Understanding our responsibilities
Responding to non-compliance
Section 360 of the IRBA Code guides our response to identified or suspected non-compliance with laws and regulations (NOCLAR). We obtain an understanding of the matter, engage with appropriate management and those charged with governance, assess their response and consider further action in the public interest. We comply with applicable reporting laws and document our judgements. Disclosure to an appropriate authority depends on the circumstances and applicable law; it is not automatic for every suspected breach.
Reportable irregularities in audits
Under the Auditing Profession Act, an unlawful act or omission by someone responsible for managing an entity can be reportable if it has caused or is likely to cause material financial loss, is fraudulent or amounts to theft, or constitutes a material breach of a fiduciary duty. Where section 45 applies, a registered auditor who is satisfied or has reason to believe an irregularity occurred or is occurring must report to IRBA without delay.
- First report: Send the required report to IRBA without delay.
- Management-board notification: Give written notification and a copy of the report within three days.
- Follow-up: Discuss the matter, consider representations and send a second report as soon as reasonably possible, within 30 days of the first report.
Independent reviews follow a separate process
Independent reviews have a separate reporting process under Companies Regulation 29. Where applicable, the first report goes to CIPC without delay, the board is notified within three business days, and the second report is submitted as soon as reasonably possible, within 20 business days of the first report.
Implications for the auditor’s report
Reporting a reportable irregularity does not automatically result in a qualified audit opinion. We assess any required disclosure in the auditor’s report separately from whether an opinion modification is necessary under applicable auditing standards. The requirements of the Auditing Profession Act and the circumstances of the engagement inform this assessment.
Transparency reporting
IRBA Rule 2 requires annual transparency reports from registered audit firms auditing publicly traded entities. Its effective date refers to client financial-statement periods beginning on or after 15 December 2025. SAAPS 7 provides guidance on report content and publication.
The report concerns the firm’s system of quality management. Auditing publicly traded entities is the reporting trigger specified by Rule 2.
Authoritative references
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