Canada: Navigating The Transition To CSAE 3416

Last Updated: March 15 2011
Article by Anthony Dias

In response to changes in third-party assurance standards in both the US and internationally, the Auditing and Assurance Standards Board has issued a new Canadian Standard on Assurance Engagements called Reporting on Controls at a Service Organization (CSAE 3416). This standard replaces the Auditor's Report on Controls at a Service Organization, Section 5970 (S 5970), which has been the standard in Canada for performing independent third-party assurance engagements.

CSAE has been designed to provide standards and guidance to an auditor who is reporting on the controls at a service organization. This is relevant to situations when the service (a specialized business task or function) being provided to customers (or user entities) impacts the user entity's financial reporting processes. In such situations, service organizations are often subjected to audits of these processes.

How will the CSAE affect my organization?

CSAE 3416 (and S 5970) allows auditors to issue two types of service auditor's reports. In a type 1 report the service auditor expresses an opinion on the fair presentation of the described controls (i.e. does the description coincide with what actually exists) and whether the controls included in the description are suitably designed to meet the control objectives. Once controls are determined to be suitably designed to achieve the control objectives, their operating effectiveness can be assessed and reported on, within a type 2 report.

In both of the above reports, the service organization is responsible for the preparation of the system description inserted into the report. This description includes the nature of the service provided, how the service is performed, and the service organization's controls over the service and related control objectives.

Why the need for change?

The CSAE is aligned with the new Statement on Standards for Attestation Engagements (SSAE 16), Reporting on Controls at a Service Organization, which was issued by the American Institute of Certified Public Accountants' (AICPA) Auditing Standards Board (ASB). The SSAE 16 standard was released in response to the new International Standard on Assurance Engagements (ISAE 3402), which was created to provide a reporting option for service organizations with the need to deliver consistent reporting worldwide.

Are there any significant differences between CSAE 3416, the new international standard ISAE 3402, and the new US standard SSAE 16?

By aligning with the new SSAE, the CSAE materially aligns with ISAE 3402 in most respects. The CSAE 3416 standard is modeled after the US standard SSAE 16, with a six month lag in effective date.

Will the new standard be as widely accepted as the existing Section 5970?

As of December 15, 2011, S 5970 will be replaced by CSAE 3416. It is expected that all current users and issuers of S 5970 reports will move to CSAE 3416, except in instances where the service organization wants to target a non-Canadian audience. In these circumstances, the SSAE 16 or ISAE 3402 may be used.

When will the new standards be effective?

CSAE 3416 will be effective for service auditor's reports for periods ending on or after December 15, 2011. This is six months after the effective date of the International Auditing and Assurance Standards Board's (IAASB) and the AICPA's standard for service auditors (June 15, 2011).

Can a single report be issued under more than one standard?

Yes it can. The report can be tailored to meet the criteria of multiple standards, with one standard being considered the anchor standard.

Have significant changes been made to CSAE 3416 that will affect a service auditor's engagement? Will these changes lead to a considerable change in the level of effort and cost to issue a report under the new standard?

While the standard does include some new requirements and changes to previous requirements as outlined in S 5970, the change in the level of effort from a service organization's standpoint would depend on how prepared they are. Factors that may affect the level of effort include the service organization's past experience with third-party assurance reporting and the overall strength of the internal controls environment. The level of effort for first time issuers of a third-party assurance report under the new standard will be significantly higher. Please refer to "A new level of trust and transparency – A perspective on transitioning from Section 5970 to CSAE 3416" for more detail in this area.

Can CSAE 3416 be used for reporting on controls over subject matter other than financial reporting?

No. While early exposure drafts considered the expansion of scope beyond controls related to financial reporting, later drafts removed this provision. CSAE 3416 (as well as S 5970) does not apply to examinations of controls over subject matter other than financial reporting. These types of engagements would be performed under Section 5025, Standards for Assurance Engagements Other than Audits of Financial Statements and other historical financial information.

What types of activities can be performed by service organizations to prepare for the move to the new standard? Is early adoption permitted?

While it is not expected that many organizations will adopt the new Canadian standard early, we're encouraging organizations to begin aligning their existing reports and supporting processes with the new requirements. If an organization chooses to adopt early, we suggest they reach out to their service auditors to discuss next steps in their transition.

Is the existing guidance to assist with the performance of S 5970 engagements being rewritten? When will the new guidance be available?

Yes. The existing AICPA guide, which is often used as a reference in Canada (AICPA guide for Service Organizations or SAS 70 guide), is being rewritten to reflect the requirements and guidance in SSAE 16. This revised guide can be consulted when performing CSAE 3416 engagements in the future, and is expected to be available in the second quarter of 2011

Can service organizations provide a CSAE 3416 service auditor's report on their services to potential customers?

No. Given that the nature of services performed by individual service organizations are different, service auditor's reports are designed to only include controls that services organizations feel are relevant to their existing clients (and user auditors). Additionally, any procedures performed by the service auditor (used to formulate their opinion) only relate to the controls that apply to existing customers. As a result, use of a CSAE 3416 report (or S 5970 report) is restricted to existing customers (user entities) of the service organization and their auditors and is not meant to be used for the purpose of marketing to potential customers.

Will entities now become "certified" under CSAE 3416 and similar standards?

No. The idea of certifying against CSAE 3416 and S 5970 (and other similar standards) is a popular misconception, since thirdparty assurance reports (including CSAE 3416 and S 5970) are meant primarily for auditor to auditor communication. Neither of these represents a prescriptive framework against which a service provider can be evaluated (unlike certification frameworks such as ISO 27001 or PCI). As a result, a service provider cannot be "certified" as CSAE 3416 compliant.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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