March 24, 2026
 

Letter to the PCAOB on QC1000 Implementation Experience and Costs

The Center for Audit Quality (CAQ) has long been of the view that a firm’s system of quality control (QC system) is foundational to audit quality and that an effective quality control system is important to strengthening auditing practices and continuously improving audit quality. As such we have strongly supported the PCAOB’s project to adopt A Firm’s System of Quality Control and Other Amendments to PCAOB Standards, Rules, and Forms (QC 1000). At the same time, we have emphasized the benefits to audit quality of closely aligning the PCAOB’s QC requirements with international standards, highlighted the importance of scalability of the requirements to firms of all sizes, and raised constructive concerns regarding certain elements of the PCAOB’s requirements.

This letter is a supplement to the letter we previously submitted to the PCAOB on July 23, 2025 regarding A Firm’s System of Quality Control and Other Amendments to PCAOB Standards, Rules, and Forms (QC 1000).

The purpose of this supplemental letter is to provide the PCAOB with additional insights based on firms’ experience implementing QC 1000.

In addition, we provide information about the costs to implement QC 1000 based on data collected from certain member firms.

Read the full letter here.