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Microlesson · 5-min read

SA 330 - The Auditor's Responses to Assessed Risks

# SA 330 — The Auditor's Responses to Assessed Risks

## Auditor's Responsibility

The auditor must design and implement responses to the ROMM identified and assessed under SA 315.

In designing Further Audit Procedures (FAP), the auditor shall:

  • Consider reasons for the risk assessment at the assertion level for each CAD — including both inherent risk and control risk
  • Obtain more persuasive audit evidence when the auditor's assessment of risk is higher

## When Must the Auditor Perform Tests of Controls (TOC)?

TOC must be performed to obtain SAAE about operating effectiveness of controls when:

1. The auditor's assessment of ROMM at assertion level includes an expectation that controls are operating effectively (i.e. the auditor intends to rely on controls), OR

2. Substantive procedures alone cannot provide SAAE at the assertion level (e.g. highly automated processing with no paper trail).

> When the audit approach consists mainly of TOC (because substantive procedures alone are insufficient), a higher level of assurance about IC operating effectiveness is required.

> When more persuasive evidence is needed about IC effectiveness → increase the extent of TOC and the degree of reliance on controls.

## Matters Determining Extent of TOC

  • Relevance and reliability of audit evidence on operating effectiveness
  • Extent to which evidence is obtained from tests of other controls
  • Length of time the auditor is relying on operating effectiveness
  • Frequency of performance of the control during the period
  • Expected rate of deviation from the control

## Using Audit Evidence Obtained in Previous Audits

To decide whether evidence from prior periods can be used, consider:

  • ROMM and the extent of reliance on the control
  • Risks from nature of control — manual vs automated
  • Effectiveness of the control and its application — including nature of deviations
  • Effectiveness of general IT-controls
  • Effectiveness of other IC elements — control environment, monitoring, RAP
  • Whether lack of change in the control poses risk due to changing circumstances

## Deviations Detected During TOC

When deviations are detected, the auditor shall make specific inquiries and determine whether:

  • TOC performed provide an appropriate basis for relying on controls
  • Additional TOCs are necessary, OR
  • The potential ROMM needs to be addressed using substantive procedures

## Substantive Procedures

Substantive procedure = an audit procedure designed to detect material misstatement (MM) at the assertion level. It comprises:

### A. Tests of Details (TOD)

  • Tests of transactions — i.e. vouching
  • Tests of balances — i.e. verification

### B. Substantive Analytical Procedures (SAP)

  • Governed by SA 520

## Mandatory Substantive Procedures — Even at Low Assessed Risk

The auditor must perform substantive procedures even when assessed ROMM is LOW, because:

  • The auditor's assessment of risk is judgmental and may not identify all ROMM.
  • IC has inherent limitations (collusion, management override, human error).

## Mix of Substantive Procedures — Auditor's Judgment

Depending on circumstances, the auditor may decide:

  • Only SAP is sufficient to reduce audit risk to an acceptably low level
  • Only TOD are appropriate
  • A combination of SAP and TOD is most responsive

> Extent of substantive procedures is INCREASED when results of TOC are UNSATISFACTORY (because controls cannot be relied upon).

## Relationship: ROMM ↔ Audit Evidence

Assessed ROMMEvidence Required
Higher ROMMMore persuasive audit evidence
Lower ROMMLess persuasive (but still required — substantive procedures cannot be eliminated)

## Quick Summary Map

```

SA 315 (identify & assess ROMM)

SA 330 (respond to ROMM)

┌────┴────┐

TOC Substantive Procedures (mandatory)

┌──────┴──────┐

TOD SAP (SA 520)

(Vouching +

Verification)

```

Worked example

### Example 1

Example 1 — When TOC is mandatory: XYZ Ltd processes 10,000 online sales transactions daily through a fully automated e-commerce system; there are no paper invoices or human approvals. Substantive procedures ALONE cannot provide SAAE because there is no trail to vouch. → Auditor MUST perform TOC on the automated application controls and general IT controls.

### Example 2

Example 2 — Reliance on prior audit evidence: During the FY 2025-26 audit, the auditor wants to rely on TOC performed on the purchase authorisation control in the prior year audit. The control is automated, there have been no system changes, general IT controls are effective, and no deviations were noted last year. → He may use prior period evidence, but must still test some controls in the current period and document the rationale.

### Example 3

Example 3 — Mix of TOD and SAP: For auditing payroll of a company with 5,000 employees: (i) Substantive Analytical Procedures — compare current month payroll expense with prior month and budget, expecting ~3% increase due to annual hike (SAP); (ii) Tests of Details — vouch a sample of 25 employees' joining letters and CTC offers to payroll register (TOD - vouching); (iii) verify the year-end payroll payable balance with the GL and bank confirmation (TOD - verification).

### Example 4

Example 4 — Response to deviation: Auditor tests 25 purchase orders for evidence of authorisation (TOC). Finds 5 without authorisation (20% deviation rate vs expected 2%). Auditor must (i) extend sample size, (ii) consider whether reliance on the control is appropriate, (iii) if reliance is no longer appropriate, INCREASE substantive procedures (more detailed vouching of purchases).

⚠️ Common exam mistakes

  • Believing that if controls are tested and found effective, no substantive procedures are needed — SUBSTANTIVE PROCEDURES ARE ALWAYS REQUIRED for material classes/balances, even at low assessed risk, because of judgmental risk assessment and inherent limitations of IC.
  • Performing TOC even when the auditor does NOT intend to rely on controls — TOC is mandatory only when (a) auditor expects controls to operate effectively, OR (b) substantive procedures alone cannot provide SAAE.
  • Treating prior period evidence on controls as automatically usable — auditor MUST consider factors like nature of control (manual/automated), changes in circumstances, general IT controls, and effectiveness of other IC elements.
  • Reducing substantive procedures when TOC results are UNSATISFACTORY — actually, when TOC results are unsatisfactory, EXTENT OF SUBSTANTIVE PROCEDURES MUST BE INCREASED.
  • Confusing 'Tests of Details (TOD)' with 'Substantive Procedures' as a whole — TOD is a SUBSET of substantive procedures, the other subset being Substantive Analytical Procedures (SAP) under SA 520.
  • Forgetting that 'tests of details' has two parts: tests of TRANSACTIONS (vouching) and tests of BALANCES (verification).
  • Missing the link between SA 315 and SA 330 — SA 330 is the RESPONSE to risks identified under SA 315; both must be discussed in problems on auditor's response.
Bare-Act text SA 330 — The Auditor's Responses to Assessed Risks · Standards on Auditing (SA) issued by ICAI · click to expand
SA 330 — The Auditor's Responses to Assessed Risks: The objective of the auditor is to obtain sufficient appropriate audit evidence regarding the assessed risks of material misstatement, through designing and implementing appropriate responses to those risks. The auditor shall design and implement overall responses to address the assessed risks of material misstatement at the financial statement level. The auditor shall design and perform further audit procedures whose nature, timing and extent are based on and are responsive to the assessed risks of material misstatement at the assertion level. The auditor shall design and perform tests of controls to obtain sufficient appropriate audit evidence as to the operating effectiveness of relevant controls if: (a) The auditor's assessment of risks of material misstatement at the assertion level includes an expectation that the controls are operating effectively; or (b) Substantive procedures alone cannot provide sufficient appropriate audit evidence at the assertion level. Irrespective of the assessed risks of material misstatement, the auditor shall design and perform substantive procedures for each material class of transactions, account balance, and disclosure.
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