External monitoring by our regulators
KPMG has a number of regulators due to the types of services we provide. This includes the Financial Reporting Council (FRC), the Institute of Chartered Accountants in England and Wales (ICAEW), the Financial Conduct Authority (FCA), the Solicitors Regulation Authority (SRA), audit third country regulators, and other regulatory and oversight bodies (including HM Government). We’re committed to meeting the expectations of our regulators and ensuring our regulatory engagement is based on the principles of openness, transparency, integrity and accountability. [FRC and ICAEW noted in intro section so decide if spell out in full in that section depending on revisions to final para]
The regulatory environment continues to evolve. Accordingly, we continually scan the horizon and prepare the firm for incoming regulatory changes. In particular, we continue to engage and work with the FRC to help shape the future for a profession that is attractive and retains skilled professionals who produce high-quality audits, acting in the public interest.
The results from the FRC’s Audit Quality Review (AQR) inspection, as well as the ICAEW’s annual inspection, together with the results of our own internal monitoring programme, and those of any other regulator including the Public Company Accounting Oversight Board (PCAOB) in the US, provide an overview of our performance of quality engagements. In addition, the FRC’s Audit Market Supervision (AMS) team assesses the firm’s ongoing design and operation of our Systems of Quality Management (SoQM). The FRC’s Audit Firm Supervision (AFS) team is responsible for the overall supervision of Public Interest Entity (PIE) audit firms, drawing together the results of work undertaken by the AMS and AQR as well as other areas of the FRC.
Audit quality is our number one priority, and we value the constructive input and challenge from the FRC through their inspection and supervision process. We continue to work closely with the FRC to understand their identified areas of good practice, and importantly where we need to continue to focus to ensure that we build trust and confidence in our profession and the markets.
FRC – Audit Quality Inspection and Supervision Report findings
89% of FRC inspections required no more than limited improvements
2023/24
(2022/23: 74%)
(2021/22: 84%)
88% of FTSE 350 inspections required no more than limited improvements
2023/24
(2022/23: 78%)
(2021/22: 91%)
No audits inspected required significant improvements
2023/24
(2022/23: One)
(2021/22: None)
The FRC's Audit Quality Inspection and Supervision report listed areas of good practice and aspects where improvement was required.
In individual audits, good practice included examples relating to risk assessment and planning, execution, and completion and reporting. Areas for improvement included instances relating to estimates, risk assessment and response to internal control deficiencies.
2023/24 was a transitional inspection cycle covering both the International Standard on Quality Management (UK) 1 (ISQM1) and the International Standard on Quality Control (UK) 1 (ISQC1). The report included a section for the first time on our firm-wide SoQM, with examples of good practice and areas for improvement.
Section 4 of the report focused on the FRC’s forward-looking supervisory approach – identifying and prioritising what firms must do to improve audit quality and enhance resilience. There, we saw recognition of how our SQP is embedded in the business and supporting our strategy:
The firm’s SQP is at the forefront of the firm’s regulatory strategy, integral to the business and a driver to sustained audit quality.”
The report also called out the significant process we have made in the last year with our Root Cause Analysis (RCA).
The firm has responded positively to feedback on its RCA process – investing significantly in the RCA team, redesigning the approach and refreshing the categories of causes. The benefits have been visible through the FRC’s engagement in 2023, including in the RCAs performed by the firm on six of the 2023/24 AQR inspections. The changes helped to ensure a clear thought process with multiple data sources when identifying the root cause.”
We will continue to evolve our root cause and remediation processes, focusing on evaluating the effectiveness of actions.
The FRC's report is available to read at the above link.
ICAEW - Monitoring review by the Quality Assurance Department
10 reviews were performed by the Quality Assurance Department of the ICAEW
2023
(2022: 11)
(2021: 12)
70% of the ICAEW reviews were assessed as “Good / generally acceptable”
2023
(2022: 91%)
(2021: 75%)
One audit reviewed required improvements
2023
(2022: None)
(2021: One)
The ICAEW identified good practice across the files reviewed which included:
- Clear evidence of challenge to management in areas including impairment testing, property valuations, revenue and going concern.
- Well-organised work on contract and non-contract revenue.
- Comprehensive documentation including group audit considerations, borrowings and going concern.
Our ICAEW results saw a slight decline this year. Our continuing commitment to enhancing audit quality saw two teams challenging prior period accounting in the year following the reviews. They identified an arising difference in the subsequent period’s financial statements which the firm reported to the ICAEW, prior to the finalisation of their review. We consider it good practice for teams to continuously improve audit quality and realise the benefit from the independent challenge of reviews.
For a summary of the QAD’s review findings, refer to the FRC’s Audit Quality Inspection and Supervision report for KPMG LLP (2024).
PCAOB
KPMG in the UK is subject to inspection every three years by the US PCAOB. In accordance with this cycle, the PCAOB was due to inspect during 2021. However, as a result of the COVID-19 pandemic, the PCAOB deferred its inspection to 2022. The firm received the final inspection report in 2024 with no Part I Inspection Observations and is required to respond to the findings by the deadline of March 2025.
Regulatory investigations and sanctions1
Ongoing FRC matters
At the end of the financial year, there was one ongoing FRC investigation into matters announced in previous years, in respect of the audit of Carr’s Group plc for the period ended 28 August 2021.
New FRC matters or developments on ongoing matters during the year
No new FRC investigations were opened during the year.
FRC matters closed during the year
One matter, which related to an audit in 2018, was closed during the year:
- In March 2024, the FRC announced sanctions against KPMG LLP and a partner of KPMG LLP relating to the audit of the financial statements of M&C Saatchi plc for the financial year ended 31 December 2018. KPMG LLP was fined £1,462,500 and severely reprimanded. The partner was fined £48,750 and severely reprimanded.
ICAEW matters
One ICAEW investigation outcome was announced during the year. This related to the audit of the financial statements of two entities by KPMG LLP.
Internal monitoring
KPMG firms have agreed to use quality monitoring and compliance programmes developed by KPMG International are used by KPMG firms to identify quality issues, perform root cause analysis and develop remedial action plans, both for individual audits and for their overall SoQM. The programmes evaluate:
- Engagement performance in compliance with the applicable professional standards, applicable laws and regulations, and key KPMG International policies and procedures.
- Our firm’s compliance with KPMG International policies and procedures and the relevance, adequacy and effective operation of key quality control policies and procedures.
The internal monitoring and compliance programmes also contribute to the evaluation of our SoQM operating effectiveness. These programmes include:
- Audit Quality Performance Review (QPR).
- KPMG Quality and Compliance Evaluation (KQCE) – formerly known as the Risk Compliance Programme (RCP).
- Global Quality and Compliance Review (GQCR)
The results of the integrated monitoring and compliance programmes are communicated at local, regional and global levels (as relevant) and we establish action plans to make improvements where needed. Results are also considered by KPMG International.
Audit Quality Performance Review (QPR) programme
The Audit QPR programme is the cornerstone of our efforts to monitor engagement quality. It assesses engagement level performance and identifies opportunities to improve engagement quality.
Risk-based approach
All engagement leaders of statutory and non-statutory audits and other assurance engagements are generally subject to selection for review at least once in a three-year cycle. A risk-based approach is used to select engagements.
We conduct the annual QPR programme in accordance with KPMG International QPR instructions, which promote consistency across the KPMG organisation. Responsibility for the QPR programme lies with our firm’s Risk Management Partner. Reviews are overseen by an independent experienced lead reviewer from another KPMG firm. QPR results are reported to KPMG International.
Evaluations from Audit QPR programme
Across the global organisation, consistent criteria are used to determine engagement ratings and KPMG firm Audit practice evaluations. Definitions of engagement ratings are explained below:
Compliant
When the audit work performed, the evidence obtained and the documentation compiled comply with internal policies, auditing standards and legal and regulatory requirements in all significant respects with no or only minor instance(s) of non-compliance; and key judgements concerning significant matters in the audit and audit opinion are appropriate.
Compliant - improvements needed (‘CIN ’)
When the auditor’s report is supported by evidence and is not incorrect in any material respects, but the independent reviewer required additional information to reach the same conclusion as the auditor; or where supplementary information obtained as part of the audit was not sufficiently documented in the audit; or where specific requirements of our audit methodology were not embedded; or where improvements to audit procedures were identified as needed in one or more areas and such improvements were judged to be more than minor but not significant. A ‘CIN’-rated engagement is not considered an adverse quality outcome.
Not Compliant
When the auditor did not perform the engagement in line with KPMG’s professional standards and policies in a more significant area, or where there are deficiencies in the related financial statements. Where appropriate, in a limited number of cases we remediate engagement files to ensure the audit evidence obtained is adequately documented and engagement teams undertake specific incremental or remedial training. In addition, engagement leaders receiving a Not Compliant rating are subject to at least one follow-up review.
Reporting
Prior to the finalisation of the review, there is a rigorous moderation process to ensure consistency of grading. A remedial action plan is created for quality audit and assurance in which deficiencies were identified which are considered to be significant, applicable at an engagement and a firm level. We share our findings from the Audit QPR programme through internal training tools and in periodic partner, manager and team meetings. Any issues are also emphasised in subsequent monitoring and compliance programmes to gauge the extent of continuous improvement and the effectiveness of the implementation of remedial actions. Lead engagement partners are notified when an assurance engagement on a cross-border subsidiary or affiliate of their audited entity receives a Not Compliant rating.
Our Audit QPR programme is designed to hold audit teams to quality levels that assess not only compliance with auditing standards but also adherence to internal requirements such as the performance of specified procedures or completion of specific mandated consultations. As such, teams that perform audits that are very substantially compliant with auditing standards may receive a rating other than Compliant in our internal reviews. Accordingly, it is difficult to make direct comparisons between the results of our internal and external inspection processes.
- Percentage of gradings at Compliant / Compliant – Improvements Needed / Not Compliant: (FY24 results 73% Compliant, 20% Compliant – Improvements Needed, 7% Not Compliant)
- Percentage of engagement leaders reviewed: 36%
- Number of engagements reviewed: 136
Rating / Compliant
Rating / Compliant - improvements needed
Rating / Not Compliant
Number of engagements reviewed
KPMG Quality and Compliance Evaluation (KQCE) programme
The KQCE programme encompasses the testing and evaluation requirements of a KPMG firm’s SoQM which are necessary to support both their compliance with ISQM1, and compliance with the firm’s quality and risk management policies. KQCE programme requirements are mandated for all KPMG firms. The 2024 KQCE programme covers the period from 1 October 2023 to 30 September 2024.
Monitoring, remediation and evaluation of the SoQM
Monitoring activities include:
- Testing of UK Member Firm SoQM controls performed in the UK and overseas, and at a Network level (including general IT controls).
- Review of ‘other sources’ e.g. QPR and GQCR findings, root cause analysis, regulatory developments etc. Please see ISQM1 section in Quality Control & Risk Management, for more information.
The evaluation of the SoQM involves the identification and assessment of findings from our monitoring activities, including any deficiencies. Judgement is required to assess whether findings result in a deficiency, and the severity and pervasiveness of any deficiencies, individually and in aggregate. Those judgements include considering both the significance of findings to the achievement of quality objectives and the extent to which actions taken up to the evaluation date mitigate the effects on the SoQM. Such judgements are made by the monitoring team, overseen by the Chief Risk Officer, and the final evaluation is scrutinised and independently challenged by the Audit Committee. Our evaluation of the effectiveness of our SoQM is set out here.
Compliance testing
During the year, member firms were required to self-assess their overall levels of compliance with quality and risk management policies not in scope of the SoQM as either compliant, substantially compliant or non-compliant.
For the year ended 30 September 2024, our approach to quality and risk management policies was rated [Update this when evaluation completed (early December, but likely to be same outcome)] substantially compliant (defined as where significant compliance findings are not pervasive in nature and action plans to address their identified causes have either already been implemented or substantially implemented or are planned to be implemented within a timeline which will allow for compliance testing in the succeeding period).
Action plans to address the identified root causes of SoQM Deficiencies and Compliance Findings have been developed and are in the process of being delivered. The status of remediation is monitored by the Risk, Operations and Audit Executives and is overseen by the Audit Committee.
Global Quality and Compliance Review (GQCR) programme
The GQCR program is a KPMG International monitoring program. The objective of the GQCR program is to assess a firm’s compliance with selected KPMG International policies, including those related to governance and SoQM.
Firms are selected for review using a risk-based approach, which considers a number of factors, including financial conditions, country risks, results of monitoring programmes and people surveys, with each firm subject to a GQCR at least once in a four-year cycle.
The GQCR team performing the review comprises partners and managers who are independent of the firm subject to review.
The UK firm was subject to a GQCR review during 2024 when (this needs to be updated when the GQCR report is finalised in mid-September) a number of opportunities for improvement were identified, including areas which were also generally identified by the UK firm’s Audit Quality and Banking Audit Quality Improvement Plans, Risk Compliance Programme/KPMG Quality and Compliance Evaluation and other compliance and quality control processes. Implementation of these improvements is largely complete.
- Critically assess audit evidence, using professional judgement and scepticism.
- Direct, coach, supervise and review, including Second Line of Defence and EQCR.
- Appropriately support and document conclusions.
- Consult when appropriate.
How an audit is conducted is as important as the result. Everyone at KPMG is expected to demonstrate behaviours consistent with our values and follow policies and procedures in the performance of effective and efficient audits.
How we apply this in the UK
Critical assessment of audit evidence, exercise of professional judgement and professional scepticism
We consider all audit evidence obtained during the course of the audit, including consideration of anything that is contradictory or inconsistent. This analysis requires each of our team members to exercise professional judgement, maintain professional scepticism and demonstrate appropriate challenge to obtain sufficient and appropriate audit evidence.
Professional judgement and scepticism training is embedded in our core audit technical training programme for junior staff and ongoing training and workshops for more experienced staff.
Timely senior involvement and monitoring of milestones
The engagement leader is responsible for the overall quality of the audit engagement and therefore for its direction, supervision and performance. Involvement and leadership from the engagement leader early in the process helps set the appropriate scope and tone for the audit. To reinforce this, we mandate the completion and review of audit planning activities within specified timeframes to evidence completion of the relevant planning activities.
The engagement leader reviews key audit documentation – in particular, documentation relating to significant matters arising during the audit and conclusions reached. The engagement manager assists the engagement leader in meeting these responsibilities as well as in the day-to-day liaison with the audited entity and monitoring of engagement milestones.
Involvement of our Second Line of Defence
Our Second Line of Defence team is a group made up of senior auditors which supports our higher risk engagements with a focus on public interest and listed entities. The team performs in-flight reviews of audits to improve the quality of audit execution and documentation, including effective challenge of management in judgemental areas. These senior auditors also help throughout the audit cycle, to identify issues before they impact audit quality. This has a dual purpose: firstly, to enable coaching of teams and, secondly, to act as another level of review and challenge to help engagement teams in the delivery of high-quality audits. In addition, it informs our ongoing horizon scanning for emerging issues that may require broader responses.
Appropriate and timely involvement of specialists
Our engagement teams have access to a network of specialists, which may include involving UK specialists or those from other KPMG member firms. Our audit methodology requires the involvement of relevant specialists in the core audit engagement team when certain criteria are met or where the audit team considers it appropriate or necessary.
Appropriate involvement of the Engagement Quality Control Reviewer
Our Engagement Quality Control Reviewers (EQCRs) are independent of the engagement team and have appropriate experience and knowledge to perform an objective review and challenge of the more critical and judgemental elements of the audit. The audit report can only be released when the EQCR is satisfied that all significant questions raised have been resolved.
An EQCR is appointed for the audits, including any related review(s) of interim financial information, of all listed entities, non-listed entities with a high public profile, engagements that require an EQCR under applicable laws or regulations, and other engagements as designated by the Audit Risk Management Partner or the Chief Auditor.
Ongoing mentoring and on-the-job coaching, supervision and review
To invest in building the skills and capabilities of our professionals, we adopt a continuous learning environment. We support a coaching culture throughout KPMG as part of enabling colleagues to achieve their full potential.
Our Coaching for Quality programme, which was developed with the support of external behavioural psychologists, gives colleagues the tools they need for productive coaching conversations.
New engagement leaders are also provided with an experienced mentor to support their transition into this critical role.
Appropriately supported and documented conclusions
Audit documentation records the audit procedures performed, evidence obtained, and conclusions reached on significant matters on each audit engagement. Our policies require review of documentation by more experienced engagement team members.
Standardised approaches and workpapers assist our audit teams with appropriately supported and documented conclusions.
Monitoring our progress
The results of our external and internal monitoring processes can be found in the ‘Activities during the year’ tab above.