Chartered Accountants ANZ has lodged a submission jointly with CPA Australia on the AUASB's Discussion Paper: Expanding Key Audit Matters Beyond Listed Entities.

Our submission does not support the expansion of mandatory reporting of KAMs beyond listed entities in Australia. There has been minimal voluntary use of KAMs by other for-profit entities, and regulators (other than ASIC) have not mandated their use.

Due to the resource intensive nature of drafting KAMs, if there is a future move by the IAASB to expand the mandatory reporting of KAMs to all public interest entities (PIEs), we believe the AUASB would need to consider the costs versus the benefits of such an extension for individual classes of entities considered to be PIEs in Australia, rather than implementing a blanket extension of the requirement.