PricewaterhouseCoopers LLP acts as scheme auditors for approximately 700 occupational pension schemes in the United Kingdom, so we appreciate the opportunity to respond to the consultation and impact assessment named above.
We agree with the proposal to update the Practice Note. Timely revision of Practice Note 15 (PN15) following the revisions to UK auditing standards is important in meeting PN15’s objective in assisting auditors in applying the requirements of ISAs (UK).
We also fully support your guiding principles, namely to reduce repetition of ISA (UK) content and other standards and information, whilst updating for changes to UK accounting standards, regulatory codes of practice, legislation and other industry developments - as this results in a shorter and more focussed Practice Note.
As a result of your detailed review and proposed revisions to the Practice Note, there have been a number of changes. Our main observation is that, whilst the guidance on the Auditor’s Statement about Contributions has been expanded and improved, it does not provide guidance on what should be included in the Auditor’s Statement, only an illustrative example. We suggest that more detailed guidance is provided. We have included our comments on the updated ISA (UK) guidance in Appendix A to this letter. Appendix B comments on other sections of the Practice Note. Rather than taking these questions separately, we have set out all of our comments on the Practice Note exposure draft, in order, within the appendices, signposting by section or paragraph number for ease of reference. Our responses therefore cover appropriateness, deleted guidance and other matters for inclusion as requested by your three questions.