Quality Control

What Was Changed?

The new standard adopted by the Board, QC 1000, A Firm’s System of Quality Control, will replace the quality control standards that were adopted by the Board on an interim, transitional basis in 2003 from QC standards originally developed and issued by the AICPA. QC 1000 is an integrated, risk-based standard that includes establishing quality objectives, identifying and assessing quality risks to the achievement of the quality objectives, designing and implementing quality responses to address the quality risks, and monitoring the firm’s QC system and remediating any deficiencies, and that encourages an ongoing feedback loop to drive continuous improvement of the QC system. The new standard establishes annual evaluation requirements as well as annual reporting requirements to the PCAOB on a new, non-public reporting form, Form QC.

The related amendments expand the auditor’s responsibility to respond to deficiencies on engagements under an amended and retitled AS 2901, Responding to Engagement Deficiencies After Issuance of the Auditor’s Report, and related amendments to our attestation standards for broker-dealer engagements. In addition, the related amendments rescind the interim ethics and independence standard, ET 102, Integrity and Objectivity, and replace it with a new standard, EI 1000, Integrity and Objectivity, to better align our ethics requirements with the scope, approach, and terminology of QC 1000.

Additional Information on the New Auditing Standard 

• SEC Action: Release No. 34-100968
• PCAOB Standard: QC 1000, A Firm’s System of Quality Control
• Adopting Release: PCAOB Release No. 2024-005
• Project History: Quality Control
  

Who Is Affected?

All registered firms will be required to design a QC system that meets the requirements of QC 1000. Firms will be required to implement and operate the QC system in compliance with QC 1000 when they lead an engagement under PCAOB standards, play a substantial role in the preparation or furnishing of an audit report (as defined in PCAOB rules), or have current responsibilities under applicable professional and legal requirements regarding any such engagement.

What Are the Key Changes?

• Emphasis on accountability, firm culture and the “tone at the top,” and firm governance through requirements for specified roles within and responsibilities for the QC system, including at the highest levels of the firm; quality objectives that link compensation to quality; and, for the largest firms, the requirement of an independent perspective on firm governance.
• New risk-based approach, which should drive firms to proactively identify and manage the specific risks associated with their practice.
• A set of mandates, including required risk assessment and other QC-related processes, quality objectives, and quality responses—which should assure that the QC system is designed, implemented and operated with an appropriate level of rigor.
• New requirements that address changes in the audit practice environment, including the increasing participation of other firms and other outside resources, the role of firm networks, the evolving use of technology and other resources, and the increasing importance of internal and external firm communications.
• Broader responsibilities for monitoring and remediation of deficiencies to encourage an ongoing feedback loop that drives continuous improvement; and
• A rigorous annual evaluation of the firm’s QC system and related reporting to the PCAOB, certified by key personnel, to underscore the importance of the annual evaluation of the QC system, reinforce individual accountability, and support PCAOB oversight.

Why Did the PCAOB Adopt QC 1000 and Other Related Amendments?

Since the PCAOB’s adoption of the interim standards in 2003, the auditing environment has evolved in many ways, including evolving and greater use of technology, and increasing auditor use of outside resources, including other firms and providers of support services. Firms themselves have also changed significantly, as has the role of firm networks.

The Board believes QC 1000 will lead registered public accounting firms to significantly improve their QC systems. An effective QC system protects investors by facilitating the consistent preparation and issuance of informative, accurate, independent, and compliant engagement reports. Properly conducted audits and other engagements enhance the confidence of investors and other market participants in the information firms report on. QC 1000 is an integrated, risk-based standard, that mandates quality objectives and key processes for all firms’ QC systems, with a focus on accountability and continuous improvement. QC 1000 was designed to be applied by firms of varying size and complexity.

What Is the Effective Date?

The new standard and amendments are effective on December 15, 2025. For firms that are subject to applicable professional and legal requirements with respect to an engagement on the date that QC 1000 becomes effective, the reporting period for the first Form QC filing will be December 15, 2025, to September 30, 2026.

• Practice Aid: Providing a High-Level Overview of Certain Features Unique to QC 1000, A Firm’s System of Quality Control (Oct. 23, 2024)
• Comparison of QC 1000 with ISQM 1 and SQMS 1 (Oct. 23, 2024)
• Webinar: PCAOB Staff Provide an Overview of QC 1000, A Firm’s System of Quality Control (Oct. 23, 2024)