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75361cajournal August2023 12
75361cajournal August2023 12
75361cajournal August2023 12
As newer technologies like Artificial Intelligence (AI) enter the business space, Chartered
Accountants must gear up to meet the challenges and seize the opportunities that present
themselves. As businesses gear up to unleash the prowess of AI in their environment,
a Chartered Accountant (CA) must understand the nature of AI and the concerns that it
may bring in. He must also envision the myriad ways in which AI could be implemented
in the accounting department of an entity – right from reconciliations through reporting
to streamlining disclosures and even beyond, to the realm of decision-support and risk
management systems in the entity. As an Auditor, a CA must look at ways to leverage
AI to increase the level of assurance – by deploying AI at various stages of the audit of
the process while reserving the responsibility of forming an opinion to himself. With the
able guidance of the ICAI, the CAs will well be able to tide over this wave of change and
emerge stronger.
the rightness of the decisions of the Information Technology adopting AI relevant to the
made by the AI systems by an Act, 2000, which deals with business context.
information systems auditor compensation for failure to
instead of seeking an explanation protect data, “Information Applications of AI in
is also proposed as an Technology (Reasonable security Accounting
alternative. Under the Consumer practices and procedures
and sensitive personal data Having discussed some basic
Protection Act, 2019, Consumer
or information) Rules, 2011” aspects of AI, now let us look at
Protection (E-Commerce)
have been issued. These Rules some specific use cases of AI in
Rules, 2020 have been issued
provide for procedures to handle accounting and compliance for
to address the issues arising
sensitive personal data or businesses:
in e-commerce.4 These Rules
require an explanation of the information.5 Under the proposed
i. Reconciliation Process
main parameters based on which Digital Personal Data Protection
Bill, 2022, unauthorised use of A significant use case of AI in
rating of sellers is made, in plain
data may constitute a “personal accounting is reconciliation – be
language. If a platform uses AI
data breach”.6 Under the it bank reconciliation or inter-
to rank goods or sellers, the
proposed Digital India Act, 2023, company reconciliation for group
requirements under these Rules
measures to regulate as well as entities or for creditors and debtors
must be factored in. It must also
to foster innovation in AI and balance confirmation processes.
be understood that explainability
other emerging technologies are If done manually as it is done at
is crucial for the developers and
being proposed.7 NASSCOM has present in many businesses, it is
businesses to ensure that the AI
also come up with Guidelines on time consuming and laborious
system is working as expected, as one witnesses the problems
not just in terms of the decision Generative AI.8 On 14th June,
2023, the European Parliament of duplicate entries, mismatched
taken but in terms of the way in entries, partially-entered invoices,
which the decision is arrived at, approved its position on the
world’s first AI Act under which tax aspects, accounting errors
which is necessary to build the and other inconsistencies. This
required level of trust to deploy it AI systems are classified based
on the risks they pose: from can be overcome with machine
for the intended purposes. learning (ML) technology that
unacceptable risk, high risk,
generative AI and limited risk, uses predefined matching rules
iv. Ethical Concerns and and which learns based on the
Regulatory Measures based on which obligations for
providers will be imposed under results of the datasets. This will
One of the ethical concerns in the rules.9 It, inter alia, seeks enable more reliable and timely
the use of AI is regarding data to ban using of AI for purposes disclosures of related party
protection and privacy. With like biometric surveillance and transactions.11 Such features are
the deployment of AI and Big recognition of emotions, and now available in ERP software as
Data analytics, an entity may requires generative AI to disclose well as in the form of applications
unintentionally or intentionally that the content is AI-generated.10 that can be deployed on existing
process sensitive data in an software or popular cloud-based
unauthorised way and that may While all these concerns still applications.
intrude on privacy interests. The remain and are addressed
lawmakers and regulators, the to some extent with evolving ii. Managing Related Party
world over, are still grappling with laws, businesses have already Transactions
the implications of AI and the started exploring the possibilities Another potential application
security and privacy concerns. that could open a floodgate could be in the very process of
At present, under section 43A of opportunities for them by identifying and understanding
4 https://consumeraffairs.nic.in/sites/default/files/E%20commerce%20rules.pdf
5 https://www.meity.gov.in/writereaddata/files/GSR313E_10511%281%29_0.pdf
6 https://www.meity.gov.in/writereaddata/files/The%20Digital%20Personal%20Data%20Potection%20Bill%2C%202022_0.pdf
7 https://www.meity.gov.in/writereaddata/files/DIA_Presentation%2009.03.2023%20Final.pdf
8 https://nasscom.in/ai/responsibleai/images/GenAI-Guidelines-June2023.pdf
9 https://www.europarl.europa.eu/news/en/headlines/society/20230601STO93804/eu-ai-act-first-regulation-on-artificial-intelligence
10 https://www.europarl.europa.eu/news/en/press-room/20230609IPR96212/meps-ready-to-negotiate-first-ever-rules-for-safe-and-transparent-ai
11 https://www.groupsoftus.com/insights/using-machine-learning-ml-in-sap-for-reconciliation/
AI in Accounting
Better
Managing screening of
Inventory Timely Management
Reconciliations Related Party vendor and
Management Reporting Accounting
Transactions customer
profiles
complex group structures of This necessitates technological alia, by screening vendor and
large conglomerates. Larger intervention both by the customer profiles from various
businesses usually arrange conglomerates for making sources and assess counter-
their ownership and control continued sense of the strategy as party default risks. This could
structure, business models and well as for better risk monitoring also ease complexities involved
transactions in the form of a by the various stakeholder groups in some disclosure requirements
complex web of group entities of these entities, especially the under the Schedule III to the
spread across geographies, lenders. For the businesses, Companies Act, 2013 like tracing
often in layers of entities, and AI tools could help in better of transactions with defunct
sometimes, wherever permitted, compliance and in making companies or disqualification
with cross-holdings or cross- complete and timely disclosures status of directors at least to the
control, formal and informal. The of related party transactions under extent of disqualification arising
group structures may or may not the applicable laws. out of a defaulting company
fall strictly under the definition under sub-section (2) of section
of related party as per the As far as stakeholders like the 164 of the Companies Act, 2013
applicable laws. lenders are concerned, they by comparing them with the
need to be able to have the database of Ministry of Corporate
Hence, the regulators world big picture of the entire group Affairs.
over are requiring increasingly to follow the money trail and
comprehensive compliance and understand whether the funds For financial sector entities, the
disclosure in respect of related have been deployed for the efforts towards understanding the
party transactions, as they are a stated purposes or whether they group structures and activities
significant indicator of the level are being siphoned off to benefit through AI as described in the
of good corporate governance. certain members of the promoter previous para could double up
In India, for instance, for listed group. Here AI could help towards strengthening fraud risk
companies, the definition of banks and financial institutions management and anti-money
‘related party’ and ‘related in understanding the overall laundering measures. It could
party transactions’ has been control structure, business model
widened to a great extent under and the consolidated financial
the SEBI (Listing Obligations strength of the borrowers with AI tools can
and Disclosure Requirements) complex group structures. This potentially be used
Regulations, 2015, so much will be a crucial information while for fraud risk mitigation,
so that even transactions with evaluating funding proposals and inter alia, by screening
arrangements – both initial and
third parties “the effect of which vendor and customer
is to benefit a related party”, ongoing.
profiles from various
or transactions of the listed
company or its subsidiaries on iii. Screening Profiles to sources and assess
the one hand with the related Manage Risks counter-party
parties of either on the other AI tools can potentially be used default risks.
hand are covered12. for fraud risk mitigation, inter
12 https://www.sebi.gov.in/legal/regulations/feb-2023/securities-and-exchange-board-of-india-listing-obligations-and-disclosure-requirements-
regulations-2015-last-amended-on-february-07-2023-_69224.html
help in setting up better Early the analyses instead of only a an audit of financial statements
Warning Signals as required sample is also available when AI is to give an opinion on whether
under the Reserve Bank of is coupled with Big Data. Entities the reporting requirements as per
India’s (RBI) Master Direction on have been able to gather data the applicable financial reporting
Frauds, and in better reporting of from various sources but if they framework have been met. Under
transactions required under the are unable to make sense of the the provisions of the Companies
provisions of the Prevention of data or they are unable to focus Act, 2013, the duty of the auditor
Money Laundering Act, 2002. on the information needs, they here is to express an opinion on
end up in a state of being Data- whether the financial statements
iv. Inventory Management Rich-Information-Poor (DRIP). present a true and fair view of
When it comes to inventory Introduction of AI here will help the affairs of the company. The
management, a combination of an entity to make sense from the auditor while arriving at this
AI together with RFID could help raw data and focus on obtaining opinion by obtaining reasonable
track, manage and account for relevant information, which can assurance on whether the
inventory on an almost real-time become actionable inputs to financial statements are free
basis, thereby enhancing the the management. Right from from material misstatements,
reliability of accounting records. automating repetitive decision- whether due to fraud or error,
Use of RFID combined with making to risk mitigation, AI can is required to evaluate whether
smart contracts and AI can help be used. However, it should be the audit evidence obtained is
establish a seamless trust-based remembered that periodic human sufficient and appropriate. In
supply chain management intervention is necessary to this process of collecting and
system. This will again go evaluate and judge the reliability evaluating sufficient appropriate
towards better accounting and of such AI-based decision- audit evidence, an auditor must
reporting. making systems. be mindful of the impact of AI.
AI can help analyse the financial AI can also help the auditor and transactions in the Report on
information of the clients his team perform an engagement Transfer Pricing as required
and assess the areas where quality control review as required under section 92E of the Income
the potential risk of material under “SQC 1 – Quality Control Tax Act, 1961, use of AI as a tool
misstatements is the highest. for Firms that Perform Audits comes in handy.
While the auditor may himself be and Reviews of Historical
subject to at least some degree Financial Information, and Other With big data, AI analytics can
of familiarity bias, the AI tool, is Assurance and Related Services greatly help the internal auditor
more likely to be free from such Engagements”, by assessing the in measuring the effectiveness
bias. The auditor may then apply appropriateness of the opinion of the internal controls in a
more substantive procedures in arrived at based on the audit comprehensive manner, although
the areas so identified. evidence collected. adequacy may be something that
will be best left to the judgment
AI may also help in determining Specifically, the auditor will be in of the internal auditor based on
materiality and in the a better position to give his / her the results of the analysis thrown
assessment of whether an opinion on the various matters by the AI. Areas of internal control
identified misstatement is covered under the Companies weaknesses can be identified in a
material in the context of the Auditors’ Report Order, 2020, much better manner.
entity. The auditor can then especially in respect of related
come with an optimized audit party transactions, material As far as forensic audit and
strategy and plan and perform uncertainty in respect of meeting investigations are concerned,
the audit in a better way. AI may the liabilities, and also with respect samples could be chosen on a
also help with sampling of test to whether the terms of the loans more scientific basis with the
cases for audit by choosing a and guarantees provided by the help of AI. Better samples would
sample free from bias thereby company are prejudicial to the lead to better information for
reducing sampling risk. interests of the company. arriving at conclusions. In case
of audit of specific transactions,
AI may also help with analysing b. AI as a tool in other audit AI tools can help arrive at the
whether the evidence might be engagements degree of correlation between
sufficient for assessing the risk AI could help not only in statutory the factors involved.
of material misstatements at audit engagements but also has
the assertion level by helping applications in internal audit, tax c. Challenges in implementing
establish a correlation between audit, forensic audit, etc. AI and results of AI in
the evidence and the assertion. auditing
It can also help assess whether In tax audits, when it comes The biggest challenge in
an audit observation based on a to verifying the matters of implementing AI is understanding
sample will be true for the entire disallowances, depreciation, how the AI tool arrives at the
set of data. TDS, TCS, reconciliation, output, so to say, how it “thinks”.
deductions, and more Although some experts are of the
When it comes to substantive importantly, in determining view that using anthropomorphic
analytical procedures, AI tools the arm’s length nature of words like “think” further
combined with big data can
help identify hidden patterns of
behaviour of various variables
and unearth and establish
relationships among financial
and non-financial information
in a more comprehensive
manner. Use of AI in analytical
procedures might help identify
red flags much earlier than
they would otherwise be and
help establish an early warning
system for the use of the
auditor.