Hi {{first_name | there}},
Here’s something that actually happened to me — but let me put you in my shoes for a moment and play out that situation.
You subscribe to a paid writing platform and built your website on it too. Initially, things feel great.
But as you kept using it, the problems start to surface one after the other:
No chat or phone support — just a ticket system with days of waiting
Clunky, horribly glitchy software that makes every session a friction exercise
Poor typography and design that makes the output feel well below amateurish
The result?
You start to hating writing.
And eventually, you break your streak and stop writing entirely.
This is the main reason for my delay between the 4th and 5th issue of The AQRM Compass.
Now, if I asked you to describe that platform in two words — what would you say?
Poor quality.
It didn't matter whether the failure was in technology, design, support infrastructure, or speed of resolution.
Every single one of those experiences pointed to the same thing:
Poor system » Poor quality.
Now, think about it.
Your clients experience your firm the same way.
They may not use the word 'quality' — but every delayed response, every sloppy file, every missed deadline registers as exactly that. And so does every smooth, reliable, well-executed engagement. They feel the sum of everything your firm does. And the name for that holistic feeling is quality.
This idea (that quality is the holistic output of your firm and its people), when formalized into a professional standard, is what we call the Quality Management Standards — CSQM 1, SQMS 1, and ISQM 1.
But here's the question most firms are still getting wrong:
Whose responsibility is quality, exactly?
QUALITY RISK OR TOPIC
So, what’s the honest answer at most firms?
It’s the partners. Or the Quality lead. Or whoever was assigned that role.
And viewing the responsibility for quality in isolation creates a risk:
Quality Risk (Use this quality risk definition as a starting point for your firm’s SoQM, and customize it as needed):
Quality responsibility is not formally assigned, communicated, or reinforced across all roles and levels of the firm, resulting in a culture where quality management is perceived as the function of leadership or a designated quality role, rather than a firm-wide professional obligation — increasing the risk of inconsistent engagement performance, undetected errors, and systemic quality failures.
This risk is pervasive because it is structural, not (always) behavioral. And also because the importance of quality is not institutionalized by the firm’s leadership.
It doesn't emerge only from one person failing to care — it emerges from a firm that never clearly told everyone that they should.
The downstream exposures are significant. For example:
Inconsistent engagement performance across teams and partners
Errors that go undetected because "someone else will catch it"
A SoQM that exists on paper but doesn't operate in practice
Inspection findings rooted not always in technical failure, but in cultural failure
Staff who don't escalate issues because they don't see it as their place to do so
INSIGHTS, INNOVATION AND SYSTEMS
The Quality Management (QM Standards are unambiguous on this point — and they use nearly identical language. Let’s look at what three of the standards say.
International Firms — International Standard on Quality Management (ISQM) 1: |
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Para 28(a)(iii): The firm demonstrates a commitment to quality through a culture that exists throughout the firm, which recognizes and reinforces: "The responsibility of all personnel for quality relating to the performance of engagements or activities within the system of quality management, and their expected behavior." |
Para A58: "Although leadership establishes the tone at the top through their actions and behaviors, clear, consistent and frequent actions and communications at all levels within the firm collectively contribute to the firm's culture and demonstrates a commitment to quality." |
Canadian Firms — Canadian Standard on Quality Management (CSQM) 1: |
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The requirement is identical in substance: Para 28(a)(iii): The firm is required to demonstrate a commitment to quality through a culture that exists throughout the firm, which recognizes and reinforces: "The responsibility of all personnel for quality relating to the performance of engagements or activities within the system of quality management, and their expected behavior." |
Para A58: Echoes the same principle and sentiment on leadership and firm-wide culture similar to ISQM 1. |
US Firms — Statements on Quality Management Standards (SQMS) — Section 10: |
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The US Standard requires the firm to establish a culture throughout the firm that recognizes and reinforces quality. Para 29(a)(iii): The firm demonstrates a commitment to quality through a culture that exists throughout the firm, which recognizes and reinforces the following: “The responsibility of all personnel for quality relating to the performance of engagements or activities within the system of quality management and their expected behavior.” |
Para A57: "The firm’s culture is an important factor in influencing the behavior of personnel." |
Para A58: “Although leadership establishes the tone at the top through its actions and behaviors, clear, consistent, and frequent actions and communications at all levels within the firm collectively contribute to the firm’s culture and demonstrate a commitment to quality.“ |
Para A30: “Quality management is not a separate function of the firm; it is the integration of a culture that demonstrates a commitment to quality with the firm’s strategy, operational activities, and business processes.“ |
Read that last sentence again.
Quality management is not a separate function. It is an integration of the firm’s culture.
That means it lives in how your admin staff communicates with clients, how your associates document working papers, how your managers review files, and how your partners set expectations on every engagement and follow through on their behavior — not just in your SoQM binder.
What this means in practice:
When your administrative staff sends a client email without proofreading it — that's a quality event.
When a junior associate locks-out an engagement file without clearing the review notes — that's a quality event.
When a manager does not provide feedback to staff in time — that’s a quality event.
When a partner signs off on a file they haven't meaningfully reviewed because the client is waiting — that's a quality event.
None of these require a Quality Partner to intervene after the fact. What they require is:
A culture where every person understands that quality is part of their job description — before anything goes wrong.
Illustrative scenario:
A mid-sized firm had a well-documented SoQM. The Quality Partner had built it diligently — risk register, policies, annual monitoring plan. Leadership was proud of it.
During a regulatory inspection, the reviewer interviewed three senior associates independently. Each one was asked: "Can you describe your firm's quality management responsibilities as they relate to your role?"
All three gave some version of the same answer: "That's more of a partner-level thing. I just focus on completing my files properly."
The inspection finding wasn't about a missing policy. It was about a firm that had built a system without building a culture. The SoQM documented everyone's responsibilities. Nobody had ever actually told them.
FREQUENTLY ASKED QUESTIONS:
We’re a small firm. Our team is close-knit and we talk constantly. Does formal quality assignment really matter if we're already communicating well?
Informal communication is valuable, but it is not a substitute for formal assignment.
Here's why:
When quality responsibility is only communicated informally, it is also informally understood — which means it is interpreted differently by different people, enforced inconsistently, and invisible to a regulator during an inspection.
More importantly, informal cultures tend to be situation-dependent. Quality behaviors hold ground when a senior person is present. They tend to erode when they're not. That's not a people problem — it's a culture problem.
The QM Standards make this explicit: it is not just leadership's tone at the top that counts — it is "clear, consistent, and frequent actions and communications at all levels within the firm" that collectively build the quality culture.
Ask yourself:
If your senior partner were away for a month, would your firm's culture behave the same or differently?
If the honest answer is "probably not," then your firm has this risk exposure (either way — good or bad).
RESOURCE OR ACTION ITEM
What can we do about it? You ask.
This week’s free resource can help you solve this problem.
I've prepared a ready-to-use Quality Risk Assessment Document (QRAD), tailored by firm type — Solo Practitioner, Small Firm, and Medium Firm — specific to this issue's topic.
Each QRAD includes:
A formal quality risk statement ready to embed in your SoQM documentation
An editable field to customize it for your firm's context
A rationalization explaining why the risk exists
An inherent risk score
A sign-off and approval page
Download the free resource here:
Actions you can take this week.
Keep it simple but intentional:
Ask three people at your firm — at different seniority levels — to describe their quality management responsibilities in one sentence. Their answers will tell you everything.
Add this issue's quality risk definition to your risk register. Use the free resource below as your starting point.
Host a 15-minute team conversation — not a training session, just a conversation — about what quality means in the context of each person's day-to-day role.
Remember, if it’s happening repeatedly, it’s no longer an exception. It’s a system failure.
Final thought
One last thing — and it's important.
Knowing the risk is only half the work. The harder question is this:
What does your firm's response look like?
How do you actually embed quality accountability across every role, every level, every engagement — in a way that survives a busy season, a staff turnover, and an inspection?
That's what Issue #7 is going to be all about.
Quality accountability is the black sheep of every firm's SoQM. Everyone knows it should be there. Nobody wants to own it.
It doesn't fail because one person dropped the ball. It fails because everyone assumed someone else was holding it.
If you like this newsletter, consider joining The ARQ — Assurance, Risk and Quality Network for SMP CPA and CA Firms.
It’s free.
You will get:
1 hour learning credit,
1 digital certificate
Peer insights and practical resources
Networking opportunity.
Click the image below to register for the next session of The ARQ.
Well, that's it for now — hope you found this useful.
If you've any feedback or questions, write to me at [email protected], and I will personally respond to your email.
Until next time,
Athreya
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