PSQC 1

Auditing Standards and Practices Council

Philippine Standard on Quality Control 1

QUALITY CONTROL FOR FIRMS THAT

PERFORM AUDITS AND REVIEWS OF
HISTORICAL FINANCIAL INFORMATION,
AND OTHER ASSURANCE AND RELATED
SERVICES ENGAGEMENTS
Conforming Amendments

Glossary of Terms

PSA 620, Using the Work of an Expert

PAPS 1012, Auditing Derivative Financial Instruments

 PSQC 1

PHILIPPINE STANDARD ON QUALITY CONTROL 1

QUALITY CONTROL FOR FIRMS THAT PERFORM AUDITS AND

REVIEWS OF HISTORICAL FINANCIAL INFORMATION, AND
OTHER ASSURANCE AND RELATED SERVICES ENGAGEMENTS

(Effective as of June 15, 2006)∗

CONTENTS

Paragraphs

Introduction ...................................................................................................... 1-5

Definitions ........................................................................................................ 6

Elements of a System of Quality Control ........................................................ 7-8

Leadership Responsibilities for Quality Within the Firm ................................ 9-13

Ethical Requirements ....................................................................................... 14-27

Acceptance and Continuance of Client Relationships and Specific

Engagements .............................................................................................. 28-35

Human Resources ............................................................................................ 36-45

Engagement Performance ................................................................................ 46-73

Monitoring ........................................................................................................ 74-93

Documentation .................................................................................................. 94-97

Effective Date .................................................................................................... 98

Acknowledgment …………………………………………………………….. 99-100

∗
This PSQC and PSA 220 (Revised), “Quality Control for Audits of Historical Financial Information,”
gave rise to amendments to the Glossary of Terms, PSA 620, “Using the Work of an Expert,” and PAPS
1012, “Auditing Derivative Financial Information.” These amendments are attached to this PSQC.
 -2- PSQC 1

Philippine Standard on Quality Control (PSQC) 1, “Quality Control for Firms that
Perform Audits and Reviews of Historical Financial Information, and Other Assurance
and Related Services Engagements” should be read in the context of the “Preface to the
Philippine Standards on Quality Control, Auditing, Other Assurance and Related
Services,” which sets out the application and authority of PSQCs.
 -3- PSQC 1

Quality Control for Firms that Perform Audits and Reviews

of Historical Financial Information, and Other Assurance
and Related Services Engagements

Introduction

1. The purpose of this Philippine Standard on Quality Control (PSQC) is to establish

basic principles and essential procedures and to provide guidance regarding a
firm’s responsibilities for its system of quality control for audits and reviews of
historical financial information, and for other assurance and related services
engagements. This PSQC is to be read in conjunction with Parts A and B of the
Code of Ethics for Professional Accountants in the Philippines (the Philippine
Code).

2. Additional standards and guidance on the responsibilities of firm personnel

regarding quality control procedures for specific types of engagements are set out
in other pronouncements of the Auditing Standards and Practices Council
(ASPC). PSA 220 (Revised), “Quality Control for Audits of Historical Financial
Information,” for example, establishes standards and provides guidance on quality
control procedures for audits of historical financial information.

3. The firm should establish a system of quality control designed to provide it

with reasonable assurance that the firm and its personnel comply with
professional standards and regulatory and legal requirements, and that
reports issued by the firm or engagement partners are appropriate in the
circumstances.

4. A system of quality control consists of policies designed to achieve the objectives

set out in paragraph 3 and the procedures necessary to implement and monitor
compliance with those policies.

5. This PSQC applies to all firms. The nature of the policies and procedures
developed by individual firms to comply with this PSQC will depend on various
factors such as the size and operating characteristics of the firm, and whether it is
part of a network.
 -4- PSQC 1

Definitions

6. In this PSQC, the following terms have the meanings attributed below:

(a) “Engagement partner” – the partner or other person in the firm who is
responsible for the engagement and its performance, and for the report that
is issued on behalf of the firm, and who, where required, has the
appropriate authority from a professional, legal or regulatory body;

(b) “Engagement quality control review” – a process designed to provide an

objective evaluation, before the report is issued, of the significant
judgments the engagement team made and the conclusions they reached in
formulating the report;

(c) “Engagement quality control reviewer” – a partner, other person in the

firm, suitably qualified external person, or a team made up of such
individuals, with sufficient and appropriate experience and authority to
objectively evaluate, before the report is issued, the significant judgments
the engagement team made and the conclusions they reached in
formulating the report;

(d) “Engagement team” – all personnel performing an engagement, including

any experts contracted by the firm in connection with that engagement;

(e) “Firm” – a sole practitioner or partnership or other entity of professional

accountants;

(f) “Inspection” – in relation to completed engagements, procedures designed

to provide evidence of compliance by engagement teams with the firm’s
quality control policies and procedures;

(g) “Listed entity”∗. – an entity whose shares, stock or debt are quoted or
listed on a recognized stock exchange, or are marketed under the
regulations of a recognized stock exchange or other equivalent body;

(h) “Monitoring” – a process comprising an ongoing consideration and

evaluation of the firm’s system of quality control, including a periodic
inspection of a selection of completed engagements, designed to enable the
firm to obtain reasonable assurance that its system of quality control is
operating effectively;

∗
As defined in the Philippine Code published in January 2004.
 -5- PSQC 1

(i) “Network firm” *. – an entity under common control, ownership or

management with the firm or any entity that a reasonable and informed
third party having knowledge of all relevant information would reasonably
conclude as being part of the firm nationally or internationally;

(j) “Partner” – any individual with authority to bind the firm with respect to
the performance of a professional services engagement;

(k) “Personnel” – partners and staff;

(l) “Professional standards” – ASPC Engagement Standards, as defined in the

ASPC’s “Preface to the Philippine Standards on Quality Control,
Auditing, Assurance and Related Services,” and relevant ethical
requirements, which ordinarily comprise Parts A and B of the Philippine
Code;

(m) “Reasonable assurance” – in the context of this PSQC, a high, but not
absolute, level of assurance;

(n) “Staff” – professionals, other than partners, including any experts the firm
employs; and

(o) “Suitably qualified external person” – an individual outside the firm with
the capabilities and competence to act as an engagement partner, for
example a partner of another firm, or an employee (with appropriate
experience) of either a professional accountancy body whose members
may perform audits and reviews of historical financial information, or
other assurance or related services engagements, or of an organization that
provides relevant quality control services.

Elements of a System of Quality Control

7. The firm’s system of quality control should include policies and procedures
addressing each of the following elements:

(a) Leadership responsibilities for quality within the firm.

(b) Ethical requirements.

(c) Acceptance and continuance of client relationships and specific

engagements.

(d) Human resources.

 -6- PSQC 1

(e) Engagement performance.

(f) Monitoring.

8. The quality control policies and procedures should be documented and

communicated to the firm’s personnel. Such communication describes the
quality control policies and procedures and the objectives they are designed to
achieve, and includes the message that each individual has a personal
responsibility for quality and is expected to comply with these policies and
procedures. In addition, the firm recognizes the importance of obtaining feedback
on its quality control system from its personnel. Therefore, the firm encourages
its personnel to communicate their views or concerns on quality control matters.

Leadership Responsibilities for Quality Within the Firm

9. The firm should establish policies and procedures designed to promote an

internal culture based on the recognition that quality is essential in
performing engagements. Such policies and procedures should require the
firm’s chief executive officer (or equivalent) or, if appropriate, the firm’s
managing board of partners (or equivalent), to assume ultimate
responsibility for the firm’s system of quality control.

10. The firm’s leadership and the examples it sets significantly influence the internal
culture of the firm. The promotion of a quality-oriented internal culture depends
on clear, consistent and frequent actions and messages from all levels of the firm’s
management emphasizing the firm’s quality control policies and procedures, and
the requirement to:

(a) Perform work that complies with professional standards and regulatory
and legal requirements; and

(b) Issue reports that are appropriate in the circumstances.

Such actions and messages encourage a culture that recognizes and rewards high
quality work. They may be communicated by training seminars, meetings, formal
or informal dialogue, mission statements, newsletters, or briefing memoranda.
They are incorporated in the firm’s internal documentation and training materials,
and in partner and staff appraisal procedures such that they will support and
reinforce the firm’s view on the importance of quality and how, practically, it is to
be achieved.
 -7- PSQC 1

11. Of particular importance is the need for the firm’s leadership to recognize that the
firm’s business strategy is subject to the overriding requirement for the firm to
achieve quality in all the engagements that the firm performs. Accordingly:

(a) The firm assigns its management responsibilities so that commercial

considerations do not override the quality of work performed;

(b) The firm’s policies and procedures addressing performance evaluation,

compensation, and promotion (including incentive systems) with regard to
its personnel, are designed to demonstrate the firm’s overriding
commitment to quality; and

(c) The firm devotes sufficient resources for the development, documentation
and support of its quality control policies and procedures.

12. Any person or persons assigned operational responsibility for the firm’s
quality control system by the firm’s chief executive officer or managing
board of partners should have sufficient and appropriate experience and
ability, and the necessary authority, to assume that responsibility.

13. Sufficient and appropriate experience and ability enables the responsible person or
persons to identify and understand quality control issues and to develop
appropriate policies and procedures. Necessary authority enables the person or
persons to implement those policies and procedures.

Ethical Requirements

14. The firm should establish policies and procedures designed to provide it with
reasonable assurance that the firm and its personnel comply with relevant
ethical requirements.

15. Ethical requirements relating to audits and reviews of historical financial

information, and other assurance and related services engagements ordinarily
comprise Parts A and B of the Philippine Code. The Philippine Code establishes
the fundamental principles of professional ethics, which include:

(a) Integrity;

(b) Objectivity;

(c) Professional competence and due care;

 -8- PSQC 1

(d) Confidentiality; and

(e) Professional behavior.

16. Part B of the Philippine Code includes a conceptual approach to independence for
assurance engagements that takes into account threats to independence, accepted
safeguards and the public interest.

17. The firm’s policies and procedures emphasize the fundamental principles, which
are reinforced in particular by (a) the leadership of the firm, (b) education and
training, (c) monitoring and (d) a process for dealing with non-compliance.
Independence for assurance engagements is so significant that it is addressed
separately in paragraphs 18-27 below. These paragraphs need to be read in
conjunction with the Philippine Code.

Independence

18. The firm should establish policies and procedures designed to provide it with
reasonable assurance that the firm, its personnel and, where applicable,
others subject to independence requirements (including experts contracted
by the firm and network firm personnel), maintain independence where
required by the Philippine Code. Such policies and procedures should
enable the firm to:

(a) Communicate its independence requirements to its personnel and,

where applicable, others subject to them; and

(b) Identify and evaluate circumstances and relationships that create

threats to independence, and to take appropriate action to eliminate
those threats or reduce them to an acceptable level by applying
safeguards, or, if considered appropriate, to withdraw from the
engagement.

19. Such policies and procedures should require:

(a) Engagement partners to provide the firm with relevant information

about client engagements, including the scope of services, to enable
the firm to evaluate the overall impact, if any, on independence
requirements;

(b) Personnel to promptly notify the firm of circumstances and

relationships that create a threat to independence so that appropriate
action can be taken; and
 -9- PSQC 1

(c) The accumulation and communication of relevant information to

appropriate personnel so that:

(i) The firm and its personnel can readily determine whether they
satisfy independence requirements;

(ii) The firm can maintain and update its records relating to
independence; and

(iii) The firm can take appropriate action regarding identified

threats to independence.

20. The firm should establish policies and procedures designed to provide it with
reasonable assurance that it is notified of breaches of independence
requirements, and to enable it to take appropriate actions to resolve such
situations. The policies and procedures should include requirements for:

(a) All who are subject to independence requirements to promptly notify

the firm of independence breaches of which they become aware;

(b) The firm to promptly communicate identified breaches of these

policies and procedures to:

(i) The engagement partner who, with the firm, needs to address
the breach; and

(ii) Other relevant personnel in the firm and those subject to the
independence requirements who need to take appropriate
action; and

(c) Prompt communication to the firm, if necessary, by the engagement

partner and the other individuals referred to in subparagraph (b)(ii)
of the actions taken to resolve the matter, so that the firm can
determine whether it should take further action.

21. Comprehensive guidance on threats to independence and safeguards, including

application to specific situations, is set out in Section 8 of the Philippine Code.
 - 10 - PSQC 1

22. A firm receiving notice of a breach of independence policies and procedures

promptly communicates relevant information to engagement partners, others in
the firm as appropriate and, where applicable, experts contracted by the firm and
network firm personnel, for appropriate action. Appropriate action by the firm
and the relevant engagement partner includes applying appropriate safeguards to
eliminate the threats to independence or to reduce them to an acceptable level, or
withdrawing from the engagement. In addition, the firm provides independence
education to personnel who are required to be independent.

23. At least annually, the firm should obtain written confirmation of compliance
with its policies and procedures on independence from all firm personnel
required to be independent by the Philippine Code.

24. Written confirmation may be in paper or electronic form. By obtaining

confirmation and taking appropriate action on information indicating
noncompliance, the firm demonstrates the importance that it attaches to
independence and makes the issue current for, and visible to, its personnel.

25. The Philippine Code discusses the familiarity threat that may be created by using
the same senior personnel on an assurance engagement over a long period of time
and the safeguards that might be appropriate to address such a threat.
Accordingly, the firm should establish policies and procedures:

(a) Setting out criteria for determining the need for safeguards to reduce
the familiarity threat to an acceptable level when using the same
senior personnel on an assurance engagement over a long period of
time; and

(b) For all audits of financial statements of listed entities, requiring the
rotation of the engagement partner after a specified period in
compliance with the Philippine Code.

26. Using the same senior personnel on assurance engagements over a prolonged
period may create a familiarity threat or otherwise impair the quality of
performance of the engagement. Therefore, the firm establishes criteria for
determining the need for safeguards to address this threat. In determining
appropriate criteria, the firm considers such matters as (a) the nature of the
engagement, including the extent to which it involves a matter of public interest,
and (b) the length of service of the senior personnel on the engagement.
Examples of safeguards include rotating the senior personnel or requiring an
engagement quality control review.
 - 11 - PSQC 1

27. The Philippine Code recognizes that the familiarity threat is particularly relevant
in the context of financial statement audits of listed entities. For these audits, the
Philippine Code requires the rotation of the engagement partner after a pre-
defined period, normally no more than five years1, and provides related standards
and guidance.

Acceptance and Continuance of Client Relationships and Specific

Engagements

28. The firm should establish policies and procedures for the acceptance and
continuance of client relationships and specific engagements, designed to
provide it with reasonable assurance that it will only undertake or continue
relationships and engagements where it:

(a) Has considered the integrity of the client and does not have
information that would lead it to conclude that the client lacks
integrity;

(b) Is competent to perform the engagement and has the capabilities, time
and resources to do so; and

(c) Can comply with ethical requirements.

The firm should obtain such information as it considers necessary in the

circumstances before accepting an engagement with a new client, when
deciding whether to continue an existing engagement, and when considering
acceptance of a new engagement with an existing client. Where issues have
been identified, and the firm decides to accept or continue the client
relationship or a specific engagement, it should document how the issues
were resolved.

29. With regard to the integrity of a client, matters that the firm considers include, for
example:

• The identity and business reputation of the client’s principal owners, key
management, related parties and those charged with its governance.

• The nature of the client’s operations, including its business practices.

1
The Philippine Code indicates five years for rotation of auditors, which is consistent with SEC Circular
Memorandum No. 2, Series of 2002, “Code of Corporate Governance.” ISQC 1, the basis for PSQC 1,
provides seven years for rotation of auditors.
 - 12 - PSQC 1

• Information concerning the attitude of the client’s principal owners, key

management and those charged with its governance towards such matters
as aggressive interpretation of accounting standards and the internal
control environment.

• Whether the client is aggressively concerned with maintaining the firm’s

fees as low as possible.

• Indications of an inappropriate limitation in the scope of work.

• Indications that the client might be involved in money laundering or other

criminal activities.

• The reasons for the proposed appointment of the firm and non-
reappointment of the previous firm.

The extent of knowledge a firm will have regarding the integrity of a client will
generally grow within the context of an ongoing relationship with that client.

30. Information on such matters that the firm obtains may come from, for example:

• Communications with existing or previous providers of professional

accountancy services to the client in accordance with the Philippine Code,
and discussions with other third parties.

• Inquiry of other firm personnel or third parties such as bankers, legal

counsel and industry peers.

• Background searches of relevant databases.

31. In considering whether the firm has the capabilities, competence, time and
resources to undertake a new engagement from a new or an existing client, the
firm reviews the specific requirements of the engagement and existing partner and
staff profiles at all relevant levels. Matters the firm considers include whether:

• Firm personnel have knowledge of relevant industries or subject matters;

• Firm personnel have experience with relevant regulatory or reporting

requirements, or the ability to gain the necessary skills and knowledge
effectively;

• The firm has sufficient personnel with the necessary capabilities and
competence;
 - 13 - PSQC 1

• Experts are available, if needed;

• Individuals meeting the criteria and eligibility requirements to perform

engagement quality control review are available, where applicable; and

• The firm is able to complete the engagement within the reporting deadline.

32. The firm also considers whether accepting an engagement from a new or an
existing client may give rise to an actual or perceived conflict of interest. Where a
potential conflict is identified, the firm considers whether it is appropriate to
accept the engagement.

33. Deciding whether to continue a client relationship includes consideration of

significant matters that have arisen during the current or previous engagements,
and their implications for continuing the relationship. For example, a client may
have started to expand its business operations into an area where the firm does not
possess the necessary knowledge or expertise.

34. Where the firm obtains information that would have caused it to decline an
engagement if that information had been available earlier, policies and
procedures on the continuance of the engagement and the client relationship
should include consideration of:

(a) The professional and legal responsibilities that apply to the

circumstances, including whether there is a requirement for the firm
to report to the person or persons who made the appointment or, in
some cases, to regulatory authorities; and

(b) The possibility of withdrawing from the engagement or from both the
engagement and the client relationship.

35. Policies and procedures on withdrawal from an engagement or from both the
engagement and the client relationship address issues that include the following:

• Discussing with the appropriate level of the client’s management and those
charged with its governance regarding the appropriate action that the firm
might take based on the relevant facts and circumstances.

• If the firm determines that it is appropriate to withdraw, discussing with

the appropriate level of the client’s management and those charged with its
governance withdrawal from the engagement or from both the engagement
and the client relationship, and the reasons for the withdrawal.
 - 14 - PSQC 1

• Considering whether there is a professional, regulatory or legal

requirement for the firm to remain in place, or for the firm to report the
withdrawal from the engagement, or from both the engagement and the
client relationship, together with the reasons for the withdrawal, to
regulatory authorities.

• Documenting significant issues, consultations, conclusions and the basis

for the conclusions.

Human Resources

36. The firm should establish policies and procedures designed to provide it with
reasonable assurance that it has sufficient personnel with the capabilities,
competence, and commitment to ethical principles necessary to perform its
engagements in accordance with professional standards and regulatory and
legal requirements, and to enable the firm or engagement partners to issue
reports that are appropriate in the circumstances.

37. Such policies and procedures address the following personnel issues:

• Recruitment;

• Performance evaluation;

• Capabilities;

• Competence;

• Career development;

• Promotion;

• Compensation; and

• The estimation of personnel needs.

Addressing these issues enables the firm to ascertain the number and
characteristics of the individuals required for the firm’s engagements. The firm’s
recruitment processes include procedures that help the firm select individuals of
integrity with the capacity to develop the capabilities and competence necessary to
perform the firm’s work.
 - 15 - PSQC 1

38. Capabilities and competence are developed through a variety of methods,

including the following:

• Professional education.

• Continuing professional development, including training.

• Work experience.

• Coaching by more experienced staff, for example, other members of the

engagement team.

39. The continuing competence of the firm’s personnel depends to a significant extent
on an appropriate level of continuing professional development so that personnel
maintain their knowledge and capabilities. The firm therefore emphasizes in its
policies and procedures the need for continuing training for all levels of firm
personnel, and provides the necessary training resources and assistance to enable
personnel to develop and maintain the required capabilities and competence.
Where internal technical and training resources are unavailable, or for any other
reason, the firm may use a suitably qualified external person for that purpose.

40. The firm’s performance evaluation, compensation and promotion procedures give
due recognition and reward to the development and maintenance of competence
and commitment to ethical principles. In particular, the firm:

(a) Makes personnel aware of the firm’s expectations regarding performance

and ethical principles;

(b) Provides personnel with evaluation of, and counseling on, performance,
progress and career development; and

(c) Helps personnel understand that advancement to positions of greater

responsibility depends, among other things, upon performance quality and
adherence to ethical principles, and that failure to comply with the firm’s
policies and procedures may result in disciplinary action.

41. The size and circumstances of the firm will influence the structure of the firm’s
performance evaluation process. Smaller firms, in particular, may employ less
formal methods of evaluating the performance of their personnel.
 - 16 - PSQC 1

Assignment of Engagement Teams

42. The firm should assign responsibility for each engagement to an engagement
partner. The firm should establish policies and procedures requiring that:

(a) The identity and role of the engagement partner are communicated to
key members of client management and those charged with
governance;

(b) The engagement partner has the appropriate capabilities, competence,

authority and time to perform the role; and

(c) The responsibilities of the engagement partner are clearly defined and
communicated to that partner.

43. Policies and procedures include systems to monitor the workload and availability
of engagement partners so as to enable these individuals to have sufficient time to
adequately discharge their responsibilities.

44. The firm should also assign appropriate staff with the necessary capabilities,
competence and time to perform engagements in accordance with
professional standards and regulatory and legal requirements, and to enable
the firm or engagement partners to issue reports that are appropriate in the
circumstances.

45. The firm establishes procedures to assess its staff’s capabilities and competence.
The capabilities and competence considered when assigning engagement teams,
and in determining the level of supervision required, include the following:

• An understanding of, and practical experience with, engagements of a

similar nature and complexity through appropriate training and
participation.

• An understanding of professional standards and regulatory and legal

requirements.

• Appropriate technical knowledge, including knowledge of relevant

information technology.

• Knowledge of relevant industries in which the clients operate.

• Ability to apply professional judgment.

 - 17 - PSQC 1

• An understanding of the firm’s quality control policies and procedures.

Engagement Performance

46. The firm should establish policies and procedures designed to provide it with
reasonable assurance that engagements are performed in accordance with
professional standards and regulatory and legal requirements, and that the
firm or the engagement partner issue reports that are appropriate in the
circumstances.

47. Through its policies and procedures, the firm seeks to establish consistency in the
quality of engagement performance. This is often accomplished through written
or electronic manuals, software tools or other forms of standardized
documentation, and industry or subject matter-specific guidance materials.
Matters addressed include the following:

• How engagement teams are briefed on the engagement to obtain an

understanding of the objectives of their work.

• Processes for complying with applicable engagement standards.

• Processes of engagement supervision, staff training and coaching.

• Methods of reviewing the work performed, the significant judgments made

and the form of report being issued.

• Appropriate documentation of the work performed and of the timing and

extent of the review.

• Processes to keep all policies and procedures current.

48. It is important that all members of the engagement team understand the objectives
of the work they are to perform. Appropriate team-working and training are
necessary to assist less experienced members of the engagement team to clearly
understand the objectives of the assigned work.

49. Supervision includes the following:

• Tracking the progress of the engagement.

 - 18 - PSQC 1

• Considering the capabilities and competence of individual members of the

engagement team, whether they have sufficient time to carry out their
work, whether they understand their instructions and whether the work is
being carried out in accordance with the planned approach to the
engagement.

• Addressing significant issues arising during the engagement, considering

their significance and modifying the planned approach appropriately.

• Identifying matters for consultation or consideration by more experienced

engagement team members during the engagement.

50. Review responsibilities are determined on the basis that more experienced
engagement team members, including the engagement partner, review work
performed by less experienced team members. Reviewers consider whether:

(a) The work has been performed in accordance with professional standards
and regulatory and legal requirements;

(b) Significant matters have been raised for further consideration;

(c) Appropriate consultations have taken place and the resulting conclusions
have been documented and implemented;

(d) There is a need to revise the nature, timing and extent of work performed;

(e) The work performed supports the conclusions reached and is appropriately
documented;

(f) The evidence obtained is sufficient and appropriate to support the report;
and

(g) The objectives of the engagement procedures have been achieved.

Consultation

51. The firm should establish policies and procedures designed to provide it with
reasonable assurance that:

(a) Appropriate consultation takes place on difficult or contentious

matters;
 - 19 - PSQC 1

(b) Sufficient resources are available to enable appropriate consultation

to take place;

(c) The nature and scope of such consultations are documented; and

(d) Conclusions resulting from consultations are documented and

implemented.

52. Consultation includes discussion, at the appropriate professional level, with

individuals within or outside the firm who have specialized expertise, to resolve a
difficult or contentious matter.

53. Consultation uses appropriate research resources as well as the collective

experience and technical expertise of the firm. Consultation helps to promote
quality and improves the application of professional judgment. The firm seeks to
establish a culture in which consultation is recognized as a strength and
encourages personnel to consult on difficult or contentious matters.

54. Effective consultation with other professionals requires that those consulted be
given all the relevant facts that will enable them to provide informed advice on
technical, ethical or other matters. Consultation procedures require consultation
with those having appropriate knowledge, seniority and experience within the firm
(or, where applicable, outside the firm) on significant technical, ethical and other
matters, and appropriate documentation and implementation of conclusions
resulting from consultations.

55. A firm needing to consult externally, for example, a firm without appropriate
internal resources, may take advantage of advisory services provided by (a) other
firms, (b) professional and regulatory bodies, or (c) commercial organizations that
provide relevant quality control services. Before contracting for such services, the
firm considers whether the external provider is suitably qualified for that purpose.

56. The documentation of consultations with other professionals that involve difficult
or contentious matters is agreed by both the individual seeking consultation and
the individual consulted. The documentation is sufficiently complete and detailed
to enable an understanding of:

(a) The issue on which consultation was sought; and

(b) The results of the consultation, including any decisions taken, the basis for
those decisions and how they were implemented.
 - 20 - PSQC 1

Differences of Opinion

57. The firm should establish policies and procedures for dealing with and
resolving differences of opinion within the engagement team, with those
consulted and, where applicable, between the engagement partner and the
engagement quality control reviewer. Conclusions reached should be
documented and implemented.

58. Such procedures encourage identification of differences of opinion at an early

stage, provide clear guidelines as to the successive steps to be taken thereafter,
and require documentation regarding the resolution of the differences and the
implementation of the conclusions reached. The report should not be issued
until the matter is resolved.

59. A firm using a suitably qualified external person to conduct an engagement

quality control review recognizes that differences of opinion can occur and
establishes procedures to resolve such differences, for example, by consulting
with another practitioner or firm, or a professional or regulatory body.

Engagement Quality Control Review

60. The firm should establish policies and procedures requiring, for appropriate
engagements, an engagement quality control review that provides an
objective evaluation of the significant judgments made by the engagement
team and the conclusions reached in formulating the report. Such policies
and procedures should:

(a) Require an engagement quality control review for all audits of

financial statements of listed entities;

(b) Set out criteria against which all other audits and reviews of historical
financial information, and other assurance and related services
engagements should be evaluated to determine whether an
engagement quality control review should be performed; and

(c) Require an engagement quality control review for all engagements

meeting the criteria established in compliance with subparagraph (b).

61. The firm’s policies and procedures should require the completion of the
engagement quality control review before the report is issued.
 - 21 - PSQC 1

62. Criteria that a firm considers when determining which engagements other than
audits of financial statements of listed entities are to be subject to an engagement
quality control review include the following:

• The nature of the engagement, including the extent to which it involves a

matter of public interest.

• The identification of unusual circumstances or risks in an engagement or

class of engagements.

• Whether laws or regulations require an engagement quality control review.

63. The firm should establish policies and procedures setting out:

(a) The nature, timing and extent of an engagement quality control

review;

(b) Criteria for the eligibility of engagement quality control reviewers;

and

(c) Documentation requirements for an engagement quality control

review.

Nature, Timing and Extent of the Engagement Quality Control Review

64. An engagement quality control review ordinarily involves discussion with the
engagement partner, a review of the financial statements or other subject matter
information and the report, and, in particular, consideration of whether the report
is appropriate. It also involves a review of selected working papers relating to the
significant judgments the engagement team made and the conclusions they
reached. The extent of the review depends on the complexity of the engagement
and the risk that the report might not be appropriate in the circumstances. The
review does not reduce the responsibilities of the engagement partner.

65. An engagement quality control review for audits of financial statements of listed
entities includes considering the following:

• The engagement team’s evaluation of the firm’s independence in relation

to the specific engagement.

• Significant risks identified during the engagement and the responses to

those risks.
 - 22 - PSQC 1

• Judgments made, particularly with respect to materiality and significant

risks.

• Whether appropriate consultation has taken place on matters involving

differences of opinion or other difficult or contentious matters, and the
conclusions arising from those consultations.

• The significance and disposition of corrected and uncorrected

misstatements identified during the engagement.

• The matters to be communicated to management and those charged with

governance and, where applicable, other parties such as regulatory bodies.

• Whether working papers selected for review reflect the work performed in
relation to the significant judgments and support the conclusions reached.

• The appropriateness of the report to be issued.

Engagement quality control reviews for engagements other than audits of financial
statements of listed entities may, depending on the circumstances, include some or
all of these considerations.

66. The engagement quality control reviewer conducts the review in a timely manner
at appropriate stages during the engagement so that significant matters may be
promptly resolved to the reviewer’s satisfaction before the report is issued.

67. Where the engagement quality control reviewer makes recommendations that the
engagement partner does not accept and the matter is not resolved to the
reviewer’s satisfaction, the report is not issued until the matter is resolved by
following the firm’s procedures for dealing with differences of opinion.

Criteria for the Eligibility of Engagement Quality Control Reviewers

68. The firm’s policies and procedures should address the appointment of
engagement quality control reviewers and establish their eligibility through:

(a) The technical qualifications required to perform the role, including

the necessary experience and authority; and

(b) The degree to which an engagement quality control reviewer can be

consulted on the engagement without compromising the reviewer’s
objectivity.
 - 23 - PSQC 1

69. The firm’s policies and procedures on the technical qualifications of engagement
quality control reviewers address the technical expertise, experience and authority
necessary to perform the role. What constitutes sufficient and appropriate
technical expertise, experience and authority depends on the circumstances of the
engagement. In addition, the engagement quality control reviewer for an audit of
the financial statements of a listed entity is an individual with sufficient and
appropriate experience and authority to act as an audit engagement partner on
audits of financial statements of listed entities.

70. The firm’s policies and procedures are designed to maintain the objectivity of the
engagement quality control reviewer. For example, the engagement quality control
reviewer:

(a) Is not selected by the engagement partner;

(b) Does not otherwise participate in the engagement during the period of
review;

(c) Does not make decisions for the engagement team; and

(d) Is not subject to other considerations that would threaten the reviewer’s
objectivity.

71. The engagement partner may consult the engagement quality control reviewer
during the engagement. Such consultation need not compromise the engagement
quality control reviewer’s eligibility to perform the role. Where the nature and
extent of the consultations become significant, however, care is taken by both the
engagement team and the reviewer to maintain the reviewer’s objectivity. Where
this is not possible, another individual within the firm or a suitably qualified
external person is appointed to take on the role of either the engagement quality
control reviewer or the person to be consulted on the engagement. The firm’s
policies provide for the replacement of the engagement quality control reviewer
where the ability to perform an objective review may be impaired.

72. Suitably qualified external persons may be contracted where sole practitioners or
small firms identify engagements requiring engagement quality control reviews.
Alternatively, some sole practitioners or small firms may wish to use other firms
to facilitate engagement quality control reviews. Where the firm contracts
suitably qualified external persons, the firm follows the requirements and
guidance in paragraphs 68-71.
 - 24 - PSQC 1

Documentation of the Engagement Quality Control Review

73. Policies and procedures on documentation of the engagement quality control

review should require documentation that:

(a) The procedures required by the firm’s policies on engagement quality

control review have been performed;

(b) The engagement quality control review has been completed before the
report is issued; and

(c) The reviewer is not aware of any unresolved matters that would cause
the reviewer to believe that the significant judgments the engagement
team made and the conclusions they reached were not appropriate.

Monitoring

74. The firm should establish policies and procedures designed to provide it with
reasonable assurance that the policies and procedures relating to the system
of quality control are relevant, adequate, operating effectively and complied
with in practice. Such policies and procedures should include an ongoing
consideration and evaluation of the firm’s system of quality control,
including a periodic inspection of a selection of completed engagements.

75. The purpose of monitoring compliance with quality control policies and
procedures is to provide an evaluation of:

(a) Adherence to professional standards and regulatory and legal

requirements;

(b) Whether the quality control system has been appropriately designed and
effectively implemented; and

(c) Whether the firm’s quality control policies and procedures have been
appropriately applied, so that reports that are issued by the firm or
engagement partners are appropriate in the circumstances.

76. The firm entrusts responsibility for the monitoring process to a partner or partners
or other persons with sufficient and appropriate experience and authority in the
firm to assume that responsibility. Monitoring of the firm’s system of quality
control is performed by competent individuals and covers both the
appropriateness of the design and the effectiveness of the operation of the system
of quality control.
 - 25 - PSQC 1

77. Ongoing consideration and evaluation of the system of quality control includes
matters such as the following:

• Analysis of:

- New developments in professional standards and regulatory and legal

requirements, and how they are reflected in the firm’s policies and
procedures where appropriate;

- Written confirmation of compliance with policies and procedures on

independence;

- Continuing professional development, including training; and

- Decisions related to acceptance and continuance of client relationships

and specific engagements.

• Determination of corrective actions to be taken and improvements to be

made in the system, including the provision of feedback into the firm’s
policies and procedures relating to education and training.

• Communication to appropriate firm personnel of weaknesses identified in

the system, in the level of understanding of the system, or compliance with
it.

• Follow-up by appropriate firm personnel so that necessary modifications

are promptly made to the quality control policies and procedures.

78. The inspection of a selection of completed engagements is ordinarily performed

on a cyclical basis. Engagements selected for inspection include at least one
engagement for each engagement partner over an inspection cycle, which
ordinarily spans no more than three years. The manner in which the inspection
cycle is organized, including the timing of selection of individual engagements,
depends on many factors, including the following:

• The size of the firm.

• The number and geographical location of offices.

• The results of previous monitoring procedures.

• The degree of authority both personnel and offices have (for example,
whether individual offices are authorized to conduct their own inspections
or whether only the head office may conduct them).
 - 26 - PSQC 1

• The nature and complexity of the firm’s practice and organization.

• The risks associated with the firm’s clients and specific engagements.

79. The inspection process includes the selection of individual engagements, some of
which may be selected without prior notification to the engagement team. Those
inspecting the engagements are not involved in performing the engagement or the
engagement quality control review. In determining the scope of the inspections,
the firm may take into account the scope or conclusions of an independent
external inspection program. However, an independent external inspection
program does not act as a substitute for the firm’s own internal monitoring
program.

80. Small firms and sole practitioners may wish to use a suitably qualified external
person or another firm to carry out engagement inspections and other monitoring
procedures. Alternatively, they may wish to establish arrangements to share
resources with other appropriate organizations to facilitate monitoring activities.

81. The firm should evaluate the effect of deficiencies noted as a result of the
monitoring process and should determine whether they are either:

(a) Instances that do not necessarily indicate that the firm’s system of
quality control is insufficient to provide it with reasonable assurance
that it complies with professional standards and regulatory and legal
requirements, and that the reports issued by the firm or engagement
partners are appropriate in the circumstances; or

(b) Systemic, repetitive or other significant deficiencies that require

prompt corrective action.

82. The firm should communicate to relevant engagement partners and other
appropriate personnel deficiencies noted as a result of the monitoring process
and recommendations for appropriate remedial action.

83. The firm’s evaluation of each type of deficiency should result in

recommendations for one or more of the following:

(a) Taking appropriate remedial action in relation to an individual

engagement or member of personnel;

(b) The communication of the findings to those responsible for training

and professional development;
 - 27 - PSQC 1

(c) Changes to the quality control policies and procedures; and

(d) Disciplinary action against those who fail to comply with the policies
and procedures of the firm, especially those who do so repeatedly.

84. Where the results of the monitoring procedures indicate that a report may be
inappropriate or that procedures were omitted during the performance of
the engagement, the firm should determine what further action is
appropriate to comply with relevant professional standards and regulatory
and legal requirements. It should also consider obtaining legal advice.

85. At least annually, the firm should communicate the results of the monitoring
of its quality control system to engagement partners and other appropriate
individuals within the firm, including the firm’s chief executive officer or, if
appropriate, its managing board of partners. Such communication should
enable the firm and these individuals to take prompt and appropriate action
where necessary in accordance with their defined roles and responsibilities.
Information communicated should include the following:

(a) A description of the monitoring procedures performed.

(b) The conclusions drawn from the monitoring procedures.

(c) Where relevant, a description of systemic, repetitive or other

significant deficiencies and of the actions taken to resolve or amend
those deficiencies.

86. The reporting of identified deficiencies to individuals other than the relevant
engagement partners ordinarily does not include an identification of the specific
engagements concerned, unless such identification is necessary for the proper
discharge of the responsibilities of the individuals other than the engagement
partners.

87. Some firms operate as part of a network and, for consistency, may implement
some or all of their monitoring procedures on a network basis. Where firms
within a network operate under common monitoring policies and procedures
designed to comply with this PSQC, and these firms place reliance on such a
monitoring system:

(a) At least annually, the network communicates the overall scope, extent and
results of the monitoring process to appropriate individuals within the
network firms;
 - 28 - PSQC 1

(b) The network communicates promptly any identified deficiencies in the

quality control system to appropriate individuals within the relevant
network firm or firms so that the necessary action can be taken; and

(c) Engagement partners in the network firms are entitled to rely on the results
of the monitoring process implemented within the network, unless the
firms or the network advises otherwise.

88. Appropriate documentation relating to monitoring:

(a) Sets out monitoring procedures, including the procedure for selecting
completed engagements to be inspected;

(b) Records the evaluation of:

(i) Adherence to professional standards and regulatory and legal

requirements;

(ii) Whether the quality control system has been appropriately designed
and effectively implemented; and

(iii) Whether the firm’s quality control policies and procedures have been
appropriately applied, so that reports that are issued by the firm or
engagement partners are appropriate in the circumstances; and

(c) Identifies the deficiencies noted, evaluates their effect, and sets out the
basis for determining whether and what further action is necessary.

Complaints and Allegations

89. The firm should establish policies and procedures designed to provide it with
reasonable assurance that it deals appropriately with:

(a) Complaints and allegations that the work performed by the firm fails
to comply with professional standards and regulatory and legal
requirements; and

(b) Allegations of non-compliance with the firm’s system of quality

control.
 - 29 - PSQC 1

90. Complaints and allegations (which do not include those that are clearly frivolous)
may originate from within or outside the firm. They may be made by firm
personnel, clients or other third parties. They may be received by engagement
team members or other firm personnel.

91. As part of this process, the firm establishes clearly defined channels for firm
personnel to raise any concerns in a manner that enables them to come forward
without fear of reprisals.

92. The firm investigates such complaints and allegations in accordance with
established policies and procedures. The investigation is supervised by a partner
with sufficient and appropriate experience and authority within the firm but who
is not otherwise involved in the engagement, and includes involving legal counsel
as necessary. Small firms and sole practitioners may use the services of a suitably
qualified external person or another firm to carry out the investigation.
Complaints, allegations and the responses to them are documented.

93. Where the results of the investigations indicate deficiencies in the design or
operation of the firm’s quality control policies and procedures, or noncompliance
with the firm’s system of quality control by an individual or individuals, the firm
takes appropriate action as discussed in paragraph 83.

Documentation

94. The firm should establish policies and procedures requiring appropriate
documentation to provide evidence of the operation of each element of its
system of quality control.

95. How such matters are documented is the firm’s decision. For example, large
firms may use electronic databases to document matters such as independence
confirmations, performance evaluations and the results of monitoring inspections.
Smaller firms may use more informal methods such as manual notes, checklists
and forms.

96. Factors to consider when determining the form and content of documentation
evidencing the operation of each of the elements of the system of quality control
include the following:

• The size of the firm and the number of offices.

• The degree of authority both personnel and offices have.

• The nature and complexity of the firm’s practice and organization.

 - 30 - PSQC 1

97. The firm retains this documentation for a period of time sufficient to permit those
performing monitoring procedures to evaluate the firm’s compliance with its
system of quality control, or for a longer period if required by law or regulation.

Effective Date

98. Systems of quality control in compliance with this PSQC are required to be
established by June 15, 2006. Firms consider the appropriate transitional
arrangements for engagements in process at that date.

Acknowledgment

99. This PSQC is based on International Standard on Quality Control (ISQC) 1,

“Quality Control for Firms that Performs Audits and Reviews of Historical
Financial Information, and Other Assurance and Related Services Engagements,”
issued by the International Auditing and Assurance Standards Board.

100. There are no significant differences between this PSA and ISQC 1 except for the
deletion of paragraphs 2 and 4 under Public Sector Perspective.

Public Sector Perspective

1. Some of the terms in the PSQC, such as “engagement partner” and “firm,”
should be read as referring to their public sector equivalents. However, with
limited exceptions, there is no public sector equivalent of “listed entities,”
although there may be audits of particularly significant public sector entities
which should be subject to the listed entity requirements of mandatory rotation of
the engagement partner (or equivalent) and engagement quality control review.
There are no fixed objective criteria on which this determination of significance
should be based. However, such an assessment should encompass an evaluation
of all factors relevant to the audited entity. Such factors include size, complexity,
commercial risk, parliamentary or media interest and the number and range of
stakeholders affected.
 - 31 - PSQC 1

2. Deleted: ISQC 1, paragraph 70, states

that “The firm’s policies and procedures
are designed to maintain the objectivity
[This paragraph does not apply in the Philippines and is therefore not used.] of the engagement quality control
reviewer.” Subparagraph (a) notes as
an example that the engagement quality
3 In the public sector, auditors are appointed in accordance with statutory control reviewer is not selected by the
engagement partner. However, in many
procedures. Accordingly, considerations regarding the acceptance and jurisdictions, there is a single statutorily
continuance of client relationships and specific engagements, as set out in appointed auditor-general who acts in a
role equivalent to that of “engagement
paragraphs 28-35 of PSQC 1, may not apply. partner” and who has overall
responsibility for public sector audits. In
such circumstances, where applicable,
4. the engagement reviewer should be
selected having regard to the need for
independence and objectivity.
[This paragraph does not apply in the Philippines and is therefore not used.]
Deleted: Similarly, the independence
of public sector auditors may be
protected by statutory measures, with the
consequence that certain of the threats to
independence of the nature envisaged by
paragraphs 18-27 of ISQC 1 are unlikely
to occur.
 - 32 - PSQC 1

This PSQC 1 was unanimously approved for adoption in the Philippines on February 21,
2005 by the members of the Auditing Standards and Practices Council:

Benjamin R. Punongbayan, Chairman Antonio P. Acyatan, Vice Chairman

Felicidad A. Abad David L. Balangue

Eliseo A. Fernandez Nestorio C. Roraldo

Joaquin P. Tolentino Editha O. Tuason

Joycelyn J. Villaflores Horace F. Dumlao

Ester F. Ledesma Manuel O. Faustino

Erwin Vincent G. Alcala Froilan G. Ampil

Eugene T. Mateo Flerida V. Creencia

Roberto G. Manabat
 - 33 - PSQC 1

Amendments to the Glossary of Terms, PSA 620 and PAPS 1012 as a

Result of PSQC 1 and PSA 220 (Revised)

Effective Dates

Systems of quality control in compliance with Philippine Standard on Quality Control

(PSQC) 1, “Quality Control for Firms that Perform Audits and Reviews of Historical
Financial Information, and Other Assurance and Related Services Engagements” are
required to be established by June 15, 2006.

Philippine Standard on Auditing (PSA) 220 (Revised), “Quality Control for Audits of
Historical Financial Information” is effective for audits of historical financial information
for periods commencing on or after June 15, 2006.

Glossary of Terms

Quality controls—As set out in PSQC 1, “Quality Control for Firms that Perform Audits
and Reviews of Historical Financial Information, and Other Assurance and Related
Services Engagements,” tThe policies and procedures adopted by a firm designed to
provide it with reasonable assurance that all audits done by the firm and its personnel
comply with professional standards and regulatory and legal requirements, and that
reports issued by the firm or engagement partners are appropriate in the circumstances are
being carried out in accordance with the Objective and General Principles Governing an
Audit of Financial Statements, as set out in International Standard on Auditing 220
“Quality Control for Audit Work.”

PSA 620, “Using the Work of an Expert”

5. An expert may be:

(a) Contracted Engaged by the entity;

(b) Contracted Engaged by the auditor;

(c) Employed by the entity; or

(d) Employed by the auditor.

 - 34 - PSQC 1

When the auditor uses the work of an expert employed by the audit firm, the auditor
will be able to rely on the firm’s systems for recruitment and training that determine
that expert’s capabilities and competence, as explained in PSA 220 (Revised),
“Quality Control for Audits of Historical Financial Information” instead of needing to
evaluate them for each audit engagement auditor, that work is used in the employee’s
capacity as an expert rather than as an assistant on the audit as contemplated in PSA
220, “Quality Control for Audit Work.” Accordingly, in such circumstances the
auditor will need to apply relevant procedures to the employee’s work and findings
but will not ordinarily need to assess for each engagement the employee’s skills and
competence.

PAPS 1012, “Auditing Derivative Financial Instruments”

15. Members of the engagement team may have the necessary skill and knowledge to plan
and perform auditing procedures related to derivatives transactions. Alternatively, the
auditor may decide to seek the assistance of an expert outside the firm, with the
necessary skills or knowledge to plan and perform the auditing procedures, especially
when the derivatives are very complex, or when simple derivatives are used in
complex situations, the entity is engaged in active trading of derivatives, or the
valuation of the derivatives are based on complex pricing models. PSA 220
(Revised), “Quality Control for Audits Work of Historical Financial Information,”
provides guidance on the supervision of individuals who serve as members of the
engagement team and assist the auditor in planning and performing auditing
procedures. PSA 620, “Using the Work of an Expert,” provides guidance on the use
of an expert’s work as audit evidence.