Comment: Deferred effective date of QC 1000

In our letter to the SEC, responding to the PCAOB’s deferral of the effective date of its quality control standard and related amendments, we support the deferral from December 15, 2025 to December 15, 2026 and further believe that action is warranted to address substantive and persistent concerns and implementation challenges. In our view, the implications of QC 1000’s incremental and prescriptive requirements underscore a critical need for stakeholder engagement in considering potential amendments to QC 1000 as well as additional guidance.

We ask the SEC and the PCAOB to solicit further stakeholder input on certain unresolved issues with the standard, including its divergence from global quality standards, as well as practical implications, such as the inflexibility of the prescribed evaluation and reporting dates, documentation and retention burdens, and an investment in new IT infrastructure.

Download our letter to read our comments in full.