Comment: Proposed amendments to QC 1000

In our remarks responding to the PCAOB’s request for comments on its proposed amendments to QC 1000, A Firm’s System of Quality Control, and related rule and forms, we support the Board’s movement toward more principles-based requirements in targeted areas, which would allow firms to design and operate quality control (QC) systems that reflect their specific facts and circumstances.

We strongly support amendments that improve the alignment of QC 1000 with other existing quality management frameworks, including International Standard on Quality Management (ISQM) 1 and Statement on Quality Management Standards (SQMS) No. 1. The removal of requirements that diverge from these frameworks, such as the design-only requirement and the concept of a “major QC deficiency,” as well as the elimination of the external QC function (EQCF) requirement, represents meaningful progress.

Further, we believe that ongoing dialogue with stakeholders as well as additional implementation guidance will support the effective application of QC 1000, particularly in such areas as monitoring and remediation, evaluation of similar engagement deficiencies across engagements, and documentation requirements.

Download (PDF - 284.46KB) our letter to read our comments in response to specific questions posed by the Board.