Determining materiality for nonquantitative subject matters

By Ken Tysiac

Determining materiality has long been one of the most difficult exercises in auditing and financial reporting.

The challenge can become even more daunting when quantitative measurements are not relevant. This topic is addressed in an AICPA invitation to comment and discussion paper issued Wednesday, Materiality Considerations for Attestation Engagements Involving Aspects of Subject Matters That Cannot Be Quantitatively Measured.

These challenges related to materiality have become an increasing concern as the demand for certain types of attestation engagements has risen. For example, with respect to an entity’s sustainability reporting, it may not be difficult to determine materiality related to quantitative measurements such as greenhouse gas emissions or fuel. But it may be much more challenging to determine materiality related to the competence of employees or fair labor practices as discussed in a sustainability report.

“In today’s world, stakeholders are placing great importance on information about an entity in addition to that which is traditionally provided in historical financial statements,” AICPA Chief Auditor Bob Dohrer, CPA, CGMA, said in a news release. “When providing assurance services, it’s important that practitioners understand what information will most significantly impact stakeholders’ decision-making process, which is central to a practitioner’s consideration of engagement materiality. In that spirit, we are asking for comments about how users of such information and practitioners consider ‘materiality’ with respect to subject matter that cannot be quantitatively measured.”

The discussion paper, prepared by a Materiality Working Group established by the AICPA Assurance Services Executive Committee (ASEC), proposes solutions for practitioners as they consider these issues. The working group was formed to:

  • Assess how practitioners consider materiality in examination and review attestation engagements involving aspects of subject matters that cannot be quantitatively measured, and
  • Develop nonauthoritative guidance to assist practitioners with making professional judgments regarding materiality in such examination and review engagements.

The discussion paper provides information for preparers as they address materiality challenges and provides examples for common engagements such as System and Organization Controls (SOC) examinations, examinations or reviews of sustainability information, and examinations or reviews of compliance with contractual or other requirements.

“Expanding a CPA’s role to address information presented in reports other than traditional historical financial statements is an important step and also enables CPAs to bring their expertise in providing independent and objective assurance to this growing marketplace,” Jim Burton, a partner at Grant Thornton who chairs ASEC, said in a news release.

Burton said ASEC has a responsibility to provide CPAs with the tools they need to perform new services in a quality manner. He said understanding how materiality is considered during these engagements is critical.

Feedback on the discussion paper is sought from those with practical experience in such attestation engagements, including preparers, practitioners, investors, and regulators. Feedback can be submitted by email to Sherry Hazel at by Oct. 31.

Ken Tysiac ( is the JofA’s editorial director.


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