Most going concern assessments document management’s forecast, confirm the numbers tie, and stop there. The second step, evaluating whether the forecast’s assumptions could plausibly fail, is the step that AFM and FRC inspectors find missing most often. In my experience, when a file gets pulled for review, this is the section partners turn to first.
December 2026 is less than a year away. ISA 570 (Revised 2024) takes effect for periods beginning on or after 15 December 2026, and it rewrites the going concern playbook. Every going concern (GC) section in your current files was built for a standard that won’t exist by then. The window to update your methodology, templates, and team training is shorter than most firms realise.
ISA 570 requires the auditor to evaluate whether a material uncertainty exists related to the entity’s ability to continue as a going concern, assess management’s GC assessment, and report appropriately based on the conclusions reached, with ISA 570 (Revised 2024) effective for periods beginning on or after 15 December 2026.
Key Takeaways
- ISA 570 (Revised) addresses one of the most publicly scrutinised areas of auditing: whether an entity can continue as a going concern. Corporate failures shortly after clean audit opinions have repeatedly damaged public trust in auditing.
- The auditor’s responsibilities include evaluating management’s assessment, remaining alert throughout the audit for going concern indicators, performing additional procedures when events or conditions are identified, and reporting appropriately (including on the adequacy of disclosures).
- Management must assess the entity’s ability to continue as a going concern for at least twelve months from the reporting date (under IAS 1). The auditor evaluates this assessment regardless of whether indicators of doubt have been identified.
- When events or conditions are identified that may cast significant doubt, the auditor must perform additional procedures: evaluating management’s plans, assessing their feasibility, obtaining written representations, and considering any additional facts.
- The reporting consequences depend on the conclusion. No material uncertainty leads to an unmodified opinion (with possible “close call” disclosure). A material uncertainty that is adequately disclosed leads to an unmodified opinion with a “Material Uncertainty Related to Going Concern” section. Inadequate disclosure triggers a qualified or adverse opinion, and an inappropriate going concern basis leads to an adverse opinion.
- ISA 570 (Revised 2024) has been approved by the IAASB and is effective for periods beginning on or after 15 December 2026. It expands the auditor’s responsibilities, including mandatory evaluation of management’s method, assumptions, and data; a dedicated “Going Concern” section in all auditor’s reports; stronger transparency for “close call” situations; and new requirements for reporting to external authorities.
Table of contents
- What is ISA 570?
- Going concern indicators
- The auditor’s process
- ISA 570 (Revised 2024): what’s coming
- ISA 570 in your jurisdiction
- Frequently asked questions
- Further reading and source references
What is ISA 570?
ISA 570 (Revised), titled “Going Concern,” addresses the fundamental assumption underpinning virtually all financial statements (FS): that the entity will continue in business for the foreseeable future. If this assumption is wrong, the FS may need to be prepared on a different basis (break-up or liquidation), and the values assigned to assets and liabilities could change dramatically.
The standard exists because users of the FS (investors, lenders, suppliers, employees) rely on the auditor to flag situations where continuity is in doubt. The expectation gap in this area is significant. The public often assumes the auditor guarantees the entity’s survival, while the standard requires the auditor to evaluate and report on management’s assessment.
On about half the engagements I’ve worked, the GC assessment becomes a tick box exercise. The team checks that management’s forecast exists, confirms it ties to the trial balance (TB), and signs the working paper. Nobody goes back to challenge whether the revenue assumption stacks up against the last two years of margin trend.
Going concern indicators
ISA 570 provides examples of events or conditions that, individually or collectively, may cast significant doubt on going concern.
Financial indicators
Net liability or net current liability position. Fixed-term borrowings approaching maturity without realistic prospects of renewal or repayment. Excessive reliance on short-term borrowings to finance long-term assets. Adverse key financial ratios. Substantial operating losses or significant deterioration in the value of assets used to generate cash flows. Arrears or discontinuance of dividends. Inability to pay creditors on due dates. Inability to comply with loan covenants. Change from credit to cash-on-delivery transactions with suppliers.
Operating indicators
Management intentions to liquidate or cease operations. Loss of key management without replacement. Loss of a major market, key customer, franchise, licence, or principal supplier. Labour difficulties. Shortages of important supplies. Emergence of a highly successful competitor.
Other indicators
Non-compliance with capital or other statutory or regulatory requirements. Pending legal or regulatory proceedings against the entity that may result in claims the entity cannot satisfy. Changes in law or regulation or government policy expected to adversely affect the entity. Uninsured or underinsured catastrophes.
The auditor’s process
Assess going concern risk
The auditor must consider whether events or conditions exist that may cast significant doubt on going concern. This is not a one-time check. The auditor must remain alert throughout the audit.
Evaluate management’s assessment
Regardless of whether indicators are identified, the auditor must evaluate management’s assessment of the entity’s ability to continue as a going concern. This includes considering whether management’s assessment covers at least twelve months from the reporting date and evaluating the process and underlying assumptions. The file should tell a story here. It should show what the team asked, what management replied, and what evidence closed each point. Where the working papers (WPs) read like a list of ticks against a template, a reviewer has nothing to verify against.
Perform additional procedures when doubt is identified
When events or conditions are identified, the auditor must:
- Request management to make or extend its assessment if it has not already done so.
- Evaluate management’s plans for future actions (such as plans to liquidate assets, borrow money, restructure debt, or increase equity).
- Evaluate the feasibility of these plans and whether their outcome will improve the situation.
- Obtain written representations regarding management’s plans and the feasibility of those plans.
- Consider whether any additional facts or information have become available since management’s assessment.
Conclude on going concern
Based on the evidence obtained, the auditor concludes whether a material uncertainty exists:
| Conclusion | Disclosure | Audit Report |
|---|---|---|
| No events/conditions identified | Normal disclosures | Unmodified opinion |
| Events/conditions identified, but no material uncertainty after evaluation | Adequate disclosure may be needed | Unmodified opinion (may be a “close call” requiring KAM disclosure for listed entities) |
| Material uncertainty exists, adequately disclosed | Going concern note with required disclosures | Unmodified opinion + “Material Uncertainty Related to Going Concern” section |
| Material uncertainty exists, inadequately disclosed | Disclosure deficiency | Qualified or adverse opinion (depending on pervasiveness) |
| Going concern basis inappropriate | Financial statements should be on break-up basis | Adverse opinion |
| Management unwilling to assess | Scope limitation | Qualified opinion or disclaimer |
The “close call” situation
One of the hardest scenarios is the “close call,” where events or conditions are identified that may cast significant doubt, but after evaluating management’s plans, the auditor concludes that no material uncertainty exists. This is not a clean bill of health. It means the entity faced genuine going concern risks that were resolved by management’s mitigating actions. For listed entity audits, this situation should typically be communicated as a Key Audit Matter (ISA 701). Under the upcoming ISA 570 (Revised 2024), close call transparency expands with explicit requirements for the auditor to describe the evaluation in the report. Mitigating plans that “appear reasonable” to the engagement team are the ones reviewers spend the most time on.
ISA 570 (Revised 2024): what’s coming
The IAASB approved ISA 570 (Revised 2024) in April 2025, effective for periods beginning on or after 15 December 2026. Key changes include the six points below.
Mandatory evaluation of management’s assessment
The auditor must evaluate the method, significant assumptions, and data underlying management’s assessment in all cases, not only when indicators of doubt are identified.
Management bias
The auditor must consider potential management bias in the going concern assessment, including overly optimistic assumptions.
Extended evaluation period
The evaluation now extends at least twelve months from the date of approval of the FS (not the reporting date), which may extend the look-forward period.
New auditor’s report section
All auditor’s reports will include a dedicated “Going Concern” section with explicit conclusions about whether management’s use of the going concern basis is appropriate and whether a material uncertainty has been identified.
Stronger “close call” transparency
For listed entities, when events or conditions are identified but no material uncertainty exists, the auditor must describe how the evaluation was conducted.
Reporting to external authorities
New requirement to consider reporting to regulators when a material uncertainty section or modified opinion is included.
ISA 570 in your jurisdiction
Netherlands
COS 570 follows ISA 570 (Revised). Going concern has been a major focus of AFM inspections, particularly in the wake of corporate failures. The AFM has criticised auditors for insufficient challenge to management’s assumptions, over-reliance on management’s representations without independent corroboration, inadequate documentation of the going concern evaluation, and failure to consider contradictory evidence. This is the finding the FRC names in every thematic review on going concern, and AFM inspection reports read almost identically. Dutch company law requires the management board to include a continuity paragraph in the annual report.
Germany
IDW PS 570 adapts ISA 570 (Revised). German practice has specific going concern considerations under the HGB, including the obligation to report in the Prüfungsbericht on going concern risks. The Fortführungsprognose (going concern prognosis) is a formal element of the auditor’s evaluation. German insolvency law (InsO) creates additional urgency. Directors have a legal obligation to file for insolvency within specific timeframes, and the auditor must consider whether these obligations are being met.
United Kingdom
ISA (UK) 570 (Revised) goes further than the international standard. The UK requires the auditor to conclude and report explicitly on whether management’s use of the going concern basis is appropriate. The UK Corporate Governance Code requires directors to state whether the company is a going concern and to make a separate “viability statement” covering a longer period (typically three to five years). The FRC has identified going concern as a persistent audit quality concern.
France
NEP 570 implements ISA 570 (Revised). French company law requires the commissaire aux comptes to report going concern doubts through a specific mechanism (the procédure d’alerte, or alert procedure). This is a graduated process. The auditor first questions the president/gérant in writing, and if the response is unsatisfactory, escalates to the board, shareholders, or the commercial court. This goes well beyond the international standard and gives the French auditor a quasi-regulatory role in going concern situations.
Frequently asked questions
Does the auditor guarantee that the entity will survive?
No. The auditor evaluates management’s assessment of going concern and concludes on whether a material uncertainty exists. The audit opinion does not provide assurance about the entity’s future viability. It provides assurance about whether the financial statements are prepared appropriately given the going concern assessment.
What if management’s assessment covers less than twelve months?
The auditor must request management to extend the assessment to at least twelve months from the reporting date. If management refuses, the auditor considers the implications. This may constitute a scope limitation leading to a qualified opinion or disclaimer.
Does a “Material Uncertainty” paragraph mean the entity is going to fail?
No. It means the auditor has identified a material uncertainty. The entity’s ability to continue as a going concern is in significant doubt, but the outcome is uncertain. Many entities that receive this paragraph in the audit report continue to operate successfully.
What is the difference between ISA 570 and ISA 560?
ISA 570 deals with the going concern assumption. ISA 560 deals with subsequent events more broadly. There is overlap: going concern indicators may be discovered during the subsequent events review (ISA 560), and ISA 570 specifically requires the auditor to consider events up to the date of the auditor’s report.
Further reading and source references
- IAASB Handbook 2024: ISA 570 (Revised) full text. The authoritative source including all application material.
- ISA 570 (Revised 2024): Approved standard. Effective for periods beginning on or after 15 December 2026.
- IAS 1: Presentation of Financial Statements. Sets out the going concern assessment requirements for IFRS reporters.
- ISA 700 (Revised): Forming an Opinion and Reporting. Governs the auditor’s report structure.
- ISA 705 (Revised): Modifications to the Opinion. Applicable when going concern conclusions require a modified opinion.
This guide reflects the ISA 570 (Revised) text as published in the IAASB 2024 Handbook, with reference to ISA 570 (Revised 2024) for upcoming changes. National implementations may include additional requirements. Always consult the applicable national standard alongside the international text. This content is for educational purposes and does not constitute legal or professional advice.
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