On the Frontlines: How to Comment on the New Standards

The purpose of the public comment period is to gather broad input from an even wider range of stakeholders on the new structure and content of the Global Internal Audit Standards — the new IPPF for the profession. This additional review ensures the Standards are accurate, complete, clearly worded, and applicable for all internal audit functions, including small and outsourced functions and those in the public sector. The board also is interested in whether internal auditors think the benefits of implementing the requirements of a standard justify the costs.

To gather this input, The IIA’s research team created a survey tool that allows individuals and organizations to easily communicate their thoughts on the new structure of the standards and its individual sections, including the domains, principles, and standards. You can access the survey and the full version of the exposure draft of the new Standards, with instructions for providing feedback, at theiia.org/IPPFEvolution.

The Standards draft is more than 100 pages and ideally should be read start to finish. Given time constraints, it is still possible to provide valuable input to the board, however. Here are a few tips for approaching your review:

1. Read, Introduction to the Global Internal Audit Standards, which offers an overview of:

• The new composition of individual standards: requirements, considerations for implementation, and considerations for evidence of conformance.
• The new overall structure of the entire body of standards, now organized into five thematic domains.

2. Read Domain I, the Purpose of Internal Auditing. This domain has no principles or standards but provides the overall foundation for understanding and articulating the value of internal auditing. The survey includes an opportunity to comment on the purpose statement overall.

3. Decide which of the remaining domains is most pertinent to you. If you are a staff auditor, Domain II (Ethics and Professionalism) and Domain V (Performing Internal Audit Services) will likely be the ones where you will find opportunities for comment. If you are a CAE, Domain III (Governing the Internal Audit Function) and Domain IV (Managing the Internal Audit Function) are the most relevant, involving some of the most significant changes to the current standards. Note that Domains III and IV need to be read together, as Domain III contains requirements for the CAE as well as for the board. However, as a CAE, it is still important to review the whole exposure draft to understand how the changes apply to your function.

4. Once in a domain, look at the principle of interest and then the specific standards under that principle. For the specific standard, read the Requirements section. This is the most critical section in terms of clarity, accuracy, and completeness. But before making a comment you should read the Considerations for Implementation and Considerations for Evidence of Conformance sections, particularly the former, because concepts that you may have expected to see in the requirements may be covered there. This is also the section that considers applications to small audit functions, public sector audit functions, and other special situations. You should also check the glossary if a term is unclear. If the term is not in the glossary and needs clarity, suggest it for additional inclusion. The survey tool allows for specific comments here as well.

5. The Considerations for Evidence of Conformance section of each standard provides ideas about how internal audit functions can demonstrate conformance to a standard. Comments on this section would be particularly welcome and may be useful for updating the new Quality Assessment Manual.

The survey tool itself does not contain the draft. Respondents should first go the IPPF Evolution landing page to find and review the PDF of the draft before starting the survey. You may find it works best to make notes about the sections of the survey you’d like to comment on before starting. You could even copy and paste from your notes into the survey.

If you start the survey and need to stop and return to it later, be careful to take note of the unique survey link that appears after you save your work.

I hope you decide to take a look at the Global Internal Audit Standards draft and comment in the survey tool. It is certainly not expected that you comment on each standard, but any input you have is important to the process.

IIA technical staff will process the incoming surveys, and the Standards Board will review the results and make appropriate changes. Given the extent of the changes represented by the new Standards, there is no doubt that changes will be made before a final draft is completed.