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PCAOB sees audit deficiencies leveling off at largest firms, but problems remain

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The Public Company Accounting Oversight Board released inspection reports for all 2023 annually inspected firms Thursday, including the six U.S. Global Network Firms.

The timing came months before the reports have been released in recent years thanks to ongoing efforts to accelerate the release of reports.

The PCAOB inspection reports came accompanied by a new staff Spotlight publication, offering an overview of staff observations from the 2023 inspections. Staff observations include the fact that while overall deficiency rates continued to increase in the aggregate, with 46% of the engagements reviewed having at least one Part I.A deficiency, “we have begun to see the aggregate deficiency rate at the Big Four firms level off, as well as improvements in the deficiency rates at several of the other annually-inspected firms.” The Spotlight report also explores how outliers influence the overall average, among other observations.

For example, the report on BDO USA seems to stand out with an 86% Part I.A audit deficiency rate. Twenty-five of the 29 audits reviewed by the PCAOB in 2023 were included in Part I.A of the report due to the significance of the deficiencies identified. The identified deficiencies primarily related to the firm’s testing of controls over and/or substantive testing of revenue and related accounts, inventory, and business combinations.  

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Grant Thornton had a 54% Part I.A deficiency rate. Fifteen of the 28 audits reviewed by the PCAOB in 2023 were included in Part I.A of this report due to the significance of the deficiencies identified. The identified deficiencies primarily related to the firm’s testing of controls over and/or substantive testing of revenue and related accounts and inventory.   

Among the Big Four, for Deloitte & Touche LLP, 12 of the 56 audits reviewed by the PCAOB in 2023 were included in Part I.A of the report due to the significance of the deficiencies identified. The identified deficiencies primarily related to the firm’s testing of controls over and/or substantive testing of revenue, inventory, investment securities, insurance-related liabilities, and allowance for credit losses/allowance for loan losses. That translated into a 21% Part I.A audit deficiency rate.

At PricewaterhouseCoopers LLP, the Part I.A deficiency rate was the lowest among the Big Four at 18%. Ten of the 57 audits reviewed by the PCAOB in 2023 were included in Part I.A of the report due to the significance of the deficiencies identified. The identified deficiencies primarily related to the firm’s testing of controls over and/or substantive testing of revenue and related accounts and goodwill and intangible assets.  

“When we look at the U.S. Big Four firms (this excludes their non-U.S. affiliates), which as of December 31, 2023 collectively audit approximately 80% of the market capitalization, aggregate Part I.A deficiencies held steady at 26% in 2023 after previously jumping from 12% in 2020 to 16% in 2021 and 26% in 2022,” said the report. “Similarly, the percentage of audits reviewed with multiple Part I.A deficiencies was nearly stagnant, at 21% in 2022 and 20% in 2023, after previously jumping from 9% in 2020 to 13% in 2021 to 21% in 2022. Aggregate Part II criticisms at the U.S. Big Four firms also fell for the first time in three years.”

At Ernst & Young LLP, 22 of the 59 audits reviewed by the PCAOB in 2023 were included in Part I.A of the report due to the significance of the deficiencies identified. The identified deficiencies mainly related to the firm’s testing of controls over and/or substantive testing of revenue and related accounts, business combinations, and inventory. That translated into a 37% Part I.A deficiency rate.

At KPMG LLP, 15 of the 58 audits reviewed in 2023 were included in Part I.A of this report due to the significance of the deficiencies identified. The identified deficiencies primarily related to the firm’s testing of controls over and/or substantive testing of investment securities and revenue and related accounts.  That translated into a 26% Part I.A audit deficiency rate.

The PCAOB also published new charts on its website illustrating much of the data in the U.S. GNF and U.S. annual Non-Affiliate Firms (NAF) inspection reports for the first time as part of its ongoing efforts to increase transparency in inspection data and make it easier for stakeholders to understand and compare inspection results both across firms and over time. The charts build on the May 2023 transparency improvements for inspection reports and the July 2023 release of new features allowing PCAOB website visitors to easily filter and compare thousands of audit firm inspection reports.

Some of the highest rates at these firms included B F Borgers CPA PC, which had a 100% Part I.A audit deficiency rate and has been suspended from public audits. Marcum LLP, which was recently acquired by publicly traded CBIZ, had an 81% Part I.A audit deficiency rate, in part due to its heavy reliance on the SPAC market for audits. Baker Tilly US had a 67% Part I.A audit deficiency rate. At Moss Adams LLP, there was a 42% Part I.A audit deficiency rate. WithumSmith+Brown, PC had a 40% Part I.A audit deficiency rate. On the low side, Cohen & Co., Ltd. had an 11% Part I.A audit deficiency rate, and Crowe US LLP had only a 7% Part I.A audit deficiency rate.

“These inspection results point to some small signs of movement in the right direction,” said PCAOB Chair Erica Williams in a statement. “Still, overall deficiency rates are unacceptable, and firms must do better. Now is the time to double down on efforts to improve and deliver the audit quality investors deserve.”

“Making inspection information accessible and actionable for PCAOB stakeholders is a top priority and a means to improve audit quality,” said Christine Gunia, director of the PCAOB’s Division of Registration and Inspections, in a statement. “We will continue to search for new ways to bring our insights to investors, audit committees, and others.”

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IRS offers penalty relief for micro-captive transactions

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The Internal Revenue Service issued a notice Friday giving some breathing room to participants and advisors involved with micro-captive insurance companies.

In January, the IRS issued final regulations designating micro-captive transactions as “listed transactions” and “transactions of interest,” akin to tax shelters. The IRS had proposed the regulations in 2023 but needed to be careful to comply with the Administrative Procedure Act to allow for a comment period and hearing after a 2021 ruling by the Supreme Court in favor of a micro-captive company called CIC Services because the IRS hadn’t followed those procedures back in 2016 when designating micro-captives as transactions of interest. However, the micro-captive insurance industry has asked for more time to comply with the new reporting and disclosure requirements, and one group known as the 831(b) Institute announced earlier this week it had sent a letter to the IRS’s acting commissioner requesting an extension.

On Friday, the IRS issued Notice 2025-24, which provides relief from penalties under Section 6707A(a) and 6707(a) of the Tax Code for participants in and material advisors to micro-captive reportable transactions for disclosure statements required to be filed with the Office of Tax Shelter Analysis. However, the relief applies only if the required disclosure statements are filed with that office by July 31, 2025. 

In the notice, the IRS acknowledged that stakeholders had raised concerns regarding the ability of micro-captive reportable transaction participants to comply in a timely way with their initial filing obligations with respect to “Later Identified Micro-captive Listed Transactions” and “Later Identified Microcaptive Transactions of Interest.”

In light of the potential challenges associated with preparing disclosure statements during tax season and in the interest of sound tax administration, the IRS said it would waive the penalties under Section 6707A(a) with respect to Later Identified Micro-captive Listed Transaction and Later Identified Microcaptive Transaction of Interest disclosure statements completed in accordance with Section 1.6011-4(d) and the instructions for Form 8886, Reportable Transaction Disclosure Statement, if the participant files the required disclosure statement with OTSA by July 31, 2025.   

The relief is limited to Later Identified Micro-captive Listed Transactions and Later Identified Micro-captive Transactions of Interest. However, the notice does not provide relief from penalties under Section 6707A(a) for participants required to file a copy of their disclosure statements with OTSA at the same time the participant first files a disclosure statement by attaching it to the participant’s tax return.  

Taxpayers who are concerned about meeting the due date for these disclosure statements can ask for an extension of the due date for their tax return to obtain additional time to file such disclosure statements. The disclosures required from participants in micro-captive listed transactions and transactions of interest on or after July 31, 2025, remain due as otherwise set forth in the regulations. 

There’s also a waiver for the material advisor penalty for similar reasons. “In light of potential challenges associated with preparing disclosure statements during tax return filing season and in the interest of sound tax administration, the IRS will waive penalties under section 6707(a) with 5 respect to Later Identified Micro-captive Listed Transaction and Later Identified Microcaptive Transaction of Interest disclosure statements completed in accordance with § 301.6111-3(d) and the instructions to Form 8918, Material Advisor Disclosure Statement, if the material advisor files the required disclosure statement with OTSA by July 31, 2025,” said the notice. “Disclosures required from material advisors with respect to Micro-captive Listed Transactions and Micro-captive Transactions of Interest on or after July 31, 2025, remain due as otherwise set forth in § 301.6111-3(e).  This notice does not modify any list maintenance and furnishment obligations of material advisors as set forth in section 6112 and § 301.6112-1. “

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Transforming accounting firms through connected leadership

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In my work with accounting firms, I’ve lost count of how many times I’ve heard partners say some version of: “We’re paying top dollar. Why are people still leaving?” One conversation particularly sticks with me — a managing partner genuinely baffled by rising turnover despite offering excellent compensation packages.

What I often discover isn’t surprising: Many firms have mastered technical excellence and client service while leadership runs on autopilot. They focus almost exclusively on metrics and deadlines, forgetting the human element. No wonder talented professionals walk out the door seeking workplaces where they’re valued for more than just their billable hours.

We’re facing a significant talent challenge in our profession. From 2020 through 2022, approximately 300,000 U.S. accountants and auditors have left their jobs — a dramatic shift that should concern all of us. While retiring baby boomers account for some of this exodus, we also see professionals in their prime years leaving the profession.

(Read more:Connected Leaders: Cultivating deeper bonds for team success“)

The timing couldn’t be worse. The Bureau of Labor Statistics projects about 136,400 accounting and auditing job openings annually through 2031, creating a significant gap between talent supply and demand. This challenge requires more than recruitment tactics or compensation increases — it demands a fundamental shift in how we lead.

The disconnection crisis

Traditional accounting leadership has often prioritized technical excellence and client service at the expense of human connection. We’ve built cultures where being constantly available somehow equals commitment, boundaries are treated as limitations rather than assets, and professional development means technical improvement instead of leadership growth.

Technology has both connected and disconnected us. I’ve worked with firms where team members haven’t had a meaningful conversation with their managers in months despite being on Zoom calls together every day. This disconnect leads to declining engagement and stalled innovation, and makes retaining talented professionals increasingly difficult.

Connected leadership isn’t complicated — it’s about creating real relationships through intentional practices that build trust. It’s the opposite of the “manage by spreadsheet” approach that’s all too common in our profession.

I love thinking about connected leadership like conducting an orchestra. Great conductors don’t just keep time — they understand what makes each musician unique, create space for individual expression within the group, and know when certain sections should shine while others provide support. Most importantly, they get that beautiful music comes from relationships, not just technical precision.

This approach sits at the heart of what I teach through The B³ Method — Business + Balance = Bliss. When leaders create environments where team members feel genuinely seen and valued, magic happens — both in personal fulfillment and on the bottom line.

orchestra conductor

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The business case for connection

Before dismissing this as too “soft” for our numbers-driven profession, consider the data. According to Gallup’s 2024 State of the Global Workplace report, low employee engagement costs the global economy $8.9 trillion annually — an extraordinary sum that affects businesses of all sizes.

Organizations with high engagement see 21% higher profitability and significantly lower turnover. What accounting leaders really need to understand is that managers account for 70% of the variance in team engagement. When managers themselves are engaged, employees are twice as likely to be engaged too. These positive shifts translate to better retention, stronger client relationships and improved profitability.

Beyond retention, connected leadership directly impacts client relationships and innovation. When team members feel psychologically safe, they’re more likely to raise concerns, suggest improvements, and deliver exceptional client service.

Becoming a connected leader

You don’t need to overhaul your entire firm to start seeing results. Try these practical approaches:

  1. Take a beat. Before jumping into solutions or directives, pause to really listen. Some of my most successful clients start meetings with “connection before content” — spending just a few minutes establishing human connection before diving into the agenda. I recently had an attendee of my Connected Leadership workshop tell me: “Taking just two minutes to meditate can remarkably reset the nervous system, providing a quick and effective way to find calm and focus during a busy workday.”
  2. Create boundary rituals. Work-life harmony isn’t about perfect balance — it’s about intentional integration. Help your team establish clear boundaries that actually enhance client service, like “no-meeting Fridays” or dedicated deep work blocks. One partner told me their key takeaway was “to take care of myself to be better in all aspects of life!”
  3. Measure what matters. Beyond billable hours and realization rates, assess team connections through regular check-ins focused on engagement and belonging. Another workshop participant noted that, as a leader, they must take “100% responsibility for my own actions and outcomes.” What gets measured gets managed — so measure the human element, too.
  4. Get comfortable with vulnerability. Share appropriate challenges and lessons learned, showing that vulnerability is a strength. Poignant feedback from my last workshop stated: “For the managing partners and leaders of the organization to put out there for us their vulnerabilities, past struggles, and pain is a testament to their humanity and endurance, and that is a powerful takeaway.”

The future of accounting leadership

Implementing connected leadership will likely face resistance, particularly in traditional accounting environments. This approach can initially be misperceived as “soft” or less important than technical skills. However, the firms that successfully navigate this transition recognize that connected leadership isn’t separate from business success — it’s foundational to it.

When faced with resistance, start small with measurable experiments. Document outcomes, adjust approaches and gradually expand successful practices. Focus on the business case rather than just the human case, though both are equally important.

As our profession navigates unprecedented talent challenges, we need to evolve how we lead. The firms that will thrive won’t just be those with the best technical expertise — they’ll be the ones where leaders prioritize connection alongside excellence.

I challenge you: Are you leading in a way that creates meaningful relationships, or are you perpetuating a culture where people feel like just another billable resource? Your answer might determine whether your firm struggles to keep talent or becomes a magnet for professionals seeking both success and fulfillment.

In an orchestra, the most powerful moments often come not from individual instruments playing louder, but from all sections playing in harmony. The same is true for our teams.

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Accounting

Ohio welcomes out-of-state CPAs after new law

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Ohio’s new law providing an alternative path to a CPA license has taken effect after 90 days and the Ohio Society of CPAs is pointing out another provision of the law, enabling out-of-state CPAs to practice in the Buckeye State.

Ohio Governor Mike DeWine signed House Bill 238 in January, enabling qualified CPAs from other states to work in Ohio, The OSCPA noted that other states are working to adopt similar language to Ohio. 

“Automatic interstate mobility essentially works like a driver’s license,” said OSCPA president and CEO Laura Hay in a statement Thursday. “You can drive through our state without an Ohio license, but you still must follow our laws and if you don’t, you’re penalized. The same applies here – a licensed CPA in good standing can now practice here but must adhere to our strict professional standards.”

Four other states — Alabama, Nebraska, North Carolina and Nevada — currently function under this model. That means a CPA with a certificate in good standing issued by any other state is recognized and allowed practice privileges in those four states as well as Ohio. A number of states like Ohio are also taking steps to provide alternative pathways to CPA licensure aside from the traditional 150 credit hours. In addition, approximately half of all jurisdictions have indicated they are shifting to automatic mobility to ensure that CPAs from all states will have practice privileges and be under the jurisdiction of the state’s board of accountancy.  

“The realities of globalization and virtualization place greater importance on the individual’s qualifications, rather than their place of licensure,” Hay stated. “And the more states we have that accept this model, the more successful we will all be in addressing the national CPA shortage.”

State CPA societies as well as the American Institute of CPAs and the National Association of State Boards of Accountancy have been working on ways to make the CPA license more accessible to expand the pipeline of young accountants coming into the profession and relieve the shortage. 

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