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SEC and PCAOB relax enforcement against auditors

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The Securities and Exchange Commission and the Public Company Accounting Oversight Board have been lightening the load on audit firms, with the SEC initiating only one enforcement action against auditors in the third quarter of the year, according to a new report.

The report, released Thursday by the Brattle Group, follows up on a report released in March by the research firm that showed early signs of a more deregulatory approach by the SEC and PCAOB in the early months of the Trump administration. The new analysis finds that the third quarter of 2025 marked a defining inflection point for auditor oversight in the U.S., especially after the confirmation in April of a new SEC chair, Paul Atkins, following the exit of former SEC chair Gary Gensler on Trump’s Inauguration Day, and the ouster of former PCAOB chair Erica Williams by Atkins. The report found the PCAOB initiated 32 actions during the third quarter, which was comparable to recent years, but one occurred before Williams’s departure in July.

“After several months of uncertainty, the third quarter of 2025 marked a defining inflection point for auditor oversight in the United States,” said the report. “With leadership changes at both agencies signaling a shift away from the aggressive enforcement posture that characterized the Gensler/Williams era, Q3 activity provided the first clear indications of how the new administration’s priorities may reshape the regulatory landscape.”

The report noted that during Q3, the PCAOB’s continued existence came under threat by a proposal to dissolve the PCAOB through President Trump’s “One Big Beautiful Bill.” But the PCAOB received a reprieve when the Senate Parliamentarian ruled that the measure could not proceed under budget reconciliation procedures. However, not long after that, Atkins announced plans to initiate an overhaul of the PCAOB board, which suggests a probably realignment of the PCAOB’s oversight priorities.

Other big leadership changes and developments happened, including the appointment of a new chief accountant, Kurt Hohl, and enforcement director, Margaret Ryan, at the SEC, and the creation of the SEC’s Cross-Border Task Force.

“Together, these events signal a shift away from the aggressive enforcement posture that characterized prior SEC and PCAOB administrations and point to a realignment of priorities,” said Alison Forman, a principal in the Brattle Group’s Chicago office and co-leader of the firm’s accounting practice.

Ongoing constitutional challenges have only added to the regulatory uncertainty at the SEC and the PCAOB, the report noted. The Supreme Court’s June 2024 decision in the case of SEC v. Jarkesy limited the SEC’s use of administrative proceedings, along with parallel “John Doe” challenges to the PCAOB’s disciplinary process, raising questions about both agencies’ adjudicatory authority. Those developments could have contributed to lower auditor-related enforcement activity during Q3 and may fundamentally change how future cases are brought and resolved.

From Q1 through Q3 2025, the PCAOB and SEC together imposed total monetary sanctions of $17.7 million on auditors and audit firms, according to the report. In comparison, monetary sanctions in the first nine months of 2024 totaled $51.1 million. The PCAOB imposed all but $230,000 of the total penalties.

The PCAOB levied penalties of more than $17.4 million in the first three quarters of 2025,more than total annual penalties imposed by the PCAOB every year except 2023 and 2024, but all but $100,000 was imposed prior to former Williams’s resignation on July 22.

Most of the penalties hit firms in other countries. Nearly two-thirds of Q1–Q3 2025 penalties ($11.25 million) were imposed on four foreign affiliates of Big Four firms for violations related to improper answer sharing. Nearly 20% of Q1–Q3 2025 penalties ($3.4 million) were levied on nine foreign affiliates of a Big Four firm for allegedly inaccurate Form APs, Auditor Reporting of Certain Audit Participants, in violation of the PCAOB’s Rule 3211. Two auditing firms were required by the PCAOB to procure an independent consultant to review and make recommendations about the firms’ systems of quality control. 

PCAOB priorities

The report’s release comes as the PCAOB hosted a two-day gathering this week of the International Institute on Audit Regulation, in Washington, D.C. The PCAOB’s acting chair, George Botic, discussed two of the emerging concerns of the PCAOB during a speech Tuesday at the conference: private equity investment in accounting firms and the rapid adoption of artificial intelligence in audits.

“These trends have the potential to transform auditing as we know it and require our continued attention,” he said. “First, private equity investments and other alternative financing arrangements in accounting firms are reshaping ownership structures. These investments can be used to acquire advanced technologies, streamline operations, and assist in attracting and retaining professionals, which can lead to enhanced audit quality. But there are concerns from regulators and standard-setters around the globe.”

Botic pointed out that this summer, the International Ethics Standards Board for Accountants issued a staff alert about the risks that private equity investments in the audit pose to auditor independence and the potential for conflicts of interest. He noted that data from the Dutch Authority for the Financial Markets shows several trends in private equity-backed audits: a decline in statutory auditor involvement, reduced identification of significant risks, and increased threats to independence.

“I, too, have my own concerns that the private equity model focused on short-term ownership and possible cost-savings may change long established incentive structures and behaviors within accounting firms and may, over time, undermine the core principles of audit quality,” said Botic.

However, he added that he recognizes that many accounting firms now face additional demands for capital that need to be met to remain competitive, and those demands may not be achieved through the traditional partnership structure.

“As regulators, we must ensure our oversight remains vigilant as this trend continues,” said Botic. “This vigilance requires engagement with all stakeholders, and in particular, it requires encouraging academic research to ensure we have a comprehensive understanding of not only the challenges and risks, but also the benefits of these investments and structures.”

On the subject of AI, Boptic cited a recent Accounting Today survey showing that 72% of respondents are “comfortable using technology for work that traditionally required human effort” with 53% of respondents reporting that AI makes them more effective. 

“A challenge then lies in the deployment of this technology and what exactly it is being used for,” said Botic.

He also cited another recent study from Wolters Kluwer that found 70% of U.S. audit professionals say they use AI weekly in their role, and more than three-quarters of firms plan to increase their AI investments.

“As AI tools begin to influence judgments traditionally made by humans, auditors must grapple with how to preserve due professional care, professional skepticism, independence, and accountability in a rapidly changing digital landscape,” said Botic.

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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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