ISA (UK) 700 and 701 Revised: Two Editions Are Live, and the New One Starts 15 December 2026

There are two live editions of ISA (UK) 700 on the FRC website right now, and two of ISA (UK) 570. Which one applies to the audit on your desk depends on when the period being audited began.

For periods commencing on or after 15 December 2026 — six weeks away — the revised editions apply. For anything earlier, the older ones do. Early adoption is permitted, which means for a while the profession will be running both.

What the FRC actually did in 2026

Two separate packages, published two months apart:

• ISA (UK) 240 on fraud and ISA (UK) 570 on going concern — revised March 2026, published 30 April 2026.
• ISA (UK) 700 on forming an opinion and reporting, ISA (UK) 701 on key audit matters, and ISA (UK) 720 — revised May 2026, published 24 June 2026.

All of them take effect for periods commencing on or after 15 December 2026, with early adoption permitted. Our earlier guide to the 240 and 570 revisions covers the first package; this post covers the second, which has had far less attention despite touching the auditor's report itself.

And note what was not revised: ISA (UK) 705 and ISA (UK) 706. The modification matrix — qualified, adverse, disclaimer, and the material-versus-pervasive judgement that drives it — is untouched by the 2026 programme. That is good news: the hardest part of the subject is stable. Our guide to picking the right modified opinion remains current.

The trap: two editions, and the old ones are still correct

This is the practical problem for anyone citing the standards in a file, a training deck or an exam answer between now and late 2027.

The previous editions are not withdrawn or superseded in the ordinary sense. ISA (UK) 700 (Revised November 2019) (Updated September 2025) remains the applicable standard for periods commencing before 15 December 2026, which includes every calendar-year 2026 audit. The revised May 2026 edition applies to periods starting from that date — so for most December year ends, the 2027 audit.

Two consequences. First, a working paper citing "ISA (UK) 700" without an edition is now ambiguous. Second, training material written in 2026 will be describing the superseded edition for most of its useful life unless it is explicit about which period it addresses. If you maintain audit methodology or exam content, this is the window to add edition references rather than after the first review query.

One thing to stop saying about the auditor's report

A correction worth making, because it circulates widely and it is in a lot of training material: ISA (UK) 700 does not prescribe the order of the auditor's report. Beyond the first two sections, it expressly declines to do so.

What it does prescribe is a list of minimum elements that the report must contain. Paragraph A70-1 of the revised edition frames the relationship with the international standard: the UK standard is consistent with ISA 700 (Revised), and a report containing the minimum elements does not preclude the auditor from being able to assert compliance with International Standards on Auditing.

So the right formulation is required content, not required sequence. Anyone marking an exam answer down for section order beyond the opening two is marking against a rule that does not exist.

The UK-only paragraphs, and one that has been cut back

The FRC carries its additions as hyphen-suffixed paragraphs, which makes them easy to identify in the text. Several are worth knowing because they have no international equivalent:

• 20-1 — the auditor's report shall be in clear and unambiguous language.
• 16 (UK) — it is not sufficient for the auditor to conclude that the financial statements give a true and fair view; compliance with the applicable framework is also required.
• A15-1 — there is no statutory definition of true and fair. Worth quoting to anyone who assumes there is.
• 49-2 — the auditor shall not sign, and hence date, the report earlier than the date on which all the other information is available.
• 45-1(d) — for public interest entity audits, a declaration that the non-audit services prohibited by the FRC's Ethical Standard were not provided.

The one that has moved is the irregularities explanation. The earlier text required the auditor to explain to what extent the audit was considered capable of detecting irregularities, including fraud. That requirement has been cut back in the 2026 revision. If your report template carries a long-form irregularities paragraph built to the old wording, it is worth checking against the revised standard rather than rolling it forward.

On the opinion wording itself, the UK has historically required the opinion to state that the financial statements give a true and fair view, where the international standard also permits "present fairly, in all material respects". Paragraph 25 of the revised edition appears to set out both formulations, which would be a change in the UK position — but we have not been able to confirm that from the standard text directly, so check it at source before relying on either reading.

Ireland diverged, and more than usual

IAASA adopts auditing standards for use in Ireland under licence from the FRC, so the two regimes normally track closely. In 2026 they did not.

IAASA ran its own narrow-scope revision covering eighteen ISAs (Ireland) and two ISQMs (Ireland) — 200, 210, 220, 240, 260, 265, 315, 510, 570, 600, 700, 701, 705, 706, 710, 720, 800 and 805 — effective for periods beginning on or after 15 December 2026, with early adoption permitted.

Look at that list against the UK one. Ireland has an ISA (Ireland) 705 (Revised May 2026) and an ISA (Ireland) 706 (Revised May 2026). The UK does not. So on modifications and on emphasis of matter paragraphs, the two jurisdictions are now working from differently dated standards. For a firm auditing on both sides of the border, that is a real methodology point rather than a technicality.

Three further Irish specifics. ISA (Ireland) 706 carries a paragraph noting that in Ireland the auditor is required by legislation to include a reference to certain matters, footnoted to section 336(6) of the Companies Act 2014. Across the 2026 suite, the term "listed entity" was replaced with "publicly traded entity" throughout — but the Glossary of Terms was not updated, so the two now sit inconsistently. And IAASA's own footnote warns that the examples in Appendices 3 and 4 have not been tailored for Ireland, which is an unusual thing for a standard-setter to say about its own illustrative reports.

IAASA also excludes the UK Corporate Governance Code material, except that dual-listed entities may elect to comply with the UK Code.

Two things people get wrong about the wider picture

ARGA is not coming. The replacement of the FRC with the Audit, Reporting and Governance Authority was shelved, and the FRC continues as regulator. Which makes the 2026 standards programme more significant rather than less: the regulator everyone expected to be replaced has just delivered the largest overhaul of auditor reporting since 2016. Our guide to why ARGA was shelved covers what actually applies now.

The Bannerman paragraph is not required. The disclaimer of liability to third parties that appears in most UK audit reports is not mandated by any standard. ICAEW strongly recommends it, which is a different thing. If you have been treating its absence as a compliance failure, it is not one.

What to do before 15 December

Three practical steps, in order.

Check which edition applies to each engagement by reference to when the audited period commenced, not when the audit is performed or signed. Add edition dates to every citation in your methodology, templates and training material, because for roughly the next year an unqualified reference to ISA (UK) 700 will be ambiguous. And review your irregularities paragraph specifically, since that is the requirement that has contracted rather than expanded.

If you audit Irish entities, add one more: confirm which ISA (Ireland) editions apply, because the Irish 705 and 706 have moved and the UK equivalents have not.