Under the Sarbanes-Oxley Act, non-U.S. public accounting firms that audit or play a substantial role in the audit of U.S. issuers, brokers, and dealers are subject to oversight by the PCAOB. Currently, over 900 non-U.S. audit firms from more than 85 countries have registered with the PCAOB. Under the Act and the Board's rules, non-U.S. registered firms are subject to PCAOB inspections in the same manner as U.S. firms. This often raises special considerations. The Board began talking about these issues with its non-U.S. counterparts not long after its establishment, and adopted a cooperative framework that allows the PCAOB to rely, to a degree deemed appropriate by the Board, on inspection or enforcement work performed by a home-country regulator. Reliance by the Board is based on a sliding scale -- the more independent and rigorous a home-country system of oversight, the more the Board may rely upon it. By developing cooperative arrangements with its counterparts, the PCAOB endeavors to minimize administrative burdens and potential legal or other conflicts that non-U.S. registered firms may face.
In countries without an independent audit regulator, or where the inspection program is nascent, the PCAOB still seeks to coordinate with the relevant financial regulator or government ministry before commencing inspections.
Also, because the Board recognizes that cooperation is a two-way street and, therefore, should be reciprocal, the PCAOB rules allow the PCAOB to assist non-U.S. regulators in their inspections and investigations of U.S. firms that are subject to dual oversight.