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Audit firms urge SEC to reject PCAOB firm and engagement metrics and reporting standards

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Auditing firms are asking the Securities and Exchange Commission to reject the Public Company Accounting Oversight Board’s recently adopted standards on firm and engagement metrics and firm reporting

The PCAOB voted to adopt the standards in November after making some modifications to assuage several of the concerns raised during the comment process on the rules originally proposed last April. But for many firms, the changes didn’t go far enough.

“The rule introduces a new public oversight model to issuer audits that, in our opinion, has not been adequately studied and is based on metrics susceptible to misinterpretation and misuse that will be costly to produce,” said a comment letter from Ernst & Young.

“We continue to believe that the PCAOB has not sufficiently demonstrated how the metrics within the Release directly relate to or enhance audit quality, which should be the primary objective of any PCAOB rule or standard,” said a comment letter from KPMG. “In fact, our own internal analyses of years of internal and external inspection data indicate that many of the metrics that the PCAOB is proposing do not have a strong correlation to an engagement receiving an inspection comment.” 

The firm and engagement metrics standard would require firms to disclose more information about partner and manager involvement in audits; workload; training hours; audit and industry experience; retention of audit personnel; allocation of audit hours; and restatement history. The PCAOB made some changes to the original proposal, reducing the number of metric areas to eight from 11; refining the metrics to simplify and clarify the calculations; increasing the ability to provide optional narrative disclosure (from 500 to 1,000 characters); and changing the effective date.

“We appreciate the revisions the Board made in its final rules in response to comments received,” said a comment letter from Crowe.  “We remained concerned, however, that the PCAOB does not sufficiently articulate the benefits that are likely to result from this rulemaking, calling into question if the rules are necessary or appropriate in the public interest or for the protection of investors.  As such, we do not support the SEC’s approval of the final Firm and Engagement Metrics rules in their current form.”

Some firms objected to the hurried process behind the new standards. “The speed with which the final rule was approved suggests that sufficient due process was not undertaken, and we believe certain concerns raised by commenters, including tangible operational challenges, were not adequately addressed by the Board in the final rule,” said a comment letter from Grant Thornton. “For such reasons, we ask the SEC not to approve the final rule.” 

The firm reporting standard also underwent modifications from the original proposal in response to comments, reducing the fee disclosure requirements, as well as streamlining disclosures about firm governance and network arrangements. But again the modifications did not go far enough for slime firms. 

“While certain noteworthy improvements have been made to the final rules, concerns persist that elements of the reporting procedures will undermine the confidentiality framework in SOX,” said a comment letter from PwC. “Because alternative effective and less costly measures could be used to gather the information, these concerns should preclude the SEC from approving the final rules.”

Another Big Four firm, Deloitte, pointed out that the burden on smaller firms would be especially acute, particularly in tandem with other recently approved PCAOB standards. 

“These challenges will be compounded by the need for all PCAOB registered firms to simultaneously focus on numerous other new or revised PCAOB requirements currently being considered, or that were recently adopted,” said Deloitte in a comment letter. “We therefore encourage the SEC to consider the cumulative resources needed for firms to implement multiple new standards and other requirements in a short period of time when assessing the costs of the rules. The scope of the Firm Reporting Rules, combined with other PCAOB requirements, will be especially challenging to smaller firms, as the significant resource commitment necessary to implement systems and processes may be necessary even where only a small portion of those firms’ audit practices are subject to PCAOB oversight.”

The American Institute of CPAs has also urged the SEC to reject the new standards. “We believe the recently adopted PCAOB rules will pose significant challenges for accounting firms, especially mid-sized and smaller firms, and may not achieve the intended benefits of improved oversight and audit quality,” said a comment letter from Susan Coffey, CEO of public accounting at the AICPA. “Therefore, we respectfully urge the SEC to refrain from approving these rules. Instead, alternative approaches that better balance transparency, cost, and the needs of audit committees, while continuing to support the quality of audit services and choice of audit providers available to perform public company audits and serve the public interest should be pursued, rather than introducing potentially detrimental unproven regulations.”

The Center for Audit Quality pointed out that any last-minute standards approved by the SEC at the close of the Biden administration could be overturned by the incoming Trump administration or by Congress under the Congressional Review Act. “Notably, any final order approving the rule would be subject to review by a new session of Congress and a new President,” wrote CAQ CEO Julie Bell Lindsay in a comment letter

The U.S. Chamber of Commerce has also come out against the rules, as it did last year in conjunction with the CAQ in opposition to the proposed PCAOB standard on noncompliance with laws and regulations, also known as NOCLAR. That standard is currently on hold.

“The Proposed Rules mandating disclosure of audit firm and engagement metrics represent rushed and problematic due process at the PCAOB,” wrote Tom Quaadman, senior vice president of economic policy at the U.S. Chamber of Commerce. “The Proposed Rules are not fit for purpose, are costly and burdensome, and will be detrimental to audit quality. The adopting release does not meet the threshold requirements for economic analysis, including appropriate consideration of need, benefits, costs, consequences and alternatives.”

With SEC chair Gary Gensler planning to step aside on Jan. 20, the SEC will be controlled by Republicans. The two Republican members of the Commission, Mark Uyeda and Hester Peirce, met with Quaadman in December to discuss extending the comment deadline.

The standards did win support from some investor and consumer groups. “There needs to be transparency throughout the process that results in the appointment and oversight of the audit firms and the audit process to ensure there is accountability to investors by the PCAOB (the regulator) and the audit committee which is charged with protecting investors interests,” said a comment letter from the CFA Institute on the firm reporting standard. “Investors themselves need this transparency to accomplish their stewardship responsibilities and to hold their agents (i.e., audit committees, management and regulators) accountable.”

“CII, therefore, supports the Commission approving the Proposed Rules because we believe the final metrics represent an important, albeit long overdue, step forward in responding to investors’ information needs relating to the audit,” said a comment letter on the firm and engagement metrics standards from the Council of Institutional Investors.

The Consumer Federation of America expressed its support. “Current PCAOB rules and standards do not require registered audit firms to publicly disclose firm or engagement-level information,” said a comment letter from Micah Hoffman, director of investor protection at the group. “As a result, investors and audit committees lack access to consistent, comparable data on audit services, which hinders their ability to make informed decisions in selecting auditors and allocating their capital. Audit firms have little incentive to voluntarily provide standardized and decision-useful information, and existing voluntary disclosures fail to meet investor needs. The amendments would help address these issues.”

“We applaud the PCAOB’s efforts to modernize its annual and special reporting requirements for audit firms,” said a comment letter from AARP legislative counsel David Certner. “Greater disclosure will support investor protection and enhance the PCAOB’s oversight capabilities. The importance of investor protections is especially key for older adults.”

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Accounting

Mandatory ESG Reporting Standards Demand Standardized Non-Financial Audit Trails

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Mandatory ESG Reporting Standards Demand Standardized Non-Financial Audit Trails

Corporate accounting departments face an expanded regulatory mandate as mandatory sustainability and Environmental, Social, and Governance (ESG) reporting frameworks take full effect internationally. Governed by the European Union’s Corporate Sustainability Reporting Directive (CSRD) and the International Sustainability Standards Board (ISSB) IFRS S1 and S2 standards, enterprise financial controllers are now legally required to track, verify, and report non-financial data with the same internal controls and auditability as traditional financial statements.

The expansion shifts ESG compliance

This regulatory expansion shifts ESG compliance from marketing departments to corporate accounting offices. Financial managers are now responsible for gathering, consolidating, and verifying carbon emissions metrics, supply chain labor conditions, water usage, and climate risk exposures across multi-tiered corporate structures. These non-financial metrics must be integrated into standardized general ledgers to withstand rigorous third-party audit assurance processes.

To comply with these rigorous reporting mandates, accounting software providers have added dedicated ESG modules designed to aggregate data from IoT sensors, utility platforms, and vendor management systems. Controllers are implementing internal control frameworks—modeled after traditional COSO frameworks—to ensure the completeness, accuracy, and consistency of sustainability disclosures, protecting organizations against greenwashing penalties and litigation risks.

The transition requires significant cross-functional collaboration between accounting teams, legal counsel, and operational directors. Accounting professionals are expanding their technical expertise beyond financial ledgers to master carbon accounting methodologies, lifecycle assessment standards, and non-financial data governance protocols, fundamentally expanding the role of the modern corporate accountant.

Why This Information Matters
Mandatory ESG disclosures require companies to treat environmental and social metrics as audited financial records. Executives, accountants, and board members must institute formal tracking and assurance processes to satisfy legal mandates, maintain investor confidence, and mitigate regulatory non-compliance risks.

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Accounting

SEC’s Semiannual Reporting Proposal Faces Investor Pushback: What CFOs Need to Know

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U.S. Securities and Exchange Commission (SEC)

A proposal from the U.S. Securities and Exchange Commission to potentially shift some public companies away from quarterly financial reporting toward a semiannual model is drawing significant pushback from investors, even as it continues moving through the regulatory process. The debate has direct implications for corporate finance teams, auditors, and the broader transparency of U.S. capital markets.

What the SEC Proposed

According to a summary published by accounting advisory firm Cohen & Co., the SEC issued a proposed rule on May 19, 2026, aimed at simplifying financial reporting requirements for many U.S. public companies. The proposal would potentially reduce the frequency of certain mandatory disclosures from quarterly to semiannual, a structural change that has not been made to core U.S. reporting requirements in decades.

The proposal follows an extended debate within U.S. policy circles, with proponents arguing that reduced reporting frequency could lower compliance costs and free up management time for longer-term strategic planning rather than quarter-to-quarter results management.

Why Investors Are Pushing Back

Comment letters submitted in response to the proposal have been extensive, and according to Cohen & Co.’s review of the public record, investors “appear to be largely opposed” to the shift, viewing frequent interim reporting as a core benefit of U.S. capital markets relative to other jurisdictions.

Accounting and law firms have taken a more measured position, generally urging any changes to remain aligned with the Financial Accounting Standards Board (FASB), whose existing disclosure requirements and guidance are built around a quarterly reporting cadence. A shift to semiannual reporting without corresponding changes to FASB guidance could create friction between SEC filing requirements and GAAP-based disclosure expectations.

Lessons From the U.K. Experience

The debate is not without precedent. The United Kingdom moved away from mandatory quarterly reporting for listed companies in 2014, returning to a semiannual disclosure requirement. According to Cohen & Co.’s analysis, that experience offers a cautionary data point: there was no measurable increase in capital expenditure or R&D investment following the change, while analyst coverage of affected companies declined as reliable interim information became less available — a particular risk for smaller and newly public companies that rely on analyst coverage to maintain investor visibility.

Practical Implications for Finance Teams

Beyond the debate over disclosure philosophy, the proposal carries practical complications. Many companies have debt covenants and credit agreements structured around quarterly financial delivery; a shift to semiannual reporting could require renegotiating those terms. Reduced reporting frequency would also extend the “window of market silence” between disclosures, a factor that governance and investor-relations teams would need to manage carefully to avoid information asymmetry.

Separately, and unrelated to the reporting-frequency debate, the SEC and FASB have continued finalizing more routine updates this year. New Accounting Standards Updates are taking effect for December 31, 2026, fiscal year-ends covering income tax disclosures, credit loss measurement, induced debt conversions, and stock compensation, according to Eide Bailly’s review of 2026 ASU activity. Additional guidance on paid-in-kind dividends and environmental credits is also on the near-term horizon.

What to Watch Next

The semiannual reporting proposal remains in the comment and review phase, and no final rule has been adopted as of this writing. Finance leaders should monitor the SEC’s regulatory agenda for further movement, while treating the current quarterly reporting requirement as the operative standard until any final rule is issued and an effective date is set.

Given the extent of investor opposition documented in the comment file, a full shift to mandatory semiannual reporting appears more likely to result in either a scaled-back compromise or continued study rather than swift adoption — though the SEC’s ultimate direction remains uncertain.

 

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Accounting

AI-Driven Automation and Continuous Accounting Frameworks

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The accounting profession is undergoing a fundamental structural transition as enterprise finance departments shift from periodic month-end closes toward automated continuous accounting models. By integrating specialized machine learning algorithms directly into enterprise resource planning (ERP) platforms, chief accounting officers are transforming financial reporting from a retrospective exercise into a real-time operational asset.

The Shift from Periodic Close to Continuous Financial Reporting
Traditional accounting workflows heavily relied on manual data reconciliation, spreadsheet calculations, and multi-week closing cycles at the end of each fiscal period. In contrast, continuous accounting frameworks utilize automated software agents to process, validate, and post transactional data in real time as business activities occur.

Automated bank reconciliation tools cross-reference incoming bank feeds, invoice records, and purchase orders automatically. By resolving transactional variances instantly throughout the month, corporate accounting teams eliminate the traditional workload spikes associated with quarterly and annual closes.

Machine Learning in Audit Trails and Anomaly Detection
Advanced natural language processing (NLP) and machine learning tools are redefining internal audit and financial control environments. Automated systems analyze 100% of general ledger entries, identifying anomalous transactions, duplicate payments, and unauthorized journal entries in real time.

Rather than relying on random statistical sampling, corporate internal auditors can focus their attention on high-risk flags automatically surfaced by algorithmic monitoring platforms. This continuous risk assessment strengthens internal controls over financial reporting (ICFR) and significantly reduces fraud risk.

Evolving Roles for Accounting Professionals
As routine data entry and manual reconciliation tasks become fully automated, the skill set required for accounting professionals is shifting toward data analysis, system design, and strategic business advisory.
– Systems Governance: Accountants are increasingly responsible for monitoring algorithmic accuracy and managing data integration pipelines.
– Business Partnership: Finance professionals leverage real-time financial dashboards to advise operational leaders on margin management and working capital allocation.
– Regulatory Compliance Management: Accounting teams utilize automated platforms to ensure compliance with dynamic tax codes and international accounting standards.

Core Implementation Recommendations
1. Deploy Automated Reconciliation Tools: Integrate continuous transaction processing modules into existing enterprise ERP architectures.
2. Establish Algorithmic Governance Controls: Implement strict internal testing protocols to ensure automated accounting rules comply with GAAP/IFRS standards.
3. Reskill Accounting Teams: Invest in training finance staff on data analytics, workflow automation, and predictive financial modeling.

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