Non-U.S. Firm Registration

Under the Sarbanes-Oxley Act and PCAOB rules, public accounting firms that prepare or issue audit reports on U.S. public companies, brokers and dealers, or that play a substantial role in the preparation or issuance of such reports, must be registered with the PCAOB and must undergo regular inspections by the PCAOB to assess the firm's compliance with applicable U.S. law and professional standards. This applies to both U.S. and non-U.S. public accounting firms.

Since 2005, when the Board started inspecting firms in non-U.S. jurisdictions, the PCAOB and local authorities in many non-U.S. jurisdictions have worked together to overcome potential impediments to PCAOB inspections. In some non-U.S. jurisdictions, however, asserted legal restrictions or objections of local authorities continue to pose unresolved obstacles to PCAOB inspections, despite the Board's efforts for several years to resolve such issues.

In October 2010, the PCAOB implemented a new registration policy to consider inspection obstacles as a potential basis for disapproval. Currently, when a firm that is located in a non-U.S. jurisdiction in which the PCAOB is unable to conduct inspections applies for registration, the PCAOB will ask — through a request for additional information -- the firm's understanding of whether a PCAOB inspection would be permitted by local law or local authorities. If the response is that the PCAOB inspection would be permitted, the firm is asked to supply with its response to the PCAOB written confirmation from the appropriate local regulatory authority. If the firm responds that its understanding is that a PCAOB inspection would not be permitted by local law or local authorities, the PCAOB will issue a notice of hearing noting as a proposed ground for disapproval of the application the obstacle to the Board's inability to inspect. The applicant also has the option of allowing the application to remain pending by not responding to the request until it is able to provide written confirmation that a Board inspection would be allowed.

Below is information regarding PCAOB registration of non-U.S. firms. Additional information on PCAOB registration may be found by referring to the Registration and Reporting link located to the right under Related Information.