Comment Letter | Letter to the PCAOB Requesting Deferral of Effective Date of the PCAOB’s QC 1000

In this letter to the PCAOB, the CAQ requests the PCAOB take action to:

1. defer the effective date of QC 1000 for at least one year (December 15, 2026) and allow a phased implementation approach for firms who audit fewer than 100 issuers,
2. issue written implementation guidance specific to the questions raised by the CAQ and our member firms to the PCAOB, and
3. gather input on whether targeted amendments to QC 1000 would enhance the scalability of the standard and address unintended consequences.

The CAQ believes that a firm’s system of quality control is foundational to audit quality and that an effective quality control system is important to strengthening auditing practices and continuously improving audit quality. That is why it is critically important to audit quality that PCAOB registered firms of all sizes have adequate time to prepare for and implement QC 1000.

Read the full comment letter here.