Firms made significant investments in designing and implementing their quality management (QM) systems, and now the focus shifts to understanding how those systems will be evaluated under the peer review process.
Peer review is a tool to evaluate and improve your firm’s QM system. Firms preparing for their first peer review under the new QM standards can get expert insights into how their system may be evaluated at the upcoming live webcast “Quality Management: Preparing for Peer Review” on July 13.
The first peer review of your firm’s QM system isn’t just a checkpoint but an opportunity to prove the system works in practice — and now is the time to prepare.
Peer review in a QM era
While the new QM standards did not cause a fundamental change to the peer review process, peer reviewers are reviewing QM systems for the first time. Even though it’s not dissimilar to what they were previously examining, there is a learning curve for all involved — and it’s important to take those differences seriously because QM is different from quality control (QC).
Under the QM standards, peer reviewers are looking to see whether the system is designed appropriately, implemented, and operating effectively in practice.
As with the superseded QC standards, peer reviewers are looking to see if controls are in place. The QM standards, however, give firms a bit more autonomy in determining what those controls are.
The responsibility for the QM system falls under the CEO or managing partner, and it’s up to them to evaluate the firm’s QM system at least once per year. Peer reviewers will still be interviewing leadership to assess that they understand the system, actively monitor it, and take responsibility for the outcomes.
QM systems require ongoing monitoring, and peer reviewers will assess whether this continuous improvement loop is functioning properly.
From documentation to demonstrable performance: What to focus on now
Your documentation is vitally important to demonstrable performance, consistency, and accountability under the QM standards — this is an area where your continued focus should be.
Your system will be tested across engagements, so ensure that policies are embedded into workflows. Be prepared to supply evidence of consistent application.
Because QM is risk based, tighten your risk assessment logic to remove any generic risks and match those risks with responses that effectively mitigate them. Peer reviewers will examine whether you’ve identified quality risks and if those responses are tailored and successful.
Firms that treat QM as an ongoing system instead of a one-time project will succeed. Prepare to show how your system has evolved since implementation and what you’re doing for continuous improvement.
Additional steps you can take to prepare include ensuring your leadership can clearly explain how the QM system works, addressing inconsistencies across teams or offices, and strengthening the monitoring and remediation processes of your firm.
Working within an evolving process
Expectations for peer reviews under the QM standards are still evolving because the first assessments of these systems started this year. Guidance is still being refined, and reviewers will still be calibrating their judgments. Outcomes will be determinant on whether firms tried to implement QM or failed to enable a new system at all.
This initial implementation process is continually being monitored by standard setters, helping determine what peer reviewers should expect and how their evaluations should be conducted.
Treat this first year as a test-and-learn period — perfection is not expected.
Quality remains the ultimate objective.
Early peer reviews will introduce new questions and practice considerations, making readiness an ongoing, iterative process rather than a one-time milestone.
The most effective way to prepare for this peer review is to focus on what doesn’t change — audit quality, risk identification and response, effective operation, and continuous improvement. Peer review in this QM era is about demonstrating that your firm’s system actively identifies objectives, quality risks, and appropriate responses to those risks, and is refined over time. Quality management checklists, review expectations, and guidance will evolve around that core principle.
Register today for the live webcast “Quality Management: Preparing for Peer Review” to get a jumpstart on what to expect for your firm’s peer review under the new QM standards. The webcast will be recorded and rebroadcasted monthly throughout 2026 with more dates added later this year. Quality management and peer review resources, guides, and tools can assist in keeping your QM system maintained.
Additional reporting by Jamie J. Roessner, M.A., a senior content writer at the AICPA®.