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Accounting

New tax law, new audit pressures: What EBP teams need to know about the OBBBA

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Congress passed the One Big Beautiful Bill on July 4, 2025. While the headlines focused on tax cuts and political wins, what catches my attention is something else: a continued shift in how Americans are expected to save and how employers will be involved in that process. This shift is even more evident with the Trump administration’s recent Executive Order, signed on Aug. 7, 2025, democratizing access to alternative assets for 401(k) investors.

These changes may have long-term consequences for how we think about retirement plans. If plan sponsors adopt them, employee benefit plan audit teams should be prepared.

A bill built for savings and for scrutiny

The OBBBA introduces new savings mechanisms like the Trump Account, expands limits for dependent care flexible spending accounts, and permanently enables telehealth coverage through health savings accounts. These provisions may not grab headlines, but they are worth watching, especially if you are in the business of auditing plans or advising on employee benefits.

The executive order encourages the Department of Labor and other federal agencies to explore ways for defined contribution plans to offer participants exposure to alternative assets, including private equity, real estate, and digital assets. Following this order, the DOL has rescinded previous guidance from the prior administration that cautioned plan fiduciaries against adding cryptocurrency to investment options. 

 Additional Trump Account details:

  • The Trump Account is a newly established type of individual retirement account designed for children under 18. It is not part of a defined contribution plan.
  • While employers and parents can contribute, the government will provide a $1,000 contribution for children born between 2025 and 2028.
  • Annual contributions are capped at $5,000 (excluding exempt contributions) and indexed for inflation. Employers may also contribute up to $2,500 per year on a tax-free basis if they establish a formal program.
  • Employer contributions trigger plan documentation requirements, nondiscrimination testing, and potentially audit relevance.
  • Distributions are prohibited until the calendar year in which the child turns 18, and earnings are tax-free under qualified withdrawal rules similar to traditional IRAs.
  • The account will become effective for taxable years beginning after Dec. 31, 2025, with contributions not accepted until July 4, 2026.

On top of that, the OBBBA includes updates to other employer-sponsored benefit programs like HSAs and FSAs:

  • HSAs: Telehealth and remote care services are now permanently allowed before meeting the deductible, effective retroactively to plan years beginning after Dec. 31, 2024. Additional expansions are scheduled for 2026.
  • FSAs: The dependent care FSA contribution limit increases to $7,500 ($3,750 for married couples filing separately), effective for tax years starting after Dec. 31, 2025. This new limit is not indexed for inflation.

These are just a few provisions of the OBBBA and the executive order, but the theme is consistent. The legislation is designed to enhance the American workforce’s ability to invest, not only for their own retirement but also for their dependents. 
Health care also plays a role in this law, reinforcing the need for these benefits. The government has moved to make preventative and corrective care more accessible. These updates reflect a broader recognition that financial security and health security go hand in hand.

These are not sweeping changes like those introduced in the SECURE 2.0 Act, but they follow the same pattern. They offer more options, which come with greater complexity and, as a result, more potential touchpoints for compliance failures. Once again, the burden of getting it right falls on fiduciaries and the professionals supporting these plans.

What matters for accounting firms

From an audit perspective, these provisions will only impact audit scope if employers choose to adopt them. If they do, the impact will depend on how the provisions are structured.

We saw this with the SECURE 2.0 Act, which introduced a wide range of mandatory and optional provisions, from delayed required minimum distributions and expanded catch-up contributions to emergency savings accounts and student loan matching. Each of these reflected a shift in how the government expects Americans to save, acknowledging that people are working longer, retiring later, and relying more on defined contribution plans. For employers, adopting these provisions often meant increased recordkeeping, compliance responsibilities, and potentially added audit scope.

The same dynamic is at play here. The Trump Account may start as a standalone savings vehicle, but if employers link it to broader benefit programs or enable payroll-based contributions, auditors will be expected to verify compliance. FSAs and HSAs are not new, but increasing their limits changes the dynamics of a plan, which means audit procedures will need to evolve. And with the new executive order, if plan sponsors allow for alternative investments within their offerings, auditors will most certainly need to expand procedures accordingly.

This is a moment for firm leaders, audit partners, and benefit plan advisors to look ahead rather than react later.

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Accounting

Global ESG Reporting Standards and Double Materiality Compliance

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Corporate accounting departments face expanding reporting expectations as international sustainability disclosure standards achieve regulatory enforcement across major global jurisdictions. Chief Accounting Officers (CAOs) and corporate controllers are establishing rigorous internal accounting controls to treat Environmental, Social, and Governance (ESG) metrics with the same data precision, auditability, and governance as traditional financial statements.

Regulatory Harmonization Under Global Sustainability Frameworks
The implementation of standardized sustainability reporting frameworks—notably rules established by international sustainability accounting boards—has created unified expectations for public and large private enterprises. Corporations must report standardized metrics covering greenhouse gas emissions (Scope 1, 2, and material Scope 3), energy utilization, workforce demographics, and supply chain governance.

In Europe and other participating international jurisdictions, double materiality principles are mandatory. Under double materiality, organizations must report both how external sustainability risks impact corporate financial performance, and how internal corporate operations affect surrounding environmental and social structures.

Integrating Sustainability Metrics into Core ERP Systems
To provide auditable non-financial data, enterprise organizations are integrating specialized carbon accounting and ESG management platforms directly into core ERP systems. Automated data collectors capture energy utility invoices, logistics fuel consumption metrics, and vendor compliance records in real time.

Establishing automated, traceable data pipelines ensures that non-financial reporting is supported by clear audit trails. This structured approach allows external financial auditors to provide reasonable assurance on sustainability disclosures during annual corporate reporting cycles.

Financial Impacts and Capital Market Disclosure
Accurate ESG reporting directly influences corporate cost of capital and institutional credit ratings. Commercial lenders and institutional asset managers systematically incorporate sustainability metrics into risk pricing models. Companies that demonstrate transparent, verifiable progress in operational energy efficiency and climate risk mitigation benefit from expanded access to green bond markets and lower debt pricing.

Action Steps for Accounting Leadership
1. Implement Double Materiality Frameworks: Conduct comprehensive assessments to identify material financial and operational sustainability metrics.
2. Build Auditable Non-Financial Data Pipelines: Automate ESG data collection within core accounting software to ensure data integrity.
3. Align Sustainability with Annual Financial Filings: Prepare non-financial disclosures concurrently with financial statements to satisfy regulatory audit expectations.

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Accounting

Modernizing Internal Controls: Machine Learning and Continuous Monitoring in Auditing

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Internal audit departments and corporate risk managers are modernizing internal control frameworks by shifting from periodic sampling techniques to continuous monitoring and machine learning analytics. As operational data volumes increase across enterprise organizations, automated control testing ensures financial integrity, prevents corporate fraud, and streamlines annual audit engagements.

The Limitation of Periodic Audit Sampling
Historically, internal and external auditors evaluated internal controls by reviewing random samples of financial transactions—often analyzing less than five percent of total ledger entries. In complex enterprise environments, periodic sampling methods carry inherent risks of overlooking localized financial misstatements, unauthorized disbursements, or operational control breakdowns.

In 2026, progressive internal audit functions are utilizing automated continuous monitoring platforms that evaluate one hundred percent of financial transactions in real time. Continuous control auditing systems continuously monitor general ledger entries, procurement approvals, and expense reimbursements across all operating subsidiaries.

AI-Powered Fraud Detection and Anomaly Identification
Machine learning models trained on historical corporate financial data excel at identifying subtle transactional anomalies that indicate potential fraud or operational error. Automated systems instantly flag duplicate invoice payments, unapproved vendor creation, unusual journal entry timing, and unauthorized override of authority thresholds.

When an anomaly is detected, the automated auditing platform generates an instant risk alert, allowing internal audit teams to investigate root causes immediately. Early detection prevents minor operational errors from escalating into material weaknesses in financial reporting.

Streamlining External Audit Preparation
Continuous internal control monitoring delivers significant benefits during annual external financial audits. External audit firms can review continuous audit logs and automated control testing documentation, reducing the time required for manual field testing.

This integrated approach lowers overall audit compliance fees, reduces administrative burdens on corporate accounting staff, and provides senior management and audit committees with real-time visibility into the organization’s overall risk profile.

Core Implementation Guidelines
1. Transition to 100% Data Testing: Replace legacy sampling methods with automated continuous audit monitoring systems.
2. Deploy Anomaly Detection Algorithms: Implement machine learning models to identify unauthorized transactions and operational control overrides.
3. Align Internal and External Audit Workflows: Coordinate continuous control testing protocols with external auditors to optimize annual compliance cycles.

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Accounting

Automated Tax Compliance and Global Regulatory Harmonization in 2026

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Corporate tax accounting departments are navigating an era of unprecedented regulatory complexity as global tax harmonization frameworks take full effect alongside real-time digital tax reporting mandates. Tax directors and accounting teams are adopting cloud-based tax compliance automation tools to manage multi-jurisdictional tax liabilities and satisfy stringent reporting rules across international jurisdictions.

Implementation of Global Minimum Tax Provisions
The implementation of international tax reform agreements—notably the Pillar Two global minimum tax framework—has reshaped multinational corporate tax planning. Multinational enterprises with consolidated revenues exceeding established thresholds must ensure an effective tax rate of at least 15% across every jurisdiction in which they operate.

Accounting teams are implementing specialized tax calculation modules integrated directly into enterprise resource planning (ERP) platforms. These automated tools calculate effective tax rates per country, identify top-up tax liabilities, and generate standardized compliance documentation required by national tax authorities.

Real-Time Digital Invoicing and E-Reporting Mandates
Tax authorities across Europe, Latin America, and Asia-Pacific have enacted mandatory electronic invoicing (e-invoicing) and continuous transaction controls (CTC). Under these systems, corporate transaction data must be submitted electronically to government portals in real time at the point of sale or invoice issuance.

This shift toward continuous digital tax reporting eliminates traditional annual tax audits in favor of ongoing automated compliance monitoring. Accounting departments are upgrading invoicing software to ensure seamless XML data formatting, digital signature authentication, and real-time validation against tax authority databases.

Automation and Data Analytics in Corporate Tax Strategy
To keep pace with dynamic tax legislation, tax departments are transitioning from reactive compliance teams to proactive strategic advisors. Machine learning algorithms analyze corporate transactional data to identify tax credits, research and development (R&D) incentives, and cross-border transfer pricing adjustments.

By automating routine tax return filings and calculations, corporate tax directors can focus on long-term capital structuring, evaluating the tax implications of corporate mergers, and optimizing international supply chain networks.

Strategic Priorities for Tax Executives
1. ERP System Upgrades: Ensure enterprise software is capable of generating real-time, granular tax data required for global minimum tax compliance.
2. E-Invoicing Integration: Implement scalable e-invoicing platforms to satisfy regional continuous transaction control regulations.
3. Strategic Tax Analytics: Utilize predictive tax modeling tools to evaluate structural changes in corporate operations and cross-border trade.

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