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Audit Quality - SQC 1 vs SA 220 and the Six Elements of SQC 1

# Audit Quality: SQC 1 vs SA 220 and the Components of SQC 1

## SQC 1 vs SA 220 — Key Distinction

ParticularsSQC 1SA 220
ScopeAll engagements — audit, reviews, other assurance and related servicesSpecific to audit engagements only
ApplicabilityThe entire firmA particular audit engagement

> Mental model: SQC 1 = firm-level quality system; SA 220 = engagement-level quality application.

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## SQC 1: The Six Elements of Quality Control

### 1. Leadership (Tone at the Top)

  • Firms must establish policies promoting an internal culture recognising quality as essential
  • Ultimate responsibility: CEO or Managing Partners of the firm
  • Leadership sets the example — quality culture flows from the top down
  • Persons assigned operational QC responsibility must have:
  • Sufficient and appropriate experience
  • Ability
  • Necessary authority

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### 2. Ethical Requirements

  • Policies to ensure compliance with the Code of Ethics issued by ICAI
  • Fundamental principles: Integrity, Objectivity, Professional Competence and Due Care, Confidentiality, Professional Behaviour
  • Independence is the basic requirement for all engagements

Firm's obligations under this element:

  • Communicate independence requirements to all personnel
  • Identify and evaluate threats → eliminate, reduce to acceptable level (via safeguards), or withdraw
  • All independence breaches → promptly notified to the firm
  • At least annually: Obtain written confirmation of independence compliance from all relevant personnel

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### 3. Acceptance and Continuance of Client Relationships

Before accepting an engagement, assess three factors:

  • Integrity of the client
  • Competence of the firm (capabilities, time, resources)
  • Compliance with ethical requirements

Integrity assessment factors — Mnemonic: B²A MAAL

LetterFactor
BBusiness reputation of principal owners, key management, related parties, TCWG
BNature of client's operations, including business practices
AAttitude of client's principal owners, key management, TCWG
MInvolvement in money laundering or other criminal activities
AWhether client is aggressive about keeping audit fees as low as possible
AReasons for appointment and non-reappointment of the previous auditor
LIndications of an inappropriate limitation in scope of work

If conflict of interest is discovered:

  • Resolve before accepting the engagement
  • If discovered after acceptance:

(a) Consider professional and legal reporting obligations (to appointing authority or regulators)

(b) Consider withdrawing from the engagement or the entire client relationship

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### 4. Human Resources

Policies must ensure the firm has personnel with:

  • Sufficient capabilities and competence
  • Commitment to ethical principles

HR policies must address:

  • Recruitment | Training | Performance evaluation
  • Compensation | Career development | Professional development

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### 5. Engagement Performance — Mnemonic: PAR²C² (partial)

CodeRequirement
PProperty — engagement documentation belongs to the firm; extracts may be shared with clients only if it doesn't undermine the validity of the work
AAssembly — final engagement files must be assembled within 60 days of the date of the auditor's report
Review — significant judgments must be reviewed by an Engagement Quality Control Reviewer (EQCR) before the report is issued, to ensure an objective view

> The 60-day deadline for file assembly is a high-frequency exam fact.

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### 6. Monitoring

(Addressed in further study material)

Worked example

### Example 1

SQC 1 vs SA 220 — scope question: An audit firm manages 60 audit clients and has just set up a firm-wide quality policy manual. Which standard governs this manual?

SQC 1 — it governs firm-level quality control systems covering all engagements. SA 220 would govern quality on each individual audit engagement.

### Example 2

Engagement documentation — client request: A client asks the audit firm to hand over the entire working paper file for their audit. How should the firm respond?

→ Engagement documentation is the property of the firm. The firm may, at its discretion, share extracts or portions — but only if doing so does not undermine the validity of the work performed.

### Example 3

60-day rule: The auditor signed the audit report on 31 March 2025. By when must the engagement file assembly be complete?

→ Within 60 days — by 29 May 2025.

### Example 4

Integrity check — criminal background: During acceptance evaluation, the firm discovers the prospective client's CFO was previously convicted for financial fraud. Is this relevant under SQC 1?

→ Yes — under B²A MAAL, the integrity of key management (including possible involvement in criminal activities — M) is a mandatory consideration. The firm should carefully evaluate whether to accept the engagement.

### Example 5

Annual independence confirmation: An audit firm of 12 partners has not obtained written independence confirmations from its staff for the current year. Which SQC 1 element is violated?

Ethical Requirements — firms must obtain written confirmation of compliance with independence requirements from all relevant personnel at least annually.

⚠️ Common exam mistakes

  • Confusing SQC 1 (firm-wide) with SA 220 (engagement-specific) — SA 220 is not a firm-wide quality system; it applies to one audit engagement at a time.
  • Forgetting the 60-day deadline for final engagement file assembly — this specific number is frequently tested.
  • Thinking B²A MAAL integrity checks only cover criminal activities — they also include business practices, aggressive fee negotiation, reasons for changing auditors, and scope limitations.
  • Missing that independence confirmations must be WRITTEN and obtained AT LEAST ANNUALLY — not just at engagement acceptance.
  • Confusing 'Leadership' under SQC 1 with TCWG of the client — here, leadership refers to the audit firm's own CEO/managing partners, not the client's governance.
  • Overlooking that the EQCR must review significant judgments BEFORE the report is issued — the review cannot happen after sign-off.
Bare-Act text SQC 1, Paragraph 16 · SQC 1 - Quality Control for Firms that Perform Audits and Reviews of Historical Financial Information, and Other Assurance and Related Services Engagements (ICAI) · click to expand
A firm shall establish a system of quality control designed to provide it with reasonable assurance that the firm and its personnel comply with professional standards and applicable legal and regulatory requirements, and that reports issued by the firm or engagement partners are appropriate in the circumstances.
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