## SA 580 – Written Representations

### Meaning

A Written Representation (WR) is a written statement by management provided to the auditor to:

Confirm certain matters, or
Support audit evidence

> Written Representations do NOT include: Financial Statements, the assertions therein, or supporting books and records.

### Critical Limitation

WRs provide necessary audit evidence but do not provide sufficient appropriate audit evidence on their own about any matter with which they deal.

### Three Objectives of the Auditor

#	Objective	Description
I	Obtain WR	Obtain WR from management (and TCWG) confirming they have fulfilled their responsibility for: (a) preparation of FS, and (b) completeness of information provided to the auditor
II	Support other AE	Use WR to support other audit evidence relevant to FS or specific assertions — when auditor determines it necessary or when other SAs require it
III	Respond appropriately	Respond appropriately when WR is provided — or when management/TCWG does not provide the requested WR

### Written Representations about Management's Responsibilities

Confirms fulfilment of management responsibilities in:

Preparation of the Financial Statements
Completeness of information provided and transactions

This is particularly appropriate when:

1. Those who signed the audit engagement terms no longer hold the relevant responsibilities

2. The terms of audit engagement were prepared in a previous year

3. There is indication that management misunderstands its responsibilities

4. Changes in circumstances make it appropriate to do so

Management's responsibilities in the WR shall be described in the same manner as in the terms of the audit engagement.

### Who Can Management Consult Before Providing WR?

Management may consult specialists who participate in preparing FS assertions:

Specialist	Area of Input
Actuary	Actuarially determined accounting measurements
Staff engineers	Environmental liability measurements
Internal counsel	Provisions for legal claims

Worked example

### Example 1

WR is Necessary but Not Sufficient: The auditor asks management for a WR confirming that all known contingent liabilities have been disclosed. Management provides the signed WR. However, the auditor cannot rely solely on this — the auditor must also review legal correspondence, consult with the company's lawyers, and scrutinise board minutes to obtain sufficient appropriate evidence about contingent liabilities. The WR supports but cannot replace this other evidence.

### Example 2

When WR about Management Responsibilities is Needed: An audit engagement letter was signed in FY 2023 by the then-CFO. In FY 2025, a new CFO is appointed. During the FY 2025 audit, the auditor requests a fresh WR because the original signatory no longer holds the relevant responsibilities. This falls under Circumstance 1 — those who signed the engagement terms no longer have the relevant responsibilities.

### Example 3

WR Supported by Specialist Input: Management provides a WR confirming the adequacy of environmental liability provisions of ₹2 crore. Since this requires specialised knowledge, management consulted their staff engineers before signing the WR. The auditor notes this is permissible — management may obtain input from specialists with relevant knowledge before making representations on complex matters.

⚠️ Common exam mistakes

Stating that Written Representations provide sufficient appropriate audit evidence — they provide necessary evidence but NOT sufficient appropriate evidence on their own
Including Financial Statements, balance sheets, or books of accounts within the definition of Written Representations — these are explicitly excluded
Merging the 3 objectives into one — obtaining WR, supporting other AE, and responding appropriately are three distinct objectives under SA 580
Forgetting all four circumstances that make WR about management responsibilities particularly appropriate — especially the circumstance where the engagement letter was signed in a prior year
Missing that management can consult actuaries, engineers, or internal counsel before providing WR — the representation can legitimately reflect specialist input

Reference: Paragraphs 10–16 (Objectives and requirements for written representations) — SA 580 – Written Representations

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