Agreed-Upon Procedures Engagements – Five Major Changes Due to SSAE No. 19

Agreed-Upon Procedures (AUP) engagements involve performing specific procedures on financial or nonfinancial subject matters and reporting findings without providing an opinion or conclusion. SSAE No. 19, Agreed-Upon Procedures Engagements, is effective for reports dated on or after July 15, 2021, with early implementation permitted. The overall objective is to provide more flexibility for delivering this type of engagement.

1. Clarification regarding independence. The practitioner must at a minimum be independent of the party responsible for the subject matter of the engagement (which may be different than the engaging party.) If the engagement is required by law or regulation, the report should state that independence was lacking.

2. Development of procedures. Procedures may be developed by the practitioner, engaging party, and/or intended users as the engagement unfolds. Prior to report issuance, at least the engaging party must agree in writing to the procedures and acknowledge the appropriateness for the intended purpose – or the practitioner must withdraw. Other specified parties may be asked to acknowledge responsibility at the discretion of either the practitioner or engaging party. 

3. No assertion required from the responsible party. The practitioner is no longer required to either request an assertion from the responsible party or disclose in the report when an assertion was not obtained.

4. Enhanced representation letter requirements from the engaging party. The engaging party must represent that all other necessary parties (such as regulators) agreed to the appropriateness of procedures, if applicable. Additional representations from a separate responsible party is at the discretion of the practitioner.

5. Ability to issue a general use report. Standard report language was modified to alert users that the procedures performed and findings obtained may not be appropriate for their specific purposes. A restricted use report may be issued at the discretion of the practitioner. 

The content contained in this article is for informational purposes only and is not tax advice. You should consult a tax advisor for advice applicable to your situation.

Jennifer has more than 25 years of experience in designing high-quality training programs in a variety of technical and “soft-skills” topics necessary for professional and organizational success. In 2003, she founded Emergent Solutions Group, LLC, where she focuses on designing and delivering practical and engaging accounting and auditing training. Jennifer started her career in audit for Deloitte & Touche. She graduated summa cum laude from Marymount University with a B.B.A. in Accounting.