Auditing and Ethics · Completion and Review

Written Representations under SA 580

Updated 4 October 2026 · Fact-checked

A written representation is a statement from management, given in writing to the auditor, to confirm certain matters or support other audit evidence. Under SA 580 you request it, evaluate its reliability, and if management refuses or it is doubtful, you take action, which may include modifying your opinion.

Understand Written Representations under SA 580

A written representation is a written statement by management provided to the auditor to confirm certain matters or to support other audit evidence. It is not a separate type of evidence that replaces testing. Written representations are necessary information the auditor requires in connection with the audit of the financial statements. They are audit evidence, but they do not on their own provide sufficient appropriate audit evidence on the matter they cover.

Why does the auditor need it? Some matters cannot be proved fully by documents or tests. Examples are management's intentions, completeness of related party details, or whether all known fraud has been disclosed. Management is best placed to speak on these. A written statement also removes later disputes about what was said orally.

SA 580 asks for two kinds of representations. First, those about management's responsibilities: that it has fulfilled its responsibility for preparing the financial statements in line with the applicable framework (and for internal control, as set out in the terms of the engagement), and that it has given the auditor all relevant information and access, and that all transactions are recorded and reflected in the financial statements. These two requests are mandatory in every audit. Second, other written representations the auditor considers necessary, such as those on specific assertions, or required by other SAs (for example on fraud, litigation, related parties, subsequent events and uncorrected misstatements). Going concern plans is one example. SA 570 requires the auditor to consider requesting written representations on management's plans for future actions relevant to going concern, where applicable. It is not one of the two requests that SA 580 makes in every audit.

The representations are normally given as 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. They cover all periods referred to in the report. Management signs it, usually the person with primary responsibility, such as the CEO and CFO.

If management refuses, or you doubt its integrity or competence, the reliability of its representations is in question. You discuss with management, reassess integrity, and determine the effect on the reliability of representations (oral or written) and on audit evidence in general.

If management does not provide the representations on its responsibilities, or you conclude there is sufficient doubt about its integrity that those representations are not reliable, you take appropriate action. This includes disclaiming an opinion under SA 705, after considering withdrawal where law permits it. For other representations that are not provided, you reassess the reliability of other representations and evidence and modify the opinion as appropriate.

Key rules to remember

Nature of evidence: Written representation = necessary information the auditor requires; audit evidence, but NOT sufficient on its own; It cannot replace other appropriate evidence that should reasonably be available on a matter.
Date of representation letter: Date: as near as practicable to, but not after, the date of the auditor's report; Covers all financial statements and periods referred to in the auditor's report.
Mandatory requests: Responsibility for FS + Information provided and completeness of transactions; These two responsibility representations must be requested in every audit. Other representations, such as management's plans relevant to going concern (which the auditor considers requesting under SA 570 where applicable), are requested as other SAs or the auditor's judgment require.
Doubt about integrity: Doubt about integrity of management → determine effect on reliability of representations and on audit evidence → if responsibility representations are not reliable or not provided → appropriate action, including disclaimer under SA 705; Discuss, reassess integrity, and consider withdrawal where law permits. If the responsibility representations are not provided, or doubt about integrity makes them unreliable, the action includes a disclaimer of opinion under SA 705. For other representations not provided, modify the opinion as appropriate.
Oral representations and inconsistency: Oral representation does not satisfy the requirement for a written representation; inconsistent representation → investigate and reconsider reliability; The auditor may request management to confirm oral representations in writing, but an oral representation cannot satisfy the requirement for a written one. If a representation is inconsistent with other evidence, investigate it and reconsider the reliability of other representations, and possibly management's integrity.

How to solve Written Representations under SA 580 questions

Use this order for any SA 580 question, whether it asks for a definition, a list of contents or a refusal scenario.

1Identify what the question asks: meaning, requirement, form, or a scenario about refusal or doubt.
2State the definition: written statement by management to confirm matters or support other evidence, not sufficient on its own.
3Name the type of representation involved: management's responsibilities (mandatory) or other representations.
4Check form and timing: written, addressed to the auditor, signed by the right person, dated not after the report date and covering all periods.
5Test reliability: is it consistent with other evidence, and do you doubt management's integrity or competence?
6If there is a refusal or doubt, list actions: discuss with management, reassess integrity, determine the effect on the reliability of representations and on audit evidence, and consider withdrawal where law permits.
7Conclude: if the responsibility representations are not provided, or are unreliable because of doubt about integrity, take appropriate action including a disclaimer of opinion under SA 705. For other representations, modify the opinion as appropriate.
8Give a clear conclusion linked to the facts, using the term the question uses.

Quickest way: Provision-facts-conclusion in four lines

When to use it: For scenario questions in the 70-mark descriptive part and for quick MCQ elimination.

Write the rule in one line: representations are necessary but not sufficient evidence.
Write the facts: who refused or what is doubtful, and on which matter.
Apply: discuss, reassess integrity, consider effect on the reliability of representations, other evidence and the report.
Conclude: if responsibility representations are not given or are unreliable, take appropriate action including disclaimer under SA 705, after considering withdrawal where law permits; for other matters, modify the opinion as appropriate. For MCQs, reject options saying representations replace audit procedures, or that oral statements satisfy the written requirement, or that the letter may be dated after the report.

Common mistakes in Written Representations under SA 580

Saying written representations are sufficient evidence so other procedures can be skipped.
Students see that management is confirming a matter and assume it settles the point.
Fix: Write that representations support but never replace other appropriate evidence. Management's statement is not independent.
Dating the representation letter after the auditor's report or well before it.
Students think the letter is part of management's own timetable.
Fix: Remember the rule: as near as practicable to, but not after, the report date.
Treating refusal as only a reason to withdraw.
Students jump to the strongest action.
Fix: Show the sequence: discuss, reassess integrity and reliability, consider effect on evidence, consider withdrawal where law permits, then disclaim or modify the opinion as appropriate.
Confusing a representation letter with an engagement letter.
Both are letters between auditor and management.
Fix: The engagement letter sets terms at the start. The representation letter is management's confirmation near the end.
Accepting representations from any staff member.
Students overlook who is responsible.
Fix: They must come from those with appropriate responsibility and knowledge, usually the CEO and CFO, or equivalent.
Ignoring representations that contradict other evidence.
Students focus on the paper and not on consistency.
Fix: If a representation conflicts with other evidence, investigate and reconsider reliability of other representations too.

Worked examples

Example 1

During the audit of Alpha Ltd, the auditor requests a representation letter containing the representations on management's responsibilities and other representations, including one that all related party relationships have been disclosed. Management refuses to give any of these representations and will not sign any representation letter, saying the auditor can rely on discussions. Advise the auditor.

Show the solution

Rule: SA 580 requires written representations that management has fulfilled its responsibility for the financial statements and has provided all information. Oral statements do not satisfy this requirement.
Facts: management refuses to give any written representation, so the responsibility representations and the other representations, including the related party representation, are not provided.
Action: discuss the matter with management, reassess its integrity, and determine the effect on the reliability of representations and on audit evidence overall.
Consider withdrawal from the engagement where law permits it.
Conclusion on the responsibility representations: because they are not provided, the auditor takes appropriate action, including disclaiming an opinion under SA 705, after considering withdrawal where law permits.
Conclusion on the other representations, such as related parties: where they are not provided, the auditor reevaluates management's integrity and the reliability of other representations and audit evidence, and takes appropriate action, which may include modifying the opinion under SA 705.

Answer: The auditor should discuss with management, reassess integrity, determine the effect on the reliability of representations and audit evidence, and consider withdrawal where law permits. Because the responsibility representations are not provided, the auditor takes appropriate action, including a disclaimer of opinion under SA 705. For the other representations not provided, the auditor reevaluates integrity and the reliability of other representations and takes appropriate action, which may include modifying the opinion under SA 705.

Example 2

Which statement about written representations under SA 580 is correct? (A) They replace the need for substantive procedures. (B) They are necessary information the auditor requires but not sufficient alone on the matter. (C) They may be dated after the auditor's report. (D) Oral representations satisfy the requirement for written representations if recorded in the working papers.

Show the solution

Check A: representations never replace other appropriate evidence, so A is wrong.
Check B: this matches SA 580, since they support but do not substitute other evidence.
Check C: the letter must not be dated after the auditor's report, so C is wrong.
Check D: oral representations do not satisfy the requirement for written representations, so D is wrong.

Answer: (B)

Exam tips

Always state that written representations are necessary but not sufficient evidence. This single line earns marks in definition and scenario answers.
For refusal questions, follow the order: discuss, reassess integrity and reliability, consider effect on evidence, consider withdrawal where law permits, then disclaim (for responsibility representations) or modify (for other representations).
Learn the date rule exactly: not after the date of the auditor's report. Examiners use it in MCQs.
Link SA 580 with other SAs: fraud, litigation, related parties and subsequent events all use representations. Mention this where relevant, and do not call going concern plans a mandatory SA 580 request.
In MCQs, eliminate options that say representations replace procedures or that oral statements satisfy the written requirement.

Practice questions from Completion and Review

Written Representations under SA 580 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 under SA 580: frequently asked questions

What is a written representation under SA 580?

It is a written statement by management given to the auditor to confirm certain matters or to support other audit evidence. It is usually in a representation letter signed by those with the right responsibility.

What if management refuses to give a written representation?

Discuss the matter with management, reassess its integrity, and determine the effect on the reliability of representations and other evidence. If management does not provide the representations on its responsibilities, or doubt about its integrity makes them unreliable, the auditor takes appropriate action, including disclaiming an opinion under SA 705, after considering withdrawal where law permits. For other representations, modify the opinion as appropriate.

Is a management representation the same as audit evidence?

Not exactly. It is a form of audit evidence, but it is not sufficient alone. You must still obtain other appropriate evidence where it can reasonably be expected to exist.

Who should sign the representation letter?

Those with appropriate responsibility for the financial statements and knowledge of the matters, usually the chief executive and chief financial officer or equivalents.