Corresponding author: Anna Gold ( anna.gold@vu.nl ) Academic editor: Barbara Majoor
© 2019 Anna Gold, Melina Heilmann.
This is an open access article distributed under the terms of the Creative Commons Attribution License (CC BY-NC-ND 4.0), which permits to copy and distribute the article for non-commercial purposes, provided that the article is not altered or modified and the original author and source are credited.
Citation:
Gold A, Heilmann M (2019) The consequences of disclosing key audit matters (KAMs): A review of the academic literature. Maandblad Voor Accountancy en Bedrijfseconomie 93(1/2): 5-14. https://doi.org/10.5117/mab.93.29496
|
Recent years have witnessed a change in the auditor reporting model. One of these developments is the auditor’s issuance of so-called Key Audit Matters in the auditor’s report, where they disclose “those matters that, in the auditor’s professional judgment, were of most significance in the audit of the financial statements of the current period”. In this paper, we review the emerging body of academic research which examines the effects of KAM disclosures in the auditor’s report. We investigate research that has examined the effect of KAM disclosures on (1) investor behavior and market reaction, (2) auditor responses, (3) auditor liability, and (4) client management responses. The objective of this paper is to provide an overview of the existing literature and to summarize the preliminary findings and implications of 22 studies.
Key audit matters, auditor reporting model, stakeholder responses
This literature review is of interest to auditors, standard setters, investors, regulators, and other stakeholders affected by auditor’s reporting, as the disclosure of KAMs significantly changes auditors’ communication. Readers will gain insights into initial research findings on KAM disclosure that will help evaluate the consequences of the new reporting requirements.
The auditor’s report is the primary mean of communication between auditors and financial statement users (
These debates and research findings have resulted in multiple initiatives across the globe to enhance the communicative value of the auditor’s report. The International Auditing and Assurance Standards Board (IAASB), the European Commission (EC), the Public Company Accounting Oversight Board (PCAOB), and the U.K. Financial Reporting Council (FRC) finalized their projects to enhance the auditor’s report. One of the most significant amendments is the disclosure of Key Audit Matters (KAMs) or Critical Audit Matters (CAMs, which are the equivalent concept in the U.S. jurisdiction) in the auditor’s report. According to ISA 701.8, key audit matters are “those matters that, in the auditor’s professional judgment, were of most significance in the audit of the financial statements of the current period”. Unlike the traditional auditor’s report, the revised form allows for more customized information disclosed about the client- and engagement-specific observations made by the auditor. As such, the primary objective of standard setters and regulators is the transformation of the traditional pass/fail-model into a more individual and valuable report in order to meet the informational needs of financial statement users.
In this paper, we review the emerging body of academic research which examines the effects of KAM disclosures in the auditor’s report. We do so by examining four distinct streams of research. First, we review research papers that investigate whether KAM disclosures indeed have the potential of meeting the expectations of standard setters and regulators with respect to providing a more valuable reporting model. Second, some scholars argue that the introduction of the KAM section in the auditor’s report may not only influence financial statement users’ perception and decisions but could also have an influence on the audit itself. For example,
The objective of this paper is to provide an overview of the existing literature and to summarize the preliminary findings and implications of 22 studies.
The remainder of this paper is organized as follows. In the next section, we provide a brief overview of related regulatory developments. Section 3 summarizes and discusses the results of academic studies on KAM disclosures. The final section presents our conclusions including implications for future research and for the audit profession.
In May 2011, the IAASB published the consultation paper “Enhancing the value of auditor reporting: Exploring options for change”, discussing possible ways to improve the auditor’s report, particularly regarding the increased need for information by users and the persisting expectation and information gap (
The European Commission aspires to improve auditor reporting in a similar way. According EU-Regulation No 537/2014 the auditor’s report shall provide: (1) a description of the most significant assessed risks of material misstatement, (2) a summary of the auditor’s response to those risks, and (3) where relevant, key observations arising with respect to those risks. The EU-Regulation is directly applicable in all Member States and is effective for audits of public interest entities from 17 June 2016 (European Parliament and European Council of the European Union 2014).
In the UK, the FRC revised their reporting requirements already in June 2013 in order to enhance the transparency of the auditor’s report aiming a better communication between auditors and users. Provisions became effective for audits of financial statements for periods commencing on or after 1 October 2012 and require auditors, among other things, to report the risks of material misstatement that had the greatest effect on: (1) the overall audit strategy, (2) the allocation of resources in the audit, and (3) directing the efforts of the engagement team (
In a similar vein, the PCAOB is currently undertaking changes to the existing auditor’s report, including the communication of Critical Audit Matters. Similar to KAMs, these are matters that were communicated to the audit committee and that: (1) relate to accounts or disclosures that are material to the financial statements, and (2) involved especially challenging, subjective, or complex auditor judgment. The new requirements regarding CAM disclosures will take effect for audits for fiscal years ending on or after 30 June 2019 for large accelerated filers. For all other companies to which the provisions apply, the new regulations will be effective for periods ending on or after 15 December 2020 (
Despite the use of different terminologies, the implemented reforms of expanded auditor reporting overlap considerably. Although the requirements differ in the details, standard setters and regulators globally have clearly concluded that there is a need to disclose additional information about risk-related matters in the auditor’s report. Thus, for the first time, investors gain insights into significant audit findings and procedures.
A substantial and growing body of literature investigates the effects of the disclosure of KAMs in the auditor’s report. To find the relevant studies, we used different databases (for example EBSCO, Google Scholar, SSRN, Web of Science) and searched for the key words “key audit matters” and “critical audit matters” in combination with “auditor reporting”, “audit report” and comparable terms. Due to the currency of the topic, a time limitation was not necessary. Although it is common to consider only published research in literature reviews, we extended our literature review to include publicly available working papers because the majority of related studies have not yet been published. Therefore, we included working papers that have been presented at pertinent academic conferences (e.g., conferences of the American Accounting Association (AAA), the European Audit Research Network (EARNet), the International Symposium on Audit Research (ISAR)).
The existing studies are based on experimental designs and archival data. We note that due to the lack of archival data, the majority of KAM research is experimental. Related reforms were adopted very recently, so that the only archival data for meaningful analyses is currently available from the UK, where auditors were required to report KAM since 2013.
We group the recent studies on KAM disclosures in four categories. The first category examines the effects of KAM disclosure on investor behavior and market reaction (
Summary of reviewed papers on the disclosure of KAMs (listed in alphabetical author name order).
Date1 | Author(s)2 | Method and Sample | Dependent Variable | Independent Variable | Main results |
---|---|---|---|---|---|
Panel A: Investor behavior and market reaction | |||||
2018 (wp) | Almulla/Bradbury | Archival; New Zealand; 2015, 2016, 2017; 132 firms | Audit effort, audit quality, client firm disclosures, investor reaction | KAM | • Association with investor uncertainty |
2018 (wp) | Bédard/Gonthier-Besacier/Schatt | Archival; France, 2002–2011; 1,857–2,341 firm-year observations | Market reaction, audit quality, audit delay, audit costs | JOA | • Short-term effects: No significant market reaction |
• Long-term effects: association with lower agreement among investors | |||||
2016 | Boolaky/ Quick | Experimental; 105 bank directors | Perceived financial statement quality | KAM, assurance level, materiality level | • No significant effect of reporting KAM or materiality level in the auditor‘s report |
• But positive impact regarding the disclosure of assurance level | |||||
2017 (wp) | Carver/ Trinkle | Experimental; 150 non-professional investors | Readability, investors judgment, management credibility | CAM | • CAMs have a negative impact on readability |
• CAMs do not influence investor‘s valuation judgments | |||||
• However, CAMs can reduce perceived management‘s credibility | |||||
2014 | Christensen/Glover/ Wolfe | Experimental; 141 Alumni from a public business school | Investor behavior | CAM | • Investors who receive a CAM are more likely to change their investment decision |
• Effect is reduced by offering a resolution paragraph | |||||
2018 | Gutierrez/ Minutti-Meza/ Tatum/ Vulcheva | Archival; UK, 2011-2015, 2560/2652/2056 firm-year observations | Market reaction, audit fee, audit quality | Risk of material misstatement | • No significant change regarding market reaction |
2016 (wp) | Köhler/ Ratzinger-Sakel/ Theis | Experimental; 89 professional and 69 non-professional investors | Communicative value | KAM | • Higher communicative value only for professional investors (no communicative value for non-professional investors) |
2018 (wp) | Lennox/ Schmidt/ Thompson | Archival; UK; 2013; 488 companies | Market reaction | Risk of material misstatement | • Investors do not find disclosures informative (both „short window“ and „long window“ tests) |
2018 | Sirois/ Bédard/ Bera | Experimental; 98 students | Information value | KAM | • Attention directing impact: users pay more attention to KAM-related disclosures |
• Disclosure of several KAMs leads to reduced attention towards remaining parts of the financial statements | |||||
Panel B: Auditor responses | |||||
2018 (wp) | Almulla/ Bradbury | Archival; New Zealand; 2015,2016,2017; 32 firms | Audit effort, audit quality, client firm disclosures, investor reaction | KAM | • No incremental effect on audit fees, audit delay or absolute abnormal accruals |
2017 (wp) | Asbahr/ Ruhnke | Experimental; 122 auditors | Auditor judgment | KAM | • No significant effect on professional skepticism |
2018 (wp) | Bédard/ Gonthier-Besacier/ Schatt | Archival; France, 2002-2011; 1,857-2,341 firm-year observations | Market reaction, audit quality, audit delay, audit costs | JOA | • Short-term effects: positive association with audit lag and audit fees |
• Long-term effects: association with lower agreement among investors and reporting quality | |||||
2018 | Gutierrez/ Minutti-Meza/ Tatum/ Vulcheva | Archival; UK, 2011-2015, 2560/2652/2056 firm-year observations | Market reaction, audit fee, audit quality | Risk of material misstatement | • No significant change regarding audit fee and audit quality |
2018 (wp) | Li/ Hay/ Lau | Archival; New Zealand; 2016; 182/242 firm-year observations | Audit quality, Audit fees | KAM | • Improvement of audit quality accompanying with an increase in audit fees |
2018 (wp) | Ratzinger-Sakel/Theis | Experimental; 73 auditors | Auditor judgment performance | KAM | • Less professional skepticism when KAM consideration is present |
2018 (wp) | Reid/ Carcello/ Li/ Neal | Archival; UK; 1088 (888, 884)/ 1304/ 1292 firm-year observations | Financial reporting quality, audit fee, audit delay | Risk of material misstatement | • Significant improvement in financial reporting quality |
• No effect on audit fee and audit delay | |||||
Panel C: Auditor liability | |||||
2018 (wp) | Backof/ Bowlin/ oodson | Experimental; 63 undergraduate students | Auditor liability | CAM | • When the audit report includes a related CAM disclosure, jurors perceive auditors as more negligent |
• However, clarifying the concept of reasonable assurance mitigates this effect | |||||
2016 | Brasel/ Doxey/ Grenier/ Reffett | Experimental; 528 participants from Amazon Mechanical Turk | Auditor liability | CAM | • CAMs reduce jurors‘ auditor liability judgments under certain conditions (but only if undetected misstatements are, absent CAM disclosure, relatively difficult to foresee) |
2016 (wp) | Brown/ Majors/ Peecher | Experimental; 239 participants from Amazon Mechanical Turk and 116 law students | Auditor liability | CAM (only as a supple-mental manipulation) | • No significant main effect of CAMs on liability judgments |
2016 | Gimbar/ Hansen/ Ozlanski | Experimental; 234 students | Auditor liability | CAM | • Under precise standards, both related and unrelated CAMs increase auditor liability |
• CAMs increase auditor liability by a lesser amount under imprecise standards than precise standards | |||||
2018 (wp) | Kachelmeier/ Schmidt/ Valentine | Experimental; 70 attorneys, 50 financial analysts and150 MBA students | Auditor legal exposure | CAM | • CAM disclosure decreases assessments of auditor responsibility when the misstatement is in the same area as the CAM |
• “Disclaimer effect” is manifest in different ways for different groups | |||||
2018 (wp) | Vinson/ Robertson/ Cockrell | Experimental; 168 participants from Amazon Mechanical Turk | Auditor liability | CAM | • Higher auditor negligence when a CAM is removed |
• Highest assessed negligence when auditor removes a CAM after reporting it for multiple years | |||||
Panel D: Client management responses | |||||
2018 (wp) | Bentley/ Lambert/ Wang | Experimental; 140 corporate managers | Manager‘s decision making | CAM | • Given a Standard CAM, managers were less likely to hedge (a risk-decreasing transaction), but more likely to speculate (a risk-increasing transaction) |
• A Disclaimer CAM mitigates the impact of CAM on speculation | |||||
2014 (wp) | Cade/ Hodge | Experimental; Alumni | Communication between management and auditors | Additional disclosures | • Managers are less willing to share accounting choices with auditors |
2018 (wp) | Klueber/ Gold/ Pott | Experimental; 54 participants | Manager‘s decision making | KAM | • Reduced earnings management if KAM section includes firm-specific information |
An experimental study by
The experimental study by
While most research thus far is based on experiments, there is also some initial evidence from archival studies. First,
In contrast to the above archival studies,
Overall, the above studies provide mixed results regarding investor behavior and market reaction in response to KAMs. Some experimental studies suggest that there is an effect on users, showing that users are less likely to invest in a company and that they focus their attention on particular parts of the financial statements in the presence of KAM disclosure. However, other experimental results do not confirm these effects and, importantly, archival research has not been able to find evidence in support of a significant market reaction. In view of these mixed results, further research is necessary to explore the economic consequences associated with KAM disclosure. In particular, archival research will be feasible once regulatory developments in other jurisdictions take effect and sufficient data is available.
While the impact of KAMs on reducing the information gap and thus investor behavior is most directly aligned with the intended objectives of the expanded audit reporting model, some researchers have also examined whether the requirement to disclose KAMs influences auditor behavior. According to
First, while not focusing exclusively on disclosure of KAMs,
While these studies provide important preliminary archival evidence, additional research over more years and in other jurisdictions will help better reconcile the longer-term effects. Finally, we are aware of two working papers that use the experimental method to examine how auditors in Germany respond to the (anticipated) disclosure of KAMs (
Again, we conclude that the evidence with respect to the association between KAM disclosure and audit-related outcomes is mixed, but we note that surprisingly many studies suggest adverse effects, which require deeper investigation to be corroborated and analyzed.
In the course of the development of the new reporting requirement auditor legal liability was a frequently debated controversy, particularly in the United States (e.g.,
A few working papers have examined whether and how client management responds to (anticipated) KAM disclosures by their auditors. It is possible that KAMs may influence managerial decision making, given the increased scrutiny by auditors as a result of KAMs. We are aware of three experimental studies which are relevant in this regard. First,
Finally,
Responding to extensive criticism of the traditional pass/fail-model of auditor reporting, standard setters and regulators worldwide have recently released new auditor reporting requirements, including the requirement for auditors to disclose Key Audit Matters (KAMs). The disclosure of KAMs is supposed to enhance the information value and decision usefulness of the auditor’s report, and may also have effects on the performance of auditors and managers, as well as liability judgments of jurors. We identified 22 research studies examining the consequences of KAM disclosures for investor behavior, auditor responses, jurors’ assessments of auditor liability, and client management responses.
Several research findings support the intended benefits of KAM disclosures. For example, experimental evidence suggests that KAMs have the potential of influencing the decisions of financial statement users, particularly with regard to non-professional investors. KAMs also have the potential of effectively directing financial statement users’ attention to pertinent areas and decrease managers’ earnings management attempts. While these findings are promising, preliminary archival research fails to support a wider capital market reaction to KAM disclosures, raising questions about the economic significance of the changed reporting model.
KAM disclosures also appear to have some unanticipated, and sometimes even adverse consequences. Archival research finds efficiency losses in terms of increased audit report lags and audit fees, and experimental evidence suggests that auditors may be less professionally skeptical in the presence of KAMs. Finally, managers’ willingness to share information with their auditor as well as their risk-taking behavior is affected by anticipated KAM disclosures, not always in a beneficial direction.
Based on the findings reviewed in this paper, we offer some important implications and recommendations for audit practice. First, auditors should be aware that the disclosure of KAMs has attention-directing impacts on financial statement users and should therefore carefully decide how many, and in particular what matters, they disclose as KAMs in the auditor’s report. Second, some adverse consequences of KAM disclosures can be mitigated by an explanation of the concept of reasonable assurance (e.g.,
In a relatively short time span, a substantial number of research papers has appeared with the objective of examining the consequences of KAM disclosures for a variety of stakeholders, suggesting this is a growing body of auditing research. The findings thus far suggest several fruitful avenues for future research. In particular, the mixed nature of results of previous studies indicate that there may be insufficient research to assess all the consequences of KAM disclosure. First, due to the mixed findings on investor and market reactions, more research is needed on how exactly investors process the additional information provided in KAM sections, while differentiating between sophisticated and unsophisticated investors. In this regard, we recommend greater use of qualitative research methods (e.g., interviews or focus groups) to better understand how users process this information. Eye-tracking research, such as the study by
Prof. dr. A. Gold is full professor of auditing at Vrije Universiteit Amsterdam and adjunct professor at Norwegian School of Economics (NHH)
M. Heilmann MSc is a Ph.D. student at Technische Universität Dortmund
In addition to the disclosure of KAMs, regulatory developments also include other changes to the content and the form of the auditor’s report. However, our literature review focuses on studies examining the impact of KAM disclosures only.
We caution readers that findings and conclusions reported in working papers may change as a result of the academic review process, which we however consider a relatively minor trade-off to our choice to include working papers in our review.