Requirements for the storage of working documents.  Retention period of the auditor's report The auditor's working papers should be kept for at least

Requirements for the storage of working documents. Retention period of the auditor's report The auditor's working papers should be kept for at least

They play a special role auditor's working papers. Sample each paper is drawn up in accordance with the rules established in practice. The information contained in the forms is confidential. Consider further the main types of working documents of the auditor.

general characteristics

Auditor working paper- a paper in which there are notes made by a specialist in the course of planning an inspection, in preparing its implementation, and summarizing the results. It may also contain information received from third parties, contractors of the inspected enterprise. The quantity and is determined individually in each case. In this case, the purpose of their design will be decisive.

Purpose

In practice, such auditor's working papers:

  1. By fixed assets. They contain information about the property of the inspected enterprise, its movement, cost, expenses, accounting, receipt and other transactions with valuables.
  2. For scheduling checks. They reflect the main stages of the audit.
  3. Confirming procedures.
  4. Containing information about the verification of reporting and information summarizing the results.

Working papers are also drawn up for:

  1. compliance with the program and plan.
  2. Ensuring the validity and legality of inspections.
  3. Quality control check.
  4. Formations auditor's report.
  5. Monitoring the activities of a specialist and substantiating remuneration.
  6. Documentation of the risk determined by the auditor with the reduction of its value.

Determining Factors

The number, content, forms of documents are selected depending on:

  1. Specialist qualifications.
  2. Terms of the contract with the inspected enterprise.
  3. previous experience.
  4. Internal standards and rules that guide the specialist.

Auditor Working Paper Form

Regardless of the purpose of use, papers are subject to General requirements. First of all, anyone should reflect complete and specific information. This is necessary in order to make it easier for another specialist to understand the essence of the activities performed.

Each is issued directly in the verification process. Filling out paperwork after or before the inspection is not allowed. When preparing documentation, the auditor must take into account not only the information that relates to the period under review, but also information for previous time periods. The papers should contain key data on which the specialist should express an opinion. It is necessary that they cover the most significant areas of inspection and the tasks set and implemented by the authorized person.

The documentation should allow the reporting to be analyzed according to the established criteria. The papers reflect the condition and assessment internal control in the organization, as well as the level of trust in it. They record the performed procedures related to verification and analysis. accounting enterprise, compliance with financial policy, compliance of reporting with statutory standards, principles and requirements.

Information is entered into each so that later it is easy to understand what is written. A mandatory requirement is to indicate the date and place of registration, the name of the specialist. The documents must be signed by the auditor, identification code. Pages are numbered. In addition, the specialist indicates the sources from which he took information for paperwork, applications fixing business and financial operations enterprises.

Classification

It is based on different criteria. Depending on the period of maintenance and execution, documents can be long-term or short-term use. According to the sources and method of obtaining paper, they are divided into those received from third-party entities or from the inspected enterprise, as well as issued by the specialist himself. Depending on the purpose, the documents may be:

  1. Overview.
  2. Checking.
  3. Informative.
  4. Confirming.
  5. Comparative.
  6. Estimated.
  7. Analytical.

According to the form of presentation, graphic, text, tabular and combined forms are distinguished. Depending on the design technique, papers can be handwritten or completed using a PC.

Auditor working papers: example

The papers that the specialist uses during the audit reflect various information. In accordance with this, papers with data are distinguished:

  1. legal nature.
  2. About the management and the employees of the company.
  3. On the structure and organization of firm.
  4. About economic fundamentals enterprise activities. These documents describe financial policy companies.
  5. About the accounting system. These include reports, primary papers, etc.
  6. On organizational and functional tasks. This includes plans, inspection programs, lists of activities and procedures, etc.
  7. About risk assessment. They include calculations.
  8. By checking individual indicators and articles of the enterprise.

Recommendations and proposals, correspondence of a specialist should also be referred to working documents.

Content Features

The specialist must reflect in the documentation information about:

  1. Scheduling the check.
  2. The nature, timing and scope of the activities carried out, their results.
  3. Conclusions that were formulated on the basis of the received and analyzed materials.

The papers must contain justification for all key points on which the final opinion will be expressed.

Nuances

  1. The nature of the task.
  2. The requirements that the conclusion must meet.
  3. Features and nature of the activity of the inspected subject.
  4. The use of control techniques and methods in the course of verification.

Working documents are the property of the audit firm. She has the right to perform any actions with them at her own discretion, if they do not contradict the law, other norms and professional ethics. Some documents or excerpts from them may be presented to the inspected establishment. But they cannot be a substitute for accounting records.

Storage

After the end of the inspection, the documentation is to be archived. The papers are booked and put into folders, established for each inspection separately. In the working documentation contained in the files "permanent and current dossier", the pages are numbered, and their number is indicated on special sheets. Papers of regular customers are stored in one set. Documents in such folders are distributed in chronological order. Files of "special" and "permanent" dossier can be transferred from one year to another. The leading specialist or other auditors subordinate to him must mark the changes on the documents, if any, the date the adjustments were made. Records are confirmed by signatures. The safety of documents, their execution, their transfer to the archive is ensured by the leading specialist responsible for a certain check.

Additionally

Each document must contain identification parameters. These include, in particular, the name of the inspected person, the period of inspection, and so on. In addition, the papers must provide identification indices, as well as cross-references. This provides faster compilation of them into files. At the end of each folder, the full name is indicated. responsible officer and his signature. Documentation can be stored on paper or electronic media, as well as on film. The period of keeping the papers handed over to the archive is not less than five years.


New retention periods for documents

Order of the Ministry of Culture of Russia No. 558 dated August 25, 2010 approved the List of standard managerial archival documents generated in the course of activities government agencies, local governments and organizations, indicating the periods of storage (hereinafter - the new List). In this regard, the order of the Federal Archives of August 26, 2010 No. 63 invalidated the List of standard management documents generated in the activities of organizations, indicating the periods of storage, approved on October 6, 2000 (hereinafter referred to as the old List). Both documents provide minimum term document storage.

The calculation of the terms of storage of files and documents begins on January 1 of the year following the year when they were completed by their office work. For example, the calculation of the storage period for cases completed in clerical work in 2010 will begin on January 1, 2011.
The calculation of the terms of storage of books (magazines) of registration (accounting) begins on January 1 after the last entry in the book (magazine). So, if the book of accounting for the movement of work books and inserts in them has been open since January 2004 and the last entry in it was made in 2009, then the calculation of the shelf life for the book will begin on January 1, 2010.

The new list consists of 12 sections:

1) documents reflecting the administrative, organizational functions of management, control functions, as well as legal support management, organization of documentation support for management and storage of documents by organizations;
2) planning and pricing documents;
3) documents on financing and lending;
4) documents on accounting and reporting;
5) documents on the organization and implementation of economic, scientific, technical, cultural and other relations of organizations;
6) documents on information services for the activities of organizations;
7) documents on the organization of labor, labor rationing, tariffication, remuneration, labor protection;
8) documents on work with personnel: admission, transfer, dismissal of employees, improvement of their qualifications, certification, as well as awards;
9) documents on the logistics of activities and organization of storage of property and material assets;
10) documents on administrative and economic services of organizations: compliance with internal regulations, operation of office buildings, transport services, internal communications, ensuring the security of organizations;
11) documents reflecting social and domestic issues, including social insurance, housing and household issues, organization of leisure;
12) documents reflecting the organization of activities of primary trade union and other public organizations (associations).

The new List applies to all organizations, regardless of the type of activity and form of ownership. The list of documents on rationing, tariffing and remuneration, labor protection, and personnel issues has been significantly expanded. In the Occupational Safety section, special attention is paid to documents on injuries, work with harmful and dangerous working conditions.

A more detailed list of orders by personnel is presented. So, in the old List, all orders for personnel should be kept for 75 years (Article 6). The exceptions were orders for the provision of regular and study holidays, duty, penalties, short-term domestic business trips. Their minimum shelf life was 5 years. In the new List, the list of orders is expanded (Article 19). For 75 years, the following orders should be kept for:
admission, transfer, combination, transfer, dismissal;
certification, advanced training, assignment of titles (ranks);
name change;
incentives, awards;
remuneration, bonuses, various payments;
all types of vacations for employees with difficult, harmful and dangerous working conditions, parental leave, unpaid leave ( wages);
duty on the profile of the main activity;
long domestic and foreign business trips, business trips for employees with difficult, harmful and dangerous working conditions.

For at least 5 years, orders concerning:
disciplinary action;
annual paid holidays;
leave in connection with training;
on duty;
short-term domestic and foreign business trips.

Consider how some of the terms of storage of accounting documents have changed. Still annual and consolidated annual (now consolidated ones have been added to them) balance sheets and records are to be kept permanently (art. 351). Quarterly - 5 years, monthly - 1 year. However, the period of storage of analytical documents (tables, reports) by the annual financial statements reduced to 5 years (Article 354). Previously, they should have been stored with annual accounts permanently (Art. 137). The new List separately (Article 352) highlights the storage periods budget reporting(balance sheets, reports, certificates, explanatory notes), although the retention periods are similar. For the first time, a retention period has been established (permanently) for accounting (financial) statements in accordance with international standards financial reporting or other standards (art. 358). The storage period for invoices has been reduced from 5 (Article 150) to 4 years (Article 368). If earlier the list of persons entitled to sign primary accounting documents had to be kept until it was replaced with a new one (Article 164), now it is for at least 5 years after its replacement with a new one (Article 380). According to the old List, the period of storage of a certificate of registration in tax authorities was equal to 5 years after deregistration (Article 169), now it should be kept permanently (Article 381). Separately, the terms of storage of documents are indicated tax accounting and tax reporting: calculation registers land tax(Article 389) - 5 years; payrolls for the deduction of insurance premiums to the FSS of the Russian Federation (Article 391): annual - constantly, quarterly - 5 years; reports on the transfer of funds for state and non-state insurance (Article 391) - constantly; tax returns (calculations) legal entities for all types of taxes (Article 392), tax returns and calculations of advance payments for the UST (Article 393), tax cards of form 1-NDFL (Article 394), declarations and calculations of advance payments for mandatory pension insurance(Article 395), income information individuals(Article 396), etc. should be stored for 5 years. We remind you that Art. 23 of the Tax Code of the Russian Federation refers to the storage of accounting data and other documents necessary for the calculation and payment of taxes, as well as documents confirming the received and incurred expenses for four years. Registers of information on the income of individuals should be kept for 75 years (Article 397). The new List contains a clause regarding documents for accounting for personal income tax, unified social tax, insurance premiums for pension insurance. If the organization does not maintain personal accounts, then the minimum storage period for these documents is no longer 5, but 75 years. For the first time, the storage period for the Books of Accounting for Income and Expenses of Organizations and individual entrepreneurs applying the simplified tax system (Article 401) - constantly. According to the author, this provision puts entrepreneurs using the simplified tax system in a disadvantageous position with those who use the regular taxation system, since the latter keep documents that are the basis for compiling tax returns, mostly 5 years. The new Schedule details the retention periods for audit documents. In the old List it was stipulated permanent term storage only for audit reports (Article 50). Now it is necessary to constantly store not only the audit report on the annual accounting (financial) statements (Article 408), but also the standards and methods for conducting an audit of an audit organization and an individual auditor (Article 404), general audit plans (Article 405), general programs audit (Article 406). These documents were not included in the old List. The period of storage of contracts for the provision of audit services remained unchanged - 5 years after the expiration of the contract.

A more detailed list of types of contracts is presented. Almost all have a storage period of at least 5 years after the expiration of the contract. An exception is made for:
donation agreements (Article 439) - permanently;
rent agreements (Article 442) - permanently;
property leasing agreements (Article 449) - permanently;
agreement on pledge of property - 10 years after the expiration of the agreement.

As you can see, the new List is more detailed and takes into account the documents that have appeared in the activities of organizations recently.

Rosarchiv has changed the terms of storage of accounting, tax, personnel and other documents. From January 1, 2020, apply the new list. The article contains convenient tables that will allow you to properly save documents and not throw them away ahead of time.

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How long to keep documents on contributions?

The periods are also regulated by the Tax Code. In the general case - within 6 years (Article 23 of the Tax Code of the Russian Federation). The rest are shown in Table 4.

Table 4. Time of storage of documents on contributions

How long is HR documentation kept?

The periods are the longest. The fact is that even if the employee quit, he may need this or that information throughout his life. In particular, according to work experience, income, etc.

As a rule, the terms are:

  • 75 years when the document was compiled before 2003;
  • 50 years - from 01.01.2003.

Table 5. Storage time of personnel documents

What to do if the period for storing documents has expired?

Expired documents are to be destroyed. To destroy documents, draw up an act in which write down the name and number of cases with documents that it is time to destroy. This act must be signed by a special commission, the composition of which CEO approved in his order.

Penalty for lack of documents

For the absence of primary documents, invoices and tax registers IFTS employees can fine an LLC in the amount of 10,000 to 30,000 rubles (Article 120 of the Tax Code of the Russian Federation), including those applying according to tax code USN.

In addition, without documents confirming business transactions, inspectors will deduct profit expenses (or single tax) and VAT deductions. Or they will calculate the amount of tax payable by the calculation method (subclause 1, clause 7, article 31 of the Tax Code of the Russian Federation).

Documents of the audit organization: what is the normative period of storage of the original audit reports - read in the article.

Question: For how many years is the audit organization obliged to keep the original reports and opinions on audits? One SRO of auditors says - 5 years, the other - forever.

Answer: Obliged to keep for at least five years after the year in which they were drawn up.

The rationale for this position is given below in the materials of the Glavbukh System and in the Decree and the Federal Antimonopoly Service of the Moscow District dated July 29, 2014 No. F05-7395 / 14 in case No. A40-101724 / 13

FEDERAL LAW DATED December 30, 2008 No. 307-FZ “On audit activity»

« Article 13. Rights and obligations of an audit organization, an individual auditor

2. When conducting an audit, an audit organization, an individual auditor must:*

1) provide, at the request of the audited entity, substantiations of the comments and conclusions of the audit organization, an individual auditor, as well as information about their membership in a self-regulatory organization of auditors;

2) transfer, within the period established by the contract for the provision of audit services, the audit report to the audited entity, the person who has concluded the contract for the provision of audit services;

3) ensure the storage of documents (copies of documents) received and compiled during the audit for at least five years after the year in which they were received and (or) compiled;

Decree of the Federal Antimonopoly Service of the Moscow District dated July 29, 2014 No. F05-7395 / 14 in case No. A40-101724 / 13

Federal Arbitration Court of the Moscow District composed of:*

presiding judge Latypova P.RV

judges: Voronina E.Yu., Kuznetsova A.M.,

when attending the meeting:

from the applicant: CJSC "HOLD-INVEST-AUDIT" - Volkova M.A. power of attorney dated July 22, 2014, Maidanchik M.I. power of attorney dated October 23, 2013,

on behalf of the person concerned: Rosfinnadzor - Basov D.K. power of attorney dated May 19, 2014 No. AC-09-30/2523, Nikiforov A.V. power of attorney dated May 19, 2014 No. AC-09-30/2524,

from third parties: NP "Institute of Professional Audits" - notified, the representative did not appear,

having considered on July 22, 2014 at the court session the cassation appeal of CJSC "HOLD-INVEST-AUDIT"

for decision Arbitration Court Moscow city

accepted by Judge Deina N.V.,

against the decision of the Ninth Arbitration Court of Appeal

adopted by Judges Potashova Zh.V., Popov V.I., Yakovleva L.G.,

according to CJSC "HOLD-INVEST-AUDIT"

on contesting orders Federal Service financial and budgetary supervision (Rosfinnadzor)

third party NP "Institute of Professional Audits"

installed:*

By the decision of the Arbitration Court of the City of Moscow dated January 17, 2014, left unchanged by the decision of the Ninth Arbitration Court of Appeal dated April 03, 2014, in satisfaction of the stated requirements of CJSC HOLD-INVEST-AUDIT (hereinafter referred to as the company) to declare illegal the Federal Service of Finance and Budget supervision of the order to eliminate violations identified as a result of an external quality control of work dated July 17, 2013 No. 43-01-09-24 / 2493 (hereinafter referred to as the Order to eliminate violations) and the Order of the Federal Service for Financial and Budgetary Supervision on the suspension of membership of CJSC " Auditing Company"HOLD-INVEST-AUDIT" in the self-regulatory organization of auditors NC "Institute of Professional Auditors" dated July 17, 2013 No. 43-01-09-24/2492 (hereinafter referred to as the order to suspend membership) - denied.

Disagreeing with the adopted judicial acts, CJSC "HOLD-INVEST-AUDIT" filed a cassation appeal, in which it asks to cancel them. In justification, he refers to the fact that the violations indicated in the instructions were eliminated in part, revealed regarding the incorrect execution of documents, do not concern violations related to the inconsistency of the conclusions with the materials of the verification on the merits. He considers that, taking into account the violations identified, the adoption of a measure of influence in the form of suspension of membership is an excessive punishment. It also indicated that, based on the results of the same check, two prescriptions were adopted, which is unacceptable given the current legislation.

At the hearing, the representatives of the society supported the arguments and demands of the cassation appeal.

Representatives of Rosfinnadzor in the court session and the submitted response objected to its satisfaction, referring to the legality and validity of judicial acts.

NP "Institute of Professional Audits", notified of the hearing of the cassation complaint in the manner prescribed by law, did not send representatives to the court. The court of cassation, guided by paragraph 3 of Article 284 of the Arbitration Procedure Code Russian Federation, found it possible to consider the cassation appeal without the participation of a person who did not appear at the hearing.

Having discussed the arguments of the cassation appeal and objections to them, having checked, in accordance with Article 286 of the Arbitration Procedure Code of the Russian Federation, the correctness of the application by the courts of the norms of substantive and procedural law, the court of cassation considers that the court of first instance and the appellate instance, when considering the dispute, correctly established the circumstances relevant to the case , objectively examined the evidence presented in their totality and interconnection and made the correct conclusions, corresponding to the actual circumstances and the evidence presented, based on the correct application of the law, and therefore finds no reason to cancel the appealed judicial acts.

From the factual circumstances established by the courts in the case, it is seen that during the audit by Rosfinnadzor it was established that CJSC HOLD-INVEST-AUDIT violated Federal Law No. 307-FZ of December 30, 2008 "On Auditing" audit activities"). The contested orders of Rosfinandzor established seven violations of the legislation regulating audit activity, ordered to eliminate the identified violations for a period of 180 calendar days, and suspended the applicant's membership in the self-regulatory organization of auditors NP "Institute of Professional Auditors".

Considering their rights violated, the company filed claims with the court.

Refusing to satisfy the stated requirements, the courts, having examined and evaluated the evidence, based on the subject and grounds of the stated claims, as well as on the sufficiency and interconnection of all evidence in their totality, establishing all the circumstances included in the subject of proof and essential for the correct resolution dispute, taking into account the specific circumstances of the case, guided by the provisions federal law"On Auditing Activities", of the Federal Auditing Standard (FSAD 1/2010) "Auditor's report on accounting (financial) statements and the formation of an opinion on its reliability" (hereinafter - FSAD 1/2010), came to a reasonable conclusion about the legality of the contested prescriptions.

The conclusions of the courts on the application of the rule of law correspond to the circumstances established in the case and the evidence available in the case.

From the factual circumstances established by the courts in the case, it is seen that in the course of an external audit of the quality of work of CJSC HOLD-INVEST-AUDIT, violations of paragraph 3 of part 2 of Article 13 of the Federal Law "On Auditing" and paragraph 13 federal rule auditing standard No. 2 "Audit Documentation" (hereinafter - FPSAD No. 2), namely, the working documents of CJSC "HOLD-INVEST-AUDIT", confirming the audit of the accounting (financial) statements of OJSC "Construction and Industrial Company Mosenergostroy" (auditor's report dated March 28, 2012) and FGU DEP No. 25 (audit report dated March 11, 2012) for 2011, were destroyed in violation of the storage deadlines.

The audit organization provided full copies of the documentation for the audit of the accounting (financial) statements of OAO Construction and Industrial Company Mosenergostroy, FGU DEP No. 25, OAO Vneshstroyimport, OAO SEZ for 2011.

With regard to the accounting (financial) statements of Mosenergostroy Construction and Industrial Company OJSC and FGU DEP No. 25 for 2011, the company issued two audit reports each, respectively (Mosenergostroy Construction and Industrial Company OJSC - audit reports dated March 28, 2012 and dated March 22, 2012). July 2012; FGU DEP No. 25 - audit reports dated March 11, 2012 and July 16, 2012).

Nevertheless, in the materials submitted to Rosfinnadzor in accordance with the above letter of the company, there were no working documents related to the audit of the accounting (financial) statements of Mosenergostroy Construction and Industrial Company OJSC and FGU DEP No. 25 for 2011, since, in violation of the storage deadlines, there were destroyed.

The courts justifiably rejected the arguments of the company regarding the availability of working documents in in electronic format is not related to the violation in question, since according to paragraph 3 of part 2 of article 13 of the Federal Law "On Auditing", when conducting an audit, an audit organization is obliged to ensure the storage of documents (copies of documents) received and compiled during the audit for at least five years after the year in which they were received and (or) compiled. This requirement applies to all documents received and compiled during the audit, regardless of the type of media on which they were stored.

In addition, the courts of first and appellate instances properly assessed the circumstances regarding the availability of working documents in electronic form and came to a legitimate and justified conclusion that these working documents were not properly executed and could not be accepted as working documents for the audit of accounting (financial) statements of Mosenergostroy Construction and Industrial Company JSC and FGU DEP No. 25 for 2011.

Contrary to the arguments of the company that the audit of the accounting (financial) statements for 2011 of OAO SEC Mosenergostroy, the audit report dated March 28, 2012 and the FGU DEP No. 25, the audit report dated March 11, 2012, is not an audit in the context of the Federal Law "On audit activities", the court of first instance and the court of appeal came to opposite conclusions.

The Company violated paragraph 15 of the Federal Rule (Standard) of Auditing Activity No. 10 "Events after reporting date"(hereinafter - FPS AD No. 10), namely, withdrew the audit reports on the accounting (financial) statements of the Federal State Unitary Enterprise "Natsrybresurs" 2011 dated April 5, 2012, the accounting (financial) statements of the State Unitary Enterprise of the City of Moscow "Moscow Research and Design Institute of Typology, Experimental Design" for 2011 of June 18, 2012, accounting (financial) statements of JSC "Construction and Industrial Company Mosenergostroy" for 2011 of March 28, 2012 and accounting (financial) statements of FGU DEP No. 25 for 2011 dated March 11, 2012, and also issued new audit reports on the accounting (financial) statements of these organizations.

The courts of the first and appellate instances fully and comprehensively investigated the circumstances of the violation in question and came to a legitimate and justified conclusion that CJSC HOLD-INVEST-AUDIT has no legal grounds to revoke and issue the relevant audit reports.

The Company violated paragraph 19 of the Federal Rule (Standard) of Auditing Activity No. 11 "Applicability of the Assumption of Business Continuity of the Audited Entity" (hereinafter - FPSAD No. 11), namely, in the documentation submitted by the group of Rosfinnadzor inspectors for the audit of the accounting (financial) statements of JSC "Vneshstroyimport" for 2011 there is no confirmation of the audit procedures to obtain proper audit evidence listed in paragraph 19 of FPSAD No. 11.

Paragraph 19 of FPSAD No. 11 requires that if factors are identified that cast significant doubt on the entity's ability to continue as a going concern, the auditor should: Review the entity's plans for future operations based on its assessment of the going concern assumption; by performing the necessary audit procedures, obtain reliable audit evidence to confirm or disprove the existence of significant uncertainties, including considering the implications of any plans of the entity and possible extenuating circumstances; require the entity's management to provide written information regarding their plans for the future.

In accordance with paragraph 6 of FPSAD No. 11, the auditor may have doubts about the applicability of the going concern assumption when considering financial (accounting) statements or when performing other audit procedures.

One indication that may raise doubts about the applicability of the going concern assumption is a negative value net assets or failure to meet established net asset requirements.

According to the Calculation of the Net Asset Value of OAO Vneshstroyimport, the net asset value as of January 1, 2011 was 18,920 thousand rubles, and as of December 31, 2011, the value of net assets was a negative value of 3,391 thousand rubles.

According to the Profit and Loss Statement (public form 0710002) for 2011 net profit for 2011 amounted to a negative value of 22311 thousand rubles. For comparison, in 2010 net profit amounted to 1,049 thousand rubles.

In the materials submitted to Rosfinnadzor on the audit of the accounting (financial) statements of OAO Vneshstroyimport for 2011, there were no documents confirming that the company had carried out audit procedures to obtain the appropriate audit evidence listed in paragraph 19 of the FPS AD No. 11.

It should also be noted that in paragraph 6 of the working document "Assumption of business continuity for the preparation of financial statements of an economic entity" dated April 12, 2012, OS-1 on the audit of the accounting (financial) statements of JSC "Vneshstroyimport" for 2011, it is noted that in the case of a negative speakers economic condition the organization needs to obtain clarifications provided by the management of the economic entity being audited regarding action plans, as a result of which an improvement in the position of the economic entity is expected. Auditor Kiseleva M.V. clearly indicated that the procedure was not carried out.

The Company violated paragraph 7 of the Federal Auditing Standard (FSAD 3/2010) "Additional Information in the Audit Report" (hereinafter - FSAD 3/2010), namely, in the audit report on the accounting (financial) statements of FGU "DEP No. 25" for 2011 year dated July 16, 2012, the part "Important circumstances" is included, which indicates a circumstance not reflected in the accounting (financial) statements.

At the time of issuing the order to eliminate violations and the order to suspend membership, the Federal Law "On Auditing" was in force.

In accordance with Part 6 of Article 20 of the Federal Law "On Auditing" in relation to an audit organization that has committed a violation of the requirements of this Federal Law, federal standards audit activities, the rules of independence of auditors and audit organizations, the code of professional ethics of auditors, authorized federal agency for control and supervision may apply disciplinary measures. Based on the results of an external audit of the quality of work, Rosfinnadzor has the right to issue a combination of disciplinary measures against one audit organization that has committed violations of the rules of audit activity.

The company's argument about the violation of the principle of proportionality between the measure of legal liability and the offense committed cannot be taken into account in connection with the following.

Based on the results of an external audit of the quality of the company's work, Rosfinnadzor decided to issue two disciplinary measures specifically for violations of the procedure for carrying out audit activities, taking into account the nature and number of violations identified and their consistency.

Violations specified in paragraphs 1 - 4 of the order to eliminate violations and the Order to suspend, refer to gross violations of the rules of auditing. The violations in paragraphs 5 through 7 of the Corrective Action Order and the Suspension Order are serious violations of federal auditing standards.

In this regard, taking into account the nature of the violations identified, the systematic and repeated violations detected, violations of three out of four paragraphs (subparagraphs a - c of paragraph 33 of the Federal Auditing Standard (FSAD 4/2010) "Principles for external quality control of the work of audit organizations, individual auditors and requirements for the organization of the specified control"), revealed during the audit of the working documentation of the auditor in relation to specific audit assignments, violations of both the requirements of the Federal Law "On Auditing", and federal standards of auditing and the Code of Professional Ethics of the Auditor (approved by the Audit Council in accordance with the protocol dated March 22, 2012 No. 4), for the entire totality, Rosfinnadzor issued Orders to CJSC HOLD-INVEST-AUDIT to eliminate violations and to suspend membership.

In connection with the indicated courts, the correct conclusion was made that the indicated prescriptions correspond to the nature of the offenses committed, meet the requirements of justice, are adequate, proportionate and commensurate.

As for the other arguments of the cassation appeal, they actually repeat the arguments set forth in the court of the first and appeal instances, were the subject of consideration by the courts, which was reflected in judicial acts. The procedural law does not refer any other assessment of the facts established by arbitration courts to the competence of the court of cassation.

The rules of procedural law, non-compliance with which is the basis for the cancellation of the decision, decision in accordance with Part 4 of Article 288 of the Arbitration Procedure Code of the Russian Federation, are not violated.

Guided by articles 284, 286 - 289 of the Arbitration Procedure Code of the Russian Federation, the court

decided:*

the decision of the Arbitration Court of the City of Moscow of January 17, 2014, the decision of the Ninth Arbitration Court of Appeal of April 03, 2014 in case No. A40-101724 / 13 to be left unchanged, the cassation appeal - without satisfaction.

Answered by Alexander Sorokin,

Deputy Head of the Operational Control Department of the Federal Tax Service of Russia

“CCP should be applied only in cases where the seller provides the buyer, including its employees, with a deferral or installment plan for payment for their goods, works, services. It is these cases, according to the Federal Tax Service, that relate to the provision and repayment of a loan to pay for goods, work, and services. If an organization issues a cash loan, receives a return of such a loan, or itself receives and repays a loan, do not use the cash desk. When exactly you need to punch a check, look at

Documentation is one of essential elements in the work of auditors. The quality and results of the audit, as well as the services associated with the audit of any economic entity, largely depend on the thoroughness, timeliness and systematic nature of the records.

Under audit documentation(working papers, working documentation) for the purposes of the ISA 230 of the same name “Audit Documentation”, materials are assumed that reflect the results of the audit procedures performed, as well as the audit evidence obtained and the conclusions made by the auditor 1 .

The need for the formation and execution of audit documentation is determined by the fact that they allow:

  • improve the efficiency of the planning process, as well as the audit on the merits of the audit engagement;
  • monitor and supervise the progress of this assignment;
  • create conditions for reporting on the work of the audit group (team);
  • take into account the constantly significant aspects for subsequent audits;
  • to control the quality of the assignment;
  • create conditions for conducting an audit in accordance with applicable laws and regulations legal acts.

The form and content of working documents, as a rule, is influenced by:

  • the size and complexity of the structure of the economic entity being audited;
  • the nature of the audit procedures to be performed to complete the audit engagement;
  • identified risks of material misstatement;
  • the significance of the audit evidence obtained;
  • the nature and extent of the identified misstatements;
  • need documentation conclusions or reasons for conclusions that are not directly documented by the results of the work done or the audit evidence obtained;
  • methods and tools used by the auditor.

The standard allows the formation of audit (working) documents on paper, electronic or other media. In addition, the audit documentation should include:

  • audit programs;
  • analytical reports;
  • a summary of the essence of significant aspects;
  • explanatory materials on them;
  • written confirmations and assurances;
  • checklists;
  • correspondence on significant aspects (including e-mail);
  • copies or extracts from the documents of the audited entity.

When preparing audit documentation, the auditor should assume that it is likely to be used by another qualified auditor who has not previously participated in the audit engagement.

Under qualified auditor in this context, we mean a specialist (both working in the audit organization and outsourced) who has practical experience in auditing and sufficient knowledge in the field of:

  • applied audit processes;
  • International Auditing Standards and the requirements of national laws and regulations;
  • commercial (external) environment (business environment, business environment) in which the audited entity operates;
  • features of auditing and preparation of accounting (financial) statements in the industry of this entity 1 .

Based on the documentation received, the specified qualified auditor should obtain sufficient and appropriate knowledge of:

  • the nature, timing and extent of audit procedures performed in accordance with ISAs and applicable national laws and regulations;
  • the results of the audit procedures performed and the audit evidence obtained;
  • significant aspects, as well as conclusions on them;
  • significant professional judgments made in the course of drawing up these conclusions.

When documenting the nature, timing and extent of the audit procedures performed, the auditor should record in writing:

  • distinguishing features of certain reviewed articles, for example, by date and unique number of posted economic entity orders or all accounting entries exceeding certain amounts, etc.;
  • information about the auditor who performed the specific work, as well as the date of its completion;
  • information about the employee who performed the review of the audit work performed, the date and extent of this review.

According to the requirements of ISA 230, the auditor must document all discussions of significant aspects with the management of the audited entity, representatives of the owner and other interested parties, while reflecting in the audit documentation the essence of these aspects, as well as information about the time and persons with whom such discussions were held.

If information is identified on one of the significant aspects that contradicts the final auditor's report, then the auditor needs to describe the measures taken to eliminate this discrepancy. In this case, inaccurate or outdated documentation may be destroyed. In other words, ISA 230 recommends that superseded draft working papers and incomplete or preliminary notes and conclusions be excluded from audit documents. In addition, it is necessary to exclude copies of documents that were subsequently corrected, as well as duplicates of these documents.

In exceptional cases, when performing additional procedures or forming completely new conclusions after the date of signing and providing the audit report, the auditor should reflect in the working documents:

  • the circumstances he faced;
  • new or additional audit procedures performed and audit evidence obtained, as well as the conclusions drawn from them and their effect on the auditor's report;
  • when and by whom changes are made to the audit documentation and checked.

Of particular interest are the inclusion in the text of ISA 230 of the requirements for the formation of the final audit file. According to the provisions of the Standard, the auditor must complete the formation of the audit file in a timely manner. international standard Quality Control (ISQC) 1 “Quality Control in Firms that Audit and Review Financial Statements, Perform Other Assurance Engagements, and Provide Related Services” requires the auditor to establish policies and procedures for completing the audit file in a timely manner. For the final formation of the audit file, a period is defined, as a rule, not exceeding 60 days after the date of signing the audit report.

Under audit file in this case refers to one or more folders or other media, in physical or electronic form, containing materials that represent the audit documentation for a specific audit engagement 1 .

Considering that the formation of the audit file is a process that does not require the implementation of new audit procedures or the development of new conclusions, then changes to the audit documentation may be made only during the formation of the audit file. Examples of these changes can only be:

  • removal or destruction of obsolete documentation;
  • sorting, organizing working documents, as well as adding cross-references to them;
  • signing the final checklists regarding the process of generating the audit file;
  • documenting the audit evidence that the auditor has obtained, discussed and agreed with members of the audit team (team) prior to the date of signing the auditor's report.

After the audit file is completed, the auditor should not remove or destroy the audit documentation. All information must be protected by confidentiality and security procedures in accordance with established practice and the rules for storing such documentation. All working documents are kept by the auditor and are his property. The retention period in accordance with ISA 230 must be at least five years after the date of the auditor's report.

In addition to these requirements, no less significant and logical is the requirement that the audit documentation contain information about all significant aspects that arise during the audit and the results of their consideration. In particular, the Standard refers to the essential aspects:

  • matters that are caused by significant business risks (ISA 315 “Identifying and assessing the risks of material misstatement through the study of the activities and commercial environment of the organization”);
  • results of audit procedures that indicate that financial information may be materially misstated, or the need for the auditor to revise the auditor's previous assessment of the risks of material misstatement and the related actions of the auditor;
  • circumstances that make it difficult for the auditor to apply the necessary audit procedures;
  • results of procedures that may result in modification of the auditor's report.

At the same time, it is allowed to prepare and retain as part of the audit documentation a summary report that describes the significant aspects identified during the audit, the procedure and result of their decision, or provides cross-references to relevant audit documentation that reflects the specified information.

Some aspects of documentation are regulated not only by ISA 230, but also by other ISAs, in particular:

  • ISA 300, Planning an Audit of Financial Statements, which defines the procedure for documenting the planning process. The standard requires an overall strategy to be included in the audit documentation. audit(in particular, a record of key decisions that are necessary and communicated to the audit team), the audit plan (the nature, timing, and extent of the risk assessment procedures and subsequent audit procedures), and any significant changes made to them during the course of the audit engagement. At the same time, the reasons for such changes should be disclosed;
  • ISA 315, “Identifying and Assessing the Risks of Material Misstatement through the Study of the Entity’s Activities and Commercial Environment,” requires the auditor to include in the audit documentation discussions among members of the audit team (team), the main conclusions drawn from the results of the study of each of the aspects of the activities of the audited entity and its commercial (external) environment, the identified risks of material misstatement, as well as the identified risks and related controls examined by the auditor;
  • ISA 320 “Materiality in planning and conducting an audit” requires the auditor to include in the audit documentation the materiality level for the accounting (financial) statements as a whole and the materiality levels for certain classes of transactions, account balances or disclosures (if any), the materiality threshold established by him , as well as any revisions thereof;
  • ISA 240, The Auditor's Responsibilities When Fraud is Detected in an Audit of Financial Statements, requires the auditor to include in the audit documentation reports of fraud to management, the owner's representatives, regulators, and others.
  • MCA 250, Accounting for Laws and Regulations in an Audit of Financial Statements, requires the auditor to include in the audit documentation information about suspected and established facts of non-compliance by the audited entity with the requirements of laws and regulations, as well as the results of discussions on these aspects with management, representatives of the owner and third parties. persons. At the same time, the audit documentation must include copies of accounting and other documents, as well as minutes of discussions with these persons;
  • MCA 540, Auditing Accounting Estimates, Including Accounting Estimates fair value and related disclosures” requires the auditor to include in the audit documentation key judgments about the reasonableness of significant risk estimates and their disclosures, as well as indications that management of the audited entity may be unreasonable;
  • MCA 550, Related Parties, requires the auditor to include in the audit documentation all names of related parties identified by the auditor and a description of the nature of the entity's relationship with those parties.

Properly prepared audit documentation can be generated without an audit at all. At the same time, it is possible to establish that the working documentation does not correspond to reality only by comparing it with the documents of the audited subject, which are often not available to the auditor. Of course, a quality audit without proper documentation is impossible. However, a judgment about the quality of an audit based solely on documentation cannot be objective and, as a result, requires a comprehensive audit of not only documents, but also directly business transactions property, inventory items, etc.