Revision of ISSAI 140 – Quality management for SAIs

Thank you for the opportunity to comment on the ISSAI 140 exposure draft. We appreciate your efforts to integrate new principles of quality management into a context of SAIs, and we find the draft to be a clarification on how SAIs can ensure sound quality management systems. The National Audit Office of Denmark – NAOD (Rigsrevisionen) has the following comments to the five questions in the draft material.

Just a small comment: Page 6 Paragraph (8): Fundamental principles: In the list of interconnected comonents, adding SAI strategy and Stakeholder engaement policy 9or strategy) among the list may add value   Page 16 paragraph (41): SAI resources The list does not consider Financial (SAI budget) resources. We believe being one of the considerations may be practical. Thank you, Amanuel Isaac

Page 5, Para 5: "ISSAI 140 serves the same purpose as International Standard on Quality Management (ISQM) 1" - an article is suggested to be added: "...the same purpose as the International Standard on Quality Management..." Page 6, Para 9: "ISSAI 140 defines the organisational requirements of the ISSAIs based on this principle in ISSAI 100. The SAI must comply with all organisational requirements of this standard in order to be able to assert that it has conducted audits in accordance with the ISSAIs." - It is rather confusing, what "this principle" means in this context as the first sentence refers to ISSAI 100 (which also includes a section on organisational requirements), while the second sentence seems to refer to ISSAI 140. That being the case, do "all organisational requirements" include these requirements both from ISSAI 100 and 140? A clarification would be desirable. Page 7, Para 11, point c): "...do not reduce to an acceptably low level, the likelihood of a related quality risk..." - the comma can be omitted. Page 8, Para 20: "individually, or in combination with other risks, adversely affecting the achievement of one or more quality objectives" - Punctuation is missing at the end of the sentence. Page 10, Para 22: "The system shall cover all types of engagements covered by the ISSAIs and may also cover jurisdictional and other activities..." - very repetitive sentence, rephrasig is suggested. Page 11, Para 29: Auxiliary verbs are suggested to be added in order to be consistent with the language used in other sections and to reflect the binding nature: " The individuals assigned those responsibilities shall have the appropriate experience, knowledge, influence and authority, and sufficient time to fulfil them to the required standard. They must understand the roles to which they are assigned and how they are accountable."

Test