Chartered Accountants Ireland responds to the FRC's invitation to comment on the Practice Note Guidance for audits of smaller and/or less complex entities

Chartered Accountants Ireland has responded to the Financial Reporting Council's (FRC's) invitation to comment on the Practice Note (PN) Guidance for audits of smaller and/or less complex entities in the UK.  The FRC launched a consultation on a PN to support auditors in the application of International Standards of Auditing (ISAs) UK when auditing smaller and/or less complex entities. This consultation is part of the FRC’s year-long SME campaign. 

As a general overarching point, Chartered Accountants Ireland does support the development of additional guidance in principle as small and medium-sized practices (SMPs) need to be able to apply ISAs UK in a scalable and proportionate manner given current challenges experienced in the small and medium-sized enterprise (SME) audit market. A key element of our response outlines that a more preferrable course of action (rather than introduction of a PN) would be to begin the process to adopt the International Auditing and Assurance Standards Board’s (IAASB) International Standard on Auditing for Audits of Financial Statements of Less Complex Entities (‘ISA for LCE’), with public consultation on adoption of the ISA for LCE being a necessary step in the process. 

Chartered Accountants Ireland has also responded to specific FRC consultation questions outlining enhancements and changes needed to the current version of the PN.  The main item we highlight throughout our response to the consultation relates to the fact that the PN, in its current form, is difficult to apply and use due to the lack of alignment mapping to the underlying ISAs, which would aid ease of reference when navigating the ISAs and would help SMPs apply ISAs in a more scalable and proportionate manner. In addition, we have recommended certain enhancements to the PN content and wording including examples provided in the PN to support SMPs with implementing the guidance more effectively and proportionately particularly in the context of the following ISAs:

• ISA (UK) 315 Identifying and Assessing the Risks of Material Misstatement

• ISA (UK) 240 Fraud

• ISA (UK) 500 Audit Evidence

• ISA (UK) 570 Going Concern

• ISA (UK) 540 Estimates

• ISA (UK) 330 Auditor’s Responses to Assessed Risks

• ISA (UK) 600 Special Considerations - Audits of Group Financial Statements (Including the Work of Component Auditors)

• Revised Ethical Standard 2024