INTERNATIONAL STANDARD ON AUDITING 706

EMPHASIS OF MATTER PARAGRAPHS AND OTHER

MATTER PARAGRAPHS IN THE INDEPENDENT
AUDITOR’S REPORT
(Effective for audits of financial statements for periods
beginning on or after December 15, 2009)

CONTENTS
Paragraph
Introduction
Scope of this ISA ......................................................................................... 1−2
Effective Date .............................................................................................. 3
Objective ..................................................................................................... 4
Definitions ................................................................................................... 5
Requirements
Emphasis of Matter Paragraphs in the Auditor’s Report .............................. 6−7
Other Matter Paragraphs in the Auditor’s Report ........................................ 8
Communication with Those Charged with Governance .............................. 9
Application and Other Explanatory Material
Emphasis of Matter Paragraphs in the Auditor’s Report .............................. A1−A4
Other Matter Paragraphs in the Auditor’s Report ........................................ A5−A11
Communication with Those Charged with Governance .............................. A12
Appendix 1: List of ISAs Containing Requirements for Emphasis of
Matter Paragraphs
Appendix 2: List of ISAs Containing Requirements for Other Matter
Paragraphs
Appendix 3: Illustration of an Auditor’s Report that Includes an
Emphasis of Matter Paragraph

International Standard on Auditing (ISA) 706, “Emphasis of Matter Paragraphs

and Other Matter Paragraphs in the Independent Auditor’s Report” should be read
in conjunction with ISA 200, “Overall Objectives of the Independent Auditor and
the Conduct of an Audit in Accordance with International Standards on Auditing.”

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Introduction
Scope of this ISA
1. This International Standard on Auditing (ISA) deals with additional
communication in the auditor’s report when the auditor considers it necessary to:
(a) Draw users’ attention to a matter or matters presented or disclosed in
the financial statements that are of such importance that they are
fundamental to users’ understanding of the financial statements; or
(b) Draw users’ attention to any matter or matters other than those
presented or disclosed in the financial statements that are relevant to
users’ understanding of the audit, the auditor’s responsibilities or the
auditor’s report.
2. Appendices 1 and 2 identify ISAs that contain specific requirements for the
auditor to include Emphasis of Matter paragraphs or Other Matter
paragraphs in the auditor’s report. In those circumstances, the requirements
in this ISA regarding the form and placement of such paragraphs apply.

Effective Date
3. This ISA is effective for audits of financial statements for periods beginning
on or after December 15, 2009.

Objective
4. The objective of the auditor, having formed an opinion on the financial
statements, is to draw users’ attention, when in the auditor’s judgment it is
necessary to do so, by way of clear additional communication in the auditor’s
report, to:

AUDITING
(a) A matter, although appropriately presented or disclosed in the financial
statements, that is of such importance that it is fundamental to users’
understanding of the financial statements; or
(b) As appropriate, any other matter that is relevant to users’ understanding
of the audit, the auditor’s responsibilities or the auditor’s report.

Definitions
5. For purposes of the ISAs, the following terms have the meanings
attributed below:
(a) Emphasis of Matter paragraph – A paragraph included in the auditor’s
report that refers to a matter appropriately presented or disclosed in the
financial statements that, in the auditor’s judgment, is of such importance
that it is fundamental to users’ understanding of the financial statements.

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(b) Other Matter paragraph – A paragraph included in the auditor’s

report that refers to a matter other than those presented or disclosed
in the financial statements that, in the auditor’s judgment, is relevant
to users’ understanding of the audit, the auditor’s responsibilities or
the auditor’s report.

Requirements
Emphasis of Matter Paragraphs in the Auditor’s Report
6. If the auditor considers it necessary to draw users’ attention to a matter presented
or disclosed in the financial statements that, in the auditor’s judgment, is of such
importance that it is fundamental to users’ understanding of the financial
statements, the auditor shall include an Emphasis of Matter paragraph in the
auditor’s report provided the auditor has obtained sufficient appropriate audit
evidence that the matter is not materially misstated in the financial statements.
Such a paragraph shall refer only to information presented or disclosed in the
financial statements. (Ref: Para. A1–A2)
7. When the auditor includes an Emphasis of Matter paragraph in the auditor’s
report, the auditor shall:
(a) Include it immediately after the Opinion paragraph in the auditor’s
report;
(b) Use the heading “Emphasis of Matter,” or other appropriate heading;
(c) Include in the paragraph a clear reference to the matter being
emphasized and to where relevant disclosures that fully describe the
matter can be found in the financial statements; and
(d) Indicate that the auditor’s opinion is not modified in respect of the
matter emphasized. (Ref: Para. A3–A4)

Other Matter Paragraphs in the Auditor’s Report

8. If the auditor considers it necessary to communicate a matter other than
those that are presented or disclosed in the financial statements that, in the
auditor’s judgment, is relevant to users’ understanding of the audit, the
auditor’s responsibilities or the auditor’s report and this is not prohibited by
law or regulation, the auditor shall do so in a paragraph in the auditor’s
report, with the heading “Other Matter,” or other appropriate heading. The
auditor shall include this paragraph immediately after the Opinion paragraph
and any Emphasis of Matter paragraph, or elsewhere in the auditor’s report
if the content of the Other Matter paragraph is relevant to the Other
Reporting Responsibilities section. (Ref: Para. A5–A11)

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Communication with Those Charged with Governance

9. If the auditor expects to include an Emphasis of Matter or an Other Matter
paragraph in the auditor’s report, the auditor shall communicate with those
charged with governance regarding this expectation and the proposed
wording of this paragraph. (Ref: Para. A12)

***

Application and Other Explanatory Material

Emphasis of Matter Paragraphs in the Auditor’s Report
Circumstances in Which an Emphasis of Matter Paragraph May Be Necessary (Ref:
Para. 6)
A1. Examples of circumstances where the auditor may consider it necessary to
include an Emphasis of Matter paragraph are:
• An uncertainty relating to the future outcome of exceptional
litigation or regulatory action.
• Early application (where permitted) of a new accounting standard
(for example, a new International Financial Reporting Standard) that
has a pervasive effect on the financial statements in advance of its
effective date.
• A major catastrophe that has had, or continues to have, a significant
effect on the entity’s financial position.
A2. A widespread use of Emphasis of Matter paragraphs diminishes the
effectiveness of the auditor’s communication of such matters. Additionally,

AUDITING
to include more information in an Emphasis of Matter paragraph than is
presented or disclosed in the financial statements may imply that the matter
has not been appropriately presented or disclosed; accordingly, paragraph 6
limits the use of an Emphasis of Matter paragraph to matters presented or
disclosed in the financial statements.

Including an Emphasis of Matter Paragraph in the Auditor’s Report (Ref: Para. 7)

A3. The inclusion of an Emphasis of Matter paragraph in the auditor’s report
does not affect the auditor’s opinion. An Emphasis of Matter paragraph is
not a substitute for either:
(a) The auditor expressing a qualified opinion or an adverse opinion, or
disclaiming an opinion, when required by the circumstances of a
specific audit engagement (see ISA 7051); or

1
ISA 705, “Modifications to the Opinion in the Independent Auditor’s Report.”

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(b) Disclosures in the financial statements that the applicable financial

reporting framework requires management to make.
A4. The illustrative report in Appendix 3 includes an Emphasis of Matter
paragraph in an auditor’s report that contains a qualified opinion.

Other Matter Paragraphs in the Auditor’s Report (Ref: Para. 8)

Circumstances in Which an Other Matter Paragraph May Be Necessary
Relevant to Users’ Understanding of the Audit
A5. In the rare circumstance where the auditor is unable to withdraw from an
engagement even though the possible effect of an inability to obtain sufficient
appropriate audit evidence due to a limitation on the scope of the audit
imposed by management is pervasive,2 the auditor may consider it necessary
to include an Other Matter paragraph in the auditor’s report to explain why it
is not possible for the auditor to withdraw from the engagement.

Relevant to Users’ Understanding of the Auditor’s Responsibilities or the Auditor’s

Report
A6. Law, regulation or generally accepted practice in a jurisdiction may require
or permit the auditor to elaborate on matters that provide further explanation
of the auditor’s responsibilities in the audit of the financial statements or of
the auditor’s report thereon. Where relevant, one or more sub-headings may
be used that describe the content of the Other Matter paragraph.
A7. An Other Matter paragraph does not deal with circumstances where the
auditor has other reporting responsibilities that are in addition to the
auditor’s responsibility under the ISAs to report on the financial statements
(see “Other Reporting Responsibilities” section in ISA 7003), or where the
auditor has been asked to perform and report on additional specified
procedures, or to express an opinion on specific matters.

Reporting on more than one set of financial statements

A8. An entity may prepare one set of financial statements in accordance with a
general purpose framework (for example, the national framework) and another
set of financial statements in accordance with another general purpose
framework (for example, International Financial Reporting Standards), and
engage the auditor to report on both sets of financial statements. If the auditor
has determined that the frameworks are acceptable in the respective
circumstances, the auditor may include an Other Matter paragraph in the
auditor’s report, referring to the fact that another set of financial statements has

2
See paragraph 13(b)(ii) of ISA 705 for a discussion of this circumstance.
3
ISA 700, “Forming an Opinion and Reporting on Financial Statements,” paragraphs 38–39.

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been prepared by the same entity in accordance with another general purpose
framework and that the auditor has issued a report on those financial statements.

Restriction on distribution or use of the auditor’s report

A9. Financial statements prepared for a specific purpose may be prepared in
accordance with a general purpose framework because the intended users have
determined that such general purpose financial statements meet their financial
information needs. Since the auditor’s report is intended for specific users, the
auditor may consider it necessary in the circumstances to include an Other
Matter paragraph, stating that the auditor’s report is intended solely for the
intended users, and should not be distributed to or used by other parties.

Including an Other Matter Paragraph in the Auditor’s Report

A10. The content of an Other Matter paragraph reflects clearly that such other
matter is not required to be presented and disclosed in the financial
statements. An Other Matter paragraph does not include information that
the auditor is prohibited from providing by law, regulation or other
professional standards, for example, ethical standards relating to
confidentiality of information. An Other Matter paragraph also does not
include information that is required to be provided by management.
A11. The placement of an Other Matter paragraph depends on the nature of the
information to be communicated. When an Other Matter paragraph is included
to draw users’ attention to a matter relevant to their understanding of the audit
of the financial statements, the paragraph is included immediately after the
Opinion paragraph and any Emphasis of Matter paragraph. When an Other
Matter paragraph is included to draw users’ attention to a matter relating to
Other Reporting Responsibilities addressed in the auditor’s report, the
paragraph may be included in the section sub-titled “Report on Other Legal and

AUDITING
Regulatory Requirements.” Alternatively, when relevant to all the auditor’s
responsibilities or users’ understanding of the auditor’s report, the Other Matter
paragraph may be included as a separate section following the Report on the
Financial Statements and the Report on Other Legal and Regulatory
Requirements.

Communication with Those Charged with Governance (Ref. Para. 9)

A12. Such communication enables those charged with governance to be made
aware of the nature of any specific matters that the auditor intends to highlight
in the auditor’s report, and provides them with an opportunity to obtain further
clarification from the auditor where necessary. Where the inclusion of an
Other Matter paragraph on a particular matter in the auditor’s report recurs on
each successive engagement, the auditor may determine that it is unnecessary
to repeat the communication on each engagement.

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Appendix 1
(Ref: Para. 2)

List of ISAs Containing Requirements for Emphasis of Matter

Paragraphs
This appendix identifies paragraphs in other ISAs in effect for audits of financial
statements for periods beginning on or after December 15, 2009 that require the
auditor to include an Emphasis of Matter paragraph in the auditor’s report in certain
circumstances. The list is not a substitute for considering the requirements and
related application and other explanatory material in ISAs.
• ISA 210, “Agreeing the Terms of Audit Engagements” – paragraph 19(b)
• ISA 560, “Subsequent Events” – paragraphs 12(b) and 16
• ISA 570, “Going Concern” – paragraph 19
• ISA 800, “Special Considerations—Audits of Financial Statements Prepared in
Accordance with Special Purpose Frameworks” – paragraph 14

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Appendix 2
(Ref: Para. 2)

List of ISAs Containing Requirements for Other Matter

Paragraphs
This appendix identifies paragraphs in other ISAs in effect for audits of financial
statements for periods beginning on or after December 15, 2009 that require the
auditor to include an Other Matter paragraph in the auditor’s report in certain
circumstances. The list is not a substitute for considering the requirements and
related application and other explanatory material in ISAs.
• ISA 560, “Subsequent Events” – paragraphs 12(b) and 16
• ISA 710, “Comparative Information—Corresponding Figures and Comparative
Financial Statements” – paragraphs 13–14, 16–17 and 19
• ISA 720, “The Auditor’s Responsibilities Relating to Other Information in
Documents Containing Audited Financial Statements” – paragraph 10(a)

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Appendix 3
(Ref: Para. A4)

Illustration of an Auditor’s Report that Includes an Emphasis of

Matter Paragraph

Circumstances include the following:

• Audit of a complete set of general purpose financial statements
prepared by management of the entity in accordance with International
Financial Reporting Standards.
• The terms of the audit engagement reflect the description of
management’s responsibility for the financial statements in ISA 210.1
• There is uncertainty relating to a pending exceptional litigation matter.
• A departure from the applicable financial reporting framework resulted
in a qualified opinion.
• In addition to the audit of the financial statements, the auditor has other
reporting responsibilities required under local law.

INDEPENDENT AUDITOR’S REPORT

[Appropriate Addressee]
Report on the Financial Statements2
We have audited the accompanying financial statements of ABC Company, which
comprise the statement of financial position as at December 31, 20X1, and the
statement of comprehensive income, statement of changes in equity and statement of
cash flows for the year then ended, and a summary of significant accounting policies
and other explanatory information.

Management’s3 Responsibility for the Financial Statements

Management is responsible for the preparation and fair presentation of these
financial statements in accordance with International Financial Reporting Standards,4

1
ISA 210, “Agreeing the Terms of Audit Engagements.”
2
The sub-title “Report on the Financial Statements” is unnecessary in circumstances when the second
sub-title “Report on Other Legal and Regulatory Requirements” is not applicable.
3
Or other term that is appropriate in the context of the legal framework in the particular jurisdiction.
4
Where management’s responsibility is to prepare financial statements that give a true and fair view,
this may read: “Management is responsible for the preparation of financial statements that give a
true and fair view in accordance with International Financial Reporting Standards, and for such ...”

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and for such internal control as management determines is necessary to enable the
preparation of financial statements that are free from material misstatement, whether
due to fraud or error.

Auditor’s Responsibility
Our responsibility is to express an opinion on these financial statements based on our
audit. We conducted our audit in accordance with International Standards on
Auditing. Those standards require that we comply with ethical requirements and plan
and perform the audit to obtain reasonable assurance about whether the financial
statements are free from material misstatement.
An audit involves performing procedures to obtain audit evidence about the amounts
and disclosures in the financial statements. The procedures selected depend on the
auditor’s judgment, including the assessment of the risks of material misstatement of
the financial statements, whether due to fraud or error. In making those risk
assessments, the auditor considers internal control relevant to the entity’s preparation
and fair presentation5 of the financial statements in order to design audit procedures
that are appropriate in the circumstances, but not for the purpose of expressing an
opinion on the effectiveness of the entity’s internal control.6 An audit also includes
evaluating the appropriateness of accounting policies used and the reasonableness of
accounting estimates made by management, as well as evaluating the overall
presentation of the financial statements.
We believe that the audit evidence that we have obtained is sufficient and appropriate
to provide a basis for our qualified audit opinion.

Basis for Qualified Opinion

The company’s short-term marketable securities are carried in the statement of
financial position at xxx. Management has not marked these securities to market but

AUDITING
has instead stated them at cost, which constitutes a departure from International
Financial Reporting Standards. The company’s records indicate that had management
marked the marketable securities to market, the company would have recognized an
unrealized loss of xxx in the statement of comprehensive income for the year. The

5
In the case of footnote 7, this may read: “In making those risk assessments, the auditor considers
internal control relevant to the entity’s preparation of financial statements that give a true and fair
view in order to design audit procedures that are appropriate in the circumstances, but not for the
purpose of expressing an opinion on the effectiveness of the entity’s internal control.”
6
In circumstances when the auditor also has responsibility to express an opinion on the effectiveness
of internal control in conjunction with the audit of the financial statements, this sentence would be
worded as follows: “In making those risk assessments, the auditor considers internal control relevant
to the entity’s preparation and fair presentation of the financial statements in order to design audit
procedures that are appropriate in the circumstances.” In the case of footnote 7, this may read: “In
making those risk assessments, the auditor considers internal control relevant to the entity’s
preparation of financial statements that give a true and fair view in order to design audit procedures
that are appropriate in the circumstances.”

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carrying amount of the securities in the statement of financial position would have
been reduced by the same amount at December 31, 20X1, and income tax, net
income and shareholders’ equity would have been reduced by xxx, xxx and xxx,
respectively.

Qualified Opinion
In our opinion, except for the effects of the matter described in the Basis for
Qualified Opinion paragraph, the financial statements present fairly, in all material
respects (or give a true and fair view of) the financial position of ABC Company as
at December 31, 20X1, and (of) its financial performance and its cash flows for the
year then ended in accordance with International Financial Reporting Standards.

Emphasis of Matter
We draw attention to Note X to the financial statements which describes the
uncertainty7 related to the outcome of the lawsuit filed against the company by XYZ
Company. Our opinion is not qualified in respect of this matter.

Report on Other Legal and Regulatory Requirements

[Form and content of this section of the auditor’s report will vary depending on the
nature of the auditor’s other reporting responsibilities.]
[Auditor’s signature]
[Date of the auditor’s report]
[Auditor’s address]

7
In highlighting the uncertainty, the auditor uses the same terminology that is used in the note to the
financial statements.

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