## SA 580: Timing and Period Coverage of Written Representations

### Rule on Date

Written representations must be dated as near as practicable to, but not after, the date of the auditor's report.

Why this timing? The auditor is concerned with events occurring up to the date of the auditor's report that may require adjustment or disclosure. Representations must therefore be current up to that point.

### Rule on Period Coverage

Written representations must cover all financial statements and all periods referred to in the auditor's report — including prior periods.

Why all periods? Management must reaffirm that representations previously made for prior periods remain appropriate.

### Special Situation: Management Change During the Audit Period

New management's argument: "We can only represent periods we were responsible for."

SA 580's position:

The fact that current management was absent during earlier periods does not reduce their responsibility for the financial statements as a whole.
Current management must still provide written representations covering the entire period referred to in the auditor's report.
Their current position carries responsibility for the entity's financial statements in totality — regardless of who ran the company in prior periods.

### Summary

Issue	SA 580 Requirement
Date of representation	As near as practicable to, but not after, auditor's report date
Period covered	All periods referred to in the auditor's report
Management change mid-period	Current management must cover all periods, including before their tenure

Worked example

### Example 1

PQ Ltd. Management Change (MTP 7 & 8): PQ Ltd.'s management changed during the audit period. New management argued they should only provide written representations from the date they took over. Guidance under SA 580: (1) The date of written representation must be as near as practicable to but not after the auditor's report date — not the date management took over. (2) Representations must cover all periods in the auditor's report, including periods under old management. (3) The fact that new management was not present for earlier periods does not diminish their overall responsibility for the financial statements. (4) Therefore, new management must provide written representations covering the entire audit period — the requirement applies to them in full.

⚠️ Common exam mistakes

Allowing new management to limit written representations only to their tenure — SA 580 requires all periods in the auditor's report to be covered regardless of management change
Dating written representations significantly before the auditor's report date — they should be as near as practicable to that date
Dating written representations after the auditor's report date — this is not permissible under any circumstance
Confusing the date of written representations with the date of management's going concern assessment or other specific evaluations

Bare-Act text Date of and Period(s) Covered by Written Representations · SA 580 – Written Representations · click to expand

The date of the written representations shall be as near as practicable to, but not after, the date of the auditor's report on the financial statements. The written representations shall be for all financial statements and period(s) referred to in the auditor's report. Situations may arise where current management were not present during all periods referred to in the auditor's report. This fact does not diminish such persons' responsibilities for the financial statements as a whole. Accordingly, the requirement for the auditor to request from them written representations that cover the whole of the relevant period(s) still applies.

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SA 580 Written Representations — Date, Period Coverage, and Management Change

Worked example

⚠️ Common exam mistakes