Post-Implementation Review of AS 3101, The Auditor's Report on an Audit of Financial Statements When the Auditor Expresses an Unqualified Opinion

The new requirement for auditors to report critical audit matters (CAMs) is the most significant change to the auditor's report in more than 70 years. 

The PCAOB is committed to fully understanding the impact of CAM requirements on audit firms, preparers, audit committees, investors, and other financial statement users. 

Interim Analysis

PCAOB staff will conduct an interim analysis in 2020 to gain an initial understanding of: (1) how auditors responded to the CAM requirements, (2) whether and how investors are using CAM communications, and (3) audit committee and preparer experiences.

The staff will also evaluate whether early evidence from the implementation of CAM requirements is suggestive of significant costs, benefits, or unintended consequences.

To inform the analysis, the staff is conducting surveys and targeted interviews of impacted stakeholders including auditors, preparers, audit committee members, investors, and other financial statement users. 

The staff has also issued a request for comment to collect information from stakeholders on initial experiences with CAM implementation. 

The PCAOB expects to produce a report in the fourth quarter of 2020 to communicate findings and provide stakeholders with early insights into initial CAM implementation.

Post-Implementation Review

The PCAOB staff will conduct a full post-implementation review of the standard after a reasonable period of time following the full implementation of AS 3101.  The results of the post-implementation review will be made available to the public.