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Creating your quality management system starts with defining your firm’s quality objectives

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All firms that perform accounting or attest engagements must have their new quality management system in place by Dec. 15, 2025. These new standards require firms to develop quality objectives around eight components. Because every firm is different — from the clients they serve to the processes and procedures they already have in place — the AICPA practice aids warn that a copy-and-paste approach won’t work. 

Many firms try to use their existing quality control document as a starting point, but we’ve found many odd things in the QCDs of the firms we’ve worked with. For example, one firm’s QCD said they would avoid employee benefit plan audits, but they’ve been doing those audits for years. Another firm’s document said its mission, vision and values statement was to be posted throughout the firm, but we were unable to find any of these posters. 

Many times, it seems the QCD is something a firm decided they would strive for, but after hitting “Save” on the document, they rarely went back to see what was still in it.

(Read more:Quality management systems: Time is running out!)

We also find that firms get bogged down when they start at the wrong place. Instead of starting with determining what the firm currently does to achieve quality to help define quality objectives for each of the components, they start by considering risk, likelihood, and magnitude of risk events. This rapidly becomes overwhelming as firms try to create processes to address every kind of risk event they can imagine. This is like starting an audit without finishing planning, a process that is unfortunately far more common than we like to admit. 

However, when we guide firms through first creating a custom set of quality objectives, this narrows the possible universe of risk events to those most likely to occur, making it much simpler to identify and evaluate the risk, likelihood, and magnitude of future risk events, and to design remediation processes. With a well-designed QMS, the likelihood of a risk event should be low; if a risk event were to occur, the magnitude of the event will vary.

How to develop quality objectives

We recommend a thoughtful and holistic approach to developing your firm’s quality objectives. This approach considers all the characteristics of your firm: Both the traits that your firm shares with all audit firms and the traits that make your firm unique. 

This holistic approach will ultimately refine your firm’s ability to provide value and will inevitably enhance profitability. The resulting QMS is also easier to update as your firm grows, making it a guiding document for the firm. 

As we described in a previous article, we recommend following the long-standing SMART approach to creating objectives around each of the components. With the SMART approach, the objectives are specific, measurable, attainable, relevant and time-oriented. 

To build out the quality objectives, you need to first understand what the requirements are in the standard and then build out objectives that follow the SMART approach. Next, your firm needs to create the policies and procedures that will support those objectives. The final step is to establish methods to track and support the achievement of those objectives.  

The eight components of your QMS are not independent but create an interactive system to reduce the risk of quality failures. The overarching goal of this process is to establish a culture of quality with actions that support that culture. 

How one accounting firm created its objectives

As an example, let’s look at the “Acceptance and Continuation of Client Relationships and Specific Engagements” component. This aspect of quality requires greater attention from many firms. In particular, let’s zero in on Sec. 31(a)ii of SQMS 1: 

“31. The firm should establish the following quality objectives that address the acceptance and continuance of client relationships and specific engagements:
“a. Judgments by the firm about whether to accept or continue a client relationship or specific engagement are appropriate based on the following:
“ii. The firm’s ability to perform the engagement in accordance with professional standards and applicable legal and regulatory requirements.”

Here is an excerpt from the document outlining the quality objectives for acceptance and continuance from one of the clients we collaborated with: 

“1. Judgments on Acceptance and Continuance:

  • Firm’s Capability and Compliance: Decisions on accepting or continuing client relationships or engagements will consider the firm’s ability to perform in accordance with professional standards and legal requirements. This involves assessing the firm’s competencies, resources, and the specific needs of the engagement. Specific industries serviced by the firm will be reviewed annually, with changes made as needed.”

This objective expands on the requirement from the standard by describing in general terms the assessments required to accept or continue a particular engagement, including the requirement that the firm intends to service only clients in specific industries. It also specifies that the list of industries is to be reviewed annually. 

Now let’s look at the policies and procedures this firm developed to support this section of their quality objective:

“Capability and compliance
“Decisions to accept or continue a client relationship or specific engagement will consider the firm’s ability to perform the engagement in accordance with professional standards and applicable legal and regulatory requirements. This includes assessing the firm’s competencies, resources, and the specific needs of the engagement to ensure compliance and quality. 
“Upon assessing the firms’ competencies and capabilities, the firm has established the following industry sectors as key niches: 

  • Construction contractors 
  • Manufacturing/Distribution 
  • Food and beverage 
  • Logistics/Transportation  
  • NFP/Government (no single audits)
  • EBP (other than DB and ESOPs plans)

“Based upon the firm’s risk assessment process, the firm has determined the following: 

  • Services we will not perform:
    • SOC 
    • PCAOB (or other public company engagements)
    • Single Audits
    • Direct examinations 
  • Industries we will not service 
    • Banking/Financial institutions 
    • Auto dealerships
    • Broker/Dealers   

“The Director of Audit and Assurance is responsible for deciding whether the firm should provide services in other industry niches on a case-by-case basis during the proposal process. The above list of niche industries will be reviewed and updated on an annual basis.”

By spelling out the industry sectors the firm will and will not work in, as well as the services the firm will not perform, the firm has a measurement system to screen out potential clients and engagements that would be a poor fit. Some firms are even using their newly created QMS as a reason to disengage from poor-fit clients.

Choosing areas the firm will work in has cascading effects. It’s far easier to develop and maintain industry expertise in a handful of areas than to be a jack of all trades. The better a firm is in a particular area, the faster the work can be completed, and the more profitable that work becomes. 

Additionally, having deep familiarity with specific industries adds significant client value by providing better insights into potential risks in their clients’ operations. Delving into unfamiliar industries and novel services tends to drive up costs and elevates the risk of missing something important.

This also reaches into governance and leadership, one of the other eight quality components. Leaders can’t arbitrarily choose a new business connection. New clients must fit the skill sets and competencies of the firm. The firm leadership now must make deliberate decisions on entering new industries.

As the final step, this section of the firm’s QMS also includes a matrix for measuring, tracking, and responding to quality risk events. For example, a new client acceptance form must be filled out and approved by a shareholder prior to sending out an engagement letter. This form is to be maintained in the engagement binder. If this process is not addressed promptly, this can lead to the occurrence of a risk event. When risk events occur, the firm must conduct a root cause analysis and develop a remediation plan to reduce the likelihood of the risk event happening again.

Developing your firm’s QMS is more complex than changing the name of your QCD. Every firm will have a different set of quality objectives. These components are not in a silo but interact to drive the holistic goal of having the right emphasis on quality to serve your clients successfully, to protect the public interest, and to be profitable. 

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Accounting

SEC’s Semiannual Reporting Proposal Faces Investor Pushback: What CFOs Need to Know

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U.S. Securities and Exchange Commission (SEC)

A proposal from the U.S. Securities and Exchange Commission to potentially shift some public companies away from quarterly financial reporting toward a semiannual model is drawing significant pushback from investors, even as it continues moving through the regulatory process. The debate has direct implications for corporate finance teams, auditors, and the broader transparency of U.S. capital markets.

What the SEC Proposed

According to a summary published by accounting advisory firm Cohen & Co., the SEC issued a proposed rule on May 19, 2026, aimed at simplifying financial reporting requirements for many U.S. public companies. The proposal would potentially reduce the frequency of certain mandatory disclosures from quarterly to semiannual, a structural change that has not been made to core U.S. reporting requirements in decades.

The proposal follows an extended debate within U.S. policy circles, with proponents arguing that reduced reporting frequency could lower compliance costs and free up management time for longer-term strategic planning rather than quarter-to-quarter results management.

Why Investors Are Pushing Back

Comment letters submitted in response to the proposal have been extensive, and according to Cohen & Co.’s review of the public record, investors “appear to be largely opposed” to the shift, viewing frequent interim reporting as a core benefit of U.S. capital markets relative to other jurisdictions.

Accounting and law firms have taken a more measured position, generally urging any changes to remain aligned with the Financial Accounting Standards Board (FASB), whose existing disclosure requirements and guidance are built around a quarterly reporting cadence. A shift to semiannual reporting without corresponding changes to FASB guidance could create friction between SEC filing requirements and GAAP-based disclosure expectations.

Lessons From the U.K. Experience

The debate is not without precedent. The United Kingdom moved away from mandatory quarterly reporting for listed companies in 2014, returning to a semiannual disclosure requirement. According to Cohen & Co.’s analysis, that experience offers a cautionary data point: there was no measurable increase in capital expenditure or R&D investment following the change, while analyst coverage of affected companies declined as reliable interim information became less available — a particular risk for smaller and newly public companies that rely on analyst coverage to maintain investor visibility.

Practical Implications for Finance Teams

Beyond the debate over disclosure philosophy, the proposal carries practical complications. Many companies have debt covenants and credit agreements structured around quarterly financial delivery; a shift to semiannual reporting could require renegotiating those terms. Reduced reporting frequency would also extend the “window of market silence” between disclosures, a factor that governance and investor-relations teams would need to manage carefully to avoid information asymmetry.

Separately, and unrelated to the reporting-frequency debate, the SEC and FASB have continued finalizing more routine updates this year. New Accounting Standards Updates are taking effect for December 31, 2026, fiscal year-ends covering income tax disclosures, credit loss measurement, induced debt conversions, and stock compensation, according to Eide Bailly’s review of 2026 ASU activity. Additional guidance on paid-in-kind dividends and environmental credits is also on the near-term horizon.

What to Watch Next

The semiannual reporting proposal remains in the comment and review phase, and no final rule has been adopted as of this writing. Finance leaders should monitor the SEC’s regulatory agenda for further movement, while treating the current quarterly reporting requirement as the operative standard until any final rule is issued and an effective date is set.

Given the extent of investor opposition documented in the comment file, a full shift to mandatory semiannual reporting appears more likely to result in either a scaled-back compromise or continued study rather than swift adoption — though the SEC’s ultimate direction remains uncertain.

 

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Accounting

AI-Driven Automation and Continuous Accounting Frameworks

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The accounting profession is undergoing a fundamental structural transition as enterprise finance departments shift from periodic month-end closes toward automated continuous accounting models. By integrating specialized machine learning algorithms directly into enterprise resource planning (ERP) platforms, chief accounting officers are transforming financial reporting from a retrospective exercise into a real-time operational asset.

The Shift from Periodic Close to Continuous Financial Reporting
Traditional accounting workflows heavily relied on manual data reconciliation, spreadsheet calculations, and multi-week closing cycles at the end of each fiscal period. In contrast, continuous accounting frameworks utilize automated software agents to process, validate, and post transactional data in real time as business activities occur.

Automated bank reconciliation tools cross-reference incoming bank feeds, invoice records, and purchase orders automatically. By resolving transactional variances instantly throughout the month, corporate accounting teams eliminate the traditional workload spikes associated with quarterly and annual closes.

Machine Learning in Audit Trails and Anomaly Detection
Advanced natural language processing (NLP) and machine learning tools are redefining internal audit and financial control environments. Automated systems analyze 100% of general ledger entries, identifying anomalous transactions, duplicate payments, and unauthorized journal entries in real time.

Rather than relying on random statistical sampling, corporate internal auditors can focus their attention on high-risk flags automatically surfaced by algorithmic monitoring platforms. This continuous risk assessment strengthens internal controls over financial reporting (ICFR) and significantly reduces fraud risk.

Evolving Roles for Accounting Professionals
As routine data entry and manual reconciliation tasks become fully automated, the skill set required for accounting professionals is shifting toward data analysis, system design, and strategic business advisory.
– Systems Governance: Accountants are increasingly responsible for monitoring algorithmic accuracy and managing data integration pipelines.
– Business Partnership: Finance professionals leverage real-time financial dashboards to advise operational leaders on margin management and working capital allocation.
– Regulatory Compliance Management: Accounting teams utilize automated platforms to ensure compliance with dynamic tax codes and international accounting standards.

Core Implementation Recommendations
1. Deploy Automated Reconciliation Tools: Integrate continuous transaction processing modules into existing enterprise ERP architectures.
2. Establish Algorithmic Governance Controls: Implement strict internal testing protocols to ensure automated accounting rules comply with GAAP/IFRS standards.
3. Reskill Accounting Teams: Invest in training finance staff on data analytics, workflow automation, and predictive financial modeling.

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Accounting

Global ESG Reporting Standards and Double Materiality Compliance

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Corporate accounting departments face expanding reporting expectations as international sustainability disclosure standards achieve regulatory enforcement across major global jurisdictions. Chief Accounting Officers (CAOs) and corporate controllers are establishing rigorous internal accounting controls to treat Environmental, Social, and Governance (ESG) metrics with the same data precision, auditability, and governance as traditional financial statements.

Regulatory Harmonization Under Global Sustainability Frameworks
The implementation of standardized sustainability reporting frameworks—notably rules established by international sustainability accounting boards—has created unified expectations for public and large private enterprises. Corporations must report standardized metrics covering greenhouse gas emissions (Scope 1, 2, and material Scope 3), energy utilization, workforce demographics, and supply chain governance.

In Europe and other participating international jurisdictions, double materiality principles are mandatory. Under double materiality, organizations must report both how external sustainability risks impact corporate financial performance, and how internal corporate operations affect surrounding environmental and social structures.

Integrating Sustainability Metrics into Core ERP Systems
To provide auditable non-financial data, enterprise organizations are integrating specialized carbon accounting and ESG management platforms directly into core ERP systems. Automated data collectors capture energy utility invoices, logistics fuel consumption metrics, and vendor compliance records in real time.

Establishing automated, traceable data pipelines ensures that non-financial reporting is supported by clear audit trails. This structured approach allows external financial auditors to provide reasonable assurance on sustainability disclosures during annual corporate reporting cycles.

Financial Impacts and Capital Market Disclosure
Accurate ESG reporting directly influences corporate cost of capital and institutional credit ratings. Commercial lenders and institutional asset managers systematically incorporate sustainability metrics into risk pricing models. Companies that demonstrate transparent, verifiable progress in operational energy efficiency and climate risk mitigation benefit from expanded access to green bond markets and lower debt pricing.

Action Steps for Accounting Leadership
1. Implement Double Materiality Frameworks: Conduct comprehensive assessments to identify material financial and operational sustainability metrics.
2. Build Auditable Non-Financial Data Pipelines: Automate ESG data collection within core accounting software to ensure data integrity.
3. Align Sustainability with Annual Financial Filings: Prepare non-financial disclosures concurrently with financial statements to satisfy regulatory audit expectations.

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