Comment: ASB’s proposed SSAEs

Our remarks responding to two of the AICPA Auditing Standards Board’s recent Statements on Standards for Attestation Engagements (SSAEs) proposals—Common Concepts, Examination Engagements, Review Engagements, and Engagements to Report on Sustainability Information (Proposal), as well as Amendments to SSAE Nos. 18-19 and 21 to Reflect Proposed SSAE Common Concepts, Examination Engagements, Review Engagements, and Engagements to Report on Sustainability Information (Conforming Amendments Proposal)—generally focus on four dominant themes:

• Clarity and consistency: We are concerned that certain aspects of the Proposal introduce unnecessary structural complexity through extensive reorganization, an increased use of headings and subheadings, and duplicative or inconsistently applied terminology.
• Scalable requirements: Certain revisions, particularly those affecting evidence, risk assessment, and the use of specialists in review engagements, appear to introduce a level of effort that is not aligned with the objective of limited assurance, which could diminish the distinction between reasonable and limited assurance.
• Principles-based framework and professional judgment: The Proposal seems to introduce a level of prescriptiveness that may inadvertently constrain professional judgment and reduce the effective application of the standards across diverse engagements.
• The cost of change: Certain aspects of the changes in the Proposal introduce structural and conceptual changes that do not appear to be directly linked to identified deficiencies in practice or peer review findings.

To read our comments in full, including detailed answers to specific questions posed by the Board, download our comment letter here (PDF - 451.65KB).