AS 1215: Audit Documentation

Amendments to paragraphs .02, .03, .06, .07, .11, .12, and .15 and new paragraph .06A have been adopted by the PCAOB and approved by the U.S. Securities and Exchange Commission. The amendments to paragraphs .02, .03, .06, .07, .11, and .12 and new paragraph .06A will be effective for all audits of financial statements for fiscal years beginning on or after December 15, 2024. The amendments to paragraph .15 will be effective:

• For registered firms that, during the calendar year ending Dec. 31, 2024, issued audit reports with respect to more than 100 issuers for audits of financial statements for fiscal years beginning on or after December 15, 2024; and
• For all other registered firms, for audits of financial statements for fiscal years beginning on or after December 15, 2025.

Effective Date of Standard: For audits of financial statements, which may include an audit of internal control over financial reporting, with respect to fiscal years ending on or after Nov. 15, 2004. For other engagements conducted pursuant to the standards of the PCAOB , including reviews of interim financial information, this standard takes effect beginning with the first quarter ending after the first financial statement audit covered by this standard.

Guidance on AS 1215: Staff Guidance for Auditors of SEC-Registered Brokers and Dealers and Staff Audit Practice Alert No. 14

Summary Table of Contents

• .01 Introduction
• .02 Objectives of Audit Documentation
• .04 Audit Documentation Requirement
• .10 Documentation of Specific Matters
• .14 Retention of and Subsequent Changes to Audit Documentation
• Appendix A - Background and Basis for Conclusions

Introduction

.01 This standard establishes general requirements for documentation the auditor should prepare and retain in connection with engagements conducted pursuant to the standards of the Public Company Accounting Oversight Board ("PCAOB"). Such engagements include an audit of financial statements, an audit of internal control over financial reporting, and a review of interim financial information. This standard does not replace specific documentation requirements of other standards of the PCAOB.

Objectives of Audit Documentation

.02 Audit documentation is the written record of the basis for the auditor's conclusions that provides the support for the auditor's representations, whether those representations are contained in the auditor's report or otherwise. Audit documentation also facilitates the planning, performance, and supervision of the engagement, and is the basis for the review of the quality of the work because it provides the reviewer with written documentation of the evidence supporting the auditor's significant conclusions. Among other things, audit documentation includes records of the planning and performance of the work, the procedures performed, evidence obtained, and conclusions reached by the auditor. Audit documentation also may be referred to as work papers or working papers.

Note: An auditor's representations to a company's board of directors or audit committee, stockholders, investors, or other interested parties are usually included in the auditor's report accompanying the financial statements of the company. The auditor also might make oral representations to the company or others, either on a voluntary basis or if necessary to comply with professional standards, including in connection with an engagement for which an auditor's report is not issued. For example, although an auditor might not issue a report in connection with an engagement to review interim financial information, he or she ordinarily would make oral representations about the results of the review.

.03 Audit documentation is reviewed by members of the engagement team 1A performing the work and might be reviewed by others. Reviewers might include, for example:

1. Auditors who are new to an engagement and review the prior year's documentation to understand the work performed as an aid in planning and performing the current engagement.

1. Supervisory personnel who review documentation prepared by other members of the engagement team.
2. Engagement supervisors and engagement quality reviewers who review documentation to understand how the engagement team reached significant conclusions and whether there is adequate evidential support for those conclusions.
3. A successor auditor who reviews a predecessor auditor's audit documentation.
4. Internal and external inspection teams that review documentation to assess audit quality and compliance with auditing and related professional practice standards; applicable laws, rules, and regulations; and the auditor's own quality control policies.
5. Others, including advisors engaged by the audit committee or representatives of a party to an acquisition.

Audit Documentation Requirement

.04 The auditor must prepare audit documentation in connection with each engagement conducted pursuant to the standards of the PCAOB. Audit documentation should be prepared in sufficient detail to provide a clear understanding of its purpose, source, and the conclusions reached. Also, the documentation should be appropriately organized to provide a clear link to the significant findings or issues. 1 Examples of audit documentation include memoranda, confirmations, correspondence, schedules, audit programs, and letters of representation. Audit documentation may be in the form of paper, electronic files, or other media.

.05 Because audit documentation is the written record that provides the support for the representations in the auditor's report, it should:

1. Demonstrate that the engagement complied with the standards of the PCAOB,
2. Support the basis for the auditor's conclusions concerning every relevant financial statement assertion, and
3. Demonstrate that the underlying accounting records agreed or reconciled with the financial statements.

.06 The auditor must document the procedures performed, evidence obtained, and conclusions reached with respect to relevant financial statement assertions. 2 Audit documentation must clearly demonstrate that the work was in fact performed. This documentation requirement applies to the work of all those who participate in the engagement as well as to the work of specialists the auditor uses as evidential matter in evaluating relevant financial statement assertions. Audit documentation must contain sufficient information to enable an experienced auditor, having no previous connection with the engagement:

1. To understand the nature, timing, extent, and results of the procedures performed, evidence obtained, and conclusions reached, and
2. To determine who performed the work and the date such work was completed as well as the person who reviewed the work and the date of such review.

Note: An experienced auditor has a reasonable understanding of audit activities and has studied the company's industry as well as the accounting and auditing issues relevant to the industry.

.07 In determining the nature and extent of the documentation for a financial statement assertion, the auditor should consider the following factors:

• Nature of the auditing procedure;
• Risk of material misstatement associated with the assertion;
• Extent of judgment required in performing the work and evaluating the results, for example, accounting estimates require greater judgment and commensurately more extensive documentation;
• Significance of the evidence obtained to the assertion being tested; and
• Responsibility to document a conclusion not readily determinable from the documentation of the procedures performed or evidence obtained.

Application of these factors determines whether the nature and extent of audit documentation is adequate.

.08 In addition to the documentation necessary to support the auditor's final conclusions, audit documentation must include information the auditor has identified relating to significant findings or issues that is inconsistent with or contradicts the auditor's final conclusions. The relevant records to be retained include, but are not limited to, procedures performed in response to the information, and records documenting consultations on, or resolutions of, differences in professional judgment among members of the engagement team or between the engagement team and others consulted.

.09 If, after the documentation completion date (defined in paragraph .15), the auditor becomes aware, as a result of a lack of documentation or otherwise, that audit procedures may not have been performed, evidence may not have been obtained, or appropriate conclusions may not have been reached, the auditor must determine, and if so demonstrate, that sufficient procedures were performed, sufficient evidence was obtained, and appropriate conclusions were reached with respect to the relevant financial statement assertions. To accomplish this, the auditor must have persuasive other evidence. Oral explanation alone does not constitute persuasive other evidence, but it may be used to clarify other written evidence.

• If the auditor determines and demonstrates that sufficient procedures were performed, sufficient evidence was obtained, and appropriate conclusions were reached, but that documentation thereof is not adequate, then the auditor should consider what additional documentation is needed. In preparing additional documentation, the auditor should refer to paragraph .16.
• If the auditor cannot determine or demonstrate that sufficient procedures were performed, sufficient evidence was obtained, or appropriate conclusions were reached, the auditor should comply with the provisions of AS 2901, Consideration of Omitted Procedures After the Report Date.

.09A Documentation of risk assessment procedures and responses to risks of misstatement should include (1) a summary of the identified risks of misstatement and the auditor's assessment of risks of material misstatement at the financial statement and assertion levels and (2) the auditor's responses to the risks of material misstatement, including linkage of the responses to those risks.

Documentation of Specific Matters

.10 Documentation of auditing procedures that involve the inspection of documents or confirmation, including tests of details, tests of operating effectiveness of controls, and walkthroughs, should include identification of the items inspected. Documentation of auditing procedures related to the inspection of significant contracts or agreements should include abstracts or copies of the documents.

Note: The identification of the items inspected may be satisfied by indicating the source from which the items were selected and the specific selection criteria, for example:

• If an audit sample is selected from a population of documents, the documentation should include identifying characteristics (for example, the specific check numbers of the items included in the sample).
• If all items over a specific dollar amount are selected from a population of documents, the documentation need describe only the scope and the identification of the population (for example, all checks over $10,000 from the October disbursements journal).
• If a systematic sample is selected from a population of documents, the documentation need only provide an identification of the source of the documents and an indication of the starting point and the sampling interval (for example, a systematic sample of sales invoices was selected from the sales journal for the period from October 1 to December 31, starting with invoice number 452 and selecting every 40 th invoice).

.11 Certain matters, such as auditor independence, staff training and proficiency and client acceptance and retention, may be documented in a central repository for the public accounting firm ("firm") or in the particular office participating in the engagement. If such matters are documented in a central repository, the audit documentation of the engagement should include a reference to the central repository. Documentation of matters specific to a particular engagement should be included in the audit documentation of the pertinent engagement.

.12 The auditor must document significant findings or issues, actions taken to address them (including additional evidence obtained), and the basis for the conclusions reached in connection with each engagement. Significant findings or issues are substantive matters that are important to the procedures performed, evidence obtained, or conclusions reached, and include, but are not limited to, the following:

1. Significant matters involving the selection, application, and consistency of accounting principles, including related disclosures. 2A
2. Results of auditing procedures that indicate a need for significant modification of planned auditing procedures, the existence of material misstatements (including omissions in the financial statements), the existence of significant deficiencies, or material weaknesses in internal control over financial reporting.
3. Accumulated misstatements and evaluation of uncorrected misstatements, including the quantitative and qualitative factors the auditor considered to be relevant to the evaluation. 2B
4. Disagreements among members of the engagement team or with others consulted on the engagement about final conclusions reached on significant accounting or auditing matters, including the basis for the final resolution of those disagreements. If an engagement team member disagrees with the final conclusions reached, he or she should document that disagreement.
5. Circumstances that cause significant difficulty in applying auditing procedures.
6. Significant changes in the auditor's risk assessments, including risks that were not identified previously, and the modifications to audit procedures or additional audit procedures performed in response to those changes. 2C

f-1. Risks of material misstatement that are determined to be significant risks and the results of the auditing procedures performed in response to those risks.

1. Any matters that could result in modification of the auditor's report.

Note: In an engagement conducted pursuant to Attestation Standard No. 1, Examination Engagements Regarding Compliance Reports of Brokers and Dealers, or Attestation Standard No. 2, Review Engagements Regarding Exemption Reports of Brokers and Dealers, significant findings or issues include, when applicable: (a) the assessment of, and the responses to, risks requiring special consideration by the auditor; (b) significant matters involving systems, processes, and controls to ensure the appropriateness of the subject matter and management's related assertions; and (c) the evaluation of identified instances of nonconformity with the evaluation criteria (e.g., errors, instances of non-compliance, or control deficiencies).

.13 The auditor must identify all significant findings or issues in an engagement completion document. This document may include either all information necessary to understand the significant findings, issues or cross-references, as appropriate, to other available supporting audit documentation. This document, along with any documents cross-referenced, should collectively be as specific as necessary in the circumstances for a reviewer to gain a thorough understanding of the significant findings or issues.

Note: The engagement completion document prepared in connection with the annual audit should include documentation of significant findings or issues identified during the review of interim financial information.

Note: When conducting an attestation engagement pursuant to Attestation Standard No. 1, Examination Engagements Regarding Compliance Reports of Brokers and Dealers, or Attestation Standard No. 2, Review Engagements Regarding Exemption Reports of Brokers and Dealers, the auditor may include the documentation of significant findings or issues related to the attestation engagement in the engagement completion document prepared in connection with the audit of the financial statements.

Retention of and Subsequent Changes to Audit Documentation

.14 The auditor must retain audit documentation for seven years from the date the auditor grants permission to use the auditor's report in connection with the issuance of the company's financial statements (report release date), unless a longer period of time is required by law. If a report is not issued in connection with an engagement, then the audit documentation must be retained for seven years from the date that fieldwork was substantially completed. If the auditor was unable to complete the engagement, then the audit documentation must be retained for seven years from the date the engagement ceased.

.15 Prior to the report release date, the auditor must have completed all necessary auditing procedures and obtained sufficient evidence to support the representations in the auditor's report. A complete and final set of audit documentation should be assembled for retention as of a date not more than 45 days after the report release date (documentation completion date). If a report is not issued in connection with an engagement, then the documentation completion date should not be more than 45 days from the date that fieldwork was substantially completed. If the auditor was unable to complete the engagement, then the documentation completion date should not be more than 45 days from the date the engagement ceased.

.16 Circumstances may require additions to audit documentation after the report release date. Audit documentation must not be deleted or discarded after the documentation completion date, however, information may be added. Any documentation added must indicate the date the information was added, the name of the person who prepared the additional documentation, and the reason for adding it.

.17 Other standards require the auditor to perform procedures subsequent to the report release date in certain circumstances. For example, in accordance with AS 4101, Responsibilities Regarding Filings Under Federal Securities Statutes, auditors are required to perform certain procedures up to the effective date of a registration statement. 3 The auditor must identify and document any additions to audit documentation as a result of these procedures consistent with the previous paragraph.

.18 The office of the firm issuing the auditor’s report is responsible for ensuring that all audit documentation sufficient to meet the requirements of paragraphs .04–.13 of this standard is prepared and retained. Audit documentation supporting the work performed by other offices of the firm and other auditors 3A must be retained by or be accessible to the office issuing the auditor’s report. 4 An other auditor must comply with the requirements of paragraphs .04–.17 of this standard, including with respect to the audit documentation that the other auditor provides or makes accessible to the office issuing the auditor’s report.

.19 In addition, the office issuing the auditor’s report must obtain, and review and retain, prior to the report release date, the following documentation related to the work performed by other offices of the firm and other auditors: 4A

An engagement completion document consistent with paragraphs .12 and .13.

.20 The auditor also might be required to maintain documentation in addition to that required by this standard. 5

[.21] [Paragraph deleted.]

Footnotes (AS 1215 - Audit Documentation):

1A The term “engagement team,” as used in this standard for audit engagements, has the same meaning as defined in Appendix A of AS 2101, Audit Planning. As used in this standard for review and attestation engagements, the term has a meaning analogous to the term’s definition in AS 2101 for audit engagements.

1 See paragraph .12 of this standard for a description of significant findings or issues.

2 Relevant financial statement assertions are described in paragraphs .28-.33 of AS 2201, An Audit of Internal Control Over Financial Reporting That Is Integrated with An Audit of Financial Statements. In an engagement conducted pursuant to Attestation Standard No. 1, Examination Engagements Regarding Compliance Reports of Brokers and Dealers, or Attestation Standard No. 2, Review Engagements Regarding Exemption Reports of Brokers and Dealers, the relevant assertions are the assertions expressed by management or the responsible party regarding the subject matter of the attestation engagement. The documentation requirements in this standard regarding assertions apply to the aspects of the subject matter to which the assertions relate.

2A See paragraphs .12-.13 of AS 2110, Identifying and Assessing Risks of Material Misstatement, and paragraphs .66-.67 of AS 2401, Consideration of Fraud in a Financial Statement Audit.

2B See paragraphs .10-.23 of AS 2810, Evaluating Audit Results.

2C See AS 2110.74 and AS 2810.36.

3 Section 11 of the Securities Act of 1933 makes specific mention of the auditor's responsibility as an expert when the auditor's report is included in a registration statement under the 1933 Act.

3A The term “other auditor,” as used in this standard, has the same meaning as defined in Appendix A of AS 2101.

4 Section 106(b) of the Sarbanes-Oxley Act of 2002 imposes certain requirements concerning production of the work papers of a foreign public accounting firm and other related documents. Compliance with this standard does not substitute for compliance with Section 106(b) or any other applicable law.

4A For multi-tiered audits, see note to paragraph .14 of AS 1201, Supervision of the Audit Engagement.

5 For example, the SEC requires auditors to retain, in addition to documentation required by this standard, memoranda, correspondence, communications (for example, electronic mail), other documents, and records (in the form of paper, electronic, or other media) that are created, sent, or received in connection with an engagement conducted in accordance with auditing and related professional practice standards and that contain conclusions, opinions, analyses, or data related to the engagement. (Retention of Audit and Review Records, 17 CFR §210.2-06, effective for audits or reviews completed on or after October 31, 2003.)