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Updates from NFRA

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There are no updates in January 2022
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November 2022

On 11 November 2022, the National Financial Reporting Authority (NFRA) published its audit quality inspection guidelines. The overall objective of inspections is to evaluate compliance of the audit firm/auditor (together termed as ‘auditors’) with auditing standards and other regulatory and professional requirements, as well as the sufficiency and effectiveness of quality control system of the auditors including:

  • Adequacy of governance framework and its functioning
  • Effectiveness of firm’s internal control over audit quality
  • System of assessment and identification of audit risks and mitigating measures.

Further the guidelines discuss the following aspects:

  • Criteria and scope
  • Methodology for selection
  • Inspections
  • Inspection report.

Criteria and scope

Criteria: The criteria for audit quality inspections include :

  • Provisions in the Companies Act 2013, NFRA Rules, 2018 and amendments thereof
  • Standard on Quality Control (SQC) 1, including code of Ethics
  • Standards of Auditing
  • Policies , guidelines, manuals etc. of the audit firm
  • Ind AS as may be applicable to selected individual audit engagements
  • Relevant circulars/directions of other regulators as applicable
  • Directions issued by internal quality boards/committees and Quality Review Board (QRB), ICAI as may be applicable.

Scope: The scope of audit and a change in the scope of audit would be intimated to auditors. Inspections could also lead to financial reporting quality reviews of financial statements of the companies whose audits are selected for inspections

Methodology for selection

Selection of auditors: Selection of audit firms and determination of periodicity of their inspections is based on:

  • Assessment of risks in the audit environment
  • Size of the firm
  • Composition and nature of the audit firm
  • Number of audit engagements completed in the year end review
  • Complexity and diversity of preparer financial statements audited by the audit firm
  • Specific concerns highlighted by the government
  • Other indicators as determined by NFRA

Selection of audit assignment: : Selection of audit engagement will be on the basis of both risk based and random selection and also on the basis of financial and non-financial indicators identified by NFRA.

Inspections

For the purpose of inspections, NFRA will issue questionnaires and request auditors to keep relevant records ready. Further, the inspection has been explained as below.

  • Start of inspection: At the start of inspections, NFRA will hold meeting with senior management of audit firms to understand working of the auditors and/or have enquiry meeting(s) with audit engagement team
  • Execution cycle:The execution cycle will comprise site-visits, interviews, review of controls, substantive testing, issue of queries and observations and follow-up of previously issued observations (in case of recurring inspections). Auditors would be required to provide written responses to queries, observations, confirmations etc.
  • Closing: Inspections would close with a meeting with the senior management of the audit firm or with the auditor, and issuance of a draft inspection report for obtaining responses of the auditors.

Inspection report

The inspection report would comprise the NFRA’s inspection approach in brief, findings or non-compliances, responses of the auditors, NFRA’s conclusions and recommendations and any other matter deemed significant by the inspection team.

(Source: Foundation for Audit Quality’s analysis, 2022 read with NFRA press release id: 1875275, dated 11 November 2022)


To access the text of the audit quality inspection guidelines, please click here

There are no updates in December 2022
There are no updates in January 2023
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June 2023

On 26 June 2023, the National Financial Reporting Authority (NFRA) issued a circular regarding statutory auditors’ responsibilities in relation to fraud in a company. Following are some of the important points discussed in the circular:

  • The circular reiterates that the auditor has a responsibility to report fraud or suspected fraud under the Companies Act, 20131 Section 143(12) of the Companies Act, 2013 and related Rules place certain reporting obligations on the auditor in relation to frauds. , the Companies (Auditor’s Report) Order (CARO) 20202 Clause (xi) of CARO 2020 requires auditors to make statements relating to reporting of fraud in his/her report. and SA 240, The Auditor’s Responsibilities Relating to Fraud in an Audit of Financial Statements . The circular also emphasises that resignation does not absolve an auditor of his/her responsibility to report fraud or suspected fraud as mandated by the law
  • Statutory auditors have a mandatory obligation to report fraud or suspected fraud if they observe any suspicious activities, transactions or operating circumstances in a company that indicate reasons to believe that an offence of fraud is being or has been committed against the company by its officers or employees. In such an event, he/she should initiate the steps prescribed under Rule 13 of the Companies (Audit and Auditors) Rules, 2014, i.e., reporting the matter to the board/audit committee within two days of his/her knowledge of the fraud
  • In situations, wherein the reporting of a fraud involves or is expected to involve individually an amount of rupees one crore or above, and the statutory auditor fails to get any reply/observations from the board/audit committee within 45 days, then he/she should forward a report in the specified form i.e., ADT-4 to the MCA secretary. This requirement would also be applicable in cases wherein the statutory auditor is not the first person to identify the fraud/suspected fraud
  • Additionally, the circular also highlights that the statutory auditor should exercise his/her own professional skepticism while evaluating fraud and need not be influenced by legal opinion provided by the company or its management.

To access the text of the circular, please click here

There are no updates in July 2023
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There are no updates in September 2024
October 2024

The National Financial Reporting Authority (NFRA) on 3 October 2024 issued a circular detailing the responsibilities of Principal Auditors and Other Auditors in group audits (the circular). The circular clarifies auditors' obligations under the Companies Act 2013 and existing requirements in SA 600, "Using the Work of Another Auditor," and related standards ensuring consistent interpretation with the Companies Act, 2013, Standard on Quality Control (SQC), and other applicable auditing standards.

Key points covered in the circular include:

  • Principal auditors’ responsibility: The principal auditor is ultimately responsible for reporting on group financial statements and must ensure that significant risks of the group companies are addressed. While SA 600 does not specifically mention reviewing the audit work papers of component auditors or other auditors by the principal auditor is required, such a review may be necessary to gather sufficient appropriate audit evidence and form an appropriate opinion on the group financial statements and should be done by an auditor in appropriate cases, in exercise of his professional duties, professional skepticism and professional judgement. The circular states that the requirements of the standards on auditing, which are governed by the Companies Act, 2013 would override the provisions of the Chartered Accountants Act, 1949, which prohibits a chartered accountant from disclosing confidential information of his/her client with any person other than his/her client3 Currently, chartered accountants in practice do not share workpapers with group auditors citing prohibition under this clause. . Currently, chartered accountants in practice do not share workpapers with group auditors citing prohibition under this clause.
  • Understanding Professional Competence of Component Auditors: Paragraph 11 of SA 600 requires the principal auditor to assess the professional competence of another auditor when planning to use their work, especially if the other auditor is not a member of the ICAI. This provision does not imply that the principal auditor should not or cannot evaluate the professional competence of the other auditor in the context of the specific assignment even if the other auditor is a member of the ICAI. The NFRA emphasises that professional competence includes experience, relevant skills, sectors audited, complexity of audit assignments handled, and availability of adequate resources, beyond just acquiring a professional degree or certification.
  • Interpreting Standards on Auditing: The word "should" in SA 600 implies mandatory responsibilities of auditors and is not recommendatory. Principal Auditors must perform all procedures specified in SA 600 and related standards in fulfilment of their obligations under the 2013 Act, unless they have valid reasons for carrying out alternative procedures that achieve the same objectives without materially impacting their opinion on the accounts being true and fair.

This circular applies to auditors of all entities covered under Rule 3 of NFRA Rules 2018 (i.e., Public Interest Entities (PIEs) and large Non-PIEs) with immediate effect i.e. 3 October 2024.


To access the circular, please click here

Action points for auditors

  • Principal auditors of the group financial statements would need to assess this circular and its implications on group audits.
There are no updates in November 2024

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