Compliance Management, Audit and Due Diligence · Peer Review and Quality Review

Quality Review Procedure and Outcomes for Company Secretaries

Updated 11 October 2026 · Fact-checked

Quality review is the Institute's check of the work and practice systems of a Company Secretary in Practice. The reviewer examines records and working papers, reports findings, and the Board recommends action. Outcomes range from guidance and corrective steps to referral to the Disciplinary Directorate for repeated or serious failures.

Understand Quality Review Procedure and Outcomes

Quality review checks whether a practising Company Secretary or firm follows professional standards and has a sound system of quality control. Think of it as a health check on the practice. It is not an audit of the client.

The review moves in a fixed order. The Institute selects the practice and informs it. The reviewer asks for records, engagement files and policies. The reviewer then tests samples of completed work against standards and the Institute's guidance.

The reviewer records findings in a report. The practice gets a chance to explain. The reviewing body then evaluates the findings and recommends outcomes. These can be corrective, such as better documentation or training, or disciplinary, such as referral to the Disciplinary Directorate for professional misconduct.

The logic is the same as in the quality control standard, SQC 1. Its Section 95 says a firm's evaluation of each type of deficiency should lead to recommendations on one or more of four things: remedial action on an engagement or person, communication to those responsible for training, changes to quality control policies, and disciplinary action against those who fail to comply, especially repeatedly. Use this as your model for outcomes.

Exact timelines, forms and the composition of the review body come from the Institute's quality review guidelines and the Company Secretaries Act, 1980 and its rules. Check the latest text for them. Do not invent periods or penalties in an answer.

Key rules to remember

Outcomes of deficiencies (SQC 1, Section 95): Remedial action + communication to training + changes to policies + disciplinary action; Recommendations may include one or more of these four. Disciplinary action is aimed especially at repeated non-compliance.
Communicating deficiencies (Section 94): Monitoring findings + recommended remedial action → relevant engagement partners and other appropriate personnel; Findings must be communicated, not kept within the monitoring team.
Monitoring documentation (Section 100): Procedures (incl. selection of completed engagements) + evaluation + deficiencies, effect and further action; The evaluation covers adherence to standards and laws, design and effective implementation of the system, and whether reports issued are appropriate.
Monitoring responsibility (Section 88): Competent individuals with sufficient experience and authority; cover design and operating effectiveness; Review is of both how the system is designed and how it works in practice.
Engagement quality control review (Sections 60, 61, 67): Required for listed-entity audits; complete before report is issued; unresolved differences stop the report; The report is not issued until the matter is resolved through the firm's procedures for differences of opinion.

How to solve Quality Review Procedure and Outcomes questions

Use this order for any case-based or descriptive question on quality review procedure and outcomes.

1Identify who is being reviewed and what is under review: the practice, its system of quality control, or a specific engagement.
2State the procedure in sequence: selection, intimation, call for records, testing of samples, findings, opportunity to respond, report.
3Match each deficiency in the facts to a type: engagement-level, people or training, policy, or repeated or serious non-compliance.
4Apply the outcome rule: remedial action, communication to training, policy change, or disciplinary action (Section 95 logic).
5Decide whether the facts amount to repeated or serious failure. If so, state that referral to the Disciplinary Directorate is the consequence under the Institute's mechanism.
6Check documentation and communication: were findings recorded and communicated to the right persons (Sections 94 and 100)?
7Conclude with a clear recommendation and one practical compliance step.

Quickest way: Four-bucket outcome check

When to use it: Use when a short case asks what action follows a deficiency found in review.

Label the deficiency: one engagement, a person, a policy gap, or repeated breach.
Pick the matching bucket: remedial action, training communication, policy change, or discipline.
Add: communicate to the engagement partner and record the evaluation.
Escalate to the Disciplinary Directorate only if the facts show serious or repeated non-compliance.

Common mistakes in Quality Review Procedure and Outcomes

Treating quality review as a punishment exercise.
Students focus on the Disciplinary Directorate and forget the other outcomes.
Fix: List all outcomes. Most findings lead to corrective action. Discipline is for serious or repeated failure.
Confusing quality review with an audit of the client's accounts.
Both involve working papers and reports.
Fix: Say that the review examines the practitioner's work and systems, not the client's compliance.
Quoting invented timelines, fees or penalty amounts.
Students try to sound precise.
Fix: State the procedure in principle and refer to the Institute's guidelines for exact periods.
Ignoring the reviewer's independence and competence.
Students skip the monitoring responsibility rule.
Fix: Mention that monitoring is done by competent persons with sufficient experience and authority (Section 88).
Saying the report can be issued despite unresolved reviewer concerns.
Mixing up review recommendations with optional advice.
Fix: Under Section 67, the report is not issued until the matter is resolved through the firm's procedure for differences of opinion.
Forgetting documentation.
Students describe only actions, not records.
Fix: Add that procedures, evaluations, deficiencies and the basis for further action are documented (Section 100).

Worked examples

Example 1

A quality review of a practising Company Secretary's firm finds that engagement files lack documentation of significant judgments, and two staff members are unaware of the firm's checklist. The firm had no earlier findings. What outcomes should the review recommend?

Show the solution

The review is of the firm's system and engagement files, not the client.
The deficiencies are documentation gaps at engagement level and a training gap among staff.
Under the Section 95 logic, remedial action on the affected engagements is appropriate, and findings go to those responsible for training.
The firm may also need to change its policies, for example by making the documentation checklist mandatory.
There is no repeated breach, so discipline is not the natural outcome.
The findings should be communicated to the engagement partners with recommended action (Section 94) and recorded (Section 100).

Answer: Recommend remedial action on the files, training for staff, and a policy change on documentation. Communicate and record the findings. Referral to the Disciplinary Directorate is not indicated on these facts.

Example 2

In a later review, the same firm again shows the same documentation failures despite earlier recommendations, and a partner ignored them. What consequences may follow?

Show the solution

The deficiency is repeated and was previously communicated.
Section 95(d) points to disciplinary action against those who fail to comply, especially repeatedly.
The review body should evaluate the effect of the failures and record the basis for further action (Section 100).
Under the Institute's mechanism, the matter may be referred to the Disciplinary Directorate for examination as possible professional misconduct.
Corrective steps still continue alongside this, such as training and policy changes.

Answer: Repeated non-compliance after recommendations can justify referral to the Disciplinary Directorate, together with continued corrective measures.

Exam tips

Write the procedure as a sequence and add outcomes in a separate short list. Examiners reward structure.
Use the four outcomes of Section 95 as your checklist in every case question.
Distinguish minor and repeated or serious deficiencies before recommending discipline.
Do not state exact timelines or penalty amounts unless you are sure of them from the Institute's text.
End with a clear conclusion and a practical compliance step.

Practice questions from Peer Review and Quality Review

Quality Review Procedure and Outcomes in other exams

The same ground in other exams, if you are preparing for more than one or want another angle on it.

ACCA Strategic ProfessionalAudit Quality, Quality Reviews and Regulatory Inspection

Quality Review Procedure and Outcomes: frequently asked questions

What happens if a company secretary fails quality review?

The findings are reported and the practitioner can respond. Outcomes usually start with corrective action such as better documentation and training. For repeated or serious failures, the matter can be referred to the Disciplinary Directorate.

Does quality review always lead to disciplinary action?

No. Recommendations can be remedial, training-related or policy changes. Disciplinary action is mainly for those who fail to comply, especially repeatedly.

Who carries out the monitoring or review?

Competent individuals with sufficient and appropriate experience and authority. They examine both the design of the quality control system and how effectively it operates.

Is quality review the same as an engagement quality control review?

No. Engagement quality control review is an objective check of significant judgments on a specific engagement before the report is issued. Quality review looks at the practice and its systems more broadly.