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Regulations & Compliance · PDF

Peer Review after a Failed Practice Review: Timing, Reviewer and Report

The eight-page clarification answers 24 questions about the historical peer-review regime implemented on 1 April 2009. It includes the full minimum report information and suggested three-engagement template, while distinguishing peer review from hot review.

Source checked · 11 October 2026 Historical document

Who is subject to the historical peer-review order

Peer review is mandatory for a public accountant who fails the practice review and receives a revisit-review order. The document states implementation from 1 April 2009 and cites section 38(1)(a) of the Accountants Act as the power for the Oversight Committee’s order. Independent fellow professionals review the accountant’s work to improve quality. An accountant placed under a hot-review order is excluded from this peer-review requirement because an appointed hot reviewer already monitors the work during that period. The historical order and legislative references should not be treated as a complete account of every later inspection regime.

Complete three reviews within twelve months

Three audit engagements signed by the accountant must be reviewed within twelve months from the order date, with reviews preferably spaced across the period. Unlike hot review, peer review may occur before or after engagement completion and report sign-off. The accountant chooses timing without ACRA approval. Exceptional changes to working papers after the auditor’s report are governed by the cited SSA 230.13; post-report review does not authorise unrestricted rewriting of documentation.

Select significant engagements rather than only convenient files

The accountant selects engagements, generally from the fifteen largest clients by audit fees. Turnover, net profit, operational size, nature and complexity can also influence selection. The source describes the top-fifteen approach as general guidance rather than stating that fees are the sole factor. All three selected audit reports must have been signed by the accountant under the order.

Reviewer eligibility, independence and engagement terms

A suitably qualified registered public accountant who passed the practice review may act, provided there is no conflict or independence issue. A former public accountant who passed and kept sufficiently current on audit-process changes can also qualify. The document refers to the ISCA PMP review panel as a starting point if a reviewer cannot be sourced. No ACRA approval of selection is needed. Compensation is privately arranged and need not be reported to ACRA. Confirm appointment in an engagement letter covering scope, remuneration, confidentiality, responsibility and professional conduct.

Peer review does not transfer the signing accountant’s responsibility

The signing accountant retains integrity, independence, diligence, objectivity and professional-judgement obligations. The reviewer checks whether the three opinions rest on audits complying with SSAs and whether the financial statements comply with the Companies Act and SFRS. ACRA states it will not hold the peer reviewer responsible merely because the accountant fails the subsequent revisit. There is no prescribed review checklist or manual; reviewer discretion operates within the objective and relevant professional standards, not outside them.

A report provides evidence of compliance

Prepare a report documenting that the reviews occurred and the order was followed. Format is discretionary, but Annex A sets minimum information. ACRA or ICPAS-appointed reviewers request copies to evaluate effectiveness and compliance. Failure to appoint a reviewer or complete the process can result in disciplinary or enforcement action. Historical ICPAS references are retained as the source’s wording rather than used to imply a separate current institution.

Every minimum report field and the three-column template

Record the accountant under review and the reviewer’s name and registration number. For each engagement include the entity, year-end, engagement-letter date, partner/manager tenure, report type and sign-off date, subsequent-events procedure date, principal activities, overall and performance materiality, uncorrected detected misstatements, audit approach, risk areas, key issues, discussion and bases of judgements, and hours spent. Include findings for each engagement, commencement and completion dates, reviewer signature and report date. The suggested template presents engagements A, B and C in parallel, separates materiality into three monetary rows, and includes seventeen engagement rows plus findings and signature details. One minimum-list bullet says hot reviewer, while the document concerns peer review; this is an inconsistent label, not a requirement to appoint an additional hot reviewer.

Official source

This article independently explains the substantive contents of the official PDF, including the relevant conditions, procedures and annexes. The linked document remains the authoritative source for its original wording, and later changes should be checked separately.

Read the official PDF ↗
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