Key Takeaways

  • The specific requirement changes between ISA 570 (Revised) and ISA 570 (Revised 2024), with paragraph references for both
  • The "gross basis" assessment concept and what it means for your planning working papers
  • Which of your current templates need updating before December 2026
  • The new auditor's report language required for all engagements (not only those with material uncertainty)

The five changes that affect every engagement

The current ISA 570 (Revised) lets you evaluate management's going concern assessment only when you've identified events or conditions that cast significant doubt. ISA 570 (Revised 2024) removes that condition. You evaluate management's assessment on every audit, whether or not you've spotted a problem. That single change restructures the going concern working paper for every engagement in your portfolio.

ISA 570 (Revised 2024) isn't a minor update. The IAASB restructured the standard in response to corporate failures (Carillion, Thomas Cook, Wirecard) that exposed gaps between what auditors did on going concern and what stakeholders expected. The changes affect risk assessment, the evaluation of management's assessment, the assessment period, auditor reporting, and documentation. Each of those areas has specific new requirements that didn't exist in the current standard.

The current ISA 570 (Revised), effective for periods ending on or after 15 December 2016, operates on a conditional model. If you identify events or conditions that may cast significant doubt, you perform additional procedures. If you don't, your going concern work is limited to inquiry and analytical procedures at planning. ISA 570 (Revised 2024) replaces that conditional model with a mandatory evaluation framework. The auditor evaluates management's going concern assessment on every engagement, regardless of whether events or conditions have been identified.

Early adoption is permitted. The IAASB encourages adoption of ISA 570 (Revised 2024) alongside ISA 240 (Revised) as a package.

Risk assessment: the gross basis requirement

Current standard (ISA 570 (Revised)): The auditor considers whether events or conditions exist that may cast significant doubt on going concern. The standard doesn't prescribe the sequence. In practice, most teams evaluate management's position (including mitigating plans) simultaneously with identifying the events and conditions.

ISA 570 (Revised 2024): The auditor must identify events and conditions on a "gross basis" before considering any mitigating factors included in management's plans for future actions. The standard makes this sequence explicit. First identify the risk. Then evaluate whether management's plans adequately address it. The two-step logic prevents the common pattern where teams conclude "management has a refinancing plan, so there's no going concern issue" without first documenting the underlying risk that triggered the need for refinancing.

This is a structural change to how going concern risk assessment works, not a documentation tweak. Your planning working paper needs to separate the identification of events and conditions (gross) from the evaluation of management's mitigating plans (net). Most current templates merge these into a single assessment.

Practical tip: template redesign

If your current going concern template combines identification and evaluation in a single column, split it into two sections before December 2026. Section A documents every identified event and condition on a gross basis. Section B evaluates management's mitigating plans for each item. The separation must be visible in the working paper structure, not just in the narrative.

Management's assessment: always evaluate, not only when triggered

Current standard (ISA 570 (Revised), paragraph 12): The auditor shall determine whether management has already performed a preliminary assessment of the entity's ability to continue as a going concern. If management has, the auditor discusses it with management and determines whether management has identified events or conditions. If management hasn't yet performed the assessment, the auditor discusses the basis for the intended use of the going concern assumption. The detailed evaluation procedures (paragraphs 16 onward) are triggered by the identification of events or conditions.

ISA 570 (Revised 2024): The auditor must evaluate management's going concern assessment on every audit, regardless of whether events or conditions have been identified. This is a substantial expansion. Under the current standard, for a healthy entity with no identified going concern indicators, the auditor's work is limited to inquiry and analytical review. Under the revised standard, even where no events or conditions are identified, the auditor evaluates the method, significant assumptions, and data management used in its assessment.

For a mid-tier firm with 60 audit engagements, this means going concern evaluation work increases on every file where the entity was previously assessed as "no indicators identified." The evaluation doesn't need to be the same depth as for an entity with identified events or conditions, but it must be performed and documented.

The assessment period: twelve months from approval, not from the balance sheet date

Current standard (ISA 570 (Revised), paragraph 13): The auditor covers the same period as that used by management to make its assessment, as required by the applicable financial reporting framework. That period must be at least twelve months from the date of the financial statements.

ISA 570 (Revised 2024), paragraph 21: Management's going concern assessment must cover a period of at least twelve months from the date of approval of the financial statements (as defined in ISA 560). If management's assessment covers less than this period, the auditor requests management to extend it.

The difference matters. Consider a 31 December 2027 year-end where the financial statements are approved on 15 April 2028. Under the current standard, the assessment period runs to at least 31 December 2028 (twelve months from year-end). Under the revised standard, it runs to at least 15 April 2029 (twelve months from the approval date). That's an additional 3.5 months. For entities with seasonal cash flow patterns or upcoming debt maturities, those extra months can change the assessment.

AspectCurrent ISA 570ISA 570 (Revised 2024)
Assessment startDate of financial statementsDate of approval of financial statements
Minimum period12 months from year-end12 months from approval date
Example (31 Dec 2027, approved 15 Apr 2028)To 31 Dec 2028To 15 Apr 2029
Additional coverage~3.5 months

Auditor's report: new sections for every engagement

Current standard: The auditor's report includes a "Material Uncertainty Related to Going Concern" section only when a material uncertainty exists and is adequately disclosed. Where no material uncertainty exists, the going concern work is referenced in the "Auditor's Responsibilities" section boilerplate but receives no specific reporting.

ISA 570 (Revised 2024): Every auditor's report must now include either a "Going concern" section (when no material uncertainty exists) or a "Material uncertainty related to going concern" section. Both sections require two explicit conclusions: (1) whether management's use of the going concern basis of accounting is appropriate, and (2) whether a material uncertainty exists. This applies to all entities, not only listed entities.

For listed entities, the revised standard adds incremental content. Where management has made significant judgements in concluding that no material uncertainty exists (the "close call" scenario), the auditor provides additional description in the Going concern section. The current standard has no requirements for reporting on close calls.

The new Going concern section for unlisted entities with no material uncertainty will include language confirming the auditor's conclusions on management's use of the going concern basis and on whether a material uncertainty exists. This is a change for every engagement. Your auditor's report template needs a new section, and the wording must follow the illustrative language in ISA 570 (Revised 2024).

Worked example: Dijkstra Logistics B.V. under both standards

Dijkstra Logistics B.V. is a Dutch freight logistics company with €45M revenue and a €12M revolving credit facility maturing in September 2028. The entity's 31 December 2027 financial statements will be approved in April 2028. EBITDA for 2027 was €3.1M against a covenant requirement of €2.8M. The entity has no other going concern indicators.

Under the current ISA 570 (Revised)

The auditor performs risk assessment procedures at planning. The revolving credit facility matures in September 2028, which is within twelve months of the year-end (31 December 2027). The auditor identifies this as an event that may cast significant doubt on going concern. Management states that refinancing discussions with ING are underway and expects a new facility by June 2028. The auditor evaluates management's plans, obtains a letter from ING confirming discussions are in progress, assesses the feasibility of refinancing, and concludes that no material uncertainty exists. The auditor's report contains no Going concern section (because no material uncertainty was identified).

Documentation note: The auditor identified the event and evaluated management's plans in a single assessment. The report is silent on going concern.

Under ISA 570 (Revised 2024)

The auditor performs risk assessment procedures. On a gross basis (before considering management's plans), the auditor identifies the September 2028 credit facility maturity as an event that may cast significant doubt. This is documented separately from management's mitigating plans.

The auditor then evaluates management's going concern assessment. Management's assessment covers the period to April 2029 (twelve months from the expected approval date). The auditor evaluates the method (cash flow forecast), the significant assumptions (revenue growth of 2%, stable margins, successful refinancing by June 2028), and the data (2027 actuals, 2028 budget). The auditor obtains the ING letter and assesses the feasibility of refinancing.

The auditor concludes that management's use of the going concern basis is appropriate and that no material uncertainty exists. The refinancing event required significant management judgement.

The auditor's report includes a "Going concern" section with explicit conclusions: management's use of the going concern basis is appropriate, and no material uncertainty exists related to events or conditions that may cast significant doubt on the entity's ability to continue as a going concern.

Documentation note: The gross identification is separate from the net evaluation. The assessment period runs to April 2029, not December 2028. The auditor's report contains a Going concern section with explicit conclusions, even though no material uncertainty was found.

AspectCurrent ISA 570ISA 570 (Revised 2024)
Identification approachCombined with evaluationGross basis (separate stage)
Assessment periodTo 31 Dec 2028To Apr 2029
Management assessment evaluationTriggered by indicatorsMandatory on every audit
Auditor's reportSilent on going concernGoing concern section with two conclusions

When to use which standard

ISA 570 (Revised 2024) applies to audits of financial statements for periods beginning on or after 15 December 2026. For calendar year-end entities, this means 2027 year-end audits are the first engagements under the new standard. Audits of 2026 year-end financial statements use the current ISA 570 (Revised).

If you're auditing a 30 June 2027 year-end, the period began 1 July 2026, which is after 15 December 2026. The revised standard applies.

If you're auditing a 31 March 2027 year-end, the period began 1 April 2026, which is before 15 December 2026. The current standard applies unless your jurisdiction permits early adoption.

Common mistakes to watch for

  • Insufficient procedures on cash flow forecasts. The FRC's 2022–23 Tier 2 and Tier 3 inspection found going concern findings in 38% of audits inspected. The most common deficiency was insufficient procedures to test cash flow forecasts and assess the impact of sensitivities. Under ISA 570 (Revised 2024), the mandatory evaluation of management's assessment on every engagement will surface this deficiency more often, because the evaluation now applies even where no going concern indicators were originally identified.
  • Failing to adjust the assessment period. The shift from twelve months after the balance sheet date to twelve months after the approval date can add two to four months of forecast coverage. For entities with debt maturities or seasonal troughs falling in that window, missing the extended period is a documentation gap.
  • Using old report templates. Every auditor's report under ISA 570 (Revised 2024) needs a Going concern section with two explicit conclusions. If your template still omits this section for engagements without material uncertainty, the report is non-compliant.

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Frequently asked questions

What is the main difference between ISA 570 (Revised) and ISA 570 (Revised 2024)?

The current ISA 570 (Revised) operates on a conditional model: detailed evaluation procedures are triggered by the identification of events or conditions. ISA 570 (Revised 2024) replaces this with a mandatory evaluation framework where the auditor evaluates management's going concern assessment on every engagement, regardless of whether events or conditions have been identified. It also requires gross-basis identification of events before considering mitigating plans.

How does the assessment period differ between the two standards?

Under the current standard, the assessment period is at least twelve months from the date of the financial statements. Under ISA 570 (Revised 2024), the period is at least twelve months from the date of approval of the financial statements. For a 31 December year-end approved in April, this adds approximately 3.5 months of additional forecast coverage.

When should I start using ISA 570 (Revised 2024)?

ISA 570 (Revised 2024) applies to audits of financial statements for periods beginning on or after 15 December 2026. For calendar year-end entities, this means 2027 audits are the first under the new standard. Audits of 2026 year-ends use the current standard. Early adoption is permitted.

Does the auditor's report change for every engagement?

Yes. Under the current standard, the report includes going concern information only when a material uncertainty exists. Under ISA 570 (Revised 2024), every report must include either a "Going concern" section or a "Material uncertainty related to going concern" section with two explicit conclusions on management's use of the going concern basis and on whether a material uncertainty exists.

What does "gross basis" identification mean in practice?

Gross basis means the auditor identifies events and conditions that may cast significant doubt on going concern before considering management's mitigating plans. A maturing loan is recorded as a going concern event regardless of refinancing plans. Only after documenting all events on a gross basis does the auditor evaluate management's plans in a separate step. This prevents merging risk identification with mitigation in a single working paper paragraph.

Further reading and source references

  • IAASB: ISA 570 (Revised 2024), Going Concern (approved April 2025, effective 15 December 2026).
  • IAASB: ISA 570 (Revised), Going Concern (effective for periods ending on or after 15 December 2016): the current standard for comparison.
  • ISA 560, Subsequent Events: defines the date of approval of the financial statements used in the revised assessment period.
  • ISA 240 (Revised), The Auditor's Responsibilities Relating to Fraud: the companion standard sharing the same effective date.
  • FRC: 2022–23 Tier 2 and Tier 3 inspection findings on going concern deficiencies.