## SA 580: Date, Form, Reliability & Non-Provision of Written Representations
### Date & Period Covered
| Requirement | Rule |
|---|---|
| Date of WR | As near as practicable to, but not after, the date of the auditor's report |
| Period covered | All financial statements and period(s) referred to in the auditor's report |
| Timing constraint | Auditor cannot express opinion or date the report before the WR is received |
| New management | Still responsible for the whole period – must provide WR covering all relevant periods |
> Why this rule? The auditor is concerned with events up to the report date – WRs must cover that same horizon.
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### Form of Written Representations
- Must be a representation letter addressed to the auditor
- If law/regulation requires management to make written public statements about its responsibilities, and those cover the required representations, those matters need not be repeated in the representation letter
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### Doubt About Reliability – ECID Framework
If the auditor has concerns about management's:
- E – Ethical values
- C – Competence
- I – Integrity
- D – Diligence
...or its commitment to/enforcement of these, the auditor must assess the effect on reliability of both WR and audit evidence generally.
If WR are inconsistent with other audit evidence:
1. Perform audit procedures to resolve the matter
2. If unresolved → reconsider ECID assessment of management
3. If WR concluded unreliable → take appropriate action, including considering a disclaimer of opinion (SA 705)
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### When Requested WR Are Not Provided – DAR
| Step | Action |
|---|---|
| D – Discuss | Discuss the matter with management |
| A – Appropriate action | Determine possible effect on audit opinion per SA 705 (including disclaimer of opinion) |
| R – Re-evaluate | Re-evaluate integrity of management and effect on reliability of all representations and audit evidence |
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### When Disclaimer of Opinion is Mandatory
The auditor shall (mandatory) disclaim an opinion if either condition is met:
(a) Sufficient doubt about management's integrity such that WR about management's responsibilities (FS preparation and completeness of information) are not reliable
OR
(b) Management does not provide the WR relating to:
- Fulfilling responsibilities for FS preparation
- Information provided and completeness of transactions
> This is a 'shall' requirement – it is mandatory, not discretionary.