Document Type : Research Paper

Authors

• Mohammad Ali Hazegh ¹
• Rouhollah Bayat ²
• Abbas Ali Daryaei ²
• Mohammad Hossein Ghaemi ²

¹ Ph.D. Student in Accounting, Department of Accounting, Imam Khomeini International University, Qazvin, Iran.

² Associate Professor, Department of Accounting, Imam Khomeini International University, Qazvin, Iran.

Abstract

the disclosure of material corporate information therein, the auditing of such reports has attracted the attention of capital market stakeholders. Accordingly, the aim of this study is to examine the existing ambiguities in the auditing practices of MD&A reports and to propose strategies for their resolution. This research adopts a qualitative approach, employing grounded theory and interviews with 24 experts, including auditing professionals, capital market analysts, managers of listed companies, and officials from the regulatory authority. The initial interviewees were selected based on theoretical sampling, drawing on their expertise in the subject area, and subsequent participants were identified through snowball sampling. The collected data were analyzed using open, axial, and selective coding techniques. Based on the findings, the main ambiguities in the current auditing practices of MD&A reports include: the auditor’s level of responsibility with respect to MD&A; the auditor’s opinion on MD&A in the context of interim financial statements; and the examination of forward-looking information in MD&A by the auditor. The key proposed strategies to address these ambiguities are: removing forward-looking information from MD&A or entering into a separate engagement with corresponding fees for the auditor to opine on these reports; refraining from expressing an opinion on MD&A in the context of interim financial statements or issuing such an opinion in accordance with review engagement procedures; and expressing an opinion on forward-looking information in MD&A in line with the relevant auditing standard.

Introduction

Given the economic conditions of Iran, which have, due to sanctions, resulted in severe inflationary pressures, systematic risks in the market have increased, and uncertainty about the future has intensified. In such an environment, investors require reliable information beyond financial statements in order to make informed decisions regarding participation in the capital market. Management’s Discussion and Analysis (MD&A) represents one of the appropriate reporting tools through which an adequate level of transparency can be established in the capital market, thereby facilitating the channeling of liquidity toward this market. In this regard, auditing MD&A is of particular importance for enhancing its reliability. However, the inherent complexity and the qualitative and interpretive nature of MD&A pose significant challenges for auditors. One of the main challenges in auditing MD&A is the absence of clear and globally accepted auditing frameworks and standards. At present, independent auditors do not provide any assurance on MD&A and merely read these reports for the purpose of identifying potential material inconsistencies with the financial statements. Consequently, under the existing practice, the manner in which credibility is attributed to MD&A is ambiguous, and it is unclear who would be held accountable in the event of material misstatements in these reports. Accordingly, the present study first seeks to identify the existing ambiguities in the current practice of auditing MD&A and the consequences arising from these ambiguities. In the next stage, it aims to identify appropriate strategies, as well as the necessary infrastructures, to eliminate the existing ambiguities and their associated consequences. The research questions addressed in this study are as follows:

What ambiguities exist in the current practice of auditing MD&A?
What are the consequences of the existing ambiguities in the current practice of auditing MD&A?
What strategies can be adopted to resolve the ambiguities in the current practice of auditing MD&A?
What infrastructures are required to improve the process of auditing MD&A by independent auditors?


Literature Review

Overall, prior studies conducted in the area of auditing Management’s Discussion and Analysis (MD&A) have primarily emphasized the importance of auditing MD&A in enhancing the credibility of these reports, users’ demand for auditors’ opinions and assurance on MD&A, as well as the influence of auditors on the tone of MD&A. In addition, several studies have examined the relationship between the quality of MD&A and auditors’ efforts in auditing these reports, as well as audit fees. Moreover, some studies have focused on the role of the audit committee in the preparation of MD&A and have concluded that the presence of a knowledgeable and expert audit committee contributes to improving the quality of MD&A auditing.

Methodology

The present study was conducted using the grounded theory methodology through interviews with 24 experts from the auditing profession, capital market analysts, managers of listed companies, and specialists from the regulatory authority. The initial interviewee was selected through theoretical sampling, based on their recognized contributions and viewpoints in the subject area of the study. Subsequently, the sample was expanded for later interviews using the snowball sampling technique. The research data were analyzed using open, axial, and selective coding. This process resulted in the development of a coherent and applicable theory regarding the existing ambiguities in the practice of auditing Management’s Discussion and Analysis (MD&A) in Iran and the strategies for addressing them, which can be utilized in both academic and practical contexts.

Results

Based on the research findings, the ambiguities identified in the current practice of auditing Management’s Discussion and Analysis (MD&A) include the level of the auditor’s responsibility with respect to MD&A, the auditor’s opinion on MD&A in the context of interim financial statements, and the auditor’s examination of forward-looking information disclosed in MD&A. The principal strategies identified to address these ambiguities include: eliminating forward-looking information from MD&A; entering into a separate engagement and paying a distinct audit fee to the auditor for providing an opinion on MD&A; refraining from expressing an auditor’s opinion on MD&A in relation to interim financial statements or, alternatively, expressing an opinion in accordance with the procedures applied in review engagements; and providing assurance on the forward-looking information disclosed in MD&A in accordance with Auditing Standard 3400.

Discussion

With respect to the auditor’s responsibility for Management’s Discussion and Analysis (MD&A) and the corresponding strategies, two distinct perspectives emerged among the experts. One group of interviewees believes that the auditor bears no responsibility for MD&A or for any potential material misstatements therein, and that the auditor’s role should be limited to reading MD&A solely in connection with the primary responsibility of auditing the financial statements and reconciling the information disclosed in MD&A with the financial statements. This group argues that, under the current circumstances, the appropriate strategy for auditing MD&A is for the independent auditor to refrain from accepting any responsibility with respect to these reports. Furthermore, independent auditors, according to this viewpoint, should neither enter into separate engagements nor receive separate fees for procedures related to MD&A. In contrast, another group of interviewees contends that, given the guidance issued by the Securities and Exchange Organization regarding the auditing of MD&A and the paragraph included in the auditor’s report pursuant to such guidance, the independent auditor does bear responsibility for MD&A. This is because the auditor’s report is subject to public interpretation, and the inclusion of this paragraph leads users to infer that the auditor’s opinion on the financial statements extends to MD&A as well, thereby implying that assurance has also been provided on this report. Accordingly, the appropriate strategy from this perspective is for the independent auditor to become formally involved in the auditing of MD&A, to enter into separate audit engagements for MD&A, and to receive a separate fee for auditing these reports.

Conclusion

It appears that, given that the independent auditor’s report is closely examined by market stakeholders and users of financial information, the auditor bears responsibility for Management’s Discussion and Analysis (MD&A) through the paragraph included in the “Other Information” section of the auditor’s report. Moreover, pursuant to paragraph T-32 of Auditing Standard 720, specific responsibilities are assigned to the independent auditor in relation to other information, to the extent that, if the auditor is unable to conclude that no material inconsistency exists in the other information or that no material misstatement is present therein, withdrawal from the audit engagement—where permitted by laws or regulations—is recommended. In addition, the auditor’s ethical and professional responsibilities require that the auditor not remain indifferent to misstatements or deviations in financial reporting, including those in MD&A, that may mislead users of financial information, and that the auditor fulfill their credibility-enhancing role with respect to the information disclosed in such reports. Therefore, if—based on these arguments—the independent auditor’s responsibility for MD&A, as one of the key reports communicated to the market, is acknowledged, the auditor’s risk in fulfilling their assurance responsibilities over financial information increases. Consequently, it is reasonable to consider the execution of separate engagement contracts and the payment of separate audit fees to independent auditors for the examination of MD&A.
 
 
 

Keywords

• Auditing
• Auditing Procedure
• Capital market
• Grounded Theory
• Management Discussion and analysis report

Main Subjects

• Financial audit
• Audit Quality
• Accounting report