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PCAOB offers guidance on Form AP

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The Public Company Accounting Oversight Board staff released a new publication Thursday aimed at helping firms complete Form AP.

PCAOB-registered audit firms are required to submit Form AP, Auditor Reporting of Certain Audit Participants, to disclose the names of engagement partners and other accounting firms that participated in their audits of public companies. Form AP disclosures reveal exactly who has participated in the audits of public companies, and omissions on such forms account for a large number of inspection deficiencies from PCAOB inspectors..

The new staff publication, Audit Focus: Form AP, includes reminders for auditors from the PCAOB rules, standards, and staff guidance related to Form AP; the PCAOB staff’s perspectives on common deficiencies; and good practices observed by the staff, such as the use of structured templates, guidance on how to complete the templates, or policies mandating review of Form AP information to ensure accuracy and completeness.

The PCAOB staff is continuing to spot a large number of deficiencies related to auditors’ Form AP filings. Those deficiencies include inaccurately reporting whether another accounting firm contributed 5% or more of total audit hours, omitting or incorrectly reporting the percentage of total audit hours contributed by a firm, or providing the incorrect date of the audit report, as well as other problems.

For each audit report that they issue for a public company, PCAOB-registered audit firms are supposed to file a Form AP. Through this form, audit firms disclose key information specific to the audit, such as the engagement partner responsible for the audit, details about the audit report, and the participation of other accounting firms in the audit. Such disclosures enable investors, audit committees, and other stakeholders to understand exactly who has participated in the audits of public companies and how the audit work is distributed among those participants.

The report comes only days after the PCAOB sanctioned nine firms in KPMG’s network in countries around the world, including Australia, Brazil, Canada, Israel, Italy, Mexico, South Korea, Switzerland and the United Kingdom, and imposed over $3.3 million in fines against them. KPMG is reportedly mulling a reorganization of its global structure in which it will merge several of the member firms in different countries, according to the Financial Times and The Wall Street Journal, reducing the number of units from over 120 to 30 or 40 by the end of 2026.

PCAOB board member Christina Ho criticized the sanctions against the KPMG in a LinkedIn post Tuesday and indicated that she didn’t think the Form AP violations were such a big deal.

“Today, the PCAOB’s hostility toward the public auditing profession has reached new heights,” she wrote, adding a disclaimer that these only represent her views and not the rest of the board. “The chest-thumping news release below stated that PCAOB sanctions 9 foreign affiliates of a Global Network Firm for violations of PCAOB Rules and Standards, including Quality Control. Based on the headline, you would think that these firms committed egregious audit quality violations. NOT SO. These violations were mostly for filing inaccurate form APs, and in many cases, the foreign affiliates filed amended form APs after identifying the inaccuracies themselves. In my view, these violations are akin to parking ticket violations, and the sanctions are punitive and excessive. I also wonder what the opportunity costs are when we spend our resources on this type of violation. Furthermore, it appears that PCAOB is determined to spread an exaggerated narrative suggesting that public company audits and the auditing profession cannot be trusted. This binary, chest-thumping approach of bashing the profession in the name of investor protection will only lead to more polarization and distrust.”

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Accounting

Art of Accounting: The end of this year’s tax season

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My original headline was “The end of tax season,” but that is not so. It is the end of this year’s tax season.

If you were designing a CPA practice from scratch, what would you do about tax season? Would you keep it as it is for you, or would you make some changes or possibly eliminate it? It is doubtful you would eliminate it. It is an essential part of what we do and generates substantial revenue and connections with clients and provides growth opportunities for staff. For those looking to grow their practice, it gives them an inside look at their client’s personal, financial and investment affairs.

I’ve always liked tax season for all those reasons. When I was employed as a staff accountant I had no control over my added hours and did what I was supposed to do. But it was a lot less burdensome than it is today. My overtime was three hours for each of two nights a week and five hours on the weekend and this started the second week of January. A downside was that there was no tax work in January and I spent my time with “busy” projects. When I had my own practice (with partners), tax season never started earlier than the first week in February with a weekend day from 9:30 to 5:00. The nights started when the work was there to be done — usually not until the middle of February. 

We also gave staff a floating weekend day in February and the weekend after March 15; and we paid for every extra hour worked on the next paycheck. We never gave a bonus but gave a nice cash gift to everyone on April 15 before we “closed” the office. We stayed closed for the next day too. Tax season was a nice time of year, and I do not remember many complaints. We needed our staff to work as hard as they could but deliberately enough so they would avoid errors. Errors were the bane of our existence and were to be avoided at all costs. We did good with tax season!

Getting back to you, what would you do to make tax season enjoyable for you and your staff to experience the benefits from it? What changes would you make? Do you have the resolve to carry those changes through for the entire tax season? We did! We did these things, not because we liked to, but because we had to. We were running a business. That business happened to be a CPA practice, and one of our service lines was preparing individual tax returns. 

We understood that if we were to grow, we would need staff to do much of our work. We also understood that what they did needed to be done the way we wanted them to do it. We set up processes, procedures and checklists for everything the staff would do. They were told they had to follow them. Our model was the McDonalds restaurants where it worked because everyone followed the processes, procedures and checklists. We wanted to replicate that McDonalds mentality and worked hard at it, training our staff to work the way we wanted them to.  

Not following a process, procedure or checklist was a big deal; a violation of the terms of their employment, and we held them to it. Another thing that was a must was they needed to check their work before they handed it upward for review. We showed them how to check their work and expected them to check it. If they didn’t, they violated the terms of their employment. 

I calculated that correcting errors on tax returns added a day’s work every week. Eliminating errors reduced their work seven or eight hours a week. That was time they had for themselves, since they needed to only work the hours necessary to handle their work assignments. No one was penalized if they went home early or worked less than some others. Some staff members worked quicker than others and some slower, but no one worked extra because they had to stay to correct their errors. Some did, and if it became a regular habit, they were no longer permitted to work for our great firm. We did not believe it made sense to carry nonperformers just to have a “body” looking like they were doing work.

It was fortunate that all our partners bought into our methods. Perhaps not happily when a new procedure was established, but as the results came in, they became believers. To be frank, not every manager did, and they were soon taken off our payroll.

I certainly do not know how most firms operate, but I know how a lot of firms do. The successful ones have procedures and make sure they are followed. There are a lot of other reasons that contribute to success, but this is a big giant step toward having a successful tax season.

I opened this column asking how you would design a successful tax season. You should work on that, and having everyone follow your processes, procedures and checklists is a fine way to start.

Do not hesitate to contact me at [email protected] with your practice management questions or about engagements you might not be able to perform.

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Accounting

There’s no such thing as an AI-first accounting firm … yet

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We’re in the middle of a professional identity shift. Artificial intelligence is here. It’s integrated into tools we already use, embedded in platforms we rely on, and is rapidly evolving. From data extraction to client communication, AI is transforming accounting workflows across tax, audit, client accounting and practice management. And yet, despite all this movement, no firm is truly AI-first today.

Yes, we’re seeing widespread experimentation. Some firms are offloading routine work to intelligent automation. Others are scaling without hiring or delivering new kinds of advisory services fueled by AI-generated insights. But even with these advancements, the way we staff, price and deliver value hasn’t caught up to the capabilities in our toolkits.

However, we are getting a clearer picture of what an AI-first firm could look like along with the changes it will drive across every function. 

Generative AI

To start, AI adoption is most visible in client accounting. Machine learning now powers bank feed reconciliation, auto-categorizes transactions and flags anomalies. In tools already used by most small firms, AI is reducing data entry and improving accuracy. Some systems do 80-90% of the work, with a human review layer to ensure quality.

AI-native platforms are pushing this even further. One firm grew its client base by 25% and saved over 800 hours annually on bookkeeping using an AI-enhanced service. And that’s with no increase in staffing. That’s not incremental efficiency; that’s a new delivery model.

But the bigger shift? When bookkeeping becomes AI-powered, accountants move from data entry to data interpretation. The value isn’t in the keystrokes, it’s in the insight. That’s a mindset change we’re still catching up to.

Audit moves from sampling to 100% risk scoring

In audit, AI is enabling a leap forward in assurance. There are tools that can analyze 100% of a client’s general ledger, risk-score every transaction and guide auditors directly to anomalies.

A Top 100 Firm reported a 66% reduction in audit sample sizes using AI, resulting in weeks of saved effort. And another top firm adopted AI audit tools across their practice, both to improve quality and to attract talent. Their younger auditors aren’t stuck in spreadsheets. They’re analyzing real insights and developing professional judgment from Day One​.

An AI-first audit team is leaner, more analytical and able to deliver higher assurance with fewer staff hours. It elevates the auditor’s role into something more strategic.

It also changes the client experience since the audit is less intrusive, more insightful and has a faster turnaround.

Tax becomes proactive and always-on

Tax is evolving, too. AI-powered tools now scan client source documents and pre-verify data entry, slashing prep time and freeing up capacity. One solution eliminates the need to verify OCR data for 65% of standard documents​.

But it gets really cool when generative AI transforms tax research. Tax questions are answered in seconds, citing code and case law, all of which can be used to draft memos and client communications. That’s a huge win during busy season.

Even more radical? AI platforms that scan your entire client base for tax law changes, identify who is impacted and generate client-ready letters. This turns reactive tax prep into scalable advisory services​.

As taxes move into the digital age, automation is simplifying things for accountants while focusing on what is valued by clients. 

Practice management goes from manual to intelligent

AI is also working its way into the back office. It’s automating tasks that once took hours and quietly transforming the client experience.

Modern practice management systems powered by AI can draft and personalize emails, summarize long threads and auto-schedule follow-ups. In one example, firms reported saving over 18 hours per employee per month on routine communication tasks​. This means client updates happen faster, projects stay on track, and partners get more time for strategic work.

The AI-first firm won’t just use tech to do the work. It will use it to create space for the work that actually builds value.

So why aren’t we there yet?

If the technology is available, what’s holding us back? Well, most firms are still operating with workflows and business models designed for a pre-AI world. AI might be helping us do the same things faster, but we haven’t fully restructured what we do or how we staff, price and deliver our services.

To get to AI-first, we need to rethink:

  • Staffing. What skills matter in a world where compliance is largely automated? What does a team look like when AI handles the first draft of everything?
  • Pricing. If your cost-to-deliver drops dramatically, how do you price for value, not effort?
  • Processes. Are your workflows built for AI-augmented work? Or are you still retrofitting automation into legacy systems?
  • Client experience. Are you using AI to create faster, more transparent service? Or are clients still waiting days for a reply?

The firms that ask these questions — and act on them — will define the next era of the profession.

What radical firms are doing with AI now

The good news is you don’t have to have it all figured out. The firms seeing real results aren’t waiting for perfection, they’re experimenting. 

  • They start small. They are automating one process at a time, sharing wins with the team and building confidence.
  • They empower staff to use AI. Staff is being trained to collaborate with the tech, not fear it.
  • They focus on outcomes, not hours. Nobody cares how long it took you to prepare a return. They care if you are proactive, insightful and accurate.

These are the foundations of a truly AI-first mindset.

Become an AI-first firm

AI won’t replace accountants. But firms that fail to evolve might just get left behind. Don’t fear the shift — lead it. Use AI to eliminate grind, improve service and build a firm that works for you, not the other way around.

Because the future of accounting isn’t just about faster tax returns or prettier dashboards. It’s about delivering more value, more consistently, with less burnout, and building firms that clients trust and talent wants to join.

AI isn’t replacing the profession. It’s giving us the opportunity to become the profession we were always meant to be.

The AI-first firm doesn’t exist … yet. But it’s coming. And if you start now, you can help define it.

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Accounting

Accountants on remote work, lifetime tax burdens and more

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This week’s stats focus on the number of PCAOB and SEC enforcement actions against auditors; the percentage of on-site versus remote job offerings for accountants on Glassdoor and LinkedIn; states with the highest and lowest lifetime tax burdens; the growth rate of Crete Professionals Alliance, the fastest growing firm of 2024; chief audit executives by generation; and the amount of employees per partner among the Top 100 Firms.

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