## Other Written Representations (SA 580)

### What Are They?

These supplement but do not form part of the Written Representation (WR) relating to management's core responsibilities. They cover:

Appropriateness of accounting policy selection and application
Plans or intentions affecting the carrying value of assets
Liabilities (actual or contingent)
Title to / control over assets; liens or encumbrances; assets pledged as collateral
Aspects of laws, regulations, and contractual agreements affecting the FS (including non-compliance)

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### Date of Written Representation

Should be as near as practicable but NOT AFTER the date of the auditor's report
Must cover all FS and all periods referred to in the auditor's report

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### Responding to Reliability Concerns

If auditor doubts reliability (concerns about management's competence, integrity, ethical values, or diligence):

1. Determine the effect on reliability of representations AND audit evidence in general

2. If WR are inconsistent with other audit evidence → perform additional procedures to resolve

3. If matter remains unresolved → reconsider ROMM assessment and determine effect on audit evidence

4. If auditor concludes WR are not reliable → SA 705: Disclaimer of Opinion

If management does NOT provide WR:

1. Discuss the matter with management

2. Re-evaluate the integrity of management

3. Take appropriate actions including considering effect on opinion per SA 705

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### When Disclaimer of Opinion Is Issued

A disclaimer is issued when:

1. Auditor concludes there is sufficient doubt about management's integrity such that core WRs (on preparation of FS, completeness of information/transactions) are not reliable

2. Management does not provide the core written representations on FS preparation and information completeness

Worked example

### Example 1

Example 1 – Reliability doubt: During the audit of XYZ Ltd., the auditor finds that management's WR states no pending litigations exist. However, legal correspondence in the audit file mentions a ₹50 lakh tax dispute. The WR is inconsistent with other evidence. The auditor should perform additional procedures (e.g., obtain legal opinion), and if unresolved, reconsider the overall reliability of management's representations and consider the impact on the audit opinion.

### Example 2

Example 2 – WR not provided: The auditor of ABC Ltd. requests WR from management regarding completeness of related-party transactions. Management refuses to sign. The auditor must: (1) discuss with management, (2) re-evaluate management integrity, (3) consider a disclaimer of opinion under SA 705 since the fundamental assertion about completeness cannot be obtained.

⚠️ Common exam mistakes

Confusing 'other written representations' with the core WR on management responsibilities — other WRs supplement but do not replace the core WR
Forgetting the date rule: WR must be dated close to but NOT AFTER the auditor's report date
Treating a reliability concern as automatically leading to a disclaimer — the auditor must first try to resolve inconsistencies through additional procedures
Not distinguishing between 'unreliable WR' (SA 705 disclaimer) and 'WR not provided' (both require SA 705 consideration but through different paths)

Bare-Act text SA 580 – Paragraphs on 'Doubts About the Reliability of Written Representations' and 'Requested Written Representations Not Provided' · SA 580 – Written Representations (ICAI) · click to expand

If the auditor concludes that the written representations are not reliable, the auditor shall take appropriate actions, including determining the possible effect on the opinion in the auditor's report in accordance with SA 705.

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Other Written Representations, Date, Reliability, and Disclaimer

Worked example

⚠️ Common exam mistakes