Advanced Auditing, Assurance and Professional Ethics · Completion and Review

SA 580 Written Representations: Objective and Requirements

Updated 5 October 2026

SA 580 deals with written representations the auditor obtains from management and, where appropriate, those charged with governance. They support audit evidence but cannot replace other evidence. You must request representations on management's responsibilities (financial statements and information given) and on other matters, addressed to the auditor, dated as near as practicable to, but not after, the date of the auditor's report.

Understand SA 580 Written Representations: Objective and Requirements

A written representation is a written statement by management given to the auditor to confirm certain matters or to support other audit evidence. It is usually a letter, called the management representation letter. It does not include the financial statements or the books of account themselves.

Why do you get one? Management knows things the auditor cannot fully verify, such as its intentions, completeness of information given and awareness of fraud or litigation. Representations are necessary audit evidence, but they are not sufficient on their own. If management says all related parties are disclosed, you still perform your procedures. A representation never replaces other evidence on a matter that can be verified.

The objectives under SA 580 are three. First, obtain written representations that management believes it has fulfilled its responsibility for preparing the financial statements and for the completeness of information given to you. Second, support other audit evidence relevant to the financial statements or specific assertions, using written representations if the SAs require them or the auditor judges them necessary. Third, respond appropriately to representations provided, or if management does not provide the ones requested.

Who provides them? The auditor requests them from those with appropriate responsibilities for the financial statements and knowledge of the matters concerned. This is usually senior management, for example the CEO and CFO, or equivalent. Where appropriate, the auditor also requests them from those charged with governance (for example the Board). If a person lacks knowledge, the auditor may ask for them to make enquiries first.

SA 580 itself requires two responsibility representations:

Management has fulfilled its responsibility for the preparation of the financial statements in accordance with the applicable framework, including fair presentation where relevant, as set out in the terms of the engagement.
Management has provided you with all relevant information and access as agreed in the terms of the engagement, and all transactions have been recorded and reflected in the financial statements.

Other specific written representations are required by other SAs when they apply. Examples are SA 240 (fraud), SA 550 (related parties), SA 560 (subsequent events) and SA 501 (litigation and claims). You may also request further representations on other matters, such as going concern plans, if you judge them necessary to support other evidence.

Key rules to remember

Nature of evidence: Written representations = necessary audit evidence, but NOT sufficient on their own; They never replace other appropriate audit evidence on a matter that can be verified.
SA 580 representation 1: financial statements: Management confirms it has fulfilled its responsibility for the preparation of financial statements as set out in the engagement terms; Includes fair presentation where the framework requires it; refers to the terms of engagement.
SA 580 representation 2: information, access and transactions: Management confirms it has provided all relevant information and access as agreed in the engagement terms, and that all transactions have been recorded and reflected in the financial statements; Two limbs: completeness of information and access given to the auditor, and recording of all transactions.
Form and addressee: Written representations are in the form of a representation letter addressed to the auditor; Dated as near as practicable to, but not after, the date of the auditor's report on the financial statements.
Who is asked: Those with appropriate responsibilities for the financial statements and knowledge of the matters; Usually senior management; those charged with governance where appropriate.
Other representations: Required by other SAs when they apply (for example SA 240 fraud, SA 550 related parties, SA 560 subsequent events, SA 501 litigation), or requested when the auditor judges them necessary to support other evidence; Other matters you may request on judgement include going concern plans.

How to solve SA 580 Written Representations: Objective and Requirements questions

Use this order for any SA 580 case question. It keeps your answer in provision-facts-conclusion form.

1Identify what is asked: objective, who provides, which representations SA 580 requires, or what to do about a refusal or doubt.
2State the provision in one or two lines, citing SA 580 in plain words.
3Classify the representation in the case: management's responsibilities (the two SA 580 requirements), a matter required by another SA when it applies (such as fraud, related parties, subsequent events or litigation), or another matter requested on judgement.
4Check who gave it: someone with appropriate responsibility and knowledge? Check addressee and date against the report date.
5Ask whether other evidence is available. If it is, the representation only supports it, never replaces it.
6Apply the facts to the provision and note any gap, such as missing item, wrong signatory or wrong date.
7Conclude with the action: accept, ask for corrected letter, perform more procedures, or consider the effect on the opinion.

Quickest way: Four-check scan of the letter

When to use it: Use when a case scenario or MCQ describes a representation letter and asks if it is acceptable.

Who: appropriate senior person with knowledge?
What: both responsibility representations present?
When: dated near, and not after, the report date?
Role: is it treated as support, not as the only evidence?
Any failed check gives your answer: obtain a proper letter or do more work.

Common mistakes in SA 580 Written Representations: Objective and Requirements

Treating the representation letter as sufficient audit evidence on a matter
Students assume a signed confirmation from management is strong evidence.
Fix: Remember it is necessary but not sufficient. Management's statement is not independent, so other evidence is still needed where it can be obtained.
Dating the letter after the auditor's report
Students think the letter can be signed after the report is ready.
Fix: The letter must be dated as near as practicable to, but not after, the date of the auditor's report on the financial statements.
Saying the auditor writes and signs the letter
The auditor often drafts the points, so the roles get mixed up.
Fix: The auditor requests it; management provides it in writing, addressed to the auditor.
Listing only matters like fraud and litigation and forgetting the responsibility representations
Other matters feel more exam-friendly and memorable.
Fix: Start with the two mandatory ones: responsibility for the financial statements and completeness of information and transactions.
Assuming only the CFO or only the auditor's client contact may sign
Students memorise one designation instead of the rule.
Fix: Write the rule: those with appropriate responsibilities for the financial statements and knowledge of the matters, usually senior management, and those charged with governance where appropriate.

Worked examples

Example 1

Case: Meridian Traders Ltd. is audited by CA Rao. The auditor reports on 20 May. Management signed a representation letter on 28 May covering fair presentation and information given. The inventory valuation is verifiable from the count records, but the auditor proposes to rely only on management's written statement of its value. Comment.

Show the solution

Provision: a representation letter is dated as near as practicable to, but not after, the date of the auditor's report. The report cannot be dated earlier than the date on which the auditor has obtained all the audit evidence, including the representations, and the financial statements have been approved (SA 700). So the letter date must be no later than the report date. Representations are necessary but not sufficient evidence.
Fact 1: the letter is dated 28 May, after the 20 May report date. The representations were obtained on 28 May, so a report dated 20 May is premature.
Fact 2: inventory value can be verified through count records, so other evidence is available.
Application: the auditor should not date the report 20 May. The report should be dated no earlier than 28 May, once the representations are obtained, all other evidence is complete and the financial statements are approved. The letter should then be dated as near as practicable to, but not after, that report date. The letter must not be backdated to 20 May. Reliance on the representation alone for inventory is also wrong, as it cannot replace other appropriate audit evidence.

Answer: The approach is not acceptable. A report dated 20 May is premature because the representations were obtained only on 28 May. The auditor should date the report no earlier than 28 May, when all evidence including the representations is obtained and the financial statements are approved. The letter should be dated as near as practicable to, but not after, that report date, and it must not be backdated. The auditor should also test inventory using the count records and other procedures, using the representation only as support.

Exam tips

In case MCQs, check date, signatory and addressee before anything else; wrong date is a favourite trap.
Write both mandatory representations by name in long answers, then add other matters as examples.
Always say representations support but do not replace other audit evidence.
Use provision-facts-conclusion layout, and end with the action the auditor takes.
Keep this topic separate from refusal and unreliability, which is examined as its own area.

Practice questions from Completion and Review

SA 580 Written Representations: Objective and Requirements: frequently asked questions

What is the objective of SA 580?

The auditor obtains written representations that management has fulfilled its responsibility for preparing the financial statements and for providing complete information and recording all transactions. The auditor also uses them to support other audit evidence and responds appropriately if management does not provide them. They are requested from management and, where appropriate, those charged with governance.

Who signs the management representation letter?

Those with appropriate responsibilities for the financial statements and knowledge of the matters concerned sign it. This is usually senior management such as the CEO and CFO, and those charged with governance may be involved where appropriate.

Can a representation letter replace other audit evidence?

No. It is necessary evidence but not sufficient. Where other evidence can reasonably be obtained, the auditor must still obtain it.

What is the date of the representation letter?

It should be dated as near as practicable to, but not after, the date of the auditor's report on the financial statements.