California Board of Accountancy

Peer Review Reporting

I submitted a Peer Review Reporting Form to the CBA during the three-year phase-in period. When do I need to report again?

Beginning January 1, 2014, the CBA will require all licensees to report their specific peer review information at the time of license renewal. The revised CBA Regulation section 45 is available on the CBA website at http://www.dca.ca.gov/cba/laws_and_rules/regs6-s45.shtml.


If I have to submit a Peer Review Reporting Form to the CBA every two years with my license renewal, do I have to have a peer review every two years?

No. Even though reporting will be done at the time of license renewal, peer reviews are still only required every three years. This means for some years you will report the same peer review results two renewal cycles in a row.


I am not a sole proprietor. Do I need to submit a Peer Review Reporting Form?

Yes. Although not all CPAs are required to undergo peer review, ALL licensees must report to the CBA by submitting a Peer Review Reporting Form at the time of license renewal.


Since the CBA does not maintain a record of individual licensees who operate as sole proprietorships, you are required to respond even if only to report that you do not operate as a sole proprietorship.


My firm, as its highest level of work, performs only compilations where no report is issued in accordance with the provisions of Statements on Standards for Accounting and Review Services (SSARS). Do I need to submit a Peer Review Reporting Form?

Yes. Although not all firms are required to undergo peer review, ALL firms must report to the CBA by submitting a Peer Review Reporting Form at the time of license renewal.


Since the CBA does not maintain a record of services provided by firms, you are required to respond even if only to report that you are not performing any services that require you to undergo a peer review.


Once I notify the CBA that I am not required to undergo a peer review, do I need to submit a Peer Review Reporting Form again in the future?

Yes. All firms and CPAs will be required to report to the CBA by submitting a Peer Review Reporting Form at the time of license renewal.


Does a firm's Peer Review Reporting Form encompass all of the individual licensees employed at the firm?

No. Individual licensees must submit a Peer Review Reporting Form for their individual license number. Individuals working for a firm or that are shareholders or partners of a firm, are not subject to peer review, but must still submit a Peer Review Reporting Form to the CBA at the time of license renewal.


I operate as a partnership. Do I need to report for my individual license and my partnership number?

Yes. You must submit separate Peer Review Reporting Forms for your individual license and any corporation and/or partnership licenses you maintain. For your individual license, you will report that you are not operating as a firm. Your partnership will report it is operating as a firm and whether or not it is subject to peer review.


I maintain a CPA license in California, but practice in another state. Do I need to submit a Peer Review Reporting Form?

Yes. Peer Review is a condition of license renewal in California regardless of where you practice.


I undergo peer review to maintain a license in another state. Can I report the out-of-state peer review to California?

Yes. As long as the peer review report is accepted by a California Board-recognized peer review program, it will meet the peer review requirement for California. Currently, the American Institute of Certified Public Accountants (AICPA) is the only Board-recognized peer review program in California.


I submitted my Peer Review Reporting Form with incorrect information. How can I correct it?

You must submit another Peer Review Reporting Form to the CBA for correction. The form must be clearly marked "Corrected Copy." You can request a form by e-mailing the Peer Review Unit at peerreviewinfo@cba.ca.gov.


What will happen if I fail to submit a Peer Review Reporting Form to the CBA?

Failure to submit a Peer Review Reporting Form to the CBA at the time of license renewal may delay processing and may also result in the CBA initiating enforcement action.


What other or additional reporting requirements do I have?

If you receive a substandard peer review, you must notify the CBA within 45 days and submit a copy of the peer review report to the CBA at:



California Board of Accountancy
Attn: Peer Review Analyst
2000 Evergreen Street, Suite 25
Sacramento, CA 95815-3832


You must also notify the CBA within 30 days if you are expelled by a Board-recognized peer review program and provide the name of the Board-recognized peer review program and the reason(s) given by the peer review program for the expulsion.


Participating in Peer Review

What is peer review?

Peer review is a systematic review of a firm's accounting and auditing services performed by a peer reviewer who is unaffiliated with the firm being reviewed to ensure work performed conforms to professional standards.


Is a sole proprietorship considered a firm in California?

Yes. Business and Professions Code section 5035.1 defines a firm to include a sole proprietorship.


Who is required to undergo peer review?

Peer review is required for all California-licensed firms, including sole proprietorships, that perform accounting and auditing services using the following professional standards:

  • Statements on Auditing Standards (SAS)
  • Statements on Standards for Accounting and Review Services (SSARS)*
  • Statements on Standards on Attestation Engagements (SSAE)
  • Government Auditing Standards (Yellow Book)
  • Audits of non-Security Exchange Commission (SEC) issuers performed pursuant to the standards of the Public Company Accounting Oversight Board (PCAOB)

*Firms, which as their highest level of work, perform only compilations where no report is issued in accordance with the provisions of SSARS are not required to undergo peer review.


If a firm performed only one accounting and auditing engagement, will it still be required to undergo a peer review?

Yes. There is no exclusion from the peer review requirement based solely on the number of engagements performed.


Are there any exclusions from the peer review requirement?

Yes. There are two exclusions from the peer review requirement.

  1. Any of a firm's engagements subject to inspection by the Public Company Accounting Oversight Board's (PCAOB) inspection program.
  2. A firm, which as their highest level of work, performs only compilations where no report is issued in accordance with the provisions of Statements on Standards for Accounting and Review Services (SSARS).

Does a firm need to submit its peer review report to the CBA?

A firm that receives a substandard peer review rating is required to submit the peer review report, along with any materials documenting prescription of remedial or corrective actions, to the CBA within 45 days after the report is accepted by the Board-recognized peer review program provider.


A firm that receives a peer review rating of pass or pass with deficiencies is not required to submit the peer review report. The firm will only need to complete the Peer Review Reporting Form and submit it to the CBA at the time of license renewal.


What are Board-recognized peer review program providers?

A Board-recognized peer review program provider is an organization that is recognized to administer peer reviews in California. Board-recognized peer review program providers will work with firms to ensure peer reviews are completed timely, firms select peer reviewers with a currency of knowledge of the professional standards to the type of practice to be reviewed, and review and accept the peer review report.


Presently, only the AICPA is recognized by the CBA to administer peer reviews. The AICPA uses several administering entities nationally, usually state certified public accountant societies, to administer its peer review program.


The California Society of Certified Public Accountants (CalCPA) administers the AICPA Peer Review Program in California. CalCPA can be contacted at (650) 522-3094 or peerreview@calcpa.org. Their website is www.calcpa.org.


The National Peer Review Committee (NPRC) administers peer reviews for firms that are required to be registered with and inspected by the PCAOB and firms that perform audits of non-Securities and Exchange Commission issuers pursuant to the standards of the PCAOB. The NPRC can be contacted at (919) 402-4502.


How does a firm select a peer reviewer?

A firm is required to enroll in a Board-recognized peer review provider program. Once enrolled, the provider will assist in a firm's selection of a qualified peer reviewer to ensure that the peer reviewer has a currency of knowledge of the professional standards related to the type of practice to be reviewed.


How can a firm receive an extension of time to undergo a peer review?

Should an extension of time be needed to have a peer review report accepted by a Board-recognized peer review program, the firm shall submit the extension request to the Board-recognized peer review program provider with which the firm is enrolled. If the extension granted extends past the firm's reporting date, the firm shall notify the CBA of the extension and provide proof of the extension. The firm shall then report the results of the peer review to the CBA within 45 days of the peer review report being accepted by the Board-recognized peer review program.


How long does it take to undergo a peer review?

Please contact the Board-recognized peer review program provider for timeframes. If undergoing a peer review for the first time, please allow sufficient time for the peer review engagement and acceptance by the Board-recognized administering entity.


How much will a peer review cost?

Please contact the Board-recognized peer review program provider for the cost to enroll in the peer review program. The fee for the peer review is negotiated between the licensee and the peer reviewer.


I am subject to peer review, but am planning on retiring and renewing my license inactive. Do I need to have a peer review?

No. Effective January 1, 2013, only licensees renewing in an active status or converting to active status are required to have a peer review. If you renew in an inactive status, you do not need to have a peer review. However, you are required to submit a Peer Review Reporting Form to the CBA at the time of license renewal.


Do I need to have a peer review if I'm dissolving my corporation/partnership?

No. Peer reviews are a condition of license renewal. A peer review would not be required if the corporation/partnership is dissolved and the CBA is notified of the dissolution prior to the renewal of the license.


Contact the CBA's Renewal/Continuing Competency Unit at (916) 561-1702 for information on dissolution.


In 2012, my firm completed a peer review which covered the year that ended December 31, 2011. The firm issued a few compilation reports in early 2012, but has not issued any since then. Does the firm need another peer review?

Yes. The firm will need another peer review (in three years) if any compilation, review, or audit reports were issued after the period covered by the last peer review.


In 2012, as a sole proprietor, I had a peer review completed for the year that ended December 31, 2011. I issued a few compilation reports in 2012, and then merged my sole proprietorship into an existing partnership. Do I need another peer review prior to renewing my CPA license?

Yes. If you issued any compilation, review, or audit reports after the period covered by your last peer review, you will need another peer review in three years.


What will happen if I fail to complete a mandatory peer review?

Failure to complete a mandatory peer review may result in the CBA initiating disciplinary action against your license.