# 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.
| Aspect | SQC 1 | SA 220 |
|---|---|---|
| Coverage | All engagement types | Audit engagements ONLY |
| Applies to | Entire FIRM | A 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
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## 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.