The Public Company Accounting Oversight Board posted an updated list of firms Monday that have registered with the PCAOB, but have not yet been inspected, even though four or more years have passed since they issued an audit report while registered.

The list, which is up to date as of June 30, indicates that four firms (two in the Netherlands and one each in Germany and Spain) were removed from the Dec. 31, 2012 version of the list because the inspection fieldwork of them has been completed.

The PCAOB has said it plans to publicly identify registered firms that have not been inspected in at least four years and will be updating the list, at a minimum, on a semiannual basis by adding firms that qualify and by removing those firms for which the inspection fieldwork has been completed or that have voluntarily deregistered from the PCAOB. Last week, a PCAOB board member suggested in a speech that firms that don’t voluntarily deregister themselves might be deregistered by the PCAOB, particularly if they are one of the 923 registered firms that do not actually audit public issuers or broker-dealers (see PCAOB Mulls Deregistering Hundreds of Accounting Firms).

However, the reasons that the inspection fieldwork for a firm has not been completed within four years of the firm having issued an audit report while registered with the PCAOB may vary, the PCAOB noted. Many of the firms included on the list are located in a jurisdiction where the PCAOB has been denied access to the information necessary to conduct inspections of registered firms on the basis of asserted restrictions under local law or objections based on national sovereignty. As of June 30, 2013, the PCAOB was unable to conduct inspections of firms located in 15 such jurisdictions (Austria, Belgium, China, Cyprus, the Czech Republic, Denmark, Greece, Hong Kong, Hungary, Ireland, Italy, Luxembourg, Poland, Portugal and Sweden).

In addition, the PCAOB was unable to conduct inspections of firms located in Venezuela despite continued communications with the Venezuelan government. The PCAOB said it continues to seek to resolve the obstacles to PCAOB inspections with the relevant authorities in all of these jurisdictions and remains optimistic about concluding bilateral agreements with many of them in the foreseeable future. The PCAOB has made a priority in particular of getting access to firms in China, but after high-level negotiations between officials with the Securities and Exchange Commission, the PCAOB and the Chinese government, so far the PCAOB has only made tangible progress on getting access to some audit work papers (see China Agrees to Send Audit Work Papers to U.S.)

With respect to certain other jurisdictions, namely Finland, France, Germany and Spain, cooperative agreements that permit PCAOB inspections have been concluded, but not all firms in the jurisdiction have been inspected to date, the PCAOB noted.

For the firms on the list of uninspected auditors, no PCAOB inspections have been completed, even though four or more years have passed since the end of the calendar year in which they first issued an audit report while registered with the PCAOB. However, the PCAOB cautioned that inclusion on the list should not be construed to support any positive or negative inferences about the quality of the firm's audit work, its systems, policies, procedures or practices.