Peer review proposal changes, clarifies standards

By Ken Tysiac

The AICPA Peer Review Board (PRB) published a proposal Friday designed to clarify peer review standards and make them easier for practitioners to read, understand, and apply.

Along with the proposed clarity (PR-C) standards, the exposure draft includes content changes that would apply to peer review. Standards changes include:

  • Removal of the requirement for the majority of procedures in a system review to be performed at the reviewed firm's office.
  • Changes to the requirements for on-site office visits in system reviews.
  • Removal of the requirement for surprise engagements in system reviews.
  • Removal of the term "significant deficiency" in engagement reviews.
  • Removal of the requirement that peer review documents for single audit engagements be included in materials for report acceptance body (RAB) meetings.
  • Removal of the guidance on performing and reporting on reviews of quality control materials.

The clarifying changes in the proposed guidance, which would not substantially change what is required of firms, reviewers, or administering entities, would:

  • Organize sections by user (reviewed firms, peer reviewers, or administering entities) and review type (system reviews or engagement reviews).
  • Provide relevant definitions for all clarified sections in the first section, which applies to any user of the standards.
  • Establish objectives for each clarified section.
  • Separate requirements from application and other explanatory material.
  • Number application and other explanatory material paragraphs using an "A" prefix and present them in a separate section after the requirements.
  • Use formatting techniques, such as bulleted lists, to enhance readability.

If approved by the PRB, the final standards would take effect for reviews beginning on or after May 1, 2022. Early implementation would not be permitted.

Comments can be submitted by Dec. 15 by emailing Brad Coffey at The PRB has provided a template for comments and suggestions that can be used to format feedback.

Ken Tysiac ( is the JofA's editorial director.

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