Change is Designed to Promote Consistency Among Peer Reviews
NEW YORK (Sept. 16, 2025) – The American Institute of CPAs’ Peer Review Board is seeking public comment on a change to its peer review program that would centralize the administration of peer reviews of firms operating under alternative practice structures (APS), including those with private equity investments.
The change, outlined in the proposed Peer Review Standards Update (PRSU) No. 3, , would require firms operating under non-traditional business models to have their peer reviews administered by the AICPA’s National Peer Review Committee, rather than one of the 23 state administering entities. The update is designed to promote the consistency of how a peer review is conducted and evaluated as the profession adjusts to new operating structures, a critical factor in promoting quality and protecting the public.
The proposed change to the standards allows the Peer Review Board discretion to require certain peer reviews be administered by the National Peer Review Committee – a panel of 15 to 17 practitioners with broad, national experience and expertise – through the issuance of application guidance.
“Changing business structures create both opportunity and risk for the profession,” said Susan Coffey, CPA, CGMA, the AICPA’s CEO of public accounting. “Making sure firms have quality management systems designed to comply with professional standards is foundational to protecting the public interest. The administration of these reviews by the National Peer Review Committee assures the appropriate and consistent degree of oversight of APS audit practices over the next several years, as more firms take on private equity investment.”
The comment period for the proposed update will be open until Oct. 25 this year. If approved by the Peer Review Board, it would be effective for peer reviews with years ending on or after Dec. 31, 2025.
Under the AICPA Peer Review Program, firms are reviewed every three years, a process designed to provide reasonable assurance they are adhering to AICPA and other professional standards in their work and have robust quality systems in place. Firms are rated “pass,” “pass with deficiencies” or “fail.” A primary emphasis of the program is on detecting deficiencies and remediation of problem areas.
The exposure draft for the proposed update notes some of the concerns raised by stakeholders about private equity investment, including the challenges of operating separate attest and nonattest entities, monitoring compliance with independence and other professional standards, and maintaining quality of services. The National Peer Review Committee administration of APS reviews will allow time for the development of guidance and training for the state administering entities.
Besides the APS-related provision, the proposed standards update also includes a change to qualifications for peer reviewers of firms that perform or assist in engagements under Public Company Accounting Oversight Board (PCAOB) standards. The change is designed to ensure that practitioners who have a deeper familiarity with those standards are assigned to those review teams.
Media Contact:
Jeff May
jeffrey.may@aicpa-cima.com