PCAOB Postpones Effective Date of QC 1000 and Related Standards, Rules, and Forms

Washington, DC, Aug. 28, 2025

The Public Company Accounting Oversight Board (PCAOB) announced today that it is postponing for one year, to December 15, 2026, the effective date for QC 1000, A Firm’s System of Quality Control, and other new and amended PCAOB standards, rules, and forms adopted by the Board on May 13, 2024. The Board’s action also postpones the related rescission date of certain rules and standards that are currently in force.

In adopting QC 1000, the Board expressed the view that a 2025 effective date struck an appropriate balance between the benefits to investors of having QC 1000 take effect as soon as practicable and the need to allow sufficient time for registered public accounting firms to design and implement robust QC 1000-compliant quality control systems. Today’s decision by the Board to postpone the effective date takes into account information from various sources that some firms have encountered implementation challenges that, as a practical matter, may be insurmountable within the previously established timeframe. The Board believes that an additional year is sufficient time for firms that have encountered implementation challenges to overcome those challenges.

The Board has not made or proposed any changes to the text of the new and amended standards, rules, or forms from the text adopted by the Board. Nor is there any change to the Board’s previous statement that registered firms are permitted to elect to comply with the requirements of QC 1000 before the effective date (except as to reporting to the PCAOB on the evaluation of the quality control system).

The Board’s May 13, 2024, adopting release and related information, including the Board’s filing with the U.S. Securities and Exchange Commission (SEC) changing the effective date, can be found on the PCAOB’s Rulemaking webpage. 

Standards, Rules, and Forms Affected by the Change to the Effective Date

  • New quality control standard QC 1000, A Firm’s System of Quality Control;
  • New PCAOB Rule 3400, Quality Control Standards;
  • New PCAOB Rule 2203A, Report on the Evaluation of the Firm’s System of Quality Control, and new PCAOB Form QC;
  • Amended and retitled AS 2901, Responding to Engagement Deficiencies After Issuance of the Auditor’s Report (formerly Consideration of Omitted Procedures After the Report Date);
  • New ethics standard EI 1000, Integrity and Objectivity;
  • New AS 1310, Notification of Termination of the Auditor-Issuer Relationship (recodifying SEC Practice Section (“SECPS”) § 1000.08(m) and applying the requirements to all registered public accounting firms and all issuer engagements); and
  • Amendments to AS 1215, Audit Documentation; AS 1220, Engagement Quality Review; AS 2101, Audit Planning; AS 2110, Identifying and Assessing Risks of Material Misstatement; AS 2201, An Audit of Internal Control Over Financial Reporting That Is Integrated with An Audit of Financial Statements; AS 2315, Audit Sampling; AS 4105, Reviews of Interim Financial Information; Attestation Standard No. 1, Examination Engagements Regarding Compliance Reports of Brokers and Dealers; Attestation Standard No. 2, Review Engagements Regarding Exemption Reports of Brokers and Dealers; AT Section 101, Attest Engagements; ET Section 101, Independence; ET Section 191, Ethics Rulings on Independence, Integrity, and Objectivity; PCAOB Rule 2204, Signatures; PCAOB Rule 2205, Amendments; PCAOB Rule 2206, Date of Filing; PCAOB Rule 3500T, Interim Ethics and Independence Standards; Form 1, Application for Registration; Form 2, Annual Report Form; and Instructions to Form AP, Auditor Reporting of Certain Audit Participants. 

The Board’s action delays the effective date of the rescission of (i) PCAOB Rule 3400T, Interim Quality Control Standards; (ii) ET Section 102, Integrity and Objectivity; and (iii) AS 1110, Relationship of Auditing Standards to Quality Control Standards, to December 15, 2026.

Until Rule 3400T is rescinded on December 15, 2026, the following interim quality control standards will remain in effect:

  • QC Section 20, System of Quality Control for a CPA Firm’s Accounting and Auditing Practice;
  • QC Section 30, Monitoring a CPA Firm’s Accounting and Auditing Practice;
  • QC Section 40, The Personnel Management Element of a Firm’s System of Quality Control-Competencies Required by a Practitioner-in-Charge of an Attest Engagement;
  • SECPS § 1000.08(d), Continuing Professional Education of Audit Firm Personnel;
  • SECPS § 1000.08(l), Communication by Written Statement to all Professional Personnel of Firm Policies and Procedures on the Recommendation and Approval of Accounting Principles, Present and Potential Client Relationships, and the Types of Services Provided;
  • SECPS § 1000.08(m), Notification of the Commission of Resignations and Dismissals from Audit Engagements for Commission Registrants;
  • SECPS § 1000.08(n), Audit Firm Obligations with Respect to the Policies and Procedures of Correspondent Firms and of Other Members of International Firms or International Associations of Firms;
  • SECPS § 1000.08(o), Policies and Procedures to Comply with Independence Requirements;
  • SECPS § 1000.38, Appendix D—Revised Definition of an SEC Client;
  • SECPS § 1000.42, Appendix H—Illustrative Statement of Firm Philosophy;
  • SECPS § 1000.43, Appendix I—Standard Form of Letter Confirming the Cessation of the Client-Auditor Relationship;
  • SECPS § 1000.45, Appendix K—SECPS Member Firms With Foreign Associated Firms That Audit SEC Registrants; and
  • SECPS § 1000.46, Appendix L—Independence Quality Controls.

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About the PCAOB

The PCAOB is a nonprofit corporation established by Congress to oversee the audits of public companies in order to protect investors and further the public interest in the preparation of informative, accurate, and independent audit reports. The PCAOB also oversees the audits of brokers and dealers registered with the Securities and Exchange Commission, including compliance reports filed pursuant to federal securities laws.

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