Chapter 1 Quality Control
Chapter 1 Quality Control
The firm should establish policies and procedures designed to provide it with reasonable assurance
that the firm and its personnel comply with relevant ethical requirements contained in the Code of
Ethics issued by ICAI. The Code establishes the fundamental principles of professional ethics, which
include: Integrity, Objectivity, Professional competence and due care, Confidentiality and Professional
behaviour.
Fundamental principles should be emphasized by:
1. Actions of the leadership of the firm
2. Spreading awareness and training
3. Monitoring
4. A process for dealing with non-compliance
Independence Requirement: Observance of “Independence” in all engagements is the founding
requirement. The firm should establish policies and procedures designed to provide it with reasonable
assurance that the firm, its personnel (including experts contracted by the firm and network firm
personnel) maintain independence where required by the Code.
Such policies and procedures should enable the firm to:
(a) Communicate its independence requirements to its personnel
(b) Identify and evaluate circumstances and relationships that create threats to independence, and
take appropriate action to eliminate those threats or reduce them to an acceptable level by
applying safeguards, or, if considered appropriate, withdraw from the engagement.
There should exist a mechanism in the firm by which engagement partners provide the firm with
relevant information about client engagements and personnel of the firm promptly notify the firm of
circumstances and relationships that create a threat to independence. All breaches of independence
should be promptly notified to the firm for appropriate action. Its objective is to ensure that
independence requirements are satisfied. At least annually, the firm should obtain written confirmation
of compliance with its policies and procedures on independence from all firm personnel required to be
independent in terms of the requirements of the Code.
Familiarity Threat – SQC 1
SQC 1 lays special emphasis on familiarity threat. Using the same senior personnel on assurance
engagements over a prolonged period may impair the quality of performance of the engagement.
Therefore, the firm should establish criteria for determining the need for safeguards to address this
threat. In determining appropriate criteria, the firm considers such matters as:
(a) The nature of the engagement, including the extent to which it involves a matter of public interest.
(b) The length of service of the senior personnel on the engagement.
Examples of safeguards include rotating the senior personnel or requiring an engagement quality
control review. The familiarity threat is particularly relevant in the context of financial statement audits
of listed entities. For these audits, the engagement partner should be rotated after a defined period,
normally not more than seven years (except in cases where audit of listed entities is conducted by a
sole practitioner). However, to ensure quality control exists in such firms and appropriate reports are
issued, there is a process for mandatory peer review of such firms.
Example – Sudhanshu’s conduct is unethical because he offers a favourable report in exchange for
audit work. This shows lack of independence and weak quality control in the firm.
A firm before accepting an engagement should acquire vital information about the client. Such
information should help the firm to decide about:
Discussing with the appropriate level of the client’s management and those charged with
governance regarding the appropriate action the firm might take based on the relevant facts and
circumstances.
If the firm determines that it is appropriate to withdraw, discussing with the appropriate level of the
client’s management and those charged with governance withdrawal from the engagement or from
both the engagement and the client relationship, and the reasons for the withdrawal.
Considering whether there is a professional, regulatory or legal requirement for the firm to remain in
place, or for the firm to report the withdrawal from the engagement or from both the engagement
and the client relationship, together with the reasons for the withdrawal, to regulatory authorities.
Documenting significant issues, consultations, conclusions and the basis for the conclusions.
Example – CA M should evaluate the client’s integrity, legal issues, risk of association, and compliance
with ethical requirements before accepting the engagement.
The firm should establish policies and procedures designed to provide it with reasonable assurance
that it has sufficient personnel with the capabilities, competence, and commitment to ethical principles
necessary to perform its engagements in accordance with professional standards and regulatory and
legal requirements, and to enable the firm or engagement partners to issue reports that are appropriate
in the circumstances. Such policies and procedures should address relevant HR issues, including:
Recruitment, Compensation, Training, Career development and Performance evaluation. There should
be emphasis on the continuing professional development of the firm’s personnel. The firm should
assign responsibility for each engagement to an engagement partner. The firm should establish policies
and procedures requiring that:
(a) The identity and role of the engagement partner are communicated to key members of the
client’s management and those charged with governance.
(b) The engagement partner has appropriate capabilities, competence, authority and time to
perform the role.
(c) The responsibilities of the engagement partner are clearly defined and communicated to that
partner.
Each engagement team should be able to carry out its responsibilities with necessary competence and
skill. Therefore, the firm should ensure that suitable people are available and groomed for their roles.
The firm should also assess the performance of partners and team members, keeping in mind their
commitment towards quality.
2.1.5 Engagement Performance
Engagement files should normally be completed within 60 days after the date of the auditor’s
report (for audit engagements).
The time limit may vary depending on the nature of engagements.
Where two or more different reports are issued relating to the same subject matter, the firm’s policies
should treat each report as a separate engagement for assembling final engagement files.
Example: An auditor’s report on component financial information for group consolidation, and A
subsequent auditor’s report on the same financial information for statutory purposes.
Policies for Safeguarding Engagement Documentation: Policies and procedures should ensure the
confidentiality, safe custody, integrity, accessibility and retrievability of engagement documentation.
Care should be taken that policies on documentation of engagement quality control review require
documentation that:
(a) The procedures required by the firm’s policies on engagement quality control review have been
performed.
(b) The engagement quality control review has been completed before the report is issued.
(c) The reviewer is not aware of unresolved matters that would cause the reviewer to believe that
the significant judgments made and conclusions reached by the engagement team are
inappropriate.
Ownership and Retention of Documentation: Unless otherwise specified by law or regulation:
Engagement documentation is the property of the firm.
The firm may allow access, at its discretion, to clients, provided such disclosure does not undermine
the validity of work performed or, in case of assurance engagements, the independence of the firm
or its personnel.
Engagement documentation should be retained for a period sufficient to enable those performing
monitoring procedures to evaluate the firm’s compliance with its system of quality control, or for a
longer period if required by law or regulation. In the case of audit engagements, the retention period
ordinarily should not be shorter than seven years from the date of the auditor’s report or, if later, the
date of the group auditor’s report.
2.1.6 Monitoring
The firm should ensure that policies and procedures relating to the system of quality control are
relevant, adequate, operating effectively and complied with in practice. Such policies and procedures
should include an ongoing consideration and evaluation of the firm’s system of quality control,
including a periodic inspection of a selection of completed engagements.
Quality control of engagements has to be monitored taking into account the following factors:
Deciding whether the quality control system of the firm has been appropriately designed and
effectively implemented.
Examining whether new developments in professional standards, legal and regulatory requirements
have been reflected in the quality control policies.
Conducting monitoring by entrusting responsibility of monitoring process to a partner or other
persons with sufficient and appropriate experience and authority in the firm.
Dealing with complaints and allegations against the firm or any employees of it regarding non-
compliance with professional standards or appropriate regulatory requirements, either from within
or outside the firm.
Taking appropriate remedial actions against personnel who did not conform to quality control
policies.
Taking action when deficiencies in the design or operation of the firm’s quality control policies and
procedures or non-compliance with the firm’s system of quality control are identified.
3. SA 220 – Quality Control for an Audit of Financial Statements
Based upon the quality control system of the firm, quality control policies relating to audit
engagements are decided by engagement teams. The engagement partner and team are responsible for
applying quality control procedures for a particular audit engagement in accordance with SA 220. SA
220 is based on the premise that the firm is subject to SQC 1. Within the context of the firm’s system of
quality control, engagement teams are responsible for implementing quality control procedures
applicable to the audit engagement and providing the firm with relevant information to enable the
functioning of the firm’s quality control system relating to independence. Engagement teams are
entitled to rely on the firm’s system of quality control, unless information provided by the firm or other
parties suggests otherwise.
Objective of the Auditor under SA 220
As per SA 220, the objective of the auditor is to implement quality control procedures at the
engagement level that provide the auditor with reasonable assurance that:
(a) The audit complies with professional standards and regulatory and legal requirements.
(b) The auditor’s report issued is appropriate in the circumstances.
Responsibilities/ Elements of Engagement Partner under SA 220
SA 220 is modelled on the lines of SQC 1. It describes the responsibilities of the engagement partner in
relation to the following matters:
(a) Leadership responsibilities for quality on audits
(b) Relevant ethical requirements
(c) Acceptance and continuance of client relationships and audit engagements
(d) Assignment of engagement teams
(e) Engagement performance
(f) Monitoring
3.1 Leadership Responsibilities for Quality on Audits
The engagement partner is responsible for the overall quality on each audit engagement. The actions of
the engagement partner and the appropriate messages to the engagement team emphasize the
importance of maintaining audit quality. The engagement partner should emphasize:
(a) The Importance of Audit Quality of:
(i) Performing work that complies with professional standards and regulatory and legal
requirements.
(ii) Complying with the firm’s quality control policies and procedures, as applicable.
(iii) Issuing auditor’s reports that are appropriate in the circumstances.
(iv) Ensuring that the engagement team can raise concerns without fear of reprisals.
(b) The Fact that Quality is Essential in Performing Audit Engagements The engagement partner must
communicate clearly to the team that audit quality is fundamental and must not be compromised in
any engagement.
The engagement partner should ensure compliance with SQC 1 while deciding:
Whether to accept a new client,
Whether to continue an existing engagement, or
Whether to accept a new engagement with an existing client.
The engagement partner should obtain information regarding: Integrity of principal owners and key
management. Competence of the engagement team, including time and resources. Compliance with
relevant ethical requirements. Such information assists the engagement partner in determining
whether the conclusions regarding acceptance or continuance of client relationships and audit
engagements are appropriate.
The engagement partner should ensure that the engagement team and any auditor’s experts who are
not part of the engagement team collectively have the appropriate competence and capabilities to
perform the audit engagement in accordance with: Professional standards, and Regulatory and legal
requirements.
The engagement partner is responsible for the direction, supervision and performance of the audit
engagement in accordance with professional standards and regulatory and legal [Link]
engagement partner should also ensure that appropriate consultation takes place on difficult or
contentious matters within the team or with experts outside the firm. The engagement partner should
be satisfied that:
Appropriate audit evidence has been obtained to support the conclusions reached.
Audit documentation is sufficient and appropriate before the auditor’s report is issued.
For audits of financial statements of listed entities, and other audit engagements where the firm
determines that an engagement quality control review is required, the engagement partner should:
(a) Determine that an engagement quality control reviewer has been appointed.
(b) Discuss significant matters arising during the audit engagement, including those identified during
the engagement quality control review, with the engagement quality control reviewer.
(c) Not date the auditor’s report until the completion of the engagement quality control review.
Matters Considered During EQCR: The engagement quality control reviewer evaluates significant
judgments made by the engagement team and the conclusions reached in formulating the auditor’s
report. This evaluation normally includes:
(a) Discussion of significant matters with the engagement partner.
(b) Review of the financial statements and the proposed auditor’s report.
(c) Review of selected audit documentation relating to the significant judgments the engagement
team made and the conclusions it reached.
(d) Evaluation of the conclusions reached in formulating the auditor’s report and consideration of
whether the proposed auditor’s report is appropriate.
Additional Considerations for Listed Entity Audits: For audits of financial statements of listed entities,
the engagement quality control reviewer also considers:
(a) The engagement team’s evaluation of the firm’s independence in relation to the audit
engagement.
(b) Whether appropriate consultation has taken place on matters involving differences of opinion or
other difficult or contentious matters, and the conclusions arising from those consultations.
(c) Whether audit documentation selected for review reflects the work performed in relation to
significant judgments made and supports the conclusions reached.
Differences of Opinion
If differences of opinion arise within the engagement team, with those consulted, or between the
engagement partner and the engagement quality control reviewer, the engagement team should follow
the firm’s policies and procedures for resolving such differences.
Even though expert opinion from ICAI resolved the issue, appointment of an engagement quality
control reviewer is still relevant, since EQCR is mandatory for listed entity audits and must be
completed before issuing the audit report.
3.7 Monitoring
An effective system of quality control includes a monitoring process designed to provide the firm with
reasonable assurance that its policies and procedures relating to the system of quality control are
relevant, adequate and operating effectively. The engagement partner should consider the results of
the firm’s monitoring process as evidenced in the latest information circulated by the firm and, if
applicable, other network firms, and whether deficiencies noted in that information may affect the
audit engagement.
3.8 Documentation
The engagement partner should document the following matters pertaining to an audit engagement:
(a) Issues identified with respect to compliance with relevant ethical requirements and how they
were resolved.
(b) Conclusions on compliance with independence requirements that apply to the audit
engagement, and any relevant discussions with the firm that support these conclusions.
(c) Conclusions regarding the acceptance and continuance of client relationships and audit
engagements.
(d) The nature and scope of, and conclusions resulting from, consultations undertaken during the
course of the audit engagement.
Documentation by Engagement Quality Control Reviewer: The engagement quality control reviewer
shall document for the audit engagement reviewed that:
(a) The procedures required by the firm’s policies on engagement quality control review have been
performed.
(b) The engagement quality control review has been completed on or before the date of the
auditor’s report.
(c) The reviewer is not aware of any unresolved matters that would cause the reviewer to believe
that the significant judgments made and conclusions reached by the engagement team were not
appropriate.
S. SQC 1 SA 220
No.
1 It applies to the entire firm and fixes the It applies to a particular audit
responsibility of the firm to be assumed by CEO or engagement and the engagement
managing partners. partner takes responsibility.
4 It pertains to establishing a system of quality control It is premised on the basis that the
designed to provide reasonable assurance that the firm is subject to SQC 1. Within the
firm and its personnel comply with professional firm’s system of quality control,
standards and regulatory requirements, and that engagement teams implement
reports issued by the firm or engagement partners quality control procedures applicable
are appropriate in the circumstances. to audit engagements.
The reporting may not fully comply with SA 220. The auditor should properly evaluate and verify the
regularity of statutory dues before making such a comment. Simply stating that the company is
“generally regular” without adequate audit evidence may not meet the quality control and reporting
requirements of SA 220.
5. Mechanisms for Review of Quality Control