The countdown is on. On Dec. 15, the AICPA Quality Management Standards (SQMS Nos. 1 and 2) become effective.

For sole practitioners and local or regional firms, the deadline is real and time is short. From our research and discovery calls, we know plenty of firms have already implemented, either on their own or with our help, but far too many have not even started. Some are still reviewing templates, while others are unsure where to begin. This 25-day countdown turns implementation into practical daily steps—starting today—to help you design, document and adopt a working system before Dec. 15.

The AICPA Practice Aid provides a clear framework that already includes the eight components and a set of prepopulated risks and responses. While many firms are exploring software solutions, there is little time left to procure, configure and train before the effective date. Start simple with the AICPA Practice Aid now, then plan to move digital once your system is up and running.

This plan assumes weekdays only, with weekends and Thanksgiving left for rest, which is equally vital for driving quality. By following the daily activities, your firm will have a functioning system and a strong foundation for continuous improvement by Dec. 15.

Days 1 to 5 | Get Started

• Day 1: Create your SQM 2025 project folder. Download the AICPA Practice Aid and explore its tabs, instructions and layout to understand how the eight components connect.

• Day 2: Establish accountability. Under SQMS No. 1, designate the managing partner or CEO equivalent as the person with ultimate responsibility for quality management, and identify who manages it day to day. Document both roles and how they coordinate.

• Day 3: Define your structure. Map how authority and decisions flow through the firm. List who makes quality decisions, how information moves between teams, and how ethics, independence, and quality messages are shared.

• Day 4: Review client acceptance. Check how your firm evaluates new and recurring clients, confirms independence and approves engagements. Note strengths and gaps that need clearer documentation.

• Day 5: Review engagement performance. Examine how supervision, review and consultation occur in practice. Choose one or two engagements that show how quality is maintained and where it can improve.

Week 1 Reflection: You have explored the Practice Aid, assigned accountability and documented how your firm operates. Next, you will identify risks that could prevent those processes from working as intended.

Days 6 to 10 | Identify and Prioritize

• Day 6: Review the prepopulated risks in the AICPA Practice Aid. Read through the examples provided and note which ones are clearly relevant to your firm and which are not.

• Day 7: Build on your list by adding risks specific to your firm such as staffing limits, inconsistent reviews or reliance on subcontractors. Remove any that do not apply and revise descriptions so they reflect your firm’s actual environment.

• Day 8: Expand and refine your list. Consider broader factors such as growth, technology changes or resource constraints that could affect quality. Update the language for clarity and consistency.

• Day 9: Review and organize your list to ensure balanced coverage across all eight components. Eliminate duplicates, group similar risks and confirm each risk is stated in clear, simple terms.

• Day 10: Rank each risk by likelihood and impact. Review the rankings with others in your firm to confirm they make sense. This becomes your firm’s Quality Risk Summary for future monitoring and improvement.

Week 2 Reflection: You now have a prioritized list of quality risks that highlights strengths and vulnerabilities. Next, connect each risk to the policies and controls that mitigate it.

Days 11 to 15 | Connect and Complete

• Day 11: Gather existing firm policies and procedures such as acceptance forms, checklists, continuance memos, independence confirmations and training logs.

• Day 12: Map each risk to the policies or practices that already address it. Use the Practice Aid documentation of response column to note where coverage exists.

• Day 13: Review each mapped response to ensure it genuinely mitigates the risk. Adjust wording for clarity and accuracy.

• Day 14: Identify gaps where no controls exist. Draft new responses directly in the Practice Aid, describing what is done, who is responsible and when it occurs.

• Day 15: Review your cross mapping to confirm that every risk has at least one response. Your updated Quality Risk Summary should now reflect a complete and practical view of how your system operates.

Week 3 Reflection: You now have a connected map of risks and responses that shows how your system works. Next, you will test that system and fine tune it to ensure it performs as intended.

Days 16 to 20 | Test and Tune

• Day 16: Review your firm’s existing monitoring activities. Identify which ones make sense to keep, such as annual inspections, independence confirmations or training evaluations, and remove or revise any that are unnecessary or redundant.

• Day 17: Assign timing and responsibility for each monitoring activity, including who performs it and how results are communicated.

• Day 18: Evaluate your firm’s resources and capacity. Describe how competence is maintained through hiring, supervision, continuing education and the use of external specialists or reviewers.

• Day 19: Test your draft system in practice. Select one or two recent activities such as an engagement review, client acceptance or independence confirmation, and compare how they were performed to your documented process. Record where procedures align and where gaps or inconsistencies appear.

• Day 20: Act on your findings. Update your documentation to close any gaps, clarify responsibilities, and confirm that each process operates as intended across the firm.

Week 4 Reflection: Your system now functions on paper and in practice. Testing it should give you confidence that your documentation reflects reality. The final phase is to adopt, monitor and sustain it.

Days 21 to 25 | Adopt and Advance

• Day 21: Record formal adoption. Write “System of Quality Management adopted Dec. 15. Signed: [Your Name, CPA / Managing Partner].” Verify that the final version is dated and approved.

• Day 22: Create a one-page executive summary highlighting your eight quality objectives, top risks and key monitoring activities. Develop short training materials or slides to explain how the system operates and what is expected of team members.

• Day 23: Deliver training and communication to all audit and assurance professionals. Review the system’s purpose, structure and responsibilities, and obtain acknowledgment of their understanding.

• Day 24: Perform a final quality check. Review the entire document to confirm that risks, responses and monitoring activities are clear and complete. Once satisfied, archive your final version and recognize the milestone.

• Day 25: Activate your system. Build a 2026 action tracker listing recurring monitoring tasks, improvement plans and follow-ups. Assign due dates and responsible people to prepare for the year ahead.

End of Countdown Reflection: Congratulations! You have completed and adopted your system of quality management. What began as a daunting project is now a practical framework that reflects how your firm truly operates.

From here, the goal is to keep it active. Monitor, evaluate and improve regularly so quality becomes part of your daily routine rather than an annual task. The system you built over these twenty-five days will evolve with your firm, strengthening consistency, confidence, and continuous improvement.