16 September 2011

IAASB（国際監査・保証基準審議会）が発行した監査報告書の価値改善に関する市中協議書に対するEBA（欧州銀行機構）のコメント

The comments are based on the EBA's perspective as a prudential banking regulator. This role comes with a degree of privileged information access not available to many market participants, giving them a somewhat unique perspective from which to examine areas for expanded auditor reporting.

EBA's comments, while not structured according to the questions in the Consultation Paper, address the matters of key relevance to us as follows:

• Principles upon which to base change
• The degree and nature of change needed and worth exploring
• Benefits and limitations of certain changes
• International harmonisation.

In order to address the existing shortcomings of audit reports, enhancements will inevitably involve an increase in information provided by the auditor beyond that in the existing report which provides the ‘binary’ outcome of the audit: unqualified or qualified.

However, any changes should be considered within the constraints of the following important principles:

Division of responsibility

There are two sources of information gaps: i) shortcomings in information provided by management by way of disclosure, and ii) insufficient information provided by the auditor about their audit. Auditors’ reporting on financial statement audits can only fill the latter gap as it must remain the responsibility of management (and ultimately the board of directors) to provide disclosures that are adequate to present a true and fair view of the company’s affairs (driven by the adequacy and application of accounting and disclosure requirements). Based on this fundamental concept, EBA agrees with the concern raised in the consultation paper about ‘duelling information’ and the risk posed if the auditor originates information about the entity rather than management.

Clear opinion

Additional information from the auditor on financial statement audits would be useful, such as the auditor’s commentary on areas of significant audit risk, judgements on key audit and accounting issues, areas of significant debate with management and the audit committee, ‘close calls’ and alternative accounting treatments, and the nature of audit evidence obtained. However, this supplementary information should complement the ultimate opinion which must remain an unequivocal (i.e. still ‘binary’) conclusion on the truth and fairness of the company’s financial statements.

Certain improvements suggested in section III, A of the consultation paper would be helpful, including the following:

• Increasing the prominence of the opinion section of the report, for instance by positioning it at the beginning of the report;
• Further explaining the respective responsibilities of auditors and management;
• Clarifying or reducing ‘technical language’;
• Cross referring to a full explanation of the scope of the audit (e.g. to elsewhere in the annual report, an appendix to the audit report, or an external source); and
• Clarifying the auditor’s responsibilities in respect of information in the annual report other than the financial statements, and requiring the use of an affirmative statement when there is no material inconsistency between these and the financial statement.

These enhancements would provide the reader with relevant additional information about the audit, thereby narrowing the expectation gap, but should be made in a concise manner avoiding an unduly enlarged audit report.

Full paper

© EBA