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ATO flags potential issues with audit pooling arrangements


The ATO is advising in-house audit firms to try and avoid entering pooled audit arrangements with other firms in order to meet the auditor independence guidance as there could still be threats that arise.

By Miranda Brownlee2 minute read

ATO director, SMSF auditor portfolio, Kellie Grant said the ATO understands that some firms are thinking about audit pooling arrangements in response to the restructured APES 110 code and APSEB Independence Guide to try and avoid any revenue loss to the firm.


“We think it is best practice for firms to avoid engaging in these arrangements and find an auditor who is completely independent,” Ms Grant said in a recent podcast of sister brand SMSF Adviser.

“This is because that auditor is then less likely to have any hesitation about qualifying an audit report for the client.”

If firms do insist on using a pooling arrangement, however, Ms Grant said they need to be aware of addressing any threats that could arise if some of the firms within the pool end up reciprocating some referrals.

“They could do this by ensuring the pool is big enough to enable a broad auditor referral base and therefore avoid any self-interest threats that could arise from fee dependency or familiarity or intimidation threats that might arise where there is a close relationship between two auditing/accounting firms,” she explained.

The ATO has previously made clear that where two SMSF firms enter a reciprocal auditing arrangement and audit each other’s fund, they will be at risk of breaching their independence requirements.

“This kind of arrangement can inappropriately influence the auditor’s judgement and behaviour if the auditing firm is solely dependent on those fees,” she warned.

ATO flags potential issues with audit pooling arrangements
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Miranda Brownlee

Miranda Brownlee


Miranda Brownlee is the deputy editor of SMSF Adviser, which is the leading source of news, strategy and educational content for professionals working in the SMSF sector.

Since joining the team in 2014, Miranda has been responsible for breaking some of the biggest superannuation stories in Australia, and has reported extensively on technical strategy and legislative updates.
Miranda also has broad business and financial services reporting experience, having written for titles including Investor Daily, ifa and Accountants Daily.

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