Changes to the Peer Review Program: Requirement for Completion of an Annual Emerging Areas Questionnaire
On November 11, 2025, the AICPA’s Peer Review Board voted to institute a required annual questionnaire for all firms enrolled in the peer review program.
The questionnaire and follow-up questions and activities will be programmed through PRIMA, the AICPA peer review program’s website.
What is the intent of the questionnaire?
The board believes that a peer review every three years is not sufficient to ensure that firms are up-to-date with emerging practice issues. The questionnaire is intended to identify changes in standards, emerging technology, and firm’s practices so they may be addressed prior to the next peer review.
When will this start?
The first required questionnaire will be distributed in June 2026 through PRIMA, and annually thereafter.
What happens if a firm doesn't comply?
If a firm fails to respond, the formal drop process will commence through PRIMA.
If a firm identifies emerging areas through the questionnaire, what is expected?
The AICPA is suggesting that firms respond to the identification of an emerging area by first responding to additional questions to help the firm assess the level of risk they have assumed or are considering assuming. A firm with higher risk associated with their work in an emerging area would be encouraged to participate in the discretionary review process.
Discretionary reviews would be performed by peer reviewers with training and experience in the emerging area.
Because this is a voluntary process, discretionary reviews will not have a formal due date.
How will this affect firms enrolled in peer review as a standard (no accounting and auditing) firm?
A small number of firms have chosen to remain enrolled in the program even though they are not performing accounting and auditing (A&A) work. These firms will also be required to complete the questionnaire annually or face the drop process.
These firms may choose to resign from the program. We would encourage firms to assess whether they intend on performing A&A engagements and, if not, consider resigning from the program. If you need help with the resignation process, please contact Lynette Lindner at lynettel@ctcpas.org or 860-259-1062.