Is The New ISQM 1 Scalable?

Is The New ISQM 1 Scalable?

Continuing our series of blogs where we last looked at the key differences between ISQM(Ireland) 1 and its predecessor the ISQC 1 establish quality objectives . This week we look at the question: ‘Is the new ISQM 1 scalable?’

Scalability

According to ISQM 1:34D-3 when designing, implementing and operating a system of quality management (SoQM), each audit firm must take into account the nature and circumstances of the firm and its engagements and ensure that its approach is appropriate. In doing this, the firm shall:

  • take into consideration the scale and complexity of the firm’s activities; and
  • be able to demonstrate to the firm’s regulatory body and to the Irish Audit & Accounting Supervisory Authority, that the policies and procedures are appropriate.

Saleability example:

For firms with low complexity and flat structures, (for example smaller partnerships) objectives about, for example, the firm’s organisational structure and the assignment of roles, responsibilities and authority may not need to contain a lot of detail. Likewise, sole practitioner auditors or firms with only one or two audit staff, objectives relating to HR much are less likely to be very complex.

Another potential factor to take into account is where there are staff working on audits, who have chosen to opt out of the audit exam topic in their professional examinations, this additional risk factor may need to feature in a firm’s risk assessment. Such staff may need additional one-to-one audit training in the auditing basics, as they have not had the benefit of such a foundation to enhance their audit skills and scepticism.

Networks: There are important objectives in the ISQM 1 for firms that are involved in international Networks. Where firms are not members of networks, they don’t need to consider any of the objectives relating to network resources or requirements.

Group audits: Firms that never participate in group audits are unlikely to need objectives surrounding the cooperation with component or group auditors.

Additional objectives

The standard expects the firm’s SoQM to reflect the firm’s nature and circumstances. This means that there could be circumstances where extra objectives will be required in addition to those provided within the standard.

E.g. in a large, complex firm with multiple offices and strategies including mergers and acquisitions, it is likely that the firm may need to expand the mandatory objectives or provide more granular detail in its objectives and risk assessment. Completely new objectives may need to be added in these circumstances.

In smaller, less complex firms it is much less likely to need to expand the mandatory objectives, although additional granular detail may be useful depending on the circumstances.

In subsequent years, firms must take account of feedback from around the firm and from the RCA (Root Cause Analysis) work to mould new or amended objectives, as the entire SoQM is a continuously iterative process.

Where in doubt, external professional expert advice should be sought.

For more assistance please see our new ISQM TOOLKIT or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard, please call or e-mail John McCarthy FCA or e-mail him at john@jmcc.ie

Publications and AML webinar

To ensure your letters of engagement and similar templates are up to date visit our site here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items if bought together.

Key Differences Between ISQM (Ireland) 1 and ISQC (Ireland) 1

Key Differences Between ISQM (Ireland) 1 and ISQC (Ireland) 1

ISQM (IRELAND) 1 (hereafter referred to as ISQM 1) is very different from its predecessor which was called ISQC (IRELAND) 1.

One of the main differences is that ISQC was ‘passive’ (it could sit on the shelf for years without really affecting how the audit work was performed) while the ISQM 1 is much more ‘proactive’ requiring more thought and tailoring in its preparation leading to corrective action like root cause analysis (RCA). More on this in a later blog.

The other key differences are that the ISQM 1:

  1. Requires the firm to take a risk-based approach to designing, implementing and operating the individual components of the system of quality management (called the SoQM). In this risk based approach firms must:
  • establish quality objectives;
  • identify and assess the risks (the quality risks) that the quality objectives referred to above might not be achieved;
  • design and implement responses to address the quality risks; and
  • test and adjust the SoQM on a regular basis (probably annually) to ensure it is always fit for purpose;
  1. The new ISQM 1 has eight components of a quality management system compared to six in the previous ISQC. The two new elements are
    1. the firm’s risk assessment process, and
    2. information and communication;
  2. The standard includes enhanced requirements related to the firm’s commitment to quality through its culture;
  3. Greater emphasis is placed on accountability for the system of quality management much more than was the case with the old ISQC;
  4. There is a much more focused approach to the relevant ethical requirements rather than just independence which was emphasised in ISQC;
  5. Resources are given more attention, so each audit firm must consider resources such as :
    1. Human;
    2. Technological;
    3. Intellectual; and
    4. Service providers.
  6. Communication and information is one of the new components of the quality management system which places more emphasis on communications with external parties;
  7. There is a new approach to the monitoring process requiring a specific technique called root cause analysis;
  8. Requirements about engagement quality control reviews (EQCR) or hot file reviews are set out in a new standard, called ISQM 2. The old ISQC dealt with these in the past; and
  9. There is new requirement to understand quality in relation to:
  • resources,
  • services and
  • monitoring provided by a firm’s network, where relevant.

It’s impossible to cover everything in this brief blog. For more assistance please see our new ISQM TOOLKIT or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard, please call or e-mail John McCarthy FCA or e-mail him at john@jmcc.ie

Publications and AML webinar

  • The ISQM TOOLKIT 2022 is available to purchase here.
  • See our latest Anti-Money Laundering Policies Controls & Procedures Manual (March 2022) – View the Table of Contents click here.
  • Also we have an updated AML webinar (March 2022) available here, which accompanies the AML Manual. It explains the current legal AML reporting position for accountancy firms and includes a quiz. Upon completion, you receive a CPD Certificate of attendance in your inbox.
  • To ensure your letters of engagement and similar templates are up to date visit our site here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items if bought together.

 

Have You Developed Your Quality Management Strategy Yet?

Have You Developed Your Quality Management Strategy Yet?

Continuing on from our recent blog where we looked at assessing the quality risks for the ISQM, this week we look at how to develop a quality management strategy.

Have You Developed Your Quality Management Strategy Yet?

There are four key steps involved in developing a quality management strategy:

  1. Respond to quality risks – what is required in ISQM 1?
  2. Map and document your responses
  3. The role of the RI in embedding audit quality
  4. Practical considerations for less complex firms

We will look at the first of these steps today.

Bear in mind that the quality management process is iterative, so you are expected to adjust the assessment at any time if you notice any risks have changed since they were last assessed. Make sure to document your changes and the reasons for the change.

Respond to quality risks – what is required in ISQM 1?

The types of quality risks that may exist will vary from firm to firm and will be influenced by the size and complexity of the clients as well as the size of the firm and the numbers of offices it has, as well as the non-audit services it provides.

The responses will be influenced by factors like the specific responses that are required by Paragraph 34 of ISQM 1 which includes responses that the firm is required to design and implement. However there is the caveat that ‘unlike the quality objectives …the specified responses are not comprehensive and would not fully address all quality risks. Accordingly, the firm is expected to design and implement responses in addition to those specified in the standards.’

There are also the 12 additional requirements to paragraph 34 added by the Irish Audit & Accounting Supervisory Authority.

Factors to be aware of will include:

  • The type of audit programme used and whether ether is an updating service;
  • The type of ISQM Manual used;
  • CPD training policies within the firm;
  • Whether the firm is part of a Network and what types of support it may offer;
  • Technical resources and having confidence that they are competent and up to date;
  • The types of non-audit services provided and whether these are offered to audit clients where there could be an ethical threat;
  • The length of time the audit partners have provided the audit service to their clients with the potential for long association risk.

This list is not exhaustive.

It’s impossible to cover everything in this brief blog. For more assistance please see our new ISQM TOOLKIT or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard, please call or e-mail John McCarthy FCA or e-mail him at john@jmcc.ie

Publications and AML webinar

  • The ISQM TOOLKIT 2022 is available to purchase here.
  • See our latest Anti-Money Laundering Policies Controls & Procedures Manual (March 2022) – View the Table of Contents click here.
  • Also we have an updated AML webinar (March 2022) available here, which accompanies the AML Manual. It explains the current legal AML reporting position for accountancy firms and includes a quiz. Upon completion, you receive a CPD Certificate of attendance in your inbox.
  • To ensure your letters of engagement and similar templates are up to date visit our site here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items if bought together.
Have You Assessed Your Quality Risks Yet?

Have You Assessed Your Quality Risks Yet?

Continuing our blog where we looked at how to establish quality objectives for the ISQM, this week we look at how to assess the quality risks.

Have you assessed your quality risks yet?

The first step is to consider the likelihood and significance of a particular risk crystallising.

Bear in mind that the quality management process is iterative, so you can adjust the assessment at any time if you think it has changed since it was last assessed, as long as you document your changes and the reasons for the change.

Develop and implement responses

There are broadly 6 mandatory responses set out in ISQM 1 (see paragraph 34 of ISQM 1) to which the IAAASA have added a further 12 of their own (see paragraph 34D-1 of ISQM 1). Paragraph 34D-2 adds some requirements for auditors of listed entities and Paragraph 34D-3 mentions  adjusting the requirements for the scalability and complexity of the audit firm and the entities it audits.

On their own they will not be sufficient for full ISQM 1 compliance.

Many of the policies and procedures you already have in place on your ISQC1 may be appropriate but be careful not to take the attitude that this is a copy and paste exercise.

The responses identified need to link back to the quality risks already identified and the established quality objectives. Please don’t give in to the temptation to work backwards by starting with your policies and procedures and then doing the responses followed by the risk assessment.

Follow this sequence:

  1. Document the key information about your firm and engagements;
  2. Think about the quality objectives in the standard and the risks that could arise by not achieving those objectives; and
  3. Then look at your current procedures and policies to identify gaps.

Where you find that your existing ISQC 1 policy or procedure doesn’t fit any of the risks, you have identified, it has one of two main consequences either:

  1. The procedure isn’t needed or
  2. You have missed a risk that needs more attention in the new ISQM 1 System of Quality Management (SOQM).

Monitor and revisit

As you progress through the standard and you evaluate and monitor your System of Quality Management (SOQM), you may revisit and change objectives, risks and responses. If deficiencies are identified, you must perform root cause analysis, the outcome of which may then involve revising either your objectives, risks or responses.

You may have already been doing this by responding to cold and hot file review and inspection findings, but perhaps not being sufficiently proactive about correcting deficiencies and ensuring they are much less likely to recur.

If you haven’t, please don’t need to wait until 15 December 2022 to start – get started now.

It’s impossible to cover everything in this brief blog. For more assistance please see our new ISQM TOOLKIT or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard, please call or e-mail John McCarthy FCA or e-mail him at john@jmcc.ie

Publications and AML webinar

  • The ISQM TOOLKIT 2022 is available to purchase here.
  • See our latest Anti-Money Laundering Policies Controls & Procedures Manual (March 2022) – View the Table of Contents click here.
  • Also we have an updated AML webinar (March 2022) available here, which accompanies the AML Manual. It explains the current legal AML reporting position for accountancy firms and includes a quiz. Upon completion, you receive a CPD Certificate of attendance in your inbox.
  • To ensure your letters of engagement and similar templates are up to date visit our site here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items if bought together.
Establishing Quality Objectives for the ISQM

Establishing Quality Objectives for the ISQM

Six of the eight components have mandatory quality objectives established in the International Standard on Quality Management (ISQM) 1 (see paragraphs 25-34 of ISQM 1). For assistance with implementing the ISQM see our ISQM TOOLKIT available for immediate download here. There is 20% off for simultaneous purchases of five items or more.

There are no mandatory objectives for the two remaining areas:

  • risk assessment or
  • monitoring and remediation.

Smaller firms may find that the quality objectives already included in ISQM 1 are sufficient for their needs, but some firms may need to establish other objectives or sub-objectives. Every firm must consider (and evidence they considered) whether they need additional objectives – it’s not safe just to assume you don’t need them.

Note that if a quality objective included in ISQM 1 is not relevant to your firm then you can ignore it.

The next step is to identify quality risks that threaten the achievement of those quality objectives:

  • Consider
    • the nature and circumstances;
    • the conditions and events;
    • the actions and inactions; and
    • the type and nature of the client engagements.
  • Much of a firm’s nature and circumstances is dictated by:
    • the people working there;
    • the environment within which it operates; and
    • the types of client it serves.

All of the above variables may have an impact on the quality risks that are most relevant to the firm, and each firm will need to assess the significance/likelihood of those risks crystallising.

The emphasis will need to be on identifying quality risks rather than focusing on the consequences of a risk crystallising – e.g.

  • not understanding the requirements of the Ethical Standard is a quality risk;
  • rather than a breach of the Ethical Standard which would be a consequence of that quality risk

Watch out that where you identify a quality risk that doesn’t result from a quality objective in ISQM 1 then you will need to establish a new quality objective.

Next week we will look at assessing risks.

It’s impossible to cover everything in this brief blog. For more assistance please see our new ISQM TOOLKIT or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard, please call or e-mail John McCarthy FCA or e-mail him at john@jmcc.ie

Publications and AML webinar

  • The ISQM TOOLKIT 2022 is available to purchase here.
  • See our latest Anti-Money Laundering Policies Controls & Procedures Manual (March 2022) – View the Table of Contents click here.
  • Also we have an updated AML webinar (March 2022) available here, which accompanies the AML Manual. It explains the current legal AML reporting position for accountancy firms and includes a quiz. Upon completion, you receive a CPD Certificate of attendance in your inbox.
  • To ensure your letters of engagement and similar templates are up to date visit our site here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items if bought together.