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Objective

Consider how PCAOB quality control (QC) standards should be revised to enhance and strengthen requirements related to a firm’s QC system.

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Most Recent Action

On November 18, 2022, the Board voted to issue a proposal for a new QC standard, QC 1000, A Firm’s System of Quality Control (proposed QC 1000), together with related amendments to PCAOB rules, standards, and forms, for public comment. The comment period is open through February 1, 2023.

In brief, the Board’s proposal would:

  • Provide 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 that encourages an ongoing feedback loop to drive continuous improvement of the QC system.
  • Require all registered firms to design a QC system that complies with QC 1000 and require firms that perform or have responsibilities with respect to engagements under PCAOB standards – for example, audit engagements for issuers or broker-dealers – to implement and operate their QC systems.  
  • Require involvement of independent individuals in firm governance for the largest firms.
  • Provide specified requirements regarding firm technological resources. 
  • Provide objectives regarding a firm’s voluntary publication of firm and engagement performance metrics.
  • Establish annual reporting requirements on QC – communication of the firm’s annual evaluation of QC system effectiveness to the audit committee of every issuer or broker-dealer client, and more detailed reporting to the PCAOB on a new, non-public reporting form, Form QC.
  • 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.
  • Establish a new standard, EI 1000, Integrity and Objectivity, to better align our ethics requirements with the scope, approach, and terminology of QC 1000.
  • Make additional changes to PCAOB rules, standards, and forms.

Additional information on the proposal:

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Background

  • Effective QC systems are crucial for supporting the consistent performance of high-quality audits and other engagements under PCAOB standards.
  • The Board’s current QC standards were developed decades ago and issued by the American Institute of CPAs before the PCAOB was established.
  • The auditing environment has changed significantly since that time, 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.
  • Advances in internal control, quality management, and enterprise risk management suggest that factors such as active involvement of leadership, focus on risk, clearly defined objectives, objective-oriented processes, monitoring, and remediation of identified issues can contribute to more effective QC.
  • Taking these considerations into account, the Board preliminarily believes its QC standards could be improved, thereby leading firms to improve their QC systems and ultimately better comply with applicable requirements.

The project has been informed by:

  • Observations from the Board’s oversight activities;
  • Information gathered through outreach efforts;
  • Relevant academic research and literature; and
  • Developments and trends in internal control, enterprise risk management, quality management frameworks, corporate governance, and audit firm governance.
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Status

The Board issued a proposal for public comment.