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What Are You Actually Supposed to Document in an SQMS Risk Assessment?

August 25, 2026

A firm risk assessment under SQMS No. 1 requires three connected pieces (paragraphs 24–27):

1Quality Objectives
2Quality Risks
3Responses

The framework is straightforward, but documenting it in a way that meets the requirements and is practical to maintain takes some thought. Below, I break down what the guidance actually requires, along with practical considerations for building your own matrix.

Using the AICPA’s risk assessment matrix? See my previous article for guidance specific to that template.

1

Quality Objectives

SQMS No. 1 prescribes quality objectives for each component (paragraphs 29–34). Paragraph A44 notes that firms are unlikely to need additional objectives.

For most firms, this step is straightforward: start with the prescribed objectives and evaluate their relevance to your firm’s circumstances.

If an objective is not relevant, document why.
How the CCC Risk Matrix Handles It

The Excel-based risk matrix includes all prescribed quality objectives, with:

  • ·Relevance dropdowns for each objective
  • ·Pre-documented explanations for common circumstances where an objective is not relevant, which firms can tailor
  • ·Pre-linked suggested quality risks associated with each objective

The result: A clear, traceable risk assessment that helps your firm demonstrate coverage of applicable quality objectives without building the connections from scratch.

2

Quality Risks

SQMS No. 1 requires firms to identify and assess risks that could prevent achievement of their quality objectives (paragraph 26). This means considering the firm’s size, structure, leadership, resources, engagements, and other relevant circumstances.

Not every possible risk needs to be documented. A quality risk is one that has a reasonable possibility of occurring and adversely affecting achievement of one or more quality objectives.

You don’t have to write every risk from scratch.

The AICPA Quality Management Practice Aid and PPC materials provide extensive libraries of suggested risks. The challenge is determining which actually apply to your firm, rather than copying every example into your assessment.

I recommend reviewing risks with firm leadership to identify vulnerabilities, evaluate the suggested risks, and add any firm-specific risks.

Do risks have to be scored? No. SQMS No. 1 permits formal ratings or scores but does not require them (paragraph A50).

How the CCC Risk Matrix Handles It

I’ve already done much of the groundwork. The matrix consolidates and organizes suggested quality risks, with pre-drafted language tailored to three firm structures:

  • ·Sole Practitioner
  • ·Single-Office Firm
  • ·Multi-Office Firm with Centralized Leadership

Each version includes:

  • ·Pre-drafted quality risks for firms to evaluate and tailor
  • ·Likelihood and magnitude ratings with suggested supporting explanations
  • ·Pre-linked objectives and responses for clear traceability throughout the assessment

The result: Your firm can focus on evaluating its actual risks rather than spending hours building and organizing a risk library.

3

Responses

SQMS No. 1 requires firms to design and implement policies and procedures that address their assessed quality risks (paragraph 27). The responses should be based on, and responsive to, the reasons for those risk assessments.

Paragraph 59 also requires firms to document their responses and explain how they address the identified quality risks.

Start with the risk, not the policy manual.

Many firms already have policies and procedures in place, whether developed internally or adapted from PPC or AICPA materials. The question is whether those responses appropriately address the firm’s actual risks.

If a policy or procedure doesn’t link to an identified risk, consider whether it’s separately required by the standard, addresses a risk you’ve overlooked, or simply reflects unnecessary legacy language.

The goal isn’t the longest policy manual. It’s a system of policies and procedures that addresses the risks your firm actually faces.

How the CCC Risk Matrix Handles It

The matrix includes a dedicated responses tab, with:

  • ·Pre-drafted policies and procedures commonly applicable to each firm type, ready for evaluation and tailoring
  • ·Pre-linked quality risks showing which risks each response is designed to address
  • ·Export-ready formatting so finalized policies and procedures can be organized and communicated to firm personnel

The result: A clear connection between your firm’s quality risks and the policies designed to address them, without building the documentation from scratch.

One More Consideration: Monitoring

Your risk assessment also lays the groundwork for monitoring. SQMS No. 1 requires firms to consider their risk assessments and responses when designing monitoring activities (paragraph 38).

As you finalize your responses, consider what evidence will demonstrate that they’re actually being performed.

The CCC Risk Matrix includes suggested monitoring references and supporting evidence for each policy and procedure. The full SQMS Toolkit builds on those references with corresponding monitoring templates and checklists.

What Should the Finished Risk Assessment Show?

A partner or peer reviewer should be able to follow the logic from beginning to end:

Quality Objectives
→
Quality Risks
→
Risk Assessment
→
Responses
→
Evidence & Monitoring

SQMS No. 1 allows firms to scale their risk assessment process and documentation to their size and complexity (paragraph A40).

Regardless of the format, the documentation should clearly connect the firm’s quality objectives, assessed risks, and responses.

Rather Not Build Your Own?

The CCC Risk Assessment Matrix is designed to save firms the time of compiling, drafting, and organizing their risk assessments from scratch.

With pre-drafted risks and responses, built-in links between objectives, risks, and policies, and suggested monitoring references, your firm can focus on evaluating and tailoring the documentation rather than building the framework.

Explore the CCC Risk Assessment Matrix
Next step

Talk through your firm's risk assessment.

Book a complimentary 30-minute call if you're deciding how to approach your firm's documentation, or want to see the Risk Assessment Matrix and the rest of the SQMS Toolkit.

Prefer email? caroline@carolinecast.cpa

This article is intended for general educational purposes and reflects practical experience applying SQMS No. 1. It is not authoritative AICPA guidance or a substitute for reviewing the applicable professional standards and considering your firm's specific facts and circumstances.