PCAOB QC 1000 Delay: What's The Impact On Your Firm?

In an unexpected move the PCAOB announced that they are deferring the effective date of QC 1000 by one year to December 15, 2026[1].

PCAOB say:

• This move will give firms additional time to overcome challenges that may not have been practicable with the original implementation date of December 15, 2025.

• The postponement is not an indication of any possible changes to the requirements themselves.

Whether the stance on changes stays the same in the coming months remains to be seen, particularly in the context of the statement from PCAOB Board member Christina Ho supporting the decision[2].

In her statement she raised two notable concerns.

This is something that we have seen firms trying to address, not only in terms of managing the differences, particularly as it relates to monitoring and remediation, but also in terms of reporting the outputs of their system.

"Firstly, the misalignments and overly prescriptive nature of QC 1000 vs. other quality management frameworks meant firms were still seeking to overcome and understand the challenges of running two separate systems, adding cost and complexity.”

There is an overlap between how firms will meet the compliance requirements of QC1000 and SQMS 1 so having to run two separate systems instantly creates additional administration that could be resolved through closer alignment between the standards.

A simple example we have seen is the possibility that the output of a monitoring activity on a response, that addresses both QC 1000 and SQMS 1 requirements, may result in a finding that is treated differently. This arises due to the difference in how a deficiency is assessed under the standards.

The differences in approach not only increase the administrative burden but also may give rise to a single system being deemed to be operating effectively under one standard but not operating effectively in another.

"Secondly, the additional burden applied within the standard for PCAOB-registered firms that do not perform engagements under its remit still being required to design a system of quality control that will never be operated in practice.”

In our experience we have seen many firms not understanding that this is the requirement. In several cases, when discussed with the firm, it leads to serious consideration for the firm in terms of:

1. Implementing a costly SOQM under QC 1000; or

2. Deregistering with the PCAOB.

As pointed out in her letter, Christina Ho details how this is counter to the goal of having a resilient public company audit marketplace.

What is clear from the change of date is that it is not a reason for firms to step away from their implementation of their relevant quality management.

SQMS 1 will come into effect in December 2025 as planned, and as most firms are already operating responses to cover this standard and QC 1000, continuing the implementation of your Risk Assessment under both standards would seem the most prudent approach.

Albeit, while her statement does mention that she hopes this timeline will prompt the PCAOB to consider a more pragmatic, cost-effective and principle based regulatory path, her personal areas of concern mostly focus on the monitoring, remediation and annual evaluation. Therefore, it may be appropriate to assume that the Risk Assessment might be subject to very few changes.

What to do next:

We suggest taking this time as a dry run to refine, improve and embed your system of quality management under all standards.

By treating this period as preparation rather than a pause, firms will be well-positioned to meet the requirements with confidence when QC 1000 takes effect in December 2026.

Early 2026 provides firms with the opportunity to test and prove their readiness - ensuring systems are not only compliant on paper but proven in practice.

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¹ Public Company Accounting Oversight Board, PCAOB postpones effective date of QC 1000 and related standards, rules, and forms, 28 August 2025. Available at: https://pcaobus.org/news-events/news-releases/news-release-detail/pcaob-postpones-effective-date-of-qc-1000-and-related-standards--rules--and-forms (Accessed 5 September 2025).

² Public Company Accounting Oversight Board (Christina Ho), Statement on the QC 1000 Effective Date Extension - Good Blooms When Reason Prevails, 28 August 2025. Available at: https://pcaobus.org/news-events/speeches/speech-detail/statement-on-the-qc-1000-effective-date-extension---good-blooms-when-reason-prevails (Accessed 5 September 2025).