ISQM 1 – Ten Tips for Smaller Audit Firms

ISQM 1 – Ten Tips for Smaller Audit Firms

The ISQM 1 regime is now fully in place since its initial roll out in 2021. Every Irish audit firm will need an ISQM-compliant System of Quality Management (‘SOQM’).

Many firms have already prepared their ISQM 1 policy statement (called the Statement of Quality Management or SoQM), but have you reviewed yours in accordance with the standard on an annual basis since its initial implementation.

Our ISQM TOOLKIT is the answer to your needs and is available to purchase now for immediate download to help you. Click here for more details.

Regulators are looking for clear evidence of progress with the application of the standard and especially with evidence of root cause analysis (RCA).

Here are our top ten tips to helping you get your SOQM across the finish line:

  1. Read the ISQM. There’s really no way around this!

We’d recommend you also get hold of the IAASM Implementation Guide, which is genuinely helpful – although be warned; this is for the international version of the ISQM and doesn’t include the additional quality responses added to the Irish standard by the Irish Audit & Accounting Supervisory Authority (IAASA).

  1. Assess your current approach to audit quality. Firms have various audit quality policies and procedures already in place. While we want to stress that you shouldn’t simply ‘bolt on’ ISQM to your existing approach, it’s helpful to get a clear insight into what’s happening now (e.g., by taking a look with a critical eye at your existing procedures and matching them to the requirements of our ISQM Toolkit).

This may mean gathering various documents (like staff appraisals, CPD plans and IES 8), clarifying existing arrangements with the rest of the audit team and organising your thoughts.

  1. Find out what your team thinks about your current approach. Chances are, you and your team already have sound insights into what’s working well and what isn’t, and some honest feedback may be painful but is essential to making progress.

John McCarthy Consulting Ltd. (working in conjunction with our colleagues in Apex Professional Consulting Ltd.) has produced the ISQM TOOLKIT for the Republic of Ireland. It comes with a unique team questionnaire that can help you to gather anonymous feedback including suggestions for tackling problem areas.

  1. Start with leadership and governance issues. For most if not all small firms, a critical success factor for ISQM compliance is the degree of support from partners, especially managing partners within firms.

Whether your firm is a sole practitioner or a larger firm, ISQM 1 challenges senior leadership to demonstrate genuine commitment to audit quality, recognising that this may not always align with a firm’s commercial strategy or its leaders’ priorities. You need to identify and deal with those conflicts, if present. You’ll also need to consider how much of the SOQM can be delegated to others and how the firm’s leadership will demonstrate that they bear ultimate responsibility for its success.

5. Don’t dismiss the appointment stage. Many firms assign consideration of (re)appointment to junior audit staff who lack the judgement to assess ethical threats and to apply the right safeguards. Accepting a client relationship or engagement inappropriately removes any chance to achieve a quality audit.

6. Be honest about priorities. Many firms say that they’re committed to audit quality, but a cursory scrutiny about how much of the firm’s time and money is spent in supporting and developing high quality audit may suggest otherwise. ISQM 1 demands that firms allocate enough resource to recruit and develop audit teams, supply them with appropriate tools (including hardware and software) and allow them the time to conduct audits thoroughly. You’ll also need to assess the quality risks of over-relying on external training providers, file reviewers or providers of methodology or IT tools.

7. Refocus on prevention rather than cure. In the past, many audit firms have relied on regular cold file reviews to ensure their quality is up to scratch. Whilst such reviews will still play a key role, firms need to consider how to avoid audit defects altogether. For many audit partners, this may mean reducing the amount of time spent in review, and increasing the time spent in directing and supervising audits whilst in progress. Better prepared and managed teams should produce better audit files that need less review and remediation.

8. Plan your monitoring as you go. As you set out your SOQM, make sure that every element is trackable and assign responsibility for monitoring to specific individuals, with clear instructions about how they should check progress and how they must record this. This should make the ‘monitoring and remediation’ part of the process much less burdensome. Don’t leave it all until the end!

9. Get familiar with Root Cause Analysis (‘RCA’). This is a tool that has increased in profile of late, and while RCA can be sophisticated, it needn’t always be so. The aim is to identify systemic defects that, if corrected, will prevent problems from recurring. Don’t be afraid of asking ‘why did X happen’ multiple times when a quality problem is spotted, until the roots are uncovered.

10. Consider external support. Whilst it’s possible to implement ISQM 1 without any other support, especially if you use a good transition tool you may find that getting the assistance of a specialist can be hugely valuable, even if just as a sounding board.

If you need assistance with implementation, or have any questions please contact John by e-mail john@jmcc.ie.

The ISQM TOOLKIT is available here to purchase now for immediate download.

All the templates on our website have had a refresh as of June 2026 and the letters of engagement have had new paragraphs added for:

  • the potential use of artificial intelligence and machine learning on client assignments;
  • along with auto enrolment for payroll assignments.

There is a bulk discount (five templates for the price of four) for purchases of five or more templates when purchased in a single transaction.

If you need an up-to-date engagement letter, there is a search bar near the bottom of our home page (www.jmcc.ie) to quickly look up the item you need. More details see here.

 

For those of you still in the process of ISQM 1 implementation, please see our ISQM TOOLKIT or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard, please call or e-mail John McCarthy FCA or e-mail him at john@jmcc.ie.

We typically tailor our training and brainstorming sessions to suit each firm’s unique requirements.

Publications:

 

All the templates on our website have had a refresh as of June 2026 and the letters of engagement have had new paragraphs added for:

  • the potential use of artificial intelligence and machine learning on client assignments;
  • along with auto enrolment for payroll assignments.

There is a bulk discount (five templates for the price of four) for purchases of five or more templates when purchased in a single transaction.

If you need an up-to-date engagement letter, there is a search bar near the bottom of our home page (www.jmcc.ie) to quickly look up the item you need. More details see here.

For those of you still in the process of reviewing your ISQM 1 implementation, please see our ISQM TOOLKIT or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard, please call or e-mail John McCarthy FCA or e-mail him at john@jmcc.ie.

We typically tailor our training and brainstorming sessions to suit each firm’s unique requirements.

Publications:

Are Your Engagement Letters Up to Date?

Are Your Engagement Letters Up to Date?

Once upon a time it was possible to have the same client engagement letter in place for several years, without too much upset.

However, the pace of change in the various pieces of overlapping legislation that impact on engagement letters, seems to be getting faster and faster.  Different obligations under criminal law, tax law, company law and anti-money laundering that are now required in the typical contract with your client, mean that there is a never-ending requirement to review your letters and issue revised and updated letters to your clients on an annual basis.

Here is a quick checklist of the legislation you need to include in audit engagement letters:

Topic Legislation
Company law Companies Act 2014
Criminal law

 

·         Section 59 Criminal Justice (Theft and Fraud Offences) Act, 2001 and 2021

·         Criminal Justice Act 2011

Tax law Section 1079 Taxes Consolidation Act, 1997
Anti-Money laundering/terrorist financing Criminal Justice (Money Laundering and Terrorist Financing) Acts, 2010 to 2021
Data Protection Data Protections Acts 1988 to 2018 and the GDPR

 

All the templates on our website have had a refresh as of June 2026 and the letters of engagement have had new paragraphs added for:

  • the potential use of artificial intelligence and machine learning on client assignments;

along with auto enrolment for payroll assignments.

If you need an up-to-date engagement letter, there is a search bar near the bottom of our home page (www.jmcc.ie) to quickly look up the item you need. More details see here.

For those of you still in the process of ISQM 1 implementation, please see our ISQM TOOLKIT or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard, please call or e-mail John McCarthy FCA or e-mail him at john@jmcc.ie.

We typically tailor our training and brainstorming sessions to suit each firm’s unique requirements.

Publications:

Potential Changes to the Audit Exemption

Potential Changes to the Audit Exemption

According to a recent Government press release, a consultation will soon commence on proposals to enhance the Companies Act 2014.

Among the issues to be considered are:

  • Amend the audit exemption regime for small/micro companies, to remove automatic loss of audit exemption and put in place a two-step, graduated procedure to deal with late filing;
  • Provide companies and industrial and provident societies with the option to hold physical/hybrid and virtual meetings including AGMs and general meetings;
  • Make amendments to the regulation of receivers;
  • Extend certain reporting obligations to examiners, interim examiners and process advisors;
  • Enhance certain powers for the Corporate Enforcement Authority, the Irish Auditing and Accounting Supervisory Authority and the Companies Registration Office to help investigate and prosecute alleged breaches of company law.

Please go to our website to see our new ISQM TOOLKIT or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard, please contact John McCarthy FCA by e-mail at john@jmcc.ie.

We typically tailor training and brainstorming sessions to suit your firm’s unique requirements.

Publications and AML webinars:

  • The ISQM TOOLKIT 2022 is available to purchase here.
  • See our latest Anti-Money Laundering Policies Controls & Procedures Manual (March 2022) – View the Table of Contents click here.
  • Also we have an updated AML webinar (March 2022) available here, which accompanies the AML Manual. It explains the current legal AML reporting position for accountancy firms and includes a quiz. Upon completion, you receive a CPD Certificate of attendance in your inbox.
  • To ensure your letters of engagement and similar templates are up to date visit our site here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items if bought together.

 

Anti-Money Laundering Compliance

Anti-Money Laundering Compliance

How is your AML Compliance?

In last week’s blog we wrote about the recent publication of the 2019 Annual Report of the Chartered Accountants Regulatory Board (CARB). The section on Money Laundering inspections will be of interest to readers.

Money Laundering Compliance Review – Every firm is required to perform an annual money laundering compliance review and document it, with findings for follow-up action.  The review should involve a thorough examination of the firm’s AML procedures, including their application on client files, a review of the firm’s AML Policies & Procedures Manual and a review of AML training within the firm.  Firms are also required to have prepared and documented a Firm Wide Business Risk Assessment.

During any subsequent Institute inspection the remedial action, identified in the firm’s review, will be expected to have been completed or substantially progressed.

AML Training – Firms must have procedures to monitor that all personnel involved in client work (not just client facing staff) receive up to date AML training.

Annual Return declarations – Firms must complete their annual returns every year. Often the AML section has errors. The Quality Assurance Committee of the Institute, to which the Professional Standard Department reports, takes incorrect declarations on the Annual Return very seriously and regulatory penalties can result where inaccuracies are identified during an inspection.

Our February 2020 up to date AML Policies & Procedures Manual is available on our site for immediate download in Word format and it contains everything you need to be up to date.

We also have several audit template letters that are up to date for GDPR and Coronavirus (COVID-19) downloadable for immediate tailoring in MS Word.

For a full list of all our webinar recordings, please go to our webinar site here. They may be viewed at any time for 12 months after the date of purchase.

We also have a complete set of letters of representation in our publications store, updated for Coronavirus (COVID-19), and letters of engagement for immediate download here.

 

New Procedures Manual to help with AML

New Procedures Manual to help with AML

We have just published an update to the AML Policies Controls & Procedures Manual last week, which is available to purchase now on our website. Our latest February 2020 edition includes the following updated items:

  1. Pronouncement by the FATF arising from their Public Consultation on FATF Draft Guidance on Digital Identity (discussed at the FATF plenary meeting in Paris from 19-21 February 2020)
  2. The latest developments on the RBO register since June 2019
  3. Further guidance on carrying out electronic searches and the validity of sourcing electronic data for client identity purposes.

This Manual contains everything you need to successfully implement the requirements of the Criminal Justice (Money Laundering and Terrorist Financing) Acts, 2010 to 2018 which became law on 26 November 2018 and the Register of Beneficial Ownership which came into effect on 22 June 2019.

This Manual comes with a, free of charge, Excel spreadsheet called the ‘AML Control Sheet’ which firms may use to give a ‘helicopter’ view of progress made with keeping client AML data up to date.

The Manual includes eleven Appendices with templates/guidance on how to implement the legislation efficiently. It retails for only €150+VAT and may be downloaded, ready to use, in Word format.