Three months until ISQM 1 - Ten tips for smaller firms

Around the globe, auditors are preparing for the imminent ISQM 1 regime, and today marks the three-month countdown to the deadline – 15 December 2022 – by which every UK audit firm will need an ISQM-compliant System of Quality Management (‘SOQM’).

While larger firms have been working for many months to prepare for ISQM 1, we’re aware that many smaller firms are only just beginning the journey towards compliance and the last thing they might welcome is a reminder that time is running out! If you’re tempted to conclude that you’ve left it too late to meet the deadline, our message is: don’t despair. There is still opportunity to get ready, although it’ll mean setting aside dedicated partner time to achieve this, and regulators will be looking for clear evidence of progress by the end of the year.

Here are our top ten tips to helping you get your SOQM across the finish line:

1. Read the ISQM. There’s really no way around this! We’d recommend you also get hold of the IAASM Implementation Guide, which is genuinely helpful – although be warned; this is for the international version of the ISQM and doesn’t include the additional quality responses added to the UK standard by the FRC.

2. Assess your current approach to audit quality. Firms aren’t (usually!) starting from scratch on audit quality and will have various policies and procedures already in place. While we want to stress that you shouldn’t simply ‘bolt on’ ISQM to your existing approach, it’s helpful to get a clear insight into what’s happening now. This may mean gathering various documents, clarifying existing arrangements with the rest of the team and organising your thoughts.

3. Find out what your team thinks about your current approach. Chances are, you and your team already have sound insights into what’s working well and what isn’t, and some honest feedback may be painful but is essential to making progress. Apex’s ISQM Toolkit comes with a team questionnaire that can help you to gather anonymous feedback including suggestions for tackling problem areas.

4. Start with leadership and governance issues. For most if not all small firms, a critical success factor for ISQM compliance is the degree of support from partners, especially managing partners within firms. ISQM 1 challenges senior leadership to demonstrate genuine commitment to audit quality, recognising that this may not always align with a firm’s commercial strategy or its leaders’ priorities. You need to identify and deal with those conflicts, if present. You’ll also need to consider how much of the SOQM can be delegated to others and how the managing partner will demonstrate that they bear ultimate responsibility for its success.

5. Don’t dismiss the appointment stage. Many firms assign consideration of (re)appointment to junior audit staff who lack the judgement to assess ethical threats and to apply the right safeguards. Accepting a client relationship or engagement inappropriately removes any chance to achieve a quality audit.

6. Be honest about priorities. Many firms say that they’re committed to audit quality, but a cursory scrutiny about how much of the firm’s time and money is spent in supporting and developing high quality audit may suggest otherwise. ISQM 1 demands that firms allocate enough resource to recruit and develop audit teams, supply them with appropriate tools (including hardware and software) and allow them the time to conduct audits thoroughly. You’ll also need to assess the quality risks of over-relying on external training providers, file reviewers or providers of methodology or IT tools.

7. Refocus on prevention rather than cure. In the past, many audit firms have relied on regular cold file reviews to ensure their quality is up to scratch. Whilst such reviews will still play a key role, firms need to consider how to avoid audit defects altogether. For many audit partners, this may mean reducing the amount of time spent in review, and increasing the time spent in directing and supervising audits whilst in progress. Better prepared and managed teams should produce better audit files that need less review and remediation.

8. Plan your monitoring as you go. As you set out your SOQM, make sure that every element is trackable and assign responsibility for monitoring to specific individuals, with clear instructions about how they should check progress and how they must record this. This should make the ‘monitoring and remediation’ part of the process much less burdensome. Don’t leave it all until the end!

9. Get familiar with Root Cause Analysis (‘RCA’). This is a tool that has increased in profile of late, and while RCA can be sophisticated, it needn’t always be so. The aim is to identify systemic defects that, if corrected, will prevent problems from recurring. Don’t be afraid of asking ‘why did X happen’ multiple times when a quality problem is spotted, until the roots are uncovered.

10. Consider external support. Whilst it’s possible to implement ISQM 1 without any other support, especially if you use a good transition tool (did we mention that Apex has an ISQM Toolkit designed for the smaller firm?), you may find that getting the assistance of a specialist can be hugely valuable, even if just as a sounding board. Many file reviewers are offering ISQM implementation help at the moment – why not ask your existing reviewer if they can help in this way?