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Microlesson · 5-min read

SA 210 - Agreeing to Terms of Audit Engagements

# SA 210: Agreeing to the Terms of Audit Engagements

## The Engagement Process — Flow

```

Client (X Ltd) → Inquiry (1) → Auditor (ABC & Co.)

Auditor → Proposal (2) → Client

Client → Letter of Appointment (5) → Auditor

Auditor → Terms of Engagement (3) → Client

Letter of Engagement (4)

```

## A. Preconditions Before Accepting the Audit

The auditor must:

1. Determine whether the Financial Reporting Framework (FRF) is acceptable

2. Obtain management's agreement on their responsibilities:

  • Preparation of financial statements
  • Maintaining internal control (IC)
  • Providing the auditor:
  • (a) Access to information
  • (b) Access to additional information on request
  • (c) Unrestricted access to persons within the entity

> Rule: If preconditions are absent → Do NOT accept the audit engagement.

## B. Contents of Engagement Letter — Mnemonic: FORAM

LetterContent
FIdentification of the applicable Financial Reporting Framework
OObjective and scope of the audit
RReference to expected form and content of reports to be issued (including note that reports may differ from expected form)
AResponsibilities of the Auditor
MResponsibilities of Management

> Exception: If law or regulation prescribes the terms in sufficient detail, no written agreement is needed — except to note that such law applies and management acknowledges its responsibilities.

## C. Limitation on Scope of Audit (LOSA) — Three Sources

SourceExample
Circumstances beyond entity's controlNatural disaster destroying records
Nature and timing of audit proceduresInventory count impossible after year-end
Imposed by managementManagement refuses access to certain documents

## D. LOSA Imposed at the Beginning (Before Accepting)

```

Management / TCWG imposes LOSA

Auditor evaluates possible effects

If LOSA will result in a disclaimer of opinion

DO NOT ACCEPT the appointment

(unless required by law or regulation to do so)

```

## E. Change in Terms of Engagement — During the Audit

```

Management requests a change in Terms of Engagement (TOE)

Auditor inquires about the reasons

┌─────────────────────────┬────────────────────────────────────┐

│ VALID (reasonable │ INVALID │

│ justification) │ │

│ ↓ │ ↓ │

│ Accept, but only │ Do NOT accept │

│ IN WRITING │ If management still won't allow │

│ │ original engagement to continue │

│ │ ↓ │

│ │ ROSA (Restriction on Scope) │

│ │ ↓ │

│ │ WITHDRAW │

│ │ (after fulfilling legal │

│ │ obligations) │

└─────────────────────────┴────────────────────────────────────┘

```

### When is justification reasonable?

  • Change in circumstances affecting the need for the service
  • Misunderstanding as to the nature of the audit originally requested
  • Restriction on the scope of the engagement
  • Change in the entity's requirements

### When is it NOT reasonable?

  • When the change relates to information that is incorrect, incomplete, or otherwise unsatisfactory
  • Classic example: Auditor cannot obtain SAAE regarding receivables → client asks to change to a review engagement to avoid a qualified/disclaimer opinion → NOT acceptable

### Before agreeing to a lower-assurance engagement:

  • Assess legal or contractual implications of the change
  • The new report must NOT reference the original audit engagement or procedures (to avoid confusing readers)
  • Exception: If changed to agreed-upon procedures, referencing procedures is normal and expected

### If auditor cannot agree and is not permitted to continue:

(a) Withdraw from the engagement (where possible under law/regulation)

(b) Determine reporting obligations — whether to report circumstances to TCWG, owners, or regulators

## F. Recurring Audit — When to Issue a Fresh Engagement Letter?

Mnemonic: MORONS

LetterCircumstance
MEntity Misunderstands the objective and scope
OSignificant change in Ownership
RChange in legal or Regulatory requirement
OChange in Other reporting requirements
NChange in Nature and size of the entity's business
SRecent change of Senior management

Worked example

### Example 1

Invalid change in TOE: During the audit of ABC Ltd, the auditor cannot obtain SAAE for trade receivables. Management asks to convert the engagement to a review engagement. Should the auditor accept?

No. This is an INVALID reason. The change is requested specifically to avoid a qualified or disclaimer of opinion — not due to a genuine change in circumstances. The auditor should not agree and may need to withdraw.

### Example 2

Management-imposed LOSA mid-audit: Management restricts the auditor's access to warehouse records, limiting the audit scope. What should the auditor do?

→ Evaluate the effect. If the limitation will result in a disclaimer of opinion, consider withdrawing. If management won't allow the original engagement to continue, WITHDRAW after fulfilling all legal obligations and consider reporting to TCWG or regulators.

### Example 3

Recurring audit — fresh letter needed? XYZ Ltd brings in new foreign promoters and completely changes its ownership structure. Should the auditor issue a fresh engagement letter?

Yes. Significant change in ownership is a MORONS trigger — a new engagement letter is required.

### Example 4

Change of terms — written record: Management verbally agrees to a change in audit scope. Can the auditor proceed on the basis of verbal agreement?

No. Any change in terms of engagement must be agreed upon and recorded in writing — a verbal agreement is not sufficient under SA 210.

⚠️ Common exam mistakes

  • Confusing LOSA at the beginning (don't accept) with LOSA during the audit (evaluate effects, then consider withdrawing) — the auditor's response is different depending on WHEN the limitation arises.
  • Forgetting that changes to the terms of engagement must always be recorded IN WRITING — verbal acceptance is insufficient.
  • Not knowing that the new report on a changed engagement should NOT reference the original audit engagement or procedures (except agreed-upon procedures).
  • Confusing FORAM — the 'R' stands for Reference to the form and content of the REPORT, not 'Responsibilities' (which is covered by A and M).
  • Thinking a recurring audit always needs a fresh engagement letter — it is only required when one of the MORONS circumstances occurs.
  • Missing that if LOSA would lead to a disclaimer of opinion, the auditor must refuse appointment at the outset — not just qualify the report.
Bare-Act text SA 210, Paragraph 9-10 · SA 210 - Agreeing the Terms of Audit Engagements (ICAI) · click to expand
SA 210 requires the auditor to agree on the terms of the audit engagement with management or those charged with governance, as appropriate. The agreed terms shall be recorded in an audit engagement letter or other suitable form of written agreement.
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