Audit Documentation Deadlines: Why Are There Two Sets of Numbers?
Issuer and nonissuer audits can follow different documentation completion and retention rules.
Nonissuer framework
Under applicable AICPA standards, a commonly tested framework uses a 60-day documentation completion period and a 5-year minimum retention period. Use your current materials for exact current requirements.
Issuer framework
PCAOB standards use a different framework, commonly tested as a 45-day documentation completion period and 7-year retention period.
What completion means
The completion period is for assembling the final audit file after report release, not extra time to perform omitted work and pretend it happened earlier.
Changes after completion
Later additions should be documented appropriately, including what changed, why, when, and by whom as required.
The takeaway
Issuer vs nonissuer is the first question. Then choose the applicable documentation rule.
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FAQ
Is completion date the same as report date?
No.
Can omitted work be backfilled during assembly?
No.
Why are retention periods different?
Different standard setters apply to different engagements.