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Dear Mr Schilder,
The European Securities and Markets Authority (ESMA) is an independent EU Authority that contributes to safeguarding the stability of the European Union’s financial system by ensuring the integrity, transparency, efficiency and orderly functioning of securities markets, as well as by enhancing investor protection.
ESMA has considered, through its Standing Committee on Corporate Reporting, the Consultation Paperissued by the IAASB: Enhancing the Value of Audit or Reporting: Exploring Options for change (the “CP”) and is pleased to provide you with the following general comments:
- Calls for changes in the auditor reporting have been raised by various stakeholders and particularly by investors because of the perception of the so called “information gap”. We appreciate IAASB efforts to explore ways to improve audit or reporting in order to better meet investors’ needs and we are in favour of improved transparency on the audit. However, while we recognize the potential benefits of a more “narrative” audit report that would enable a better understanding of the auditor’s work effort and of the key judgements and conclusions relevant to that specific audit, wewould caution on changes in the auditor’s mandate that would lead to ask auditors to give information that should, more appropriately, be given by management and those charged with governance.It is important not to create potential for confusion among different roles and responsibilities and in this regard we believe that auditors’ role should continue to be to provide assurance on information provided by the company.
- There could be benefits in auditors providing some form of assurance beyond the audit of financial statements. However any extension of the auditor’s mandate on information beyond the financial statements should be carefully considered taking into account the level of assurance that can reasonably be provided by auditors (considering also the risk of an increase in the expectations gap) and the existence of standards and principles as appropriate points of reference for those who prepare the information and for the auditors.
- Auditor reporting, not withstanding its importance, is only one element of the broader corporate financial reporting process which depends on the legal and regulatory environment, and on the decisions of management and those charged with governance. To achieve high-quality corporate reporting considerations should also be given to these other factors. In broadest terms it is important to explore ways for enhanced corporate reporting models.
- Our focus is on securities markets and therefore the views expressed in this letter are relevant toaudits of listed companies.
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