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Microlesson · 5-min read

SA 260 – Communication with Those Charged with Governance

# SA 260: Communication with Those Charged with Governance (TCWG)

## Who Are TCWG?

Those Charged with Governance (TCWG) are person(s) or organisation(s) responsible for:

  • Overseeing the strategic direction of the entity
  • Obligations related to the accountability of the entity
  • Overseeing the financial reporting process
Governance StructureExample
Separate supervisory + executive boardsLarge corporates
Single combined boardMid-size companies
Governance embedded in legal structureCompany directors
One person (owner-manager or sole trustee)Small/sole-proprietor entities
Governance not formally definedFamily-owned entities, some NPOs

> In cases where appropriate persons are not clearly identifiable, the auditor must discuss and agree with the engaging party who to communicate with.

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## Objectives of the Auditor Under SA 260

1. Communicate the auditor's responsibilities and an overview of the planned scope and timing of the audit

2. Obtain information relevant to the audit from TCWG

3. Provide timely observations significant to TCWG's oversight of the financial reporting process

4. Promote effective two-way communication between auditor and TCWG

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## Why Two-Way Communication Matters

Effective two-way communication assists:

BeneficiaryHow It Helps
Both auditor + TCWGUnderstand audit matters in context; develop constructive working relationship (without compromising independence)
AuditorObtains audit-relevant information — entity context, evidence sources, specific transactions/events
TCWGFulfils oversight responsibility → reduces Risk of Material Misstatement (ROMM)

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## Matters the Auditor Must Communicate

### 1. Auditor's Responsibilities

  • Auditor forms and expresses an opinion on the FS prepared by management under TCWG oversight
  • The audit does not relieve management or TCWG of their own responsibilities

### 2. Planned Scope and Timing

  • Overview of planned scope and timing, including significant risks identified

### 3. Significant Findings

  • Views on significant qualitative aspects: accounting policies, estimates, disclosures
  • Significant difficulties encountered during the audit
  • (Unless all TCWG are involved in managing the entity):
  • Significant matters discussed with, or subject to correspondence with, management
  • Written representations the auditor is requesting
  • Circumstances affecting the form and content of the auditor's report
  • Any other significant matters in the auditor's professional judgment

### 4. Independence — Listed Entities Only

  • A statement that the engagement team, the firm, and (if applicable) network firms have complied with relevant ethical requirements on independence
  • All relationships/matters between the firm, network firms, and the entity that may bear on independence — including total fees for audit and non-audit services
  • Related safeguards applied to eliminate or reduce threats to independence

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## The Communication Process

AspectRequirement
Form, timing, contentAuditor shall communicate these expectations to TCWG upfront
Significant findingsIn writing if oral communication would not be adequate
Written communicationsNeed NOT include all audit matters — only significant ones
Independence (listed entities)Must always be in writing
TimelinessAll communications must be timely

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## Evaluating the Adequacy of Communication

  • Auditor must evaluate whether two-way communication was adequate for audit purposes
  • If inadequate → evaluate effect on ROMM assessment and ability to obtain sufficient appropriate evidence → take appropriate action

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## Documentation

Mode of CommunicationDocumentation Requirement
OralRecord in audit documentation: what was communicated, when, and to whom
WrittenRetain a copy of the written communication in audit documentation

Worked example

### Example 1

Example 1 — Identifying TCWG in different entity types:

Scenario A: ABC Ltd. is a listed company with a Board of Directors and an Audit Committee. The Audit Committee oversees financial reporting.

TCWG = Audit Committee (primary recipient of SA 260 communications), with the full Board as secondary.

Scenario B: Mr. Sharma is both the sole owner and the sole director of a small private company. He manages day-to-day operations.

TCWG = Mr. Sharma (owner-manager). However, since he is also management, some communication requirements (e.g., matters discussed with management) may not apply separately.

Scenario C: A family-owned partnership has no formal governance structure.

→ Auditor must discuss and agree with the engaging party to identify appropriate persons for communication.

### Example 2

Example 2 — Independence communication for a listed entity:

During the audit of XYZ Ltd. (a listed company), the auditor's firm also provided tax advisory services to a subsidiary of XYZ Ltd. Total fees: ₹15 lakh (audit) + ₹5 lakh (tax advisory).

The auditor must communicate in writing to TCWG:

  • Statement that the team, firm, and network firms have complied with independence requirements
  • Disclosure of the tax advisory relationship and total fees (₹20 lakh across services)
  • Safeguards applied (e.g., separate team for advisory, partner review for independence threats)

This is NOT required for non-listed entities.

⚠️ Common exam mistakes

  • Treating 'management' and 'TCWG' as always the same — they can overlap (e.g., owner-manager) but are conceptually distinct; some communication requirements only apply when they are different persons
  • Assuming written communication is always required — oral may suffice for most matters; written is mandatory only for significant findings where oral is inadequate, and for independence in listed entities
  • Forgetting that independence communication under SA 260 is exclusive to listed entities — non-listed entities are exempt from this specific requirement
  • Confusing the auditor's role (expressing an opinion on FS) with TCWG's role (oversight of financial reporting) — the audit does not transfer TCWG's responsibility to the auditor
  • Thinking the auditor must communicate ALL matters that arose during the audit in writing — written communications need not be exhaustive, only covering significant matters
Bare-Act text Objectives of the Auditor · SA 260 (Revised) issued by ICAI · click to expand
The objective of the auditor is to communicate clearly with those charged with governance the responsibilities of the auditor in relation to the financial statement audit, and an overview of the planned scope and timing of the audit; obtain from those charged with governance information relevant to the audit; provide those charged with governance with timely observations arising from the audit that are significant and relevant to their responsibility to oversee the financial reporting process; and promote effective two-way communication between the auditor and those charged with governance.
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