Last fall, George Kurtz, the chief executive officer of CrowdStrike Holdings Inc., gave investors a quarterly financial update that sent shares soaring. Among the details Kurtz highlighted was a major deal to sell cybersecurity tools for use by the U.S. government.
“Identity threat protection wins in the quarter included an eight-figure total deal value win in the federal government,” Kurtz said on the earnings call after markets closed on Nov. 28, 2023.
Kurtz was referring to a $32 million order from Carahsoft Technology Corp., which serves as a middleman between technology companies and government agencies, that arrived on the last day of CrowdStrike’s fiscal third quarter. It was for identity threat protection software intended for the Internal Revenue Service, according to documents from both companies.
But the IRS never bought the software, according to records reviewed by Bloomberg News and people with knowledge of the situation.
Still, Carahsoft has been making on-time payments on the $32 million to CrowdStrike, according to the cybersecurity firm. When asked for comment by Bloomberg News, both companies explained that they had a “non-cancellable order” between them. They declined to say why that deal was struck without a purchase in place from the IRS.
Some legal and accounting experts, who reviewed the arrangement at Bloomberg’s request, said it raises red flags that merit scrutiny from regulators. The deal also raised concerns within CrowdStrike — according to people familiar with the matter and the company itself — and many specifics of the transaction remain unclear.
CrowdStrike’s offices in Sunnyvale, California.
Benjamin Fanjoy/Bloomberg
Depending on how CrowdStrike accounted for the deal in financial statements — the company didn’t explain those details — it was big enough that it could have made the difference between the company beating or missing Wall Street projections for the period. The day after CrowdStrike reported results for the record quarter, its shares rose 10%.
Jeremy Fielding, a spokesperson representing CrowdStrike, dismissed employees’ concerns as baseless and the order’s timing as insignificant. The Austin, Texas-based cybersecurity firm closes deals “throughout the quarter, starting the first day and often through the last day,” he said.
“The Carahsoft deal went through a separate and extensive review,” he said, adding that it “was given a clean bill of health.” Fielding characterized the experts’ comments as “inaccurately speculating about a transaction that CrowdStrike confirmed fully met” an accounting standard on revenue from contracts.
CrowdStrike “closed and recognized” the deal once Carahsoft placed the order, and its booking of the revenue is consistent with standard accounting principles, according to Thomas Clare and Elizabeth Locke, lawyers representing the cybersecurity company.
A representative of Carahsoft, Mary Lange, said in an email, “Carahsoft is a private company and we do not disclose financial information or customer details. That said, we placed a valid, non-cancellable order with CrowdStrike and stand by that transaction.” The company declined to answer any other questions.
The IRS didn’t answer detailed questions. The tax agency said in a statement that it doesn’t hold any contracts with CrowdStrike directly and, in keeping with federal procurement rules, acquires its software and services through third-party vendors.
No IRS contract or payments matching the deal appear in the public government spending database USASPENDING.gov. The database excludes some information — for instance, material that could compromise national security. But the tax agency’s purchases of CrowdStrike’s products through vendors total less than $10 million, according to a person familiar with the matter.
This story is based on records of the transaction and interviews with five people familiar with the matter, who requested that their names not be published because they aren’t authorized to discuss it.
“It raises an eyebrow,” said Lawrence Cunningham, director of the University of Delaware’s John L. Weinberg Center for Corporate Governance.
“It appears on its face to be uncompensated risk, and rational businesses don’t usually accept uncompensated risk,” Cunningham said, referring to Carahsoft’s payments to CrowdStrike.
Carahsoft declined to answer questions about whether it was taking a loss on the deal or if it found a way to recoup the money.
In recent months, separate issues at CrowdStrike and Carahsoft have drawn negative attention and government scrutiny.
CrowdStrike, with annual revenues of more than $3 billion, sells security software to thousands of businesses and government agencies globally. But in July, a flawed update from the firm knocked out millions of Windows computers around the world, disrupting air travel, medical care, banks and other businesses. Executives have apologized repeatedly, including before members of Congress; the company’s share price plummeted after the outage and hasn’t fully recovered.
Carahsoft is a dominant player among resellers and distributors that help technology companies navigate the complexities of selling to government agencies. In September, agents from the FBI and the Department of Defense searched the company’s Reston, Virginia, headquarters. Lange, the Carahsoft spokesperson, previously said the company was cooperating with the FBI probe and that it involved “an investigation into a company with which Carahsoft has done business in the past.”
The Justice Department is also conducting a civil probe of Carahsoft and software giant SAP SE for potential price fixing on government contracts. The German firm is cooperating with the civil probe, a spokesperson said. SAP chief financial officer Dominik Asam told Bloomberg News that SAP had “gotten written assurance from Carahsoft” that the FBI search was “entirely unrelated” to SAP and a U.S. subsidiary.
There’s no known link between CrowdStrike and either the civil investigation or search of Carahsoft’s office. Fielding, the CrowdStrike representative, said neither investigation is connected to the cybersecurity company.
A potential deal for the IRS dates to early 2023, when CrowdStrike sales representatives began talking with agency officials about buying an identity verification tool to help prevent fraud in a new program that lets people file their taxes directly with the government, according to three people familiar with the matter.
Work continued on a potential deal in the following months, but by mid-October it had become clear to at least some CrowdStrike staff that the IRS wouldn’t order the software before the company’s quarter closed at the end of the month, the people said.
Nevertheless, on Halloween, Carahsoft ordered $32.25 million worth of subscription access to CrowdStrike’s “Government National Identity Threat Protection” service for as many as 40 million users, according to records and two of the people. The order split the purchase into four $8 million payments, with the final payment due at the end of this October. The order indicates that Carahsoft should be billed for the CrowdStrike software and that it should be shipped to the IRS’s Washington headquarters.
That day, CrowdStrike sent an automated email to dozens of staff, saying, “Opportunity has been Closed Won for Internal Revenue Service (IRS).”
The closing of the deal and Kurtz referring to it on the earnings call alarmed some staff who raised internal concerns that CrowdStrike was “pre-booking” a transaction that they viewed as incomplete because it was unclear whether the IRS would ever make the large purchase, according to three of the people. U.S. regulators have in some cases sued and fined companies over alleged pre-booking, also known as channel stuffing, claiming they misled investors by improperly recognizing revenue to inflate their financial figures.
Fielding said it was “demonstrably false” that there was any pre-booking.
That quarter, $32 million was enough to make the difference between CrowdStrike beating analysts’ expectations on two key financial metrics — annual recurring revenue and net new annual recurring revenue — or falling short of them. CrowdStrike highlighted both metrics in the earnings announcement for the quarter, but the company declined to answer questions about whether the deal was recorded under them.
Annual recurring revenue is widely used by software companies to track income from subscriptions. CrowdStrike has consistently emphasized it with investors, writing in a 2019 regulatory filing that it “is a key metric to measure our business.”
Theresa Gabaldon, a professor at the George Washington University Law School, said that for CrowdStrike to appropriately book the deal as revenue it would need to have not only received payment but also delivered the product. Neither CrowdStrike nor Carahsoft answered questions about what became of the subscription software.
“I characterize it as raising red flags,” Gabaldon, who teaches securities regulation, law and accounting, said of the deal.
Whatever happened, Carahsoft was among the companies that CrowdStrike feted at a June “partner symposium.” There, Kurtz and other CrowdStrike staff mingled with guests at a luxury resort on the southern California coast. A video shows attendees enjoying drinks and live string music on a bluff overlooking the Pacific Ocean and getting sushi-making lessons from a celebrity chef.
At the event, CrowdStrike named Carahsoft “Distributor of the Year.”
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.
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.
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.