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Microlesson · 5-min read

SA-701: Key Audit Matters (KAM)

## SA-701: Communicating Key Audit Matters (KAM)

### Definition

Matters which, in the auditor's professional judgment, were of most significance in the audit of the current period's financial statements.

> Think of KAM as the auditor telling users: "These are the hardest and most important things I had to audit this year."

### Applicability

SA-701 applies to:

1. Listed entities (always mandatory)

2. Circumstances where auditor decides to communicate KAM

3. When required by law to communicate KAM

### Purpose of KAM

1. Ensure communicative value of the auditor's report for users

2. Provide additional understanding about the entity and areas of Significant Management Judgment (SMJ)

### Determining What Qualifies as KAM

A matter is likely a KAM when:

TriggerDescription
High RMM / Significant RiskArea has elevated risk of material misstatement
SMJ with High Estimation Uncertainty (HEU)Management made complex judgments with uncertain outcomes
Significant transaction or eventMajor event occurred during the period affecting FS

### Common Examples of KAM

  • Impairment assessment
  • Taxation matters (multiple jurisdictions, uncertain tax positions)
  • Valuation of financial instruments
  • Revenue recognition
  • Provisions for losses

### Disclosure in the Auditor's Report

  • Separate section with heading: "Key Audit Matters"
  • Each KAM is described with: what the matter is, how it was addressed in the audit

### Critical Limitations — What KAM Is NOT

KAM is NOT a substitute for…Reason
Disclosures required to be made by management in FSManagement's disclosure obligation stands independently
Modified opinion under SA-705If FS are misstated, issue modified opinion — don't just flag as KAM
SA-570 disclosure (going concern uncertainty)Material uncertainty on going concern needs specific SA-570 reporting

KAM does NOT provide a separate opinion on individual matters — it communicates significance, not a conclusion.

### When There Is NO Requirement to Disclose KAM

  • Law precludes the disclosure
  • Adverse effect of disclosure would affect public interest

### Documentation Requirements

Auditor must document:

1. Rationale for determining a matter AS a KAM

2. Rationale when there is no KAM to report

3. Rationale when deciding not to communicate a specific KAM (e.g., public interest exception)

Worked example

### Example 1

Q: XYZ Ltd (a listed company) has significant revenue from long-term construction contracts involving complex percentage-of-completion estimates. Should this be a KAM?

A: Yes. This involves Significant Management Judgment (SMJ) with High Estimation Uncertainty (HEU) — specifically, the percentage-of-completion estimates and revenue recognized. It also carries a high risk of material misstatement. The auditor should disclose it as a KAM under SA-701 in a separate section describing the matter and how the audit addressed it.

### Example 2

Q: During audit, the auditor finds that revenue recognition is a KAM. Can the auditor just report it as KAM instead of issuing a qualified opinion if the revenue is materially misstated?

A: No. KAM is NOT a substitute for a modified opinion. If revenue is materially misstated, the auditor must issue the appropriate modified opinion under SA-705 (qualified, adverse, or disclaimer depending on pervasiveness). KAM reporting and modified opinions serve different purposes and can coexist — one does not replace the other.

### Example 3

Q: An auditor of a listed company concludes there are no Key Audit Matters. What must the auditor document?

A: Even when there are no KAMs, the auditor must document the rationale for concluding that no matter qualified as a KAM. This is a specific documentation requirement under SA-701 and cannot be omitted.

⚠️ Common exam mistakes

  • Thinking KAM is only applicable to listed entities — it also applies when the auditor voluntarily decides to communicate KAM or when law requires it.
  • Confusing KAM with a modified opinion — KAM is a communication about significant audit areas, not a qualification of the opinion.
  • Forgetting that KAM cannot be a substitute for SA-570 disclosures on going concern — both must be done separately if applicable.
  • Missing the documentation requirement when there are NO KAMs — students often only remember documentation when KAM exists.
  • Thinking the auditor never needs to justify NOT disclosing a KAM — the public interest exception still requires documentation of the rationale.
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