PAPS 1010
Philippine Auditing Practice Statement 1010
THE CONSIDERATION OF ENVIRONMENTAL
MATTERS IN THE AUDIT OF
FINANCIAL STATEMENTS
Auditing Standards and Practices Council
PAPS 1010
PHILIPPINE AUDITING PRACTICE STATEMENT 1010
THE CONSIDERATION OF ENVIRONMENTAL
MATTERS IN THE AUDIT OF FINANCIAL STATEMENTS
CONTENTS
Paragraphs
Introduction 1-12
Guidance on the Application of PSA 310, Knowledge
of the Business 13-16
Guidance on the Application of PSA 400, Risk
Assessments and Internal Control 17-29
Guidance on the Application of PSA 250, Consideration
of Laws and Regulations in an Audit of Financial Statements 30-34
Substantive Procedures 35-47
Management Representations 48
Reporting 49-50
Effective Date 51
Acknowledgment 52-53
Appendix 1: Obtaining Knowledge of the Business from an
Environmental Point of View – Illustrative Questions
Appendix 2: Substantive Procedures to Detect a Material
Misstatement due to Environmental Matters
PAPS 1010
Philippine Auditing Practices Statements (“Statements”) are issued by the Auditing
Standards and Practices Council (“ASPC”) to provide practical assistance to auditors in
implementing the Philippine Standards on Auditing (“PSAs”) or to promote good
practice. Statements do not have the authority of PSAs.
This Statement does not establish any new basic principles or essential procedures: its
purpose is to assist auditors, and the development of good practice, by providing guidance
on the application of the PSAs in cases when environmental matters are significant to the
financial statements of the entity. The extent to which any of the audit procedures
described in this Statement may be appropriate in a particular case requires the exercise of
the auditor’s judgment in the light of the requirements of the PSAs and the circumstances
of the entity.
This Statement was approved by the ASPC in April 2003.
The ISAs on which the PSAs are based are generally applicable to the public sector,
including government business enterprises. However, the applicability of the equivalent
PSAs on Philippine public sector entities has not been addressed by the Council. It is the
understanding of the Council that this matter will be addressed by the Commission on
Audit itself in due course. Accordingly, the Public Sector Perspective set out at the end of
an ISA has not been adopted
into the PSAs.
PAPS 1010
Introduction
The Purpose of this Statement
1. Environmental matters are becoming significant to an increasing number of
entities and may, in certain circumstances, have a material impact on their
financial statements. These issues are of growing interest to the users of financial
statements. The recognition, measurement, and disclosure of these matters is the
responsibility of management.
2. For some entities, environmental matters are not significant. However, when
environmental matters are significant to an entity, there may be a risk of material
misstatement (including inadequate disclosure) in the financial statements arising
from such matters: in these circumstances, the auditor needs to give consideration
to environmental matters in the audit of the financial statements.
3. Environmental matters can be complex and may therefore require additional
consideration by auditors. This Statement provides practical assistance to auditors
by describing:
(a) the auditor’s main considerations in an audit of financial statements with
respect to environmental matters;
(b) examples of possible impacts of environmental matters on financial
statements; and
(c) guidance that the auditor may consider when exercising professional
judgment in this context to determine the nature, timing, and extent of
audit procedures with respect to:
knowledge of the business (PSA 310);
risk assessments and internal control (PSA 400);
consideration of laws and regulations (PSA 250); and
other substantive procedures (PSA 620 and some others).
The guidance under (c) reflects the typical sequence of the audit process. Having
acquired a sufficient knowledge of the business the auditor assesses the risk of a
material misstatement in the financial statements. This assessment includes
consideration of environmental laws and regulations that may pertain to the entity,
and provides a basis for the auditor to decide whether there is a need to pay
attention to environmental matters in the course of the audit of financial
statements.
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Appendix 1 provides illustrative questions that an auditor may consider when
obtaining knowledge of the business, including an understanding of the entity’s
control environment and control procedures from an environmental point of view.
Appendix 2 provides examples of substantive procedures that an auditor may
perform to detect a material misstatement in the financial statements due to
environmental matters. These appendices are included for illustrative purposes
only. It is not intended that all, or even any, of the questions or examples will
necessarily be appropriate in any particular case.
4. This Statement does not establish any new basic principles or essential
procedures: its purpose is to assist auditors, and the development of good practice,
by providing guidance on the application of the PSAs in cases when
environmental matters are significant to the financial statements of the entity. The
extent to which any of the audit procedures described in this Statement may be
appropriate in a particular case requires the exercise of the auditor’s judgment in
the light of the requirements of the PSAs and the circumstances of the entity.
5. The Statement does not provide guidance on the audit of the financial statements
of insurance companies with regard to claims incurred under insurance policies
relating to environmental matters affecting policyholders.
The Auditor’s Main Considerations with respect to Environmental Matters
6. The objective of an audit of financial statements is:
“…to enable the auditor to express an opinion whether the financial
statements are prepared, in all material respects, in accordance with an
identified financial reporting framework.” (PSA 200, paragraph 2).
7. The auditor’s opinion relates to the financial statements taken as a whole and not
to any specific aspect. When planning and performing audit procedures and in
evaluating and reporting the results thereof, the auditor should recognize that
noncompliance by the entity with laws and regulations may materially affect the
financial statements. However, an audit cannot be expected to detect
noncompliance with all laws and regulations (PSA 250, paragraph 2). In
particular, with respect to the entity’s compliance with environmental laws and
regulations, the auditor’s purpose is not to plan the audit to detect possible
breaches of environmental laws and regulations; nor are the auditor’s procedures
sufficient to draw a conclusion on the entity’s compliance with environmental
laws and regulations or the adequacy of its controls over environmental matters.
1
1
Examples of environmental laws and regulations are the Philippine Clean Air Act of 1999 and the Philippine Ecological Solid
Waste Management Act of 2000.
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8. In all audits, when developing the overall audit plan, the auditor assesses inherent
risk at the financial statement level (PSA 400, paragraph 11). The auditor uses
professional judgment to evaluate the factors relevant to this assessment. In
certain circumstances these factors may include the risk of material misstatement
of the financial statements due to environmental matters. The need to consider,
and extent of the consideration of, environmental matters in an audit of financial
statements depends on the auditor’s judgment as to whether environmental matters
give rise to a risk of material misstatement in the financial statements. In some
cases, no specific audit procedures may be judged necessary. In other cases,
however, the auditor uses professional judgment to determine the nature, timing
and extent of the specific procedures considered necessary in order to obtain
sufficient appropriate audit evidence that the financial statements are not
materially misstated. If the auditor does not have the professional competence to
perform these procedures, technical advice may be sought from specialists, such as
lawyers, engineers, or other environmental experts.
9. To conclude that an entity operates in compliance with existing environmental
laws or regulations ordinarily requires the technical skills of environmental
experts, which the auditor cannot be expected to possess. Also, whether a
particular event or condition that comes to the attention of the auditor is a breach
of environmental laws and regulations is a legal determination that is ordinarily
beyond the auditor’s professional competence. However, as with other laws and
regulations:
“…the auditor’s training, experience and understanding of the entity and
its industry may provide a basis for recognition that some acts coming to
the auditor’s attention may constitute noncompliance with laws and
regulations. The determination as to whether a particular act constitutes or
is likely to constitute noncompliance is generally based on the advice of an
informed expert qualified to practice law but ultimately can only be
determined by a court of law.” (PSA 250, paragraph 4.)
Environmental Matters and their Impact on the Financial Statements
10. For the purpose of this Statement, “environmental matters” are defined as:
(a) initiatives to prevent, abate, or remedy damage to the environment, or to
deal with conservation of renewable and non-renewable resources (such
initiatives may be required by environmental laws and regulations or by
contract, or they may be undertaken voluntarily);
(b) consequences of violating environmental laws and regulations;
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(c) consequences of environmental damage done to others or to natural
resources; and
(d) consequences of vicarious liability imposed by law (for example, liability
for damages caused by previous owners).
11. Some examples of environmental matters affecting the financial statements are the
following:
the introduction of environmental laws and regulations may involve an
impairment of assets and consequently a need to write down their carrying
value;
failure to comply with legal requirements concerning environmental
matters, such as emissions or waste disposal, or changes to legislation with
retrospective effect, may require accrual of remediation, compensation or
legal costs;
some entities, for example in the extraction industries (oil and gas
exploration or mining), chemical manufacturers or waste management
companies may incur environmental obligation as a direct by-product of
their core businesses;