Siddharth Gupta’s Post

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Partner at Trilegal | White Collar Crimes (Investigations)

Revised SA 600 – What it means for companies?   The recent debate between NFRA and ICAI over application of SA 600 and duties and responsibilities of principal auditors has turned many heads. While the current standard prescribes that the principal auditors can rely upon the work of component auditors (unless there is anything materially significant), the revisions proposed by NFRA enhances the role of principal auditors as group auditors, with higher responsibilities towards the entire group, and not just the parent entity. This may include not just audit planning at the group level (with both principal auditors and component auditors working together according to such plan), but also principal auditor’s unhindered access to the books and records of the subsidiaries. The revisions are pursuant to frauds identified in subsidiary audits during an NFRA’s quality review, and the principal auditor’s failure to take into considerations such material risks.   What does it mean for the companies? While this seems to be a welcome step from corporate governance standpoint, with the principal auditor providing a view on overall group’s consolidated financial statements, this may also subject the subsidiaries to disclose a lot more information to the principal auditors of the companies, which to some extent, may be considered privileged. Although it is not amply clear as of today, an example of this could be disclosure of whistleblower complaints and the corresponding investigation reports (which may be privileged at times), investigated by subsidiaries and their counsels to the principal auditors. This may also include demand of unfettered access by the principal auditors of the privileged and confidential information and records of such complaints/investigation reports.   While the basic principles for the companies will remain same, i.e. cooperate with the statutory auditors (see this, https://lnkd.in/gENsNSvh), a larger balance needs to be struck now between the subsidiaries, component auditors, parent company and the principal auditor to ensure protection of everyone’s legal rights and interests. This would be an interesting development to note. Views are personal. #nfra #SA600 #icai #CARO #whistleblow #statutoryaudit #fraud

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