Conducting an On-Site Peer Review Visit — A Reviewer's Playbook

The on-site visit is the heart of every Peer Review. It's the 5-6 working days where the reviewer walks into the Practice Unit's office and tests both the firm's quality-control system (Compliance Procedures) AND specific sample engagement files (Substantive Procedures). Get this right and your Form 9 + Annexures practically write themselves. Get it wrong and you'll be issuing a Preliminary Report with weak evidence — which the PU's representation will easily challenge.

This playbook walks the reviewer through the on-site visit end-to-end.

Before you arrive — preparation (Day 8-10)

Most rookie reviewers under-prepare. The Form 1 they received already tells them everything about the PU. Use it.

Pre-visit checklist: 1. Re-read Form 1 Part B (SQC 1 questionnaire) — note every "No" response and items with vague Yes responses 2. Re-read Form 1 Part C (AQMM) — note any inflated self-scores 3. List 3-5 high-risk engagements from the sample for substantive testing — biggest clients, listed entities, FRRB-flagged files 4. Prepare a sample-engagement request list to give the PU at the start of the visit 5. Plan 2-3 firm-level interviews — managing partner, engagement-quality control partner (if any), HR head 6. Bring printed Compliance Procedures checklist (~11 items) + Substantive Procedures checklist (~14 items)

Send the PU a written intimation 2 working days before arrival listing the engagement files they should keep ready.

Day 1 — Opening meeting + Compliance Procedures kick-off

Morning:

• Opening meeting with managing partner (30-45 min)
• Walk the agenda for the visit
• Confirm working hours and office logistics
• Get firm's SQC 1 manual (or equivalent policy document)
• Begin Compliance Procedures — test the SQC 1 system
• Element 1: Leadership Responsibilities — who's the QC partner? Is it in writing?
• Element 2: Ethical Requirements — independence declarations on file per engagement?

Afternoon:

• Continue Compliance Procedures
• Element 3: Client Acceptance/Continuance — documented process? Risk-rated?
• Element 4: Human Resources — recruitment, training, performance evaluation

Day 2 — Compliance Procedures completion + Sample selection

Morning:

• Element 5: Engagement Performance — supervision evidence, EQCR for listed audits, consultation process
• Element 6: Monitoring — internal monitoring / cold-file review evidence

Afternoon:

• Review AQMM Part C in detail (if listed-entity PU)
• Walk every item against actual firm documentation
• Note the differences between PU's self-score and your independent re-score
• Finalise the sample of engagement files for substantive testing
• Confirm Annexure B size + 10 selection criteria are satisfied
• Add any specific engagements you want tested (high-risk, partner-concentration, FRRB-related)

Days 3-5 — Substantive Procedures (engagement-file testing)

This is where 60% of your visit time goes. For each sampled engagement:

A. Engagement setup

• Engagement letter on file (SA 210), signed before audit work commenced
• Independence declaration for THIS engagement
• Audit planning memorandum (SA 300) — scope, timing, resources
• Risk assessment procedures (SA 315) — entity, environment, internal controls
• Materiality determined and documented (SA 320), re-assessed during the audit

B. Audit evidence

• Sufficient + appropriate evidence (SA 500)
• Sampling methodology documented (SA 530)
• Related-party transactions identified, evaluated (SA 550)
• Going-concern assessment performed (SA 570)
• Management representation letter obtained on the audit report date (SA 580)

C. Reporting

• Communication with TCWG (SA 260, 265)
• Audit report complies with SA 700 series
• UDIN generated and quoted
• Audit file assembled + archived within 60 days (SQC 1 / SA 230)

Documentation tip: For each engagement, write a 1-page summary: clean / minor observations / major observations. Reference the specific working-paper page numbers where issues were found.

Day 6 — Synthesis + Preliminary findings

Morning:

• Aggregate Compliance + Substantive findings
• Decide: is the system adequate (Cl. 9(1) — straight to Final Report Unqualified) OR NOT adequate (Cl. 9(2) — issue Preliminary Report)?

Afternoon:

• Closing meeting with managing partner
• Share preliminary observations verbally
• Listen to clarifications — many "issues" resolve when the partner explains context
• Decide whether to issue a written Preliminary Report

If issuing a Preliminary Report, the deadline is Day 17 of the 20-WD clock (1 WD after review completion). PU's representation is due Day 19 (2 WD).

Writing the Preliminary Report (Appendix XII format)

Per Cl. 9(2), the Preliminary Report should:

• List specific observations referenced to SQC 1 element OR Standard on Auditing
• Reference the specific engagement file where issue was identified (without naming the client publicly)
• State the impact on the audit opinion (if any)
• NOT include advice or suggestions — Advisory ¶17 explicitly forbids reviewers from "suggesting" remediation. Stick to pointing out deficiencies.

Receiving the PU's representation (Cl. 9(3))

The PU has 2 WD to respond. Common responses:

• Documentation existed but wasn't in the file you saw → ask for the documentation to be added to the file (this becomes part of the audit trail)
• Disagreement on facts → ask for written supporting evidence
• Acknowledgement + remediation plan → note in your conclusion

Reviewer's view is final on factual conflicts (Cl. 24(3)(iii)) — the PU cannot overrule you on what was or wasn't in the file. But you must consider their representation in good faith.

Day 20 — Final Report + Form 9 submission

You have 1 WD from receipt of the PU's representation to submit Form 9 with all attachments to the PRB:

1. Final Report — Unqualified (Appendix XIII-A) OR Qualified (Appendix XIII-B) 2. Annexure I — Process particulars + Q/A summary 3. Annexure II — SQC 1 compliance (all firms) 4. Annexure III — AQMM re-score with differences explained (listed-entity only) 5. Sample list with basis of selection per the 10 criteria 6. Preliminary Report (if issued) + PU's representation + your verification 7. PU's filled Form 1 copy 8. Fee receipt in your individual capacity

All annexures must bear the same date as the Final Report (Advisory ¶27). Use your personal/individual letterhead — firm letterhead is prohibited (Advisory ¶1, 21).

What you can't do

• No extracts of PU client files (Cl. 30(3), Advisory ¶35) — you can review but not photocopy or take working-paper extracts
• No advice or suggestions in the Preliminary Report — only observations
• No accepting any professional assignment from the PU for 2 years post-review (Cl. 26(3))
• No firm letterhead — always personal capacity
• No EQCR-style critique — Peer Review is not engagement quality control review; it's about the system

Form 7 fallback — if it's running long

If the on-site visit looks like it'll take more than 6 WD (e.g., the PU has 15 branches you need to cover, or you've identified material issues requiring deeper testing), file Form 7 jointly with the PU before Day 20 elapses. Standard request: 10-15 additional WD.

Closing thought

A good on-site visit is 65% Substantive, 35% Compliance, methodical, well-documented, and ends with a Closing Meeting that the PU doesn't dread. The reviewer's job isn't to "fail" PUs — it's to ensure the system is sound and to surface improvements the PU should make in the next cycle.

Our Peer Reviewer Tool Visit tab gives reviewers a 25-item Compliance + Substantive procedures checklist with SQC 1 / SA references baked in. Tick as you go. The system also tracks visit start/end dates with 6-WD cap enforcement and Annexure I/II/III attachment status for Form 9.

Questions on a specific on-site testing item? WhatsApp CA Jatin Tagra at +91 99531 40464.