Statement on Auditing Standards No. 128, Using the Work of Internal Auditors

Publisher: AICPA
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As a result of its Clarity Project, the Auditing Standards Board (ASB) has issued Statement on Auditing Standards (SAS) No. 128, Using the Work of Internal Auditors, to

  • supersede SAS No. 65, The Auditor's Consideration of the Internal Audit Function in an Audit of Financial Statements (AICPA, Professional Standards, AU sec. 322 and AU-C sec. 610), and
  • amend:
    • SAS No. 122, Statements on Auditing Standards: Clarification and Recodification, section 315, Understanding the Entity and Its Environment and Assessing the Risks of Material Misstatement (AICPA, Professional Standards, AU-C sec. 315);
    • Various other sections in SAS No. 122 (AICPA, Professional Standards, AU-C secs. 200, 220, 230, 240, 260, 265, 300, 402, 500, 550, and 600); and
    • Statement on Quality Control Standards No. 8, A Firm's System of Quality Control (Redrafted) (AICPA, Professional Standards, QC sec. 10).

SAS No. 128 addresses the external auditor's responsibilities when using the work of internal auditors if it includes (a) using the work of the internal audit function in obtaining audit evidence and (b) using internal auditors to provide direct assistance under the direction, supervision, and review of the external auditor.

Consistent with International Standard on Auditing (ISA) 610 (Revised 2013), SAS No. 128 introduces the concept of a systematic and disciplined approach, which is not included in SAS No. 65. Paragraph 13 of SAS No. 128 would require, among other things, as a prerequisite to being able to use the work of the internal audit function, that the external auditor evaluate the application by the internal audit function of a systematic and disciplined approach, including quality control. Paragraphs A12 – A14 of SAS No. 128 provide application guidance with regard to the application of a systematic and disciplined approach. The ASB believes that relative to SAS No. 65, this requirement represents an additional and explicit evaluation that the external auditor would need to perform to conclude on the appropriateness of using the work of internal auditors.


SAS No. 128 was developed using ISA 610 (Revised 2013) as a base. Differences in objectives, definitions, or requirements between SAS No. 128 and ISA 610 (Revised 2013) are identified in the exhibit to SAS No. 128.

Effective Date

SAS No. 128 is effective for audits of financial statements for periods ending on or after December 15, 2014.

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About the AICPA
The American Institute of CPAs (AICPA) is the world's largest member association representing the accounting profession, with more than 412,000 members in 144 countries, and a history of serving the public interest since 1887. AICPA members represent many areas of practice, including business and industry, public practice, government, education and consulting. The AICPA sets ethical standards for the profession and U.S. auditing standards for private companies, nonprofit organizations, federal, state and local governments. It develops and grades the Uniform CPA Examination, and offers specialty credentials for CPAs who concentrate on personal financial planning; forensic accounting; business valuation; and information management and technology assurance. Through a joint venture with the Chartered Institute of Management Accountants, it has established the Chartered Global Management Accountant designation, which sets a new standard for global recognition of management accounting.