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Microlesson · 5-min read

SQC 1 & SA 220 - Quality Control

# SQC 1 & SA 220 — Quality Control

## The big picture

Quality Control operates at two levels:

  • Firm level (SQC 1) — covers the entire firm and ALL engagements (audit, review, other assurance, related services).
  • Engagement level (SA 220) — covers a particular audit engagement.

> Key premise: SA 220 assumes the firm is already subject to SQC 1. SA 220 sits ON TOP of SQC 1.

AspectSQC 1SA 220
CoverageAll engagement typesAudit engagements ONLY
Applies toEntire FIRMA particular audit engagement

## Objective of QC System (QCS)

Firms must establish a QCS providing reasonable assurance that:

  • The firm complies with Professional, Regulatory & Legal (PRL) requirements.
  • Reports issued are appropriate in the circumstances.

## The Six Elements (firm) vs Six Responsibilities (EP)

Use the same six headings — read 'firm' for SQC 1 and 'Engagement Partner' for SA 220:

1. Leadership responsibility for quality

2. Ethical requirements (incl. independence)

3. Acceptance & continuance of client relationships and engagements

4. Human Resources (SQC 1) / Assignment of Engagement Teams (SA 220)

5. Engagement performance

6. Monitoring

---

## 1. Leadership Responsibilities for Quality on Audits

The Engagement Partner (EP) is personally responsible for overall quality on each audit. EP's actions must emphasise:

  • Quality is essential.
  • Compliance with PRL requirements.
  • Compliance with the firm's QCS policies & procedures.
  • The team's ability to raise concerns without fear of reprisals (punishment).
  • Issuing audit reports appropriate in the circumstances.

## 2. Ethical Requirements — Independence is the core

The firm/EP must:

  • Communicate independence requirements to personnel.
  • Identify & evaluate threats to independence.
  • Evaluate breaches and take action — apply safeguards or withdraw.
  • Ensure breaches are promptly notified to the firm.
  • Obtain a written confirmation of compliance with independence policies from all firm personnel at least annually.

## 3. Acceptance & Continuance of Client Relationships

Before accepting, gather info on:

  • Integrity of the client.
  • Competence (capabilities, time, resources).
  • Compliance with ethical requirements.
  • Significant matters from current/previous engagements.

If issues arise but the firm still accepts — document how issues were resolved.

### Matters re: integrity of client

  • Reasons for proposed appointment / non-reappointment of previous firm.
  • Nature of client's operations.
  • Identity & business reputation of principal owners, key mgt, TCWG.
  • Attitude of those parties towards control environment and accounting standards.
  • Indications of inappropriate scope limitation.
  • Aggressive fee minimisation by client.
  • Indications of money laundering / criminal activity.

### When info points to DECLINING

  • Consider PRL responsibilities — whether to report to appointing person / regulator.
  • Consider possibility of withdrawing.

## 4. Human Resources

Sufficient personnel with capabilities, competence and commitment to ethical requirements.

## 5. Engagement Performance

### Consultation

Consultation takes place on difficult or contentious (controversial) matters — within or outside the firm.

### Engagement Quality Control Review (EQCR)

  • Reviews significant judgments in the engagement.
  • Does NOT reduce the EP's responsibilities.
  • Mandatory for audits of listed entities. For others, the firm should form its own criteria.

EP's duties re: EQCR:

  • Determine that an EQCR has been appointed.
  • Discuss significant matters with the EQCR.
  • Do not date the audit report until the EQCR is complete.

### Difference of Opinion

  • May arise within the team, with consultants, or between the EP and EQCR.
  • The audit report can only be issued after the difference is resolved.
  • If EQCR's recommendations are not accepted and the matter is not resolved to the reviewer's satisfaction — escalate via firm's procedures (another practitioner, professional/regulatory body).

### Engagement Documentation

Maintain confidentiality, safe custody, integrity, accessibility and retrievability (mnemonic: C-SIAR).

## 6. Monitoring

Ensure QCS policies are relevant, adequate, operating effectively and complied with.

## EP Documentation Requirements

EP must document:

  • Issues identified about compliance with ethical requirements & how resolved.
  • Conclusions on compliance with independence requirements.
  • Conclusions on acceptance & continuance.
  • Nature & scope of consultations during the audit.

Worked example

### Example 1

Example 1 — EQCR for listed entity: XYZ Ltd is a listed entity. The EP wants to issue the audit report on 30 May. The EQCR is still finalising the review of significant judgments on revenue recognition. The EP must NOT date the report until EQCR is complete — SA 220 expressly prohibits this.

### Example 2

Example 2 — Difference of opinion: During audit of a listed company, the EP believes a particular legal claim need not be disclosed as a contingent liability, but the EQCR disagrees. The audit report cannot be issued until the difference is resolved. If unresolved, the firm escalates through its established procedure — e.g., consulting another practitioner or the ICAI.

### Example 3

Example 3 — Annual independence confirmation: A firm with 50 partners and 200 audit staff must obtain a written confirmation of compliance with independence policies from EVERY person AT LEAST ANNUALLY. Verbal confirmation is not sufficient.

### Example 4

Example 4 — Client acceptance: Before accepting audit of ABC Ltd, the partner discovers that the previous auditor resigned after raising concerns about possible round-tripping transactions. This is an integrity red flag — the firm should investigate, and if it still accepts, must DOCUMENT how the issues were resolved.

⚠️ Common exam mistakes

  • Confusing the scope: SQC 1 applies to the entire firm and all engagement types; SA 220 applies only to a particular audit engagement.
  • Believing EQCR reduces the Engagement Partner's responsibilities — it does NOT.
  • Forgetting that the audit report cannot be DATED before EQCR is complete (for engagements where EQCR applies).
  • Treating EQCR as mandatory for all audits — it is mandatory only for LISTED entities; for others the firm decides the criteria.
  • Saying independence confirmations are obtained 'on appointment' only — they must be obtained AT LEAST ANNUALLY.
  • Issuing an audit report despite an unresolved difference of opinion between EP and EQCR — not permitted.
Reference: — SQC 1 (ICAI) & SA 220 - Quality Control for an Audit of Financial Statements (ICAI)
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