ACC Comment Letter on PCAOB Strategic Priorities

The Audit Committee Council (ACC), an independent advisory group of the Center for Audit Quality, submitted a comment letter to the Public Company Accounting Oversight Board (PCAOB) outlining key recommendations for the Board’s 2026–2030 strategic priorities. The ACC strongly supports the PCAOB’s investor protection mission and emphasizes the need for a more effective, consistent, and transparent regulatory framework that enhances audit quality while reducing unnecessary burden on stakeholders.

Top Recommendations

1. Strengthen the PCAOB inspections program
   The ACC urges the PCAOB to prioritize improvements to the focus, consistency, and timeliness of inspections. A more risk‑based and quality‑control‑focused approach would provide more meaningful insights to audit committees and reduce unnecessary pressure on audit engagement teams. “Enhancements to focus, consistency, and timeliness would meaningfully improve usefulness to stakeholders.”
2. Promote regulatory efficiency and durable standards
   The letter encourages the PCAOB to ensure that new or revised standards deliver clear benefits relative to their costs and are applied consistently across firms. The ACC also supports a more transparent and empowered standard‑setting function—particularly through a formal consultation process within the Office of the Chief Auditor.
3. Prioritize initiatives with the greatest impact
   The ACC cautions against an overly expansive agenda and recommends disciplined sequencing of projects to avoid implementation challenges and resource strain.

Additional Key Themes

• Inspection reporting enhancements: Provide clearer distinctions in severity of findings, improve timeliness, and offer industry‑level insights.
• Quality control focus: Leverage firm‑level quality management systems and consider alignment with international standards such as ISQM 1.
• Standard‑setting priorities: Avoid unnecessary overhauls; finalize a re‑scoped NOCLAR project; modernize independence rules while reducing duplication.
• Technology and AI: Strengthen data governance and transparency around PCAOB use of advanced technologies.
• Stakeholder engagement: Expand structured dialogue with audit committees and improve transparency around how stakeholder feedback informs PCAOB decisions.