You Have Less Than Just Six Months Left to Implement the AICPA’s New SQMS and the PCAOB’s New QC 1000 Standards
Nine months ago, we warned that two new sets of quality control and management standards were coming due on December 15, 2025 and strongly advised public accounting firms not to wait until the last minute to begin implementing them.
Well, it’s now the last minute.
With just six months left until the the American Institute of Certified Public Accountants’ (AICPA) new Statements on Quality Management Standards (SQMS) and the Public Company Accounting Oversight Board’s (PCAOB) new QC 1000 quality control standards go into force, there’s no time left to delay or procrastinate.
Here’s a short overview of each set of standards and what’s necessary, but you can find our full blog for the AICPA’s new SQMS here, and the PCAOB’s new QC 1000 standards here. Both will require extensive effort to come into compliance.
The AICPA’s SQMS
The SQMS are what we here at Collemi Consulting & Advisory Services like to call the “thinking standards.”
This means you really have to think it through and customize it for your attest practice, based on the type of clients you have and the services you provide, as the SQMS now takes an entirely new, risk-based approach to quality.
There are now eight SQMS components, including two completely new ones: Risk Control, and Information and Communication.
The new risk assessment process requires firms to establish specific quality objectives, meaning they must “identify and assess quality risks, and then they must design and implement responses to those risks that are tailored to the firm’s unique circumstances.”
Information and communication requires the establishment of processes that support the SQMS, including reliable internal and external sources of information. It also mandates the creation of a culture that supports and reinforces the responsibility for sharing information with colleagues and the firm.
All of the six other quality objectives have new requirements as well:
● Governance and leadership
● Relevant ethical requirements
● Acceptance and continuance of client relationships and specific engagements
● Engagement performance
● Resources (formerly Human Resources)
● Monitoring
Firms have three responsibilities between now and December 15:
1) Continue using the extant standard (Statement of Quality Control Standard (SQCS) No. 8 (Redrafted)
2) Perform the risk assessment and gap analysis, and then design and implement the new standards.
3) Consult with your peer reviewer before final implementation
Firms then have until Dec. 15, 2026 to carry out an annual evaluation of their new quality management system.
The PCAOB’s New QC 1000 Standards
The PCAOB’s new QC 1000 standard is intended to make independent registered public accounting firms who audit issuers (public companies) and broker-dealers significantly improve their quality control (QC) systems.
It applies to all PCAOB-registered member firms. Those that audit more than 100 issuer clients annually have more extensive requirements to contend with.
The new standard enables firms to identify their specific risks and design a quality control system, including policies and procedures to guard against those risks. The goal is to create what the PCAOB refers to as a “a continuous feedback-loop for improvement.”
QC 1000 has quality control requirements that do not appear in other QC standards. They tend to be more prescriptive and more tailored to the U.S. legal and regulatory systems.
There are 10 areas in which the QC 1000 goes beyond what can be found in other existing standards.
These are:
● Evaluation and Reporting
● Governance and Leadership
● Ethics and Independence
● Monitoring and Remediation
● Quality Objectives
● Information and communications
● Resources
● Risk Assessment Processes
● Roles and Responsibilities
● Documentation
That’s not even an exhaustive list, and it’s coming into effect at the same time as the AICPA’s SQMS.
Our recommendation is to make two completely separate documents rather than trying to roll it all into one giant document. It’ll be too confusing, especially for people who might not have to audit both public companies, broker-dealers and private companies.
We also advise you to appoint a separate champion within the firm for each of the two different sets of standards. Otherwise it just gets too complex.
Like we said, time is running out. It’s time to get it done or get help doing it.
Collemi Consulting leverages over three decades of experience to provide trusted technical accounting and auditing expertise when you need it the most. We regularly work with CPA firm leadership to help them reduce risk and maximize efficiencies. To schedule an appointment, contact us at (732) 792-6101.



