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Microlesson · 5-min read

SA 701 — Key Audit Matters (KAM)

## SA 701: Communicating Key Audit Matters in the Auditor's Report

### Applicability

SA 701 applies to audits of:

  • Listed entities
  • Entities where required by law or regulation
  • Public interest entities

> SA 701 does not apply to all companies — only to listed and notified entities.

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### What are Key Audit Matters (KAM)?

KAM are those matters that, in the auditor's professional judgement, were of most significance in the audit of the FS in the current period.

  • KAM are selected from matters communicated with TCWG (Those Charged with Governance).
  • KAM shall not pertain to previous years' audit matters.

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### How to Determine KAM — Three Criteria

The auditor selects matters that required significant auditor attention:

CriterionDescription
1. Higher Risk of Material Misstatement (ROMM)Areas with higher assessed ROMM or significant risks per SA 315
2. Significant Management JudgementAreas involving high estimation uncertainty or complex accounting estimates
3. Significant Events or TransactionsImpact of significant events/transactions that occurred during the period

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### Communicating KAM

  • KAM are matters of most significance addressed during the audit.
  • The auditor does not provide a separate opinion on KAM — they are communicated for transparency.
  • KAM are discussed in the context of the audit as a whole.

### When KAM Will NOT Be Communicated

1. Laws or regulations prohibit disclosure

2. Possible adverse consequences of disclosure (e.g., commercially sensitive)

3. Highly confidential information

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### Objective of SA 701

1. To enhance communicative value of the audit report through greater transparency.

2. To assist users in understanding matters of most significance in the audit of current period FS.

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### What KAM is NOT a Substitute For

KAM Cannot ReplaceReason
Disclosures in FSManagement's disclosure duty remains
Modified opinion (SA 705)KAM is not a qualification
Going Concern reporting (SA 570)Separate obligation
Separate opinion on individual mattersKAM is part of the holistic audit report

Worked example

### Example 1

Example 1 — Identifying KAM:

During the audit of a real estate company (listed), the auditor identifies the following: (a) valuation of unsold inventory involving significant management estimates, (b) a routine payroll processing review, (c) a major acquisition completed during the year.

Which of these qualify as KAM?

Answer:

  • (a) KAM — involves significant management judgement and high estimation uncertainty (Criterion 2).
  • (b) Not KAM — routine payroll is not a matter of most significance.
  • (c) KAM — a significant transaction during the period (Criterion 3).

KAM would be reported for (a) and (c) in the audit report.

### Example 2

Example 2 — KAM vs. Modified Opinion:

The auditor identifies a highly material issue with revenue recognition but reports it only as a KAM in the audit report. Is this correct?

Answer: No. KAM is not a substitute for a modified opinion under SA 705. If the issue is material enough to affect the overall truth and fairness of the FS, the auditor must issue a Qualified or Adverse Opinion. KAM merely highlights significant audit focus areas — it does not replace the auditor's duty to modify the opinion when warranted.

⚠️ Common exam mistakes

  • Thinking KAM applies to all companies — it applies only to listed entities, entities required by law, and public interest entities.
  • Confusing KAM with 'Emphasis of Matter' (EMP) — EMP highlights already-disclosed matters; KAM reports significant audit focus areas.
  • Stating that KAM can relate to prior year audit matters — KAM must pertain to the CURRENT period only.
  • Treating KAM as a separate opinion on specific items — the auditor explicitly does NOT give a separate opinion on KAM.
  • Forgetting that KAM are selected only from matters communicated with TCWG (Those Charged with Governance).
Bare-Act text Definition and Determination of KAM · SA 701 — Communicating Key Audit Matters in the Independent Auditor's Report (ICAI) · click to expand
Key Audit Matters are those matters that, in the auditor's professional judgement, were of most significance in the audit of the financial statements of the current period. Key audit matters are selected from matters communicated with those charged with governance.
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