PCAOB wants input on its strategic plan: What should firms suggest?

The Public Company Accounting Oversight Board voted Monday to request public comment on the goals and objectives for its 2026-2030 strategic plan.

"We must remain responsive to investors and market participants, provide greater clarity around our decision-making process, and foster trust through meaningful two-way communications and feedback," said PCAOB chairman Demetrios "Jim" Logothetis during an open meeting Monday at PCAOB headquarters in Washington, D.C. "At the same time, how we do this work matters. Achieving our mission depends on attracting and developing exceptional talent, equipping staff with modern technology and data-driven tools, and promoting operational excellence across the organization. That is what we aim to achieve in our PCAOB's 2026 through 2030 strategic plan."

He asked for input from investors, audit committee members, preparers, auditors, academics and others will rely on high-quality, independent audits. Earlier this year, he noted, the PCAOB launched an open comment period for its draft strategic priorities and received nearly 70 comment letters, more than twice as many as the number of comments previous boards received the last two times that the PCAOB requested comments on its draft strategic plans. Over 50 of the letters came from those we had never submitted a comment letter in the board's strategic planning process before. The PCAOB has already outlined three reinforcing draft priorities: 

1. Advance audit quality and investor protection;
2. Clarify expectations and our bases for decisions leading to understandable outcomes; and,
3. Transform how oversight is delivered.

The six draft goals are:

1. Modernize standard setting and implementation.
2. Modernize the inspections and registration programs.
3. Sharpen enforcement focus on conduct harmful to investors.
4. Deepen stakeholder engagement and communication.
5. Modernize oversight through technology and data.
6. Strengthen organizational effectiveness and stewardship.

The three priorities, "Advance, Clarify and Transform" are abbreviated as A-C-T, he noted.

Logothetis is expected to take a far more deregulatory approach than the previous PCAOB chair, Erica Williams, who was asked to resign by SEC chairman Paul Atkins last July. Audit enforcement actions fell sharply last year at both the PCAOB and the SEC after a mostly new set of board and commission members took over. The PCAOB has also moved to soften the requirements for the new QC 1000 quality control standard after postponing the effective date last year. Logothetis, who spent over 40 years working at Ernst & Young before retiring in 2019, is expected to take a much more friendly approach to auditing firms and has already laid out some of his priorities.

"The risks facing investors today look very different from the risks that shaped the PCAOB's design more than 20 years ago," said Logothetis. "Opening this comment period ensures that our direction is informed by those realities and by the voices of the people we are here to protect. We are committed to building a framework that strengthens trust, improves outcomes, and positions the BCAO to meet the challenges ahead with clarity and purpose."

George Botic, the longest-serving member of the PCAOB who was the only holdover from the previous set of board members and was acting chairman between Logothetis and Williams' terms, also said he supported the request for public comment.

He noted that the draft strategic plan articulates six broad goals and 17 more specific, but high-level objectives. The six goals include aspects related to the PCOB's primary functions: standard setting, registration, inspections and enforcement. In addition, they include goals addressing stakeholder engagement in communication, technology and data, and organizational effectiveness. 

The draft strategic plan continues to focus on engagement with investors and other outside stakeholders, as well as the use of technology and data, he noted. 

"I have long believed that our ultimate success depends on the extent to which we engage with and listen to all stakeholders," said Botic. "I'm also glad that the strategic plan has a clear emphasis on the use of technology and data. Given the tempo of change that we are experiencing across all facets of the finance reporting ecosystem, it is necessary that the PCAOB ensure that it is diligent in making sufficient investments in technologies, including artificial intelligence tools, that will allow us to fully utilize the data we collect to more quickly gain insights to better support our standard-setting inspection and enforcement activities going forward."

He encouraged all of the PCAOB's stakeholders to consider commenting on the draft strategic plan.

PCAOB board member Steven Laughton noted that the SEC plans to take on a more active role in regulating the audit profession. 

"In the next few years, we intend to focus our enforcement resources on violations that present the most risk," he said. "We will need to work closely with the SEC on this objective, especially since the SEC is building its own capacity to investigate significant audit deficiencies, independence failures and noncompliance with professional standards. We need new administrative protocols with the SEC to support these efforts. I believe the SEC's different legal authorities give them advantages in enforcement cases over the PCAOB. I have great respect for the PCAOB enforcement staff, but the Sarbanes-Oxley Act of 2002, as amended, limits the PCAOB's ability to get bad actors off the street quickly. Partly, this is because registered firms and associated persons can seek SEC review of any disciplinary action of the board, which stays the board's decision until the commission orders otherwise. We know there will be cases where the SEC's legal authority tacked more nimbly will better protect investors, and where the PCAOB can best fulfill its mission by supporting the SEC."

One of the objectives in the draft plan is Objective 3.2: "Clarify Enforcement Principles and Priorities and Strengthen SEC Coordination. We intend to strengthen the strategic focus, transparency, and effectiveness of the enforcement program by clarifying enforcement principles, priorities, and processes and formalizing aspects of coordination with the SEC. Establishing clearer protocols for investigative leadership responsibilities could streamline coordination and free enforcement resources to focus on advancing timely investor-protection outcomes."

"Needless to say, it will be critical that any protocols we develop under Objective 3.2 let nothing fall through the cracks," said Laughton. "I believe that the proposed 2026 through 2030 strategic plan keeps faith with our mission to protect investors by improving audit quality."

Another new board member, Mark Calabria, said he believes the PCAOB inspection reports need to have more clarity. "If an inspection report is too delayed, too opaque or too difficult to compare across firms, I believe it loses much of its value," he said. "The plan's emphasis on improving inspection report clarity and timeliness, in my opinion, is critical. It's an important step toward making our oversight more useful to investors, audit committees, and other market participants."

Calabria, who formerly worked at the White House Office of Management and Budget, said that as an economist, wants to see more emphasis on the costs vs. benefits of standards and enforcement. 

"Enforcement is essential for accountability and deterrence, but it is most effective when the board is clear about the types of conduct that warrant the most significant attention," he said. "A sharper focus on matters that present significant risk to investors and market integrity will ensure that enforcement resources are directed to where they can have the greatest public benefit. Second, cost-benefit discipline. Every regulator should not only ask whether a rule, standard, inspection approach, our program is well intended. We should also ask whether the action is likely to produce benefits that justify the costs. These costs, of course, are not limited to the dollars spent by audit firms. They include demands on talent, time, systems, audit committees, issuers and ultimately investors."

He noted that the draft plan also commits to post-implementation evaluation of standards. "Once the board adopts a standard, our work is not done," said Calabria. "We should ask whether the standard is working as intended in improving audit quality. We should also consider whether guidance or clarification is needed, and whether costs and implementation burdens are consistent with what the board anticipated. That feedback loop is essential if we want our standard to remain effective and credible over time."