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AICPA quality management changes will require new firm documentation by Dec. 15, 2025, OSCPA warns
Summary
OSCPA and committee members said the AICPA’s shift from quality control to quality management standards means firms must create a quality management document by 12/15/2025 or face automatic pass-with-deficiency peer-review ratings; OSCPA is running outreach and templates.
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Darlene Bowles, OSCPA peer review program representative, told the committee the AICPA has shifted to a quality management standard and firms must have a documented system in place by Dec. 15, 2025. "If they don't, it'll be an automatic, pass with deficiency, re‑rating on the report," Bowles said, and stressed the change affects firms of all sizes, from sole practitioners to large regional firms.
Committee members said the OSCPA and AICPA have posted resources and that many firms—especially smaller practices—may not yet be aware of the new documentation requirement. John Howell, speaking from experience as a reviewer, recommended firms use published practice aids and vendor templates as starting points to personalize their documentation.

