Understanding Non-Audit Services and Auditor Independence Threats

Assess and mitigate threats to auditor independence before providing non-audit services.

Providing non-audit services poses potential challenges to auditor independence, especially concerning future audit engagements. Auditors must carefully evaluate and mitigate these threats using a conceptual framework to ensure compliance with independence standards.

Key Insights

  • Non-audit services are defined as professional services other than audits or attestation engagements and require careful consideration of independence threats.
  • The conceptual framework assists auditors in determining whether safeguards can be applied to reduce independence threats to an acceptable level before proceeding with non-audit services.
  • Audit organizations must establish policies distinguishing audit from non-audit services, ensuring that entity management assumes responsibilities when non-audit services are provided.

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Non-audit services are professional services other than audits or attestation engagements. While these services can provide value to an entity, they may also create threats to auditor independence, particularly if the auditor later performs a GAGAS audit for that same entity.

Before providing a non-audit service, an audit organization must determine whether the service would create a threat to independence. If a threat exists, the organization must assess whether safeguards can be applied to eliminate the threat or reduce it to an acceptable level. The GAGAS conceptual framework for independence provides guidance to help auditors evaluate these situations.

If safeguards are sufficient to reduce the threat to an acceptable level, the non-audit service may be provided. If independence would be impaired, the service should not be performed. Audit organizations are responsible for establishing policies that define which services they will and will not provide.

Because non-audit services are outside the scope of audits and attestation engagements, GAGAS does not apply in the same way. As a result, a GAGAS compliance statement is generally not included when performing non-audit services.

Management Responsibilities in Non-Audit Services

When auditors provide non-audit services to an entity for which they also perform audits, they must obtain assurance that management fulfills specific responsibilities. These responsibilities help preserve auditor independence.

Entity management must:

  • Assume all management responsibilities related to the service.
  • Designate an individual, preferably within senior management, who possesses suitable skill, knowledge, or experience to oversee the service.
  • Evaluate the adequacy and results of the services performed.
  • Accept responsibility for the results of the service.

If management does not fulfill these responsibilities, the auditor’s independence may be impaired.

Applying the GAGAS Conceptual Framework

The GAGAS conceptual framework guides auditors in evaluating threats to independence when considering non-audit services. The process involves identifying and assessing threats and determining whether safeguards can eliminate or reduce those threats to an acceptable level.

If no threat is identified, the auditor may proceed. If a threat is identified, the auditor evaluates whether safeguards are available and effective. If safeguards reduce the threat to an acceptable level, the auditor documents the nature of the threat and the safeguards applied and may proceed with the service.

If the threat cannot be eliminated or reduced to an acceptable level, independence is considered impaired, and the auditor must not proceed.

This structured evaluation process ensures that audit organizations maintain independence while determining whether non-audit services can be performed responsibly.

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Penny Popps

Penny N. Popps recently joined the Graduate School USA instructor team in early 2025, teaching in the area of Audit. She is an exceptional leader with over 20 years of private and public sector experience in accounting, audit, compliance, risk management, fraud, and internal controls. A recipient of numerous public service, recognition, and performance awards, she is committed to developing the next generation of financial management and audit professionals.

During her nearly 15 years as a Federal Government Public Servant, Penny held several pivotal transformational leadership roles, including serving as the first Fraud Risk Manager at the U.S. Small Business Administration (SBA), where she successfully helped mature its Fraud Risk Management Program.

She holds a B.B.A. in Accounting from the University of Texas at Arlington, an MBA from Texas Woman’s University, an Advanced Technical Certificate in Professional Accountancy from Dallas College, and multiple professional credentials, including Certified Fraud Examiner (CFE), Certified Internal Controls Auditor (CICA), Department of Defense Financial Management Certification, and an ICF Associate Certified Coach (ACC) Certification.

Prior to her tenure at SBA, Penny spent more than six years at the Department of Housing and Urban Development (HUD), managing projects that advanced the delivery of affordable, safe, and decent housing while safeguarding HUD programs from fraud, waste, and abuse. She led multiple audit teams in conducting complex quality control reviews of independent public accounting firms, CIGIE reviews, financial assessments, staffing studies, and annual OMB A-123 risk assessment reviews for the Accountability, Integrity, & Risk (AIR) Program.

During her federal career, Penny also served as the Branch Chief of Financial Reporting at the DHS ICE OCFO, Office of FM–Financial Service Center. She oversaw the operations of the Payroll and Fund Balance with Treasury Units for all DHS ICE components, which processed approximately $5.2 billion in payroll transactions and reconciled $10.1 billion in cash transactions, significantly improving financial management operations.

She also led and supervised audit teams at the Defense Contract Audit Agency (DCAA), recovering millions in questioned costs from contractors. In state government, she recovered millions in sales and use tax dollars owed to the Texas State Comptroller of Public Accounts, ensuring taxpayer funds were used responsibly and efficiently.

Penny’s private-sector experience includes helping build successful internal audit divisions at major corporations such as Essilor Group and Fossil Group. Throughout her career, she has continued to expand her expertise while paying it forward by mentoring, coaching, and training professionals entering the accounting, audit, compliance, risk management, fraud, and internal controls fields.

Deeply committed to service, Penny is passionate about her philanthropic and volunteer work, especially with Alpha Kappa Alpha Sorority, Inc. and the Junior League of Washington. Her mission is to provide service to all mankind throughout her career, retirement, and life. She currently resides in Alexandria, VA, and enjoys spending her leisure time reading.

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