In order to increase the meaningfulness of audit opinions, to avoid misunderstandings about the tasks and content of the audit ("expectation gap") and to ensure internationally uniform reporting, the international standards of the IAASB have been introduced into German law.
The following key features of future reporting should be noted:
- Precedence of the audit opinion
- More detailed breakdown of the audit opinion
- Supplementary requirements to the auditor's report for capital market-listed and other so-called PIE companies (Key Audit Matters)
- Hierarchy between the different standards for the audit opinion
Precedence of the audit opinion
In contrast to the previous German rules, the opinion on the financial statements always comes first in the new auditor's reports. Contrary to the original drafts of the audit standard IDW PS 400, the IDW is now proposing to combine the opinion on the audit of the financial statements with the audit of the management report. This is a deviation from the international approach in accordance with ISA 700, and is intended to highlight the particular significance of the management report in Germany.
More detailed breakdown of the audit opinion
The extended scope of the audit opinion compared with previous practice means that the auditor's opinion will be further subdivided in the future. The audit opinions are followed by separate sections on the basis of the audit opinions, Key Audit Matters, any necessary disclosure of uncertainties in connection with going-concern issues, and the responsibilities for the financial statements and the auditor's responsibilities, as well as any other applicable reporting obligations.
Key Audit Matters
The concept of Key Audit Matters is prescribed by the EU directive for all audits of Public Interest Entities (PIE), i.e. publicly traded companies and certain banks and insurance companies, while the ISAs (ISA 701) prescribe the concept for all audits of financial statements of listed companies.
The term Key Audit Matters (KAM) derives from international auditing practice and describes the most important facts of an audit, which the auditor has also discussed with the company's supervisory bodies. Individual judgements and amendments to required financial statement disclosures are not regarded as contents of Key Audit Matters. Rather, specific information should be presented on the conduct of the audit or on particular focal points of the audit.
The delimitation of Key Audit Matters is not unproblematic, since there is no fixed rule indicating which information should be included or even not disclosed. This margin of discretion is also of great importance with regard to potential resulting liability. Similarly, the repetition of such Key Audit Matters in formulaic language from one report to another could also pose a problem, since it could simply turn into boilerplate. To be fair, we will have to wait a while before we can tell whether this assumption is true.
The selection of Key Audit Matters should be conceived as a filter in which the auditor selects from the set of topics with the corporate bodies appointed to supervise in a step-by-step process the information to be classified as being of greatest importance for the audit.
Typical audit areas that could be the subject of Key Audit Matters include development costs, goodwill, deferred taxes, revenue recognition and high individual provisions, e. g. from litigation risks.
Hierarchy of the various standards for the audit opinion
In contrast to previous German practice, the requirements for the audit opinion will in future be divided into several standards. This necessitates the need to differentiate the importance of the individual standards. The basic standard (PS 400) is followed by the regulations on modifications of the BestV (restrictions and denials), followed by the auditor's statements on going-concern issues, which in turn are followed by the comments on Key Audit Matters and the notes.
The adoption of the corresponding IDW auditing standards is scheduled for December 2017. At PIE companies, reporting must already be in a new format for financial years ending after 16 June 2017. For all other companies, the first-time application is planned for 31 December 2018.