The Public Company Accounting Oversight Board (PCAOB) announced yesterday that the effective date for QC 1000, A Firm’s System of Quality Control, would be delayed until December 15, 2026, though audit firms may elect to comply with the requirements earlier (other than with respect to reporting to the PCAOB as required under QC 1000). The PCAOB cited implementation challenges that, in some cases, may be “insurmountable” absent an extension of the implementation timeline.

QC 1000 will require, upon its effectiveness, all audit firms, regardless of whether they audit public companies, to design quality control systems within the standard’s framework. Audit firms that audit public companies or broker dealers will also need to implement and operate these systems. An evaluation of the quality control system’s effectiveness will need to be reported to the PCAOB annually.

Despite the delay in implementation, the PCAOB made changes to neither the text of QC 1000 nor other rules or standards adopted or amended by the PCAOB, as set out in their May 13, 2024 adopting release for QC 1000. 

In light of the delay, PCAOB Rule 3400T, Interim Quality Control Standards, and several other rules and standards that were set to be rescinded concurrently with QC 1000’s effectiveness will remain in effect until December 15, 2026, when QC 1000 takes effect. Similarly, the effective date for all other standards, rules, and forms adopted or amended by the PCAOB on May 13, 2024, will be postponed until December 15, 2026. 

The PCAOB’s decision will give audit firms much-needed additional time to comply with QC 1000.  Audit Committees should consider engaging with their auditors to understand whether they will be early adopting QC 1000 and whether the delay will have any effects on audits for fiscal 2025.