I sitt remissvar den 21 maj 2001 till IAPC på den föreslagna ändringen av ISA 700 (jfr. Balans nr 5/2001) tar FAR även allmänt upp frågor om översättning och definition av nyckelord och andra ord.
Behandlingen av nyckelord har varit en av de viktigaste frågorna i FARs arbete med översättningen av ISA. I remissvaret ges ett exempel på ett sådant ord där det redan på engelska saknas en sammanhängande och koncis definition av termen. FAR rekommenderar att IAPC alltid särskilt ber om synpunkter i översättnings- och definitionsfrågor vid framtida remisser av standarder och uttalanden. FAR rekommenderar också att IAPC preciserar innebörden i ISA-sammanhang av använda ord på engelska som också har en mer allmän betydelse på engelska.
FARs remissvar återges i sin helhet nedan.
Remissvar
In response to your request for comments on the Exposure Draft The Auditor’s Report on Financial Statements FAR has the following comments.
FAR’s position
General view of proposed revision
FAR supports the substance of the proposed revision to ISA 700. However for better guidance we believe that also the end of the opinion paragraph in paragraph 28 needs revision. And as a consequence of such a change also paragraph 21 would need amendment.
Reasons for comments and proposed amendments
The proposed revision to ISA 700 has already been implemented in the current FAR standard on Auditor’s Report in Sweden. The Swedish standard is however otherwise based on ISA 700.
Considering the change made at the beginning of paragraph 28 keeping the wording ”...in accordance with ...” at the end of that paragraph is confusing and unclear. We suggest that either the wording ”...in accordance with ...” at the end is deleted or the dots following ”with” be replaced by the appropriate wording taking the new text at the beginning of the paragraph into account. We leave it to IAPC to decide what such an ”appropriate wording” would be. Also paragraph 21 and its reference to footnote 4 would be affected by any change of paragraph 28 in this respect.
Comments on issues raised by IAPC
We do not foresee any implementation problems and therefore we support the proposed date on which the new standard becomes effective.
We do not foresee any problems with the translation of the amendments into Swedish. However please note our ”Other comments” below.
Other comments
FAR has recently completed a translation of the ISAs into Swedish. The aim of that process is to introduce standards on auditing in Sweden based on the ISAs within a couple of years. Thus having experienced a number of translation problems during the last two and a half years FAR warmly welcomes that IAPC recognises and highlights translation problems as an important issue to comment on in exposure drafts. We have also noted the ongoing discussion in the English-speaking world, i.e. JWG letter to IAPC 11 October 1999, of what would be the specific meaning in the context of the ISAs of certain English words which have a meaning in common usage (for instance verbs such as ”assess”, ”consider” etc.). Also developments and communication from IAPC within this area would be welcomed and strongly supported by FAR. In this context we take the opportunity to propose another issue to highlight for comments in the future exposure drafts. Namely if certain terms, expressions or words in the ED in question have been identified which ought to be defined in the specific ISA and also included in the Glossary of Terms. To give you an idea of what we mean by that we will give you an example from our translation process with a clear reference to ISA 700. The expression ”on a test basis” (”the use of testing”) presently lacks a concise, comprehensive definition in the ISAs and the Glossary of Terms. Being one of the very critical terms, if not the very critical one, in ISA 700 and ISA 120 and other ISAs as well as in auditing as such we believe that it would be a significant improvement of the ISAs if that term was defined in a concise and comprehensive way by IAPC.
Lars-Gunnar Larsson