A small firm's audit capacity is set by who is on the payroll in September. Work arrives in a few months and cannot be spread out the way staffing can. The firms that handle this well do not hire in January. They keep a bench: a known group of people who can step in for a season, who have already been through the firm's onboarding and who the engagement partner can rely on.
This guide is about process: roles, onboarding, supervision and the compliance points that apply when some of the team is seasonal, contract or remote. It does not rely on labor-market statistics, because a bench is built from specific people and not averages. For scheduling and workload, see managing busy season and audit capacity planning.
Why the bench is a quality issue, not only a staffing one
The standards put the responsibility squarely on the engagement partner. Under AU-C 220 (SAS 146), which applies to engagements for periods beginning on or after December 15, 2025, the engagement partner must determine that sufficient and appropriate resources are assigned or made available to the engagement team in a timely manner, and that the team collectively has the appropriate competence and capabilities, including sufficient time, to perform the engagement. If resources are insufficient, the partner must take action, including asking for more.
SQMS No. 1, which became effective on December 15, 2025, puts the same idea at firm level: the firm's system of quality management must address the resources assigned to engagements. A bench is how a small firm answers that requirement in practice. It turns "we will find someone" into a named list of people with documented competence.
Three kinds of bench member
Returning seasonal staff. People who work a defined season each year, often a former employee, a semi-retired professional or an accountant with a seasonal schedule. They know the firm's templates and clients. They are the most valuable bench members because they require the least supervision, and they are usually employees on a recurring seasonal basis.
Contract or per-engagement staff. Individuals or firms engaged for specific engagements or a block of hours. They bring flexibility and need clearer instructions and tighter review, because they do not know the firm's methodology or the client.
Remote team members. Anyone who works from outside the firm's office, whether employee or contractor. The label describes location, not status, and each group above can be remote.
Keep a one-page profile for every bench member: credentials, industries and engagement types they have worked on, tools they are trained on, hours available by month, and the supervising senior or manager who has worked with them. This is the document the partner uses to support the competence determination.
Start building in the off-season
The bench is assembled between May and September, when people have time to talk and the firm has time to train.
- Debrief and rebuild the list in the weeks after the last major deadline, while performance is fresh. Who was reliable, who needed rework, who wants to return.
- Recruit from known pools. Alumni, referrals from other firms, university accounting programs with part-time or internship pipelines, and professionals returning to work. The AICPA and NASBA approved model legislation in May 2025 adding a licensure path of a bachelor's degree, two years of experience and the CPA Exam. States must adopt it before candidates can use it, so the pool of people in the experience period of that path differs from state to state.
- Hold a short paid orientation in the fall for anyone new. A half day on the firm's file structure, tick marks, review-note conventions and tools removes weeks of friction in February.
- Agree availability in writing by October: start date, weekly hours, blackout dates.
Onboarding: a checklist
For every bench member, before client data is shared:
- Confidentiality. Under the AICPA Code's interpretation on third-party service providers (ET 1.700.040), a member using a provider must either enter a contractual agreement with the provider to protect the confidentiality of client information, with reasonable assurance of appropriate safeguards against unauthorized release, or obtain the specific consent of the client before disclosing. Employees are covered by firm policy; contractors by written agreement. See outsourced audit support.
- Independence. Confirm independence for each client before assignment. Anyone who performs audit procedures is part of the engagement team and is subject to the relevant ethical requirements, including independence. Record the confirmation.
- Systems access. Provision only the access each person needs, to the clients they are assigned. Remove it at the end of the season.
- Methodology. The firm's audit programs, file index, tick-mark legend, sampling approach and review process. See audit tick marks and how to document audit procedures.
- Scope and reporting line. Which engagements, which sections of the file, who they report to, who reviews.
Supervision when part of the team is not in the office
The definition of the engagement team in SAS 146 includes all partners and staff performing the engagement and any other individuals who perform audit procedures on it, including people from a firm that is not a network firm or from another service provider. Individuals located in a service delivery center can be part of the team. Everything the standard requires for direction, supervision and review therefore applies to bench members, whatever their employment status.
Three specific points from the standard are useful for remote work:
- Direction and supervision of individuals in a service delivery location, and the review of their work, may need to be more formalized and structured than when the team shares an office, using IT to support communication.
- Remote reviews may not be effective in providing the necessary direction in some circumstances, and may need to be supplemented by in-person interaction.
- Less experienced team members need more detailed instructions and more frequent interaction. The approach is scaled to the member's experience with the client and the area, the complexity of the engagement and the assessed risks.
In practice that means: written instructions for each file section, a fixed check-in cadence (daily during fieldwork for new members, less often for returners), a shared issues list, and review notes cleared in the file rather than by email. Higher-risk areas such as revenue, estimates and related parties go to the most experienced people, not to whoever is available.
Worker classification
A bench member who is a contractor must actually be one. The IRS looks at the whole relationship across three areas: behavioral control (whether the firm controls what the worker does and how), financial control (how the worker is paid, who supplies tools, who bears expenses) and the type of relationship (written contracts, benefits, permanence and whether the work is central to the business). No single factor decides, and the IRS says each factor used should be documented. It also notes that working remotely does not make someone a contractor if the business controls what is done and how.
Audit staff work under the firm's methodology, review process and schedule, using the firm's templates, and those facts point toward employee status for many individuals. Returning seasonal staff are often best handled as seasonal employees. Classification is a decision for the firm's counsel and payroll provider, made before the first day of work, and not corrected after the season.
Keep the bench warm
For peer review and for the engagement partner's own conclusion under AU-C 220, the file should show: the competence profile of each bench member, the independence confirmation, the confidentiality agreement or client consent, the assignment and the supervising reviewer, and evidence of review. SAS 146 also requires documentation of significant issues on ethical requirements and independence. See SQMS 1 quality management.
Frequently asked questions
Are seasonal and contract staff part of the audit engagement team?
Yes, if they perform audit procedures. The engagement team includes all partners and staff on the engagement and any other individuals who perform audit procedures.
Do clients have to be told when remote or contract staff work on their audit?
For third-party service providers, the AICPA Code requires either a contractual confidentiality agreement with the provider and reasonable assurance of safeguards, or specific client consent. The engagement letter is the natural place to address it.
Can remote reviewers rely only on email and video calls?
The standard recognizes that remote review may not provide the necessary direction in every case, and that it can be supplemented by in-person interaction. Scale the approach to risk and the staff member's experience.
Sources
- AICPA, SAS No. 146, Quality Management for an Engagement Conducted in Accordance With GAAS (AU-C 220), effective for engagements for periods beginning on or after December 15, 2025 (engagement team definition, resources, and documentation requirements): https://a-us.storyblok.com/f/1015104/x/32853782b6/aicpa-sas-146.pdf
- Journal of Accountancy, AICPA unveils new QM resources to help firms meet Dec. 15 deadline (SQMS No. 1 effective date): https://www.journalofaccountancy.com/news/2025/aug/aicpa-unveils-new-qm-resources-to-help-firms-meet-dec-15-deadline/
- Journal of Accountancy, AICPA confidentiality rule (ET 1.700.040, disclosing information to a third-party service provider): https://www.journalofaccountancy.com/issues/2015/mar/aicpa-confidentiality-rule/
- IRS, Independent Contractor (Self-Employed) or Employee: https://www.irs.gov/businesses/small-businesses-self-employed/independent-contractor-self-employed-or-employee
- NASBA, AICPA and NASBA Approve Model Legislation for New CPA Licensure Path (May 2025): https://nasba.org/blog/2025/05/13/aicpa-and-nasba-approve-model-legislation-for-new-cpa-licensure-path/
CORAA prepares ready-to-review audit files for US CPA firms from QuickBooks books; you review and sign. See /us.
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AU-C references are to AICPA Professional Standards, paraphrased here; read the standard itself before relying on a requirement. This page is guidance, not professional advice. Report an error