What is an agreed-upon procedures engagement?
This can be defined as an engagement in which a practitioner agrees on specific procedures, usually audit-like in nature, with a client or a third party, and provides a report on findings against those agreed procedures. There is no assurance provided by the report, and the user is left to draw their own conclusions based on the agreed procedures and the findings reported against them. Previously, these were often referred to as factual findings.
Are these engagements subject to a standard?
Yes! The standard that applies to Agreed-Upon Procedures is ISRS4400 – International Standard on Related Services 4400 (Revised): Agreed-Upon Procedures Engagements. This standard was recently revised by the IAASB, and the revised standard is applicable for engagements where the terms of engagement are agreed on or after 1 January 2022. The revision of this standard by the IAASB (previously ISRS4400 – which replaced ISA920) Engagements to Perform Agreed Upon Procedures Regarding Financial Information) addressed the increasing demand for these types of engagements for both financial and non-financial information and incorporated the types of updates generally being made to the standards to enhance professional judgment, independence, accountability and consistency in the profession.
Are these engagements common?
Yes, increasingly so. In many cases, agreed-upon procedures are requested by third parties on specific aspects of a client’s business, and often these parties have a template or format for the reports they require. When this happens, practitioners may not always identify that the engagement being performed falls into the scope of ISRS4400. The term “factual findings report” may be more commonly used or identified. These engagements are the ones that fall into the scope of ISRS4400 (and are now referred to only as findings, and not factual findings). Some common engagements that fall into the scope of agreed-upon engagements include:
- Reports to a funder on whether grant expenditure by a grant recipient is incurred in terms of the conditions of the approved grant or contract.
- Confirmations or certificates of turnover provided to franchisors on the turnover earned by franchisees.
- The verification of claims against investment or incentive schemes managed by the Department of Trade and Industry (for example in automotive, IT, import and export sectors).
- Section 18 certificates for non-profit organisations confirming that donations are spent for the intended purpose.
- Business TV licence audits.
- Due diligence reviews.
- Confirmations of earnings or EBITDA or other calculations for debt covenants
What is challenging about accepting and conducting these engagements?
Even with the revisions in the new standard, the nature and extent of these engagements varies greatly in size, frequency, complexity and risk. Although they are not assurance engagements, the report issued by a practitioner must still comply with the standard as well as with the extant ISQC1 and the new international standards on quality management – these will become effective in 2022, and thus, still exposes practitioners to quality risks. Given the extremely varied nature of these engagements, applying a consistent approach has been challenging in the past. Some of these challenges have arisen from the following:
- The previous standards applied to financial information which provided very little guidance on procedures that were compliance, performance or non-financial in nature.
- Difficulty in establishing a consistent, repeatable approach between engagements and between recurring engagements. Because all engagements require procedures that are unique to the activity, it is not possible to apply a standard set of work programmes, and therefore, very difficult to obtain, and maintain, a consistent approach with comparable work flows, work programmes and internal quality management mandates.
- The standard is not well known and does not generally form part of the graduate accounting education syllabi. This means that practitioners need to read, understand, and interpret, the standard for themselves, if they are aware of it at all. This has resulted in the past in inconsistent approaches between practitioners.
- Difficulty in communicating requirements of procedures with clients or third parties. The engaging party is usually clear on what they need in a report and what it will be used for, and thus provide their understanding of the procedures they require to be performed. In the execution of these procedures, there is often more detail or a sub-set of additional processes that the practitioner needs to perform to identify and acquire the information required to report against the original method. It can be challenging for team members to determine how to obtain the evidence needed to perform the required tasks, or what to request from the client – this may need to be explained differently to the wording of the agreed-upon process.
- Where these engagements are performed manually i.e., not through specifically designed software, there is substantial repetition between recording the agreed-upon procedures in an engagement letter; doing so again in the working papers and again in the Agreed-Upon Procedures Report. Where the engagement comprises many procedures, this is very time consuming and subject to many errors of omission or transposition and carries a higher risk of the report not aligning with the initial required methods in the engagement letter.
- The higher volume of manual documentation and repetition can also result in these engagements not being as viable – in terms of the time required in relation to the fees earned for these activities.
- There is also the additional cost of having to repeat, or re-populate, documentation on engagement files for recurring activities in said manual files.
- The use of manual engagement files always carries an increased risk to practitioners’ inefficiencies through the requirements for manual signoffs, document misplacements, lack of evidence on completion, timelines of reviews etc., and ensuring that file assembly and archiving requirements are met.
An efficient, quality solution to conduct Agreed-Upon Procedure engagements
Caseware Africa has introduced a cloud-based Smart Engagements solution for Agreed-Upon Procedure Engagements called ISRS AGREED UPON, that addresses and resolves many of the quality and efficiency challenges.
- By using ISRS AGREED UPON for engagements, files can be populated with client and standing information relating to acceptance, continuance, skills, capacity, and independence requirements in the first engagement, and rolled forward to subsequent encounters, enabling practitioners to harness efficiencies in recurring events.
- The procedures included in the ISRS AGREED UPON solution have been compiled to ensure compliance with the requirements of the new ISRS 4400(R) standard relating to acceptance and continuance, ethical and independence requirements and the other changes brought into the new standard, for example, the use of experts. These changes have been fully incorporated and thus practitioners using this product will not have to rewrite previous manual work programmes for the changes in the standard.
- ISRS AGREED UPON can be adapted for the level of guidance required by your team. There is an option to select procedures that are core, or that are extended. Both facilitate compliance with the ISRS(R)4400 standard. Core procedures create efficiencies by reducing the number of procedures required for experienced users who understand the requirements for documentation, whist the extended procedures facilitate better documentation and therefore, make compliance easier for inexperienced users who require more detailed prompts or questions in order to arrive at the conclusions that an experienced user would.
- ISRS AGREED UPON automates the inclusion of the actual agreed-upon procedures throughout the engagement file and related documents. The procedures themselves are captured once, and the engagement letter, work programmes and the Agreed-upon Procedures Report is populated from this source. This drives efficiencies by reducing the amount of repetitive documentation, and also resolves challenges relating to inconsistencies between agreed processes and reported procedures and findings.
- ISRS AGREED UPON enables the practitioner to “reword” or tailor an initially agreed procedure to an inquiry or procedure that will facilitate asking for relevant information from clients in a manner that is understandable and will elicit the correct information/response. This “rewording” continues to be linked to the originally agreed procedure, ensuring a clear link between the work performed and the procedure to which it relates.
- ISRS AGREED UPON enables the practitioner or team members to capture, at the time that the procedure is performed and concluded upon, the finding that should be integrated into the Agreed-upon procedures report. This finding is automatically transferred to the report within ISRS AGREED UPON, creating efficiencies between executing procedures and compiling the Agreed-upon procedures report. This also ensures that the agreed-upon procedures are directly aligned to the conclusions per procedure that are included in the Agreed-upon procedures report.
One of the primary drivers of the IAASB’s revision of the Agreed Upon Procedures standard was the increasing use of these engagements for both financial and non-financial information. Taking into consideration the changes and expansion in financial and non-financial reporting and the increased level of assurance that users, funders, and regulators require from businesses, the investment in a solution that facilitates compliance and drives efficiencies will ensure that you are able to viably provide these services to clients with confidence, increasing the value offered to clients and improving efficiencies and quality.