Regulatory status as at the date of this update: standard out for public consultation, with no final approval and no application date in Spain. This article will be updated when the ICAC publishes the approval resolution.
Few things worry a director as much as reading a reference to going concern in the auditor’s report. With some industrial sectors in the province under pressure, it is worth understanding what the auditor assesses, what may change with the new standard and what management can prepare. This article is part of our series on ICAC and NIA-ES developments for the 2025 and 2026 audits.
Status of NIA-ES 570 (Revised 2024)
The ICAC Resolution of 16 July 2026, published in Spain’s Official State Gazette (BOE) no. 192 of 7 August 2026, puts out for public consultation NIA-ES 570 (Revised 2024), “Going Concern”, together with conforming amendments to 22 other NIA-ES, including 200, 315, 700, 701, 705 and 706. Comments could be submitted for two months from the day after publication, to the ICAC or to the professional bodies representing auditors.
The resolution sets no date of entry into force or application. After the comment period, the ICAC will have to publish a final approval resolution. As at the date of this update, there is no ICAC announcement of approval. Therefore, the current NIA-ES 570 (Revised) applies today; it was amended in January 2026 together with other reporting standards.
| Aspect | Today (current NIA-ES 570) | When the revision is approved (pending) |
|---|---|---|
| Status | Mandatory | Draft out for public consultation; final text and date to be confirmed |
| Assessment by management | The auditor evaluates management’s assessment of the ability to continue | Foreseeably, a more demanding evaluation of methods, assumptions and data, as in the international standard |
| Period considered | The one set by the current standard | The international standard extends the horizon; the Spanish approach is yet to be confirmed |
| Auditor’s report | Specific section if there is a material uncertainty | Foreseeably, more transparency about the work performed |
What going concern means in an audit
Unless there is evidence to the contrary, annual accounts are prepared on a going concern basis: it is assumed that the entity will continue operating for the foreseeable future. Management is responsible for assessing whether that basis is appropriate and for disclosing significant uncertainties in the notes to the annual accounts.
The auditor obtains evidence on whether the use of that basis is appropriate and whether there is a material uncertainty about the entity’s ability to continue. The consequences for the report depend on the conclusion:
- If there is a material uncertainty and the notes describe it adequately, the report includes a specific section on it. It is not a qualification, but it does draw the reader’s attention to a relevant matter.
- If the notes do not describe it adequately, the auditor may express a qualified or adverse opinion.
- If the going concern basis is not appropriate and the accounts have been prepared on that basis, the opinion will be adverse.
What the international revision strengthens
NIA-ES 570 (Revised 2024) adapts ISA 570 (Revised 2024) of the IAASB, the international body that issues auditing standards. According to the IAASB, the international standard applies to audits of periods beginning on or after 15 December 2026 and strengthens four aspects:
- Risk assessment that is earlier and more complete regarding events or conditions that may cast doubt.
- Evaluation of management’s assessment in all cases, analysing the method, the assumptions and the data, and possible bias.
- Assessment period of at least twelve months from the date of approval of the financial statements.
- Greater transparency in the auditor’s report and in communication with those charged with governance.
Important caveat: these are the changes in the international standard. How the final Spanish text reflects them, including the assessment period and its application date, is pending approval by the ICAC.
Standards affected by conforming amendments
The revision is not limited to one standard. The project amends 22 other NIA-ES, such as those on the overall objectives of the auditor (200), engagement terms (210), documentation (230), risk identification (315), subsequent events (560), written representations (580) and all the reporting standards (700, 701, 705, 706). This is why, once approved, the representation letter and the structure of the report are expected to change.
What management can prepare
Whatever the application date, the trend is clear: the auditor will ask for more support for management’s forecasts. It is useful to have it ready before the year-end:
- Cash flow forecast covering at least the following twelve months, with explicit assumptions and reconciled with the budget.
- Debt schedule: maturities, covenants and renewals of credit facilities.
- Sensitivity analysis: what happens if sales fall, a customer is lost or financing costs rise.
- Viability plan if there are recurring losses or liquidity pressures, with specific measures and people responsible.
- Disclosures in the notes consistent with all of the above.
If the situation worsens, Law 16/2022, which reformed the Spanish Consolidated Insolvency Act (TRLC), offers pre-insolvency tools such as notifying the opening of negotiations with creditors and restructuring plans, available even where there is a likelihood of insolvency. And remember that the debtor must file for insolvency proceedings (concurso de acreedores) within two months of the date on which it became aware, or should have become aware, of its current insolvency (art. 5.1 of the consolidated text). These decisions require specific legal advice.
In the province of Alicante, manufacturing industry lost value added in 2025, according to the overview by the Alicante Chamber of Commerce and CaixaBank reported in the press. We analyse the warning signs in the footwear sector in our guide to the footwear crisis in Elche and Elda.
Frequently asked questions
What is a material uncertainty related to going concern?
It is an uncertainty about events or conditions that may cast significant doubt on the entity’s ability to continue operating and whose magnitude and potential impact make it necessary to disclose it in the notes and in the auditor’s report.
Is a going concern section in the report a qualification?
No, if the uncertainty is adequately described in the notes: the opinion can be unmodified with that specific section. If the disclosures in the notes are insufficient, it may lead to a qualification. Each case requires the auditor’s judgement.
When will the new NIA-ES 570 apply in Spain?
This is not yet known. It will be set by the ICAC’s final approval resolution, which has not been published as at the date of this update.
Do I need a viability plan so that the auditor does not include that section?
A plan does not guarantee any particular conclusion by the auditor, but sound, documented forecasts allow the auditor to evaluate management’s assessment on a proper basis. What matters is that the plan is realistic and verifiable.
Official sources
- BOE-A-2026-17276: ICAC Resolution of 16/07/2026, NIA-ES 570 (Revised 2024) out for public consultation
- BOE-A-2026-2234: ICAC Resolution of 22/01/2026, amendment of the NIA-ES reporting standards
- ICAC: announcements
- IAASB: ISA 570 (Revised 2024), release note
- Law 16/2022, reforming the consolidated text of the Insolvency Act (BOE)
- Consolidated text of the Insolvency Act, consolidated version (BOE)
If your company is facing liquidity pressures or wants to reach the year-end with forecasts that will stand up to the auditor’s review, we can help you prepare a sound viability plan. If we are your auditors, before accepting any additional service we will analyse the incompatibilities established by audit regulations; in that case, our role will be to evaluate your forecasts as part of the audit of annual accounts. For questions about whether you must be audited, see the mandatory audit thresholds in 2026. Contact us.
Article prepared by Controlaudit’s technical team. Updated on 8 October 2026. This content is for information purposes only and is not a substitute for professional advice on your specific case.