressed to the auditor. It is necessary evidence, but it is not sufficient on its own. It can never replace other evidence that you could reasonably expect to obtain.

The key idea is that representations are only as good as the people giving them. If what management says conflicts with other evidence, or if you doubt their honesty, the letter loses value. SA 580 therefore asks you to judge reliability before you rely on it.

There are three problem situations. First, a representation is inconsistent with other audit evidence. Second, you have concerns about the competence, integrity, ethical values or diligence of management, or about their commitment to these. Third, management does not provide one or more requested representations.

The response is a ladder. In the first case, investigate the matter, try to resolve it, and reconsider the reliability of other representations. In the second, decide whether the representations can be relied on at all. In the third, discuss with management and those charged with governance, reassess integrity, and then consider the effect on the opinion.

There are two separate disclaimer triggers. Keep them apart.

Para 20(a): integrity concerns. You conclude that the concerns about management's integrity are so serious that the written representations on management's responsibilities (preparation and fair presentation of the financial statements, and providing complete information and access) are not reliable. You disclaim an opinion.
Para 20(b): responsibilities representations not provided. Management does not provide the representations on its responsibilities (paras 10 and 11). You disclaim an opinion, whatever your view on integrity.

If other requested representations are missing or unreliable, the disclaimer is not automatic. You decide the effect under SA 705, depending on the materiality and pervasiveness of the possible effects on the financial statements. The result may be a qualified opinion, an adverse opinion or a disclaimer.

Key rules to remember

Inconsistent representation: Representation conflicts with other evidence → investigate → if unresolved, reconsider reliability of all representations; Also consider whether the risk assessment is still appropriate and whether further procedures are needed.
Concerns about integrity: Doubt on integrity or diligence of management → representations may be unreliable → determine effect on opinion; If the concern is so serious that the representations on management's responsibilities are unreliable, disclaim an opinion (para 20(a)).
Representations not provided: Not provided → discuss with management and TCWG → reassess integrity → take appropriate action → reassess effect on opinion; Take the actions in this order. Do not jump straight to the disclaimer.
Mandatory disclaimer: para 20(a): Integrity concerns so serious that responsibilities representations (paras 10 and 11) are unreliable → disclaim an opinion; The trigger is the auditor's conclusion on reliability of the responsibilities representations.
Mandatory disclaimer: para 20(b): Management does not provide the responsibilities representations (paras 10 and 11) → disclaim an opinion; Applies after discussion and reassessment of integrity, even if the auditor has no integrity doubt.
Other representations missing or unreliable: Other representation not provided or unreliable → effect on opinion under SA 705 by materiality and pervasiveness; Outcome can be qualified, adverse or disclaimer. It is not automatically a disclaimer.
Date of representations: Date of written representations = as near as practicable to, but not after, the date of the auditor's report; They cover all financial statements and periods referred to in the auditor's report.
Form of representations: Written representations are in the form of a representation letter addressed to the auditor; Oral representations, or the signed financial statements alone, do not meet the requirement.
Status as evidence: Written representations are necessary audit evidence but do not provide sufficient appropriate evidence on their own; They do not affect the nature or extent of other evidence the auditor expects to obtain.

How to solve Reliability, Doubts and Refusal of Written Representations questions

Use this method for any case question on unreliable, doubtful or refused representations. Answer in provision-facts-conclusion form.

1Identify the problem: is it an inconsistency, an integrity doubt, or a refusal or non-provision?
2State the SA 580 provision that applies to that problem in one or two lines.
3Apply it to the facts: name the representation involved and what other evidence conflicts with it or is missing.
4Show the first response: discuss with management and those charged with governance, and investigate to resolve the issue.
5Reassess integrity and the reliability of other representations and other evidence.
6Decide the effect on the opinion: is it a responsibilities representation (disclaimer under para 20(a) or 20(b)) or another matter (SA 705 modification by materiality and pervasiveness)?
7Check the date and form: letter, addressed to the auditor, dated as near as practicable to but not after the report date.
8Conclude clearly with the recommended action and the opinion.

Quickest way: Three-question triage

When to use it: Use when you have little time on an MCQ or a short case-scenario answer.

Ask: what is wrong - conflict, integrity doubt, or refusal?
Ask: does it concern management's responsibilities for the financial statements (preparation, fair presentation, complete information and access)? If yes and the representations are not given, or integrity concerns make them unreliable, the answer is disclaimer.
Ask: otherwise, what is the effect on the opinion? Discuss, reassess integrity, then modify under SA 705 as materiality and pervasiveness require.
Add a one-line check on date: not later than the report date.

Common mistakes in Reliability, Doubts and Refusal of Written Representations

Treating the representation letter as sufficient audit evidence.
Students see it is signed by management and assume it settles the matter.
Fix: Write that representations are necessary but not sufficient and cannot replace other evidence that could reasonably be expected.
Disclaiming an opinion immediately when management refuses any representation.
Students memorise 'refusal means disclaimer'.
Fix: Show the sequence: discuss, reassess integrity, take appropriate action, then decide the effect. Disclaimer is required under para 20(b) if the responsibilities representations are still not provided, and under para 20(a) if integrity concerns make them unreliable. For other representations, apply SA 705 by materiality and pervasiveness.
Mixing up para 20(a) and para 20(b).
Both lead to a disclaimer, so students treat them as one rule.
Fix: Para 20(a) is about integrity concerns making the responsibilities representations unreliable. Para 20(b) is about those representations not being provided. In 20(b) the disclaimer applies even without integrity doubts.
Dating the representation letter after the auditor's report.
Students think the letter is signed once the report is finalised.
Fix: Remember: as near as practicable to, but not after, the date of the auditor's report.
Ignoring the impact on other representations when one is found unreliable.
Students treat each statement in the letter separately.
Fix: State that you must reconsider the reliability of other representations and other audit evidence as a whole.
Accepting oral representations or a management assertion in the financial statements as the written representation.
Confusion between oral evidence, the financial statements and the representation letter.
Fix: Say that the requirement is for a written letter addressed to the auditor, covering the specified matters.
Confusing written representations with audit evidence such as confirmations.
Both are obtained from outside the audit working papers.
Fix: Remember that representations come from management, who are not independent, so they are weaker evidence than external confirmations and cannot corroborate themselves.

Worked examples

Example 1

Case: During the audit of Sunrise Ltd, the auditor asks management for a written representation letter. The managing director says the company's policy is not to sign such letters, though he is willing to answer questions orally. The auditor has no specific reason to doubt management's honesty. Advise the auditor.

Show the solution

Provision: under SA 580, the auditor requests written representations that management has fulfilled its responsibilities for preparing and fairly presenting the financial statements and has provided complete information and access. Oral statements are not a substitute.
Facts: management refuses to provide a written letter and offers only oral answers. There is no other known integrity concern.
First response: discuss the matter with the managing director and those charged with governance, and explain that the letter is a requirement.
Reassess integrity: the refusal may raise concerns about management's integrity and about the reliability of other representations and evidence. It is not proof of an integrity problem on its own, but the auditor must reassess.
Effect on opinion: if management still does not provide the responsibilities representations specified in paras 10 and 11, SA 580 (para 20(b)) requires the auditor to disclaim an opinion. The basis is that these responsibilities representations are not provided. This applies whether or not integrity doubts remain.

Answer: The auditor should discuss the matter with management and those charged with governance and reassess management's integrity. If the written representations on management's responsibilities (paras 10 and 11) are still not provided, the auditor must disclaim an opinion under SA 580 para 20(b), whether or not integrity doubts remain.

Example 2

Case: In the audit of Zenith Ltd, management's representation letter says there are no pending claims against the company. The auditor's review of legal expense ledgers and a lawyer's letter show a significant pending claim. The audit report is to be dated 20 May. The representation letter is dated 25 May. The report has not yet been issued. Advise on the issues.

Show the solution

Provision: if a representation is inconsistent with other evidence, the auditor investigates, tries to resolve the matter, and reconsiders the reliability of other representations.
Facts: the representation about claims conflicts with the lawyer's letter, which is external evidence and more reliable.
Action: discuss with management, find out why the claim was omitted, and reconsider the risk assessment and the reliability of all other representations.
Integrity: if the omission appears deliberate or is not resolved, there is a doubt about management's integrity, and the auditor must determine the effect on the opinion. If the auditor concludes that the responsibilities representations are unreliable, the auditor disclaims an opinion under para 20(a).
Date: the written representations must be dated not after the date of the auditor's report, and the report cannot be dated earlier than the date on which management approves the financial statements. The letter is dated 25 May, but the planned report date is 20 May, so as planned the letter would be dated after the report. Since the report is not yet issued, there are two ways to fix this. First, date the report no earlier than 25 May, and only once all procedures are complete, including resolving the claims issue. Second, obtain a letter dated on or before the report date. The letter must not be backdated. Because the claims issue is unresolved, any letter should be obtained after the issue is resolved, so that it reflects the true position.

Answer: The auditor should investigate and resolve the inconsistency, reassess the reliability of other representations, and consider the effect on the opinion (a disclaimer under para 20(a) if the integrity concern makes the responsibilities representations unreliable). The representations must be dated not after the report, and the report cannot be dated before management approves the financial statements. With the letter dated 25 May, the report must be dated no earlier than 25 May and only after all procedures, including the claims issue, are complete. Otherwise a letter dated on or before the report date is obtained. The letter must not be backdated, and a corrected letter is taken only after the claims issue is resolved.

Exam tips

In case-scenario MCQs, look for the trigger word: 'refuses', 'inconsistent' or 'doubt about integrity', then pick the matching SA 580 response.
Write the sequence in descriptive answers: discuss, reassess integrity, take action, decide effect on the opinion. Marks follow the steps.
Always check the date. A letter dated after the auditor's report is a standard trap, and backdating is never the fix.
Separate the disclaimer cases from the ordinary modification cases. Responsibilities representations not provided (para 20(b)) or unreliable due to integrity concerns (para 20(a)) lead to disclaimer. Other missing representations go through SA 705.
Link to SA 705 in your conclusion: state the type of modified opinion and the reason.

Practice questions from Completion and Review

Reliability, Doubts and Refusal of Written Representations in other exams

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

Reliability, Doubts and Refusal of Written Representations: frequently asked questions

What does the auditor do if management refuses to give a written representation letter?

The auditor discusses the matter with management and those charged with governance, reassesses management's integrity and the reliability of other evidence, and takes appropriate action, including determining the effect on the opinion under SA 705. If management does not provide the representations on its responsibilities for the financial statements, the auditor must disclaim an opinion under para 20(b), even if there is no other integrity doubt. A refusal may raise integrity concerns, but it is not proof of them.

When must the auditor disclaim an opinion under SA 580?

There are two cases. Under para 20(a), the auditor concludes that concerns about management's integrity are so serious that the representations on its responsibilities are unreliable. Under para 20(b), management does not provide those responsibilities representations. Other missing representations lead to a modification under SA 705, depending on materiality and pervasiveness.

What should be the date of the written representations?

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

How are written representations different from other audit evidence?

Written representations are statements from management and are necessary evidence, but they do not on their own give sufficient appropriate evidence. Other evidence, such as external confirmations, is usually more reliable because it comes from independent sources.