At first glance, accounting judgments may appropriately be viewed as routine accounting practices done in the normal course of business: estimates required due to business uncertainty, and assumptions necessary to complete financial reporting obligations. But when such judgments are overly optimistic, unsupported or poorly documented, they can tip into the territory of accounting errors or fraud, leading to restatements, public scrutiny and even regulatory enforcement. And in the current U.S. enforcement climate, the stakes remain as high as ever.

While the Securities and Exchange Commission has, under the new administration, indicated publicly that it may reduce its enforcement focus in areas of ESG and crypto disclosures, its scrutiny of accounting and auditing practices will remain robust. In 2024 alone, the SEC brought more than 45 enforcement actions involving financial misreporting. This pattern suggests that, even amid a broader shift toward deregulation, financial reporting integrity is still very much in the crosshairs, primarily due to concerns that inaccurate financial reporting erodes investor confidence and the market as a whole.

Given the significance of accounting estimates in financial reporting, it’s no surprise that many enforcement actions cite a registrant’s failure to appropriately consider all relevant facts and circumstances that could materially impact key assumptions that form the basis of accounting estimates, or intentionally ignore them. A prime example: In late 2024, United Parcel Service was fined $45 million by the SEC for materially misrepresenting its earnings. The company relied on an external valuation of one of its business units but withheld key information from the consultant. As a result, the unit was grossly overvalued, and UPS avoided recording a goodwill impairment. This case illustrates how selective disclosure, even without overt intent to deceive, can result in significant enforcement and reputational damage.

The judgment-fraud continuum

Management accounting judgments are not inherently problematic — after all, no standard can prescribe treatment for every unique transaction. But it’s when those judgments lack a sound basis, are inconsistently applied from one reporting period to the next, ignore contradictory evidence, or aren’t clearly documented that problems arise.

Case in point 1: Percentage of completion accounting

Consider revenue recognition in long-term contracts, a recurring hotspot in SEC enforcement. U.S. GAAP and IFRS both permit revenue to be recognized based on progress toward completion. This requires assumptions about future costs, contract modifications and the likelihood of contingent income. These assumptions should be reasonable and evidence-based — but our investigations often reveal overly optimistic revenue forecasts or misreporting of costs that can artificially boost profits.

A recent example relates to the AI-enabled robotic company Symbotic Inc., which reported errors related to its revenue recognition practices in 2024 due to material weaknesses in its internal controls that prematurely recognized expenses related to goods and services it was providing to customers under milestone achievements. In addition, the company failed to recognize cost overruns that could not be recovered and should have therefore been written off. Due to Symbotic recognizing revenue under a percentage of completion basis, the recognition of expenses prior to the satisfaction of key milestones resulted in the early recognition of revenue. Symbotic was sued for securities fraud in a class-action lawsuit, following a more than 35% decline in its share price and has announced an ongoing investigation by the SEC. 

This issue also crosses industries and geographies. U.K. oilfield services and engineering company Wood Group plc experienced an over 68% decrease in its share price since it announced in November 2024 that it had identified “inappropriate management pressure and override to maintain previously reported positions” leading to information being withheld from internal auditors. Reports have suggested the company engaged in over-optimistic accounting judgment and a lack of evidence to support assumptions made and positions taken.

Case in point 2: Straightforward accounting estimates

While fraud may be easier to conceal in complex areas of accounting, it can also manifest itself in more straightforward recurring practices. At the end of each reporting period, companies are required to estimate and record accruals for expenses that have been incurred but for which an invoice has not yet been received. Macy’s reported that a single employee had made unsupported or unjustified adjustments to the retailer’s accrual entries to conceal $151 million of small-package delivery expenses over a two-year period from Q4 2022 through Q3 2024. While the SEC has not announced a formal investigation, a securities class action was filed against the company, and the company announced it had initiated a $600,000-plus clawback in executive bonuses.

A company’s response: Getting ahead of the risk

The key takeaway? Judgment-related risks aren’t going away — and neither is regulatory scrutiny. U.S. enforcement bodies may be shifting their focus, but accounting misstatements remain a primary concern. And with the SEC’s emphasis on financial transparency and accurate reporting, businesses can no longer afford to treat accounting judgments as mere technicalities.

Key areas that a company can consider to address the risk of inaccurate or unsupported accounting estimates include:

• Identify those accounting estimates that are most significant to the business from both a qualitative and quantitative perspective: what estimates and key assumptions have a) the most significant impact on reported results, and/or b) have the greatest element of uncertainty and, therefore, highest probability of being incorrect.
• Understand the methodology for developing accounting estimates including the availability and reliability of data sources, how such sources are generated, whether there have been adjustments to how the data is compiled from period to period, and whether there are alternative or supplementary sources that can better inform the facts.
• Stress-test the estimates by assessing the impact of applying alternative assumptions or weightings of information sources. Similarly, conduct regular retrospective testing of historical assumptions relative to actual results to identify how accurate prior estimates were, what factors or assumptions contributed to the accuracy and inaccuracy of prior estimates, and identify amendments and modifications to future estimation processes.
• Ensure all significant judgments are clearly documented and evidence-based. Regulators and litigation plaintiffs use hindsight to “re-audit” or “recreate” accounting estimates so it’s critical that companies document a complete account of the information available to them at the time, and the assumptions, thoughts and alternatives that were considered when generating accounting estimates. Estimates project future events and will inevitably be incorrect. However, a well documented record that demonstrates the company made a balanced, thorough and good-faith approach to developing its estimates provides a strong mechanism to defend against any scrutiny that may be levied in the future.
• Ensure that estimates, the processes followed and assumptions made are done in a clear and transparent manner with the company being open to the thoughts, ideas and comments from others within the business, including those outside the accounting function.

Ultimately, sound accounting judgment is not just a matter of technical compliance — it’s central to maintaining stakeholder trust and avoiding costly regulatory action.

House Republicans have added a plan to raise billions of dollars to help pay for President Donald Trump’s massive tax cuts through the sale of thousands of acres of federal land — a politically charged idea that has drawn opposition from some in their own party. 

The plan, a late-night addition to a legislative package approved early Wednesday by the House Natural Resources Committee, mandates the sale of dozens of parcels totaling more than 11,000 acres (4,450 hectares) of federal land in Utah and Nevada.  

In all, the committee’s legislative package would raise more than $18 billion through increasing federal oil, gas and coal lease sales as well as timber sales and other means. House Republicans are aiming for $2 trillion in spending reductions paired with $4.5 trillion in reduced revenue from tax cuts.

The chairman of the House tax committee warned lawmakers from high-tax states demanding relief from a $10,000 cap on the state and local deduction that they will have to settle for an “unhappy” compromise.

House Ways and Means Committee Chairman Jason Smith said Tuesday in a Bloomberg Television interview that he will strike a balance between those who want no limit on the SALT deduction and those who want no write-off at all.  

“The number we’ll find will probably make everyone unhappy,” Smith, a Missouri Republican, said. “And so that means it’s probably the right number.”

Smith said there will be an increase from the current $10,000 cap in the bill. While he did not reveal his preferred solution, lawmakers have been discussing at least doubling the cap for joint filers and indexing it to inflation. 

Lawmakers from high-tax states including New York, New Jersey and California are fighting for much bigger increases including $40,000 for individuals and $80,000 for joint filers.  

Such a change could cost more than $800 billion over ten years however, limiting the ability of Congress to pass other tax priorities, such as eliminating taxes on overtime and tips.

“We don’t have money sitting in a jar somewhere,” House Majority Leader Steve Scalise told reporters on Tuesday.

Those pushing a large SALT cap increase say they are not backing down. 

Representative Nick LaLota, a New York Republican, said five GOP lawmakers from five high-tax suburban districts are resolved to not back down on their unstated bottom line on a new SALT cap.

House Republican leaders cannot afford to lose support from more than three Republican lawmakers, unless they make concessions to Democrats — which the GOP leaders have said they would not do.

“Our strength is in numbers,” Lalota said. He told reporters that the SALT talks are far apart, on the 25-yard line with 75 yards to go. 

Smith said despite a postponement of a Ways and Means Committee vote on the tax package this week, Congress is still on track to enact the giant tax cut package by July 4. 

Ways and Means Committee member Kevin Hern of Oklahoma said that the committee would try to iron out its provisions behind closed doors by Friday in order to hold votes on them next week. 

In a separate Bloomberg Television interview, House Budget Committee Chairman Jodey Arrington said the biggest challenge to passing the bill will be ensuring the Senate agrees to trillions in spending cuts that the House wants in the package. The Senate outline for the bill only requires $4 billion in cuts while the House is aiming for $2 trillion. 

“That’s the scary piece for budget hawks like us,” he said.