IFAC SMP Committee Comment Letter on the IAASB's Exposure Draft on Quality Management at the Firm and Engagement Level

The SMPC is concerned that the QM standards' complexity may eventually drive a compliance mindset, especially amongst smaller firms who become subject to proportionately greater documentation burdens to “explain/prove” their compliance. Therefore, it is important for the IAASB to ensure that the final suite of QM standards address this issue to foster an effective focus on the quality of the engagement each individual firm delivers, as opposed to compliance with complex standards. In any case, the SMPC believes that the implementation period should not be less than 24 months after the approval of the standards by the PIOB.