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 of Critical Audit Matter Requirements

The PCAOB has released an interim analysis report and two accompanying white papers analyzing the initial impact of the CAM requirements. The PCAOB has also made available the CAMs dataset used in its analysis. The interim analysis report and white papers are part of an ongoing evaluation of the overall effect of the CAM requirements on key stakeholders in the audit process.

Staff of the PCAOB's Office of Economic and Risk Analysis conducted extensive stakeholder outreach and performed large-sample statistical analysis to provide an initial understanding of:

  • Audit firm and audit engagement team responses to the CAM requirements.
  • Investor use of CAM communications.
  • Audit committee and preparer experiences related to CAM implementation.

Key findings from the staff's analyses include the following:

  • Audit firms made significant investments to support initial implementation of the CAM requirements.
  • Investor awareness of CAMs communicated in the auditor's report is still developing, but some investors are reading CAMs and find the information beneficial.
  • The staff has not found evidence of significant unintended consequences from auditors' implementation of the CAM requirements for audits of large accelerated filers in the initial year.

Further information on implementation of the CAM requirements is available in the Standards section of this website.

Post-Implementation Review

The PCAOB expects to issue a further report in 2022 to provide perspectives on any changes the staff observes in the communication of CAMs and to provide insights on the initial impact of CAMs communicated in the audit reports of smaller issuers. Because some of the effects of the CAM requirements may take several years to fully manifest or stabilize, the PCAOB expects to publish a more comprehensive post-implementation review in 2024.


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