Practice Note

PIE Auditor 14
Registration

Guidance for Transitional Applications

August 2022
Contents
Page

1. Introduction 2

2. Submitting a Transitional Application 2

3. Supporting statement 4

4. Information gathering and sharing 10

5. Assessment of Transitional Applications 10

6. Granting a Transitional Application 11

7. Granting a Transitional Application with Undertakings 12

8. Granting a Transitional Application with Conditions 13

9. Refusing a Transitional Application 13

10. Internal Review 14

11. Appeals 14
12. Failing to register 14

FRC | PIE Auditor Registration | Guidance for Transitional Applications 1

1. Introduction
1.1. The Public Interest Entity (PIE) Auditor Registration Regulations (the Regulations), which take
effect on 5 December 2022, require that, to undertake Statutory Audit Work1 for PIEs, (i)
audit firms and (ii) Responsible Individuals (RIs) who are, or may be, responsible for signing
an Audit Report for a PIE, must be on the FRC’s PIE Auditor Register (PAR).

1.2. The Regulations provide for a Transitional Period which begins on 5 September 2022 and
ends on 4 December 2022. During the Transitional Period, audit firms who are, at the start of
the Transitional Period, undertaking Statutory Audit Work for a PIE should make a
Transitional Application to be included on the PAR. Successful Applicants will thereby be
registered on the PAR by 5 December 2022 and so will avoid any potential interruption to
their PIE related Statutory Audit Work. Prospective Applicants should consider Part 6 and
Annex 1 of the Regulations when assessing whether they are eligible to make a Transitional
Application.

1.3. This guidance is designed to assist audit firms in the making of Transitional Applications. It
should be read in conjunction with the Regulations, which take precedence over this
guidance.

1.4. If audit firms have any questions regarding the application of the Transitional Regulations
and/or the making of Transitional Applications which are not addressed in this guidance,
they are encouraged to liaise with the FRC in a timely manner. All enquiries should be
directed to registration@frc.org.uk.

2. Submitting a Transitional Application

2.1. The FRC has a compendium of audit firms that audit PIEs. The FRC intends to contact each of
those audit firms prior to the commencement of the Transitional Period to provide them
with access to the Transitional Application form (which is an MS Forms document) and an
MS Excel spreadsheet (which should be used to provide the details of an Applicant firm’s
designated RIs).

2.2. The Transitional Regulations do not provide for the making of Transitional Applications by
RIs. However, audit firms that submit Transitional Applications must designate the RIs they
wish to be PIE Registered RIs for the purposes of that Transitional Application. Audit firms
must also confirm that the designated RIs meet the Registration Requirements in Part 5 of
the Regulations.

2.3. In addition to completing the electronic Transitional Application form and an MS Excel
spreadsheet with the list of RIs it wishes to designate as PIE Registered RIs, an Applicant
audit firm must:

1
Definitions and interpretations of the terminology used in this guidance can be found in Part 2 of the Regulations, with the exceptions that ‘audit firm’ and ‘RI’ are used
instead of 'Statutory Audit Firm', ‘PIE Registered Audit Firm’ and ‘PIE Registered RI’.

FRC | PIE Auditor Registration | Guidance for Transitional Applications 2

 • Confirm that it will adhere to the Regulations and all other relevant regulations, procedures
and rules of the FRC;

• Submit details of:

a. the number of PIE Audit Reports it has signed in the last 12 months (or any longer
period agreed by the FRC);

b. the number of PIE Audit Reports it expects to sign in the next 24 months (or any
longer period agreed by the FRC);

c. the Recognised Supervisory Body (RSB) with which it is registered and with which
each of its designated RIs is registered;

• Submit a supporting statement (see section 3 below) which briefly explains how it meets the
Registration Requirements in Part 4 of the Regulations;

• For each of its designated RIs, confirm that they:

a. have signed PIE Audit Reports in the last 12 months (or any longer period agreed by
the FRC);

b. are expected to sign PIE Audit Reports in the next 24 months (or any longer period
agreed by the FRC);

c. have undertaken continuing professional development in the last 12 months (or any
longer period agreed by the FRC) that is appropriate for PIE Statutory Audit Work;

d. meet the Registration Requirements in Part 5 of the Regulations.

2.4. Additionally, the audit firm will be required to submit a list of its PIEs, along with the
assigned RIs. The list should also indicate who the assigned RI for each PIE will be in the next
12 months and the following 12 months, if this is different from the current information.

2.5. The completed Transitional Application form must be submitted as instructed on the form.
All supporting documentation should be submitted via the Applicant audit firm’s dedicated
FRC SharePoint site. Details of how to access the SharePoint site will be communicated to
audit firms prior to 5 September 2022.

2.6. The Transitional Application form requires Applicant audit firms to provide details of a
Principal Authorised Contact (PAC). All correspondence from the FRC regarding the
Transitional Application and related registration matters will be addressed to the Applicant’s
PAC (and/or any Authorised Contact appointed and authorised by the PAC).

2.7. Applicant audit firms should use their RSB registration number and submission ID, as
appropriate, in all correspondence with the FRC regarding PIE auditor registration. This
registration number will be the key identifier used by the FRC in all casework and
correspondence concerning the Applicant.

FRC | PIE Auditor Registration | Guidance for Transitional Applications 3

3. Supporting statement
3.1. As noted at paragraph 2.3 above, Applicant audit firms are required to submit a supporting
statement as part of their Transitional Applications. In this, the Applicant needs to explain
briefly how they meet certain Registration Requirements found in Part 4 of the Regulations.
The table below explains which of the Registration Requirements must be explained in the
supporting statement.

3.2. Using the relevant Registration Requirements as headings, the supporting statement of each
Applicant audit firm should:

• include a brief description of the relevant policies, procedures and resources that the audit
firm has in place in respect of its PIE related Statutory Audit Work;

• confirm that it meets the relevant Registration Requirements;

• include confirmation from its PAC that the Applicant audit firm has satisfied itself that it
currently meets each Registration Requirement and that it will continue to do so for so long
as it is registered on the PAR (with any potential non-compliance being flagged); and

• be dated and signed-off by the PAC, who must have authority to confirm the veracity and
accuracy of all declarations made on behalf of the Applicant audit firm.

3.3. It is essential that Applicant audit firms are open and honest in their supporting statements,
including by highlighting any potential weaknesses within the audit firm’s procedures to the
FRC. The responses audit firms give in the supporting statement may be subject to scrutiny
during the course of the FRC’s inspection and quality assurance activity.

3.4. During the Transitional Period, the FRC will be unable to review large volumes of
documentation, and therefore Applicant audit firms are requested not to submit large
documents to support their Transitional Applications. Compliance with the Registration
Requirements in Transitional Applications should be demonstrated through summary
statements rather than detailed explanations and supporting documents.

3.5. The table below provides guidance on how Applicant audit firms should demonstrate, in a
Transitional Application, their compliance with each of the Registration Requirements, either
through a confirmation in the Transitional Application form, or through their supporting
statement. The FRC expects responses to be proportionate to the size and complexity of the
Applicant audit firm and the number of PIEs for which it undertakes Statutory Audit Work.

Registration Requirement Guidance for Transitional Applicants

Reg 4.1(i) and (ii) – The audit firms meets To be confirmed in the Application form.
the Eligibility Criteria and is a Statutory
Audit Firm

FRC | PIE Auditor Registration | Guidance for Transitional Applications 4

 Reg 4.1(a) knows, or has reasonable
grounds to believe, it will undertake at
least one audit of a PIE within the period
of 24 months
Reg 4.1(b) has designated one or more
individuals to apply to be PIE Registered
RIs and has authorised and supports the
Applications of these individuals to be PIE
Registered RIs
4.1(c) has in place, and will maintain,
procedures to determine the continuing
competence, experience and fit and
proper status both of its designated PIE
Registered RIs and of all of its Principals
and employees involved in PIE Statutory
Audit Work (including any such Principal
or employee who is not a PIE Registered
RI)
FRC | PIE Auditor Registration | Guidance for Transitional Applications
To be confirmed in the Application form.
To be confirmed in the Application form and Excel
spreadsheet.
In the Transitional Period, RIs will not formally make
Applications. The Applicant audit firm will be required
to provide an Excel spreadsheet along with its
Application form, which lists all the RIs the audit firm
wishes to designate as PIE Registered RIs together
with details of each designated RI’s RSBs. The
Applicant audit firm must also confirm that all the
designated RIs meet the Registration Requirements.
To be explained and confirmed in the supporting
statement.
Continuing competence and experience
The Applicant audit firm must explain the procedures
it has in place for ensuring the ongoing training and
development of all staff involved in PIE Statutory
Audit Work. The Applicant audit firm may wish to
reference the following in its supporting statement:
• The audit firm’s annual training plan
• How personal development plans are formulated
• How the audit firm meets the training
requirements of the relevant RSBs
• Whether the audit firm provides any sector-
specific training pertinent to its PIE audit portfolio
• Whether the audit firm subscribes to any
periodicals
• How the audit firm ensures staff comply with its
prescribed training plans
5

Reg 4.1(d) has in place, and will
maintain, procedures to ensure all
Principals and employees involved in PIE
Statutory Audit Work are aware of, and
comply with, these Regulations
Reg 4.1(e) can satisfy the FRC of its
suitability to be a PIE Registered Audit
Firm including demonstrating that it is fit
and proper
Reg 4.1(f) has provided all necessary
evidence and information with its
Application, along with any further
explanations required by the FRC
FRC | PIE Auditor Registration | Guidance for Transitional Applications
• How the audit firm evaluates the success of
training
• How the audit firm ensures learning has been
embedded
Fit and proper procedures
The Applicant audit firm must provide an overview of
what internal processes are in place for confirming
the fitness and propriety of its staff involved in PIE
Statutory Audit Work; for example, by explaining if
the audit firm carries out an annual fit and proper
check.
To be explained and confirmed in the supporting
statement.
The Applicant audit firm must explain how all staff
involved in PIE Statutory Audit Work, including those
who are not required to be registered with the FRC,
will be made aware of the requirements of the
Regulations.
Furthermore, the Applicant audit firm must set out
the processes it will put in place to enable all of its PIE
Registered RIs to comply with the Registration
Requirements found in Part 5 of the Regulations. This
will include ensuring appropriate and timely
notifications to the FRC when there is a Relevant
Change affecting a PIE Registered RI.
To be confirmed in the Application form.
The Applicant audit firm must confirm that it is fit and
proper. The Applicant audit firm must also confirm it
has provided any updates to its RSB, as required by its
RSB’s procedures for fit and proper disclosures.
To be confirmed in the Application form.
6
 Reg 4.1(g) has paid to the FRC and/or its
RSB, any registration fees set by the FRC
and/or its RSB in relation to its Statutory
Audit Work, including for PIEs
Reg 4.1(h) has, and will maintain, in
place appropriate resources and an
appropriate system of quality
management to enable it to perform PIE
Statutory Audit Work to the required
standards
FRC | PIE Auditor Registration | Guidance for Transitional Applications
To be confirmed in the Application form.
Fees relate to the relevant RSB’s fees for registration
as a Statutory Auditor. The FRC has not currently set
any additional fees for registration on the PAR.
To be explained and confirmed in the supporting
statement.
Appropriate resources
The Applicant audit firm must explain how it has
sufficient financial and non-financial resources,
enabling it to perform PIE Statutory Audit Work to the
required standards.
Audit firms may wish to reference the following:
• How the audit firm plans and allocates resources
(including people and other costs) for its PIE
Statutory Audit Work
• Staffing levels (and trends in levels) for audit
teams dealing with PIE Statutory Audit Work
• Industry and technical specialisms of audit teams
dealing with PIE Statutory Audit Work
• Processes and measures for assessing appropriate
capacity of audit teams working on PIE Statutory
Audit Work
• Methods of seeking regular feedback from teams
working on PIE Statutory Audit Work, e.g.
feedback surveys
• Budgeting and forecasting for future resource
needs in PIE Statutory Audit Work
Appropriate systems of quality management
The requirements for audit firms in respect of systems
for quality management are set by the International
Standard on Quality Control (ISQC)1, which is
transitioning to the International Standard on Quality
Management (ISQM)1. An Applicant audit firm must
summarise its design and implementation strategy in
7

Reg 4.1(i) has, and will maintain,
governance arrangements, Principals,
management and ownership interests in
the PIE Registered Audit Firm, which are
suitable to operate and/or control a
business that carries out PIE Statutory
Audit Work
FRC | PIE Auditor Registration | Guidance for Transitional Applications
respect of ISQM1. The summary should include a
description of the internal resources the audit firm
has allocated to quality management.
The FRC would expect an Applicant audit firm’s
approach to quality management to be proportionate
to the size and complexity of the Applicant firm and
the size and complexity of its PIE audit portfolio.
To be explained and confirmed in the supporting
statement.
The FRC issues the Audit Firm Governance Code
(AFGC), which the FRC expects audit firms should
apply if they audit 20 or more PIEs or if they audit one
or more FTSE 350 companies (This is the revised Code
which is applicable to financial years beginning on or
after 1 January 2023)
The AFGC states that audit firms that fall below this
threshold may wish to apply the AFGC in a manner
that is proportionate to the size of the firm and the
nature of the entities they audit.
It is not a requirement that all audit firms applying for
PIE auditor registration should apply the full AFGC,
unless the thresholds are met. Nonetheless, Applicant
audit firms may wish to use the AFGC to structure this
section of their supporting statement, setting out how
the audit firm’s leadership, as well as its people,
values and behaviours, are appropriate for an audit
firm working in the PIE market.
All audit firms must comply with ISQC/ISQM1 in
relation to governance. Applicant audit firms who are
not in scope of the AFGC may wish to reference how
they comply with the relevant ISQC/ISQM
requirements in their response.
Applicant audit firms may also wish to provide a high-
level organisational chart, indicating which individuals
perform key roles in respect of PIE Statutory Audit
Work.
8
 Reg 4.1(j) has in place (or will have in
place prior to commencing any PIE
Statutory Audit Work) and will continue
to have during the period that it is
registered, at least the Minimum Level of
Professional Indemnity Insurance and has
supplied its Professional Indemnity
Insurance information to the FRC
To be explained and confirmed in the supporting
statement.
The Applicant audit firm must confirm it meets the
minimum requirements as set by its RSB. The audit
firm should also confirm that its actual level of cover
is commensurate to the size and risk of its portfolio of
PIE audits. The audit firm may also wish to discuss any
risk-assessments that have been undertaken in
respect of PII cover for its PIE Statutory Audit work.

The audit firm may wish to provide the FRC with a

copy of its PII policy document.

Reg 4.1(k) has agreed that the FRC, the To be confirmed in the Application form.
FRC’s directors and staff and the FRC’s
Board and Committees cannot be held
liable for damages for anything done or
not done in dealing with the functions
connected with registration under these
Regulations, unless the act or omission is
shown to have been in bad faith

Reg 4.1(l) has provided the FRC with the To be confirmed in the Application form.
contact details of its Principal Authorised
Contact

Reg 4.1(m) has supplied and will supply To be confirmed in the Application form.
information or documents that may be
required by the FRC to demonstrate
compliance with the Registration
Requirements

Reg 4.1(n) commits to: To be confirmed in the Application form.

i. comply with these Regulations,

and other relevant regulations,
procedures or rules of the FRC,
including the Audit Firm
Governance Code (where
relevant);

FRC | PIE Auditor Registration | Guidance for Transitional Applications 9

 ii. comply with any Conditions
and/or Undertakings attached
to its entry on the PAR;

iii. deal with the FRC, including its

staff and representatives, in an
open, cooperative and timely
manner;

iv. notify the FRC in writing as

soon as possible, and in any
event within 10 working days,
of becoming aware of a
Relevant Change; and

v. comply with all relevant

legislation, auditing standards,
ethical standards and quality
control standards relating to
PIE related Statutory Audit
Work.

4. Information gathering and sharing

4.1. Prior to making a decision on a Transitional Application, the FRC may gather information
and/or take account of any information that is otherwise available to it from any source and
which, in either case, it considers to be relevant to the Application (including in relation to
any of the Applicant audit firm’s designated RIs).

4.2. FRC personnel who are considering an Application may make enquiries of other sections of
the FRC. The FRC may also make enquiries of the Applicant audit firm’s RSB and the RSBs of
any of the Applicant audit firm’s designated RIs.

4.3. While the primary purpose of the enquiries referenced at paragraph 4.2 is to collect
additional information that is relevant to a Transitional Application, the FRC may also ask for
verification of the information contained in the Transitional Application.

5. Assessment of Transitional Applications

5.1. Once it is in receipt of a duly completed Transitional Application, together with all
supporting documentation and information, the FRC will process the Application and make a
decision on it. As noted above, provided Transitional Applications are received in good time,
the FRC’s objective is to process all Transitional Applications and communicate outcomes to
Applicants during the Transitional Period. Transitional Applications will not, however,

FRC | PIE Auditor Registration | Guidance for Transitional Applications 10

 automatically be granted within the Transitional Period given the public interest in ensuring
audit firms on the PAR meet the applicable requirements.

5.2. Straightforward Transitional Applications (i.e. Applications which do not raise any
compliance issues and in respect of which neither Undertakings nor Conditions are
proposed) will be processed, and a decision taken, within 25 working days of the date on
which all required documentation and information has been submitted to the FRC (including
any required clarifications/confirmations). More complex Applications, such as those where
Undertakings are being agreed or the FRC is proposing to attach Conditions, will require
additional time. Where this is the case, the FRC will notify the Applicant (before the expiry of
the above-mentioned 25 working day period) that additional time is needed, why the
additional time is needed and by when the FRC’s decision will be made. Applications that are
not processed within the above-mentioned time-periods will not be deemed to have been
granted.

5.3. In making a decision, the FRC will decide whether the Application meets the requirements of
the Regulations, and whether there is any reason in the public interest not to grant the
Application. Following the assessment of a Transitional Application the FRC may:

• Grant the Application

• Invite the Applicant to agree Undertakings to which the Applicant’s PAR registration will be
subject

• Inform the Applicant that the FRC is considering attaching Conditions on their PAR
registration (which may be in addition to Undertakings)

• Inform the Applicant that the FRC is considering refusing the Application.

5.4. Where Undertakings and/or Conditions are being considered, the Application will not be
granted until any associated process in respect of the putting in place of Undertakings or
Conditions has concluded.

5.5. While RIs cannot make Transitional Applications, the FRC will assess every Applicant audit
firm’s designated RIs as part of its assessment of the relevant Applicant audit firm’s
Application.

5.6. Accordingly, Applicant designated RIs may be approved for entry on the PAR without
Undertakings and/or Conditions; approved for entry on the PAR with Undertakings and/or
Conditions; or may not be approved. Where the FRC is proposing to agree Undertakings
and/or attach Conditions to a designated RI’s approval, it will communicate separately with
the relevant Applicant audit firm, and the affected designated RI (via the PAC).

6. Granting a Transitional Application

6.1. Where a Transitional Application is granted, the FRC will issue a Registration Notice to the
Applicant audit firm’s PAC. Paragraphs 3, 4 and 5 of the Transitional Regulations list the
information that will be included in the Registration Notice.

FRC | PIE Auditor Registration | Guidance for Transitional Applications 11

6.2. Part 3 of the Regulations sets out the details that will appear on the PAR.

6.3. The FRC will also set out in the Registration Notice, sent to the Applicant audit firm’s PAC,
details of the designated RIs who have been approved (without Undertakings or Conditions).
A separate Registration Notice may be issued regarding the audit firm’s designated RIs
whose registration has been approved with Undertakings and/or Conditions, or whose
registration has been refused.

7. Granting a Transitional Application with Undertakings

7.1. As noted in section 5 above, the FRC may determine that a Transitional Application should
only be granted subject to Undertakings. The FRC may determine that Undertakings are
necessary either in the public interest or in order for the Applicant audit firm and/or any of
its designated RIs to meet the Registration Requirements. Where Undertakings are being
considered, the FRC will write to the Applicant audit firm and/or any of its affected,
designated RIs (via the PAC), setting out the reasons why Undertakings are thought
necessary, and outlining the proposed Undertakings.

7.2. The FRC will propose Undertakings which address the specific issues identified, as well as the
individual circumstances of the Applicant audit firm and/or any affected, designated RI(s).

7.3. The Applicant audit firm and/or each of its affected, designated RIs are likely to be given the
opportunity to comment on the proposed Undertakings within a timeframe set out by the
FRC. Applicants may, for example, wish to suggest practical amendments to the proposed
Undertakings.

7.4. Once any amendments have been agreed, or if none have been requested, the FRC will write
to the PAC with an invitation to agree Undertakings. The Applicant audit firm and/or each of
its affected, designated RIs must respond in writing within 10 working days, via the PAC, to
confirm whether they agree to the Undertakings.

7.5. Once the Undertakings have been agreed, the FRC will send the Applicant audit firm’s PAC
the Applicant audit firm’s Registration Notice which will indicate that the Application has
been granted subject to Undertakings. The Registration Notice will include details of those
of the Applicant’s designated RIs who have been approved (including whether the approval
is subject to Undertakings and/or Conditions). Paragraphs 4 and 5 of Annex 1 of the
Regulations describe the information that will be included in the Registration Notice.

7.6. The FRC may publish information relating to an Undertaking if it considers it to be in the
public interest to do so. The FRC is developing its PIE auditor registration publications policy.
This will be published separately to this guidance, with the FRC’s aim to publish it in
September 2022.

7.7. If an agreement on Undertakings is not reached, or if a response to the invitation to agree

Undertakings is not received within the specified timeframe, the FRC may consider whether
the Application should be granted with Conditions. Alternatively, the FRC may consider
whether to refuse the Application.

FRC | PIE Auditor Registration | Guidance for Transitional Applications 12

8. Granting a Transitional Application with Conditions
8.1. Upon reviewing a Transitional Application, the FRC may consider that the Application should
only be granted subject to Conditions. The FRC may determine that Conditions are
necessary either in the public interest or in order for the Applicant audit firm (or any of its
designated RIs) to meet the Registration Requirements.

8.2. Where the FRC is considering Conditions, it will follow the process outlined in Part 8 of the
Regulations. The FRC will write to the Applicant audit firm and/or any of its affected,
designated RIs (via the PAC) to notify them that the FRC is considering applying Conditions
and inviting the Applicant audit firm and/or each of its affected, designated RIs to provide
written representations within the specified Notice Period (during the Transitional Period,
the FRC will encourage Applicants to provide their representations in less than 20 days).

8.3. Once representations have been received, or if no response is received within the Notice
Period, the FRC will reach a final decision on whether or not the Application should be
granted with Conditions.

8.4. The FRC may decide to grant the Application without Conditions or to seek to agree
Undertakings, as an alternative to Conditions. The FRC may also consider whether to refuse
the Application.

8.5. If the FRC decides the Application should be granted subject to Conditions, the FRC will
issue a Registration Notice to the Applicant’s PAC indicating that the audit firm’s Application,
or the registration of one of its designated RIs, has been granted subject to Conditions.
Paragraphs 4 and 5 of Annex 1 of the Regulations describe the information that will be
included in the Registration Notice.

8.6. The FRC may publish information relating to Conditions unless it believes it is not the public
interest to do so. As noted above, the FRC is developing its PIE auditor registration
publications policy.

9. Refusing a Transitional Application

9.1. Where the FRC decides that a Transitional Application does not meet the requirements of
the Regulations, or that it would not be in the public interest to grant the Application, the
FRC will write to the Applicant audit firm (via the PAC) in accordance with paragraph 7.4 of
the Regulations to notify them of the FRC’s intention to refuse to grant the Application and
inviting their representations within the Notice Period.

9.2. Once representations have been received, or if no response is received within the Notice
Period, the FRC will reach a final decision on whether or not to refuse the Application.

9.3. After considering any representations received, the FRC may, instead, consider whether the
Application should be granted with Conditions or seek to agree Undertakings. The FRC may
also grant the Application without Undertakings or Conditions.

FRC | PIE Auditor Registration | Guidance for Transitional Applications 13

9.4. If the FRC decides that the Application should be refused, the FRC will notify the Applicant
audit firm’s PAC of the decision in writing in accordance with paragraph 7.5 of the
Regulations.

10. Internal Review

10.1. The grounds for requesting an Internal Review and the procedure for the FRC to conduct an
Internal Review of certain decisions made in respect of a Transitional Application can be
found in Part 14 of the Regulations.

10.2. An application for Internal Review should be submitted with supporting evidence where
necessary. The request for review should be sent to registration@frc.org.uk. Requests made
in respect of Transitional Applications should be made promptly and, in any event, should be
submitted within 20 working days of the date of the relevant Registration Notice, Formal
Notification or other notification of the decision being challenged. Requests submitted
outside of this timeframe will only be considered in exceptional circumstances.

10.3. The Internal Review shall be conducted by a person or persons who are at least as senior as
the original decision maker(s) and who were not involved in the original decision. The
reviewer(s) will have the same powers available to them as the original decision maker(s).

10.4. Paragraph 14.6 of the Regulations sets out the potential outcomes from an Internal Review.

10.5. Once the reviewer(s) have made a decision, the FRC will communicate the decision to the
Applicant audit firm in a Formal Notification addressed to the PAC, in accordance with
paragraph 14.7 of the Regulations.

11. Appeals
11.1. The option to appeal a decision only becomes available once the Internal Review process
outlined above has been exhausted.

11.2. The audit firm or RI who wishes to bring the Appeal must make the request for Appeal in
writing to the FRC within 20 working days of the date of the Formal Notification of the
outcome of the Internal Review, stating the grounds of appeal. The request for Appeal
should be sent to registration@frc.org.uk.

11.3. Further details on the Appeals process can be found in Part 14 of the Regulations and in the
Appeal Rules at Annex 2 of the Regulations. Further guidance and policies on matters
affecting Appeals is expected to be issued by the FRC in due course.

12. Failing to register

12.1. On and from 5 December 2022, audit firms and RIs may only undertake PIE related Statutory
Audit Work if they are PIE Registered Audit Firms or PIE Registered RIs, as appropriate.

FRC | PIE Auditor Registration | Guidance for Transitional Applications 14

12.2. If the FRC becomes aware of PIE related Statutory Audit Work being (or having been or
about to be) carried out by an audit firm other than a PIE Registered Audit Firm or by an RI
other than a PIE Registered RI, it may, amongst other things, consider instigating an
investigation and, if appropriate, take enforcement action in relation to that conduct under
the FRC’s Audit Enforcement Procedure.

FRC | PIE Auditor Registration | Guidance for Transitional Applications 15

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