Written representations
A written statement obtained from an NPO's management, and its governance body, on material assessment issues — necessary audit evidence for a Social Impact Assessor, but never sufficient on its own.
In plain language
An assessor may want proof of something management already said. One way to get that proof is to ask for it in writing. This written proof is called a written representation.
The workbook tells the assessor to ask for these. The assessor asks management for them. Where it makes sense, the assessor also asks those in charge of governance. The ask covers material issues found during the assessment. The workbook treats this as evidence the assessor needs.
But the workbook is just as clear about the limits. A written representation is not enough evidence on its own. It does not replace the assessor's own checking. Getting a signed note from the people being assessed does not change how much other proof the assessor must still gather. It does not change whether management actually met its duties.
How it works
The workbook's own words (Chapter 5, section 5.9): "The social impact assessor should request written representations from management and, where appropriate, those charged with governance on material social impact assessment issues. Although written representations provide necessary audit evidence, they are not sufficient or appropriate by itself. Written representations do not affect the nature or extent of other audit evidence that the social impact assessor obtains about the fulfilment of management's responsibilities, or about specific assertions."
Two conditions, read together:
| What the workbook says | What it means |
|---|---|
| "Necessary audit evidence" | The assessor must obtain them where the criteria call for it. Skipping this step is a gap. |
| "Not sufficient or appropriate by itself" | A signed statement from management alone can never close out a material issue. Independent evidence is still required. |
Where this sits. Written representations are requested as part of the Social Impact Assessment Engagement (section 5.9), the same element of the engagement that also covers the three-party relationship and communication with Board members or Trustees on the assessment's scope and timing.
A worked example
Illustrative engagement; figures are made up.
An assessor reviewing Prerna Trust's ₹90 lakh nutrition programme asks the trust's programme director for a written representation confirming that all 14,000 beneficiary records shown to the assessor are complete, and that no material cases of double-counting exist.
The director signs the representation. The assessor still independently cross-checks a sample of 500 records against village-level attendance registers, and finds 22 discrepancies, a rate the assessor judges immaterial, but only after actually checking.
Had the assessor accepted the signed representation alone, without the independent sample check, that would have breached the workbook's own rule: the written representation is necessary evidence, but it is never, by itself, sufficient.
Why NISM asks about it
Chapter 5 (Social Impact Assessment and Social Impact Assessors), section 5.9 (Social Impact Assessment Engagement), requires the assessor to obtain written representations from management and governance on material issues, while stating plainly that they are not sufficient evidence on their own. Expect a question testing whether written representations alone can satisfy an assessor's evidence requirement. They cannot.
Common exam traps
- "Necessary" does not mean "sufficient." The workbook uses both words deliberately. Written representations are required, but never enough by themselves.
- They are obtained from management, and where appropriate, those charged with governance, not from beneficiaries or field staff.
- They do not reduce the assessor's other evidence-gathering duties. Getting a signed statement does not shrink the sampling, verification or field work otherwise required.
- Do not confuse written representations with the assessor's own engagement file — the engagement file stores the assessor's working papers and evidence; written representations are one specific type of evidence obtained from the client, not the assessor's own documentation.
Where this is taught
Free preparation for NISM Series XXIIIRelated terms
- Engagement fileThe assembled record — hard copy or soft copy — of an assessor's engagement documentation, which must be completed within about 60 days of the social impact assessment report and then kept, not discarded.
- Social Impact AssessmentA systematic evaluation of the social, ethical, cultural and environmental consequences of a project or organisation — positive and negative, intended and unintended — taking an "outside in" view.
- Social Impact AssessorAn individual registered with an SRO (under ICAI or another SEBI-specified agency) who has passed the NISM certification and holds a valid certificate; performs independent verification of impact reports.
- Means of verificationThe data sources, tools or methods used to measure an indicator — the evidence side of the logframe, fixed by funders with the social enterprise at the project design stage.