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 NFRA issues Draft Procedure for Submission of Audit Files
 Auditors barred from putting a value on companies they are auditing
 Standard on Internal Audit (SIA) 18, Related Parties
 Standard on Internal Audit (SIA) 17, Consideration of Laws and Regulations in an Internal Audit
 Standard on Internal Audit (SIA) 16, Using the Work of an Expert
 Standard on Internal Audit (SIA) 14, Internal Audit in an Information Technology Environment
 Standard on Internal Audit (SIA) 13, Enterprise Risk Management
 Standard on Internal Audit (SIA) 12, Internal Control Evaluation
 Standard on Internal Audit (SIA) 11, Consideration of Fraud in an Internal Audit
  Standard on Internal Audit (SIA) 9, Communication with Management
  Standard on Internal Audit (SIA) 8, Terms of Internal Audit Engagement

Standard on Internal Audit (SIA) 220, Conducting Overall Internal Audit Planning
November, 28th 2018
STANDARD ON INTERNAL AUDIT (SIA) 220
 CONDUCTING OVERALL INTERNAL AUDIT
             PLANNING
                                          Contents
                                                                                        Paragraph(s)
Introduction ............................................................................................. 1
Objectives ......................... .................................................................... 2
Requirements .......................................................................................... 3
Explanatory Comments ............................................................................ 4
Effective Date .......................................................................................... 5


This Standard on Internal Audit (SIA) 220, "Conducting Overall Internal
Audit Planning," issued by the Council of the Institute of Chartered
Accountants of India should be read in conjunction with the "Preface to
the Standards on Internal Audit," "Framewor k Governing Internal
Audits" and "Basic Principles of Internal Audit" issued by the Institute.





    Note: This Standard on Internal Audit (SIA) supersedes some part or all of the following
    current SIAs (recommendatory in nature):
    1. Standard on Internal Audit (SIA) 1, Planning an Internal Audit , issued in August,
        2006.
    2. Standard on Internal Audit (SIA) 15, Knowledge of the Entity and its Environment ,
        issued in March, 2009
1.    Introduction
1.1   Internal audit planning is conducted at two levels:
      (a)   An overall internal audit plan for the entire entity is prepared for
            a given period of time (usually a year) and presented to the
            highest governing body responsible for internal audits,
            normally, the Board of Directors, or the Audit Committee.
      (b)   A number of specific internal audit plans are prepared for
            individual assignments to be undertaken covering some part of
            the entity and presented to the Chief Internal Auditor.
1.2   This Standard on Internal Audit (SIA) covers the first level of planning,
      "Conducting Overall Internal Audit Planning " for the entity as a whole.
      Standard on Internal Audit (SIA) 310, deals with "Planning of Internal
      Audit Assignments " for a particular part of the entity.
1.3   In the case of Companies under Companies Act, 2013, it is a legal
      requirement for the Audit Committee or its Board of Directors to
      formulate the overall internal audit plan of the company. Companies
      (Accounts) Rule 13(2) of Companies Act, 2013 provides as under:
             "The Audit Committee of the company or the Board shall, in
             consultation with the Internal Auditor, formulate the scope,
             functioning, periodicity, and methodology for conducting the
             internal audit."
      The Audit Committee or the Board takes the active support of the
      Chief Internal Auditor, to develop the Overall Internal Audit Plan, in
      consultation with the Executive Management.
1.4   Conducting the Overall Internal Audit Planning involves the following
      key elements:
      (a)   It is undertaken prior to the beginning of the plan period
            (generally, the financial year).
      (b)   It is comprehensive in nature covering the entire entity.
      (c)   It is directional in nature and considers all the Auditable Units
            (i.e., locations, functions, business units and legal entities
            including third parties, where relevant), along with the
SIA 220






            periodicity of the assignments to be undertaken during the plan
            period.
      (d)   It is normally prepared by the Chief Internal Auditor (or the
            Engagement Partner, where an external service provider is
            appointed to conduct internal audits).
      (e)   The outcome of this exercise is an "Overall Internal Audit Plan"
            (or the "Audit Engagement Plan," if outsourced).
1.5   Scope: This SIA deals with the Internal Auditor's responsibility to
      prepare the Overall Internal Audit Plan, also referred to as the Annual
      Internal Audit (Engagement) Plan. Where only part of the internal audit
      activity is outsourced, this SIA shall apply to the extent the Internal
      Auditor needs to plan the activities of the outsourced part of the
      engagement only, as defined in their terms of engagement, which
      shall also clarify the extent of the planning responsibilities.
2.    Objectives
2.1   The objectives of an Overall Internal Audit (Engagement) Plan are to:
      (a)   ensure that the planned internal audits are in line with the
            objectives of the internal audit function, as per the internal
            audit charter of the entity (and terms of engagement, where it is
            an outsourced engagement) and also in line with the overall
            objectives of the organisation.
      (b)   align the organisation's risk assessment with the effectiveness
            of the risk mitigation implemented through internal controls.
      (c)   confirm and agree with those charged with governance the
            broad scope, methodology and depth of coverage of the
            internal audit work to be undertaken in the defined time-period.
      (d)   ensure that overall resources are adequate, skilled and
            deployed with focus in areas of importance, complexity and
            sensitivity.
      (e)   ensure that the audits undertaken conform at all times with the
            applicable pronouncements of the Institute of Chartered
            Accountants of India.




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                                 Conducting Overall Internal Audit Planning

3.    Requirements
3.1   The planning exercise shall follow a laid down process (Para. 4.1), the
      outcome of which shall be a written document (Para. 4.8) containing
      all the essential elements required to help achieve the objectives of
      the plan as outlined under Paragraph 2 above. Technology
      deployment (Para. 4.6) and resource allocation (Para. 4.7) shall form
      essential elements of the overall internal audit plan.
3.2   The overall internal audit plan shall be reviewed and approved by the
      highest governing body responsible for internal audits, normally, the
      Board of Directors, or the Audit Committee.
3.3   Knowledge of the entity, its business and operating environment shall
      be undertaken to determine the types of audit assignment which could
      be conducted (Para. 4.2). As part of the planning process, a
      discussion with management and other stakeholders shall be
      undertaken to understand the intricacies of each auditable unit subject
      to audit (Para. 4.3).
3.4   An Audit Universe shall be prepared prior to establishing the scope of
      the overall internal audit plan (Para. 4.4). The scope shall be
      consistent with the goals and objectives of the internal audit function
      (and terms of engagement, where it is an outsourced engagement) as
      listed in the internal audit charter. The scope shall also be in line with
      the nature and extent of the assurance to be provided.
3.5   A risk based planning exercise shall form the basis of the overall
      internal audit plan. The Internal Auditor shall undertake an
      independent risk assessment exercise to prioritise and focus the audit
      work on high risk areas, with due attention to matters of importance,
      complexity and sensitivity (Para. 4.5).
3.6   The Audit Universe and the overall internal audit plan shall be
      continuously monitored during the execution phase for achievement of
      the objective and to identify any deviations. Certain deviations may
      require to be notified to the stakeholders or even require a formal
      modification to the plan. However, any significant modification to the
      plan shall be done only after consultation with those who approved the
      original plan. Such changes shall be formally documented, including



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SIA 220

      reasons for the change, and communicated to all impacted
      stakeholders.
4.    Explanatory Comments
4.1   The Planning Process (refer Para. 3.1): The Internal Auditor
      conducting the overall internal audit planning shall use professional
      judgement for the process to be followed in completing all essential
      planning activities. A documented planning process shall be in place
      which stipulates the essential inputs, steps to complete the planning
      and the nature of output required to conduct a comprehensive
      planning exercise.
4.2   Knowledge of the Business and its Environment (refer Para. 3.3):
      The Internal Auditor shall gather all the information required to fully
      understand the entity's business environment, the risks it faces and its
      operational challenges.
      The extent of information required shall be sufficient to enable the
      Internal Auditor to identify matters which have a significant effect on
      the organisation's financials. Hence, there is a need to connect the
      financial aspects of the business with other business elements, such
      as industry dynamics, company's business model, operational
      intricacies, legal and regulatory environment, and the system and
      processes in place to run its operations.
4.3   Discussion with Management and Stakeholders (refer Para. 3.3):
      A key element of planning involves extensive discussion and
      deliberation with all stakeholders, including executive management,
      risk owners, process owners, statutory auditors etc. Their inputs are
      critical in understanding the intricacies of each assignment under
      consideration, in identification of important matters of relevance and to
      align stakeholder expectations with audit objectives.
4.4   Audit Universe and Scope of Coverage (refer Para. 3.4): Prior to
      defining the scope of internal audit, a complete identification of all the
      Auditable Units (locations, functions, business units, legal entities,
      including third parties where relevant) of the organisation shall be
      made. This list of all the Auditable Units is, generally, referred to as
      the "Audit Universe". It covers every conceivable audit assignment
      which could be taken up for review during the plan period. The audit







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                                 Conducting Overall Internal Audit Planning

      universe helps to ensure that the audit scope does not overlook any
      Auditable Unit. It forms the basis from which the overall internal audit
      plan is derived by consciously excluding certain units or areas from
      the scope, for justifiable reasons, such as low risk.
      The internal audit objectives and the nature of assurance to be
      provided will also help to establish the scope of internal audit. On
      certain occasions, especially in the case of outsourced engagements,
      the management may define or mandate the scope and may even
      restrict the coverage of certain areas or transactions. When finalising
      the scope, it is important to clearly highlight any scope limitations in
      the internal audit plan as part of the communication to approving body,
      such as, the Audit Committee.
4.5   Risk Assessment (refer Para. 3.5): The internal auditor shall
      undertake an independent risk assessment of all the Auditable Units
      identified in the Audit Universe and align this with the risk assessment
      conducted by the management and the statutory auditor. This is
      required to prioritise and focus audit work on high risk areas, with due
      attention to matters of importance, complexity and sensitivity.
      The internal auditor may also plan to undertake a dedicated audit of
      the company's Risk Management Framework and processes, as a
      separate review or assignment.
4.6   Technology Deployment (refer Para. 3.1): A key element of the
      overall internal audit planning exercise involves understanding the
      extent to which:
      (a)   the entity has deployed information technology (IT) in its
            business, operations and transaction processing, and
      (b)   the auditor needs to deploy IT tools, data mining and analytic
            procedures, and the expertise required for conducting the audit
            activities and testing procedures.
      This helps to design and plan the audit more efficiently and effectively.
4.7   Resource Allocation (refer Para. 3.1): The Internal Auditor shall
      prepare a detailed work schedule to estimate the time required for
      each audit assignment depending on the audit attention it deserves
      (on the basis of risk assessment) and maps this with the
      competencies (knowledge, experience, expertise, etc.) of the

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SIA 220

      resources available. The requirements are then matched with the
      limited resources available to:
      (a)   finalise the scope and depth of coverage of audit assignments;
      (b)   identify any critical skills/expertise gaps in audit team; and/or
      (c)   seek other means of acquiring additional resources required
            (internal or external sourcing).
4.8   Documentation: To confirm compliance of audit procedures with the
      SIA, all key steps undertaken in the planning process shall be
      adequately documented to confirm their proper completion.
      Essential documentation shall be as follows:
      (a)   Information gathered about the business and its operations,
            systems and processes and past or known issues.
      (b)   Audit Universe and summary of Auditable Units.
      (c)   Summary of meetings and communication                    with   key
            stakeholders, with a summary of their inputs.
      (d)   Risk assessment documentation.
      (e)   Summary of available resources, their competencies and the
            proper matching of their skills with the audit requirements.
      (f)   Final overall internal audit plan, duly approved by the
            competent authorities.
5.    Effective Date
5.1   This Standard is applicable for internal audits beginning on or after a
      date to be notified by the Council of the Institute.




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