Form AP, Auditor Reporting of Certain Audit Participants

What Was Changed

Registered audit firms are required to submit Form AP, Auditor Reporting of Certain Audit Participants, to disclose the names of engagement partners and other accounting firms that participated in their audits of public companies. 

Additional information on the rule: 

• SEC Action: Release No. 34-77787
• PCAOB Rule: 3211. Auditor Reporting of Certain Audit Participants
• Adopting Release: PCAOB Release No. 2015-008
• Fact Sheet: Disclosure of Engagement Partner and Certain Other Participants on New PCAOB Form AP

Why Was This Rule Created?

The PCAOB adopted the rule to improve transparency regarding the engagement partner and other accounting firms that took part in the audit. 

Investors and others can find out who is leading and participating in the audits of public companies through  AuditorSearch, a public database based on Form AP filings.

Explore AuditorSearch

Staff Guidance

The PCAOB staff guidance provides information on completing Form AP and covers other provisions of the recently enacted rules. The guidance was last updated as of July 1, 2024, to align the example of Form AP reporting for a reverse merger/de-SPAC transaction with the requirements under the SEC’s SPAC rules. Other technical updates are summarized on the “Summary of July 1, 2024 Updates” table. Staff may update this guidance as needed.

• Form AP, Auditor Reporting of Certain Audit Participants, and Related Voluntary Audit Report Disclosure Under AS 3101, The Auditor’s Report on an Audit of Financial Statements When the Auditor Expresses an Unqualified Opinion (July 1, 2024)

Form AP Instructions

Firms may submit an individual Form AP using a web form or may submit multiple forms at once using XML. 

• Form AP General Instructions
• Form AP Sample Form

XML Technical Specification

XML submissions for Form AP should conform to the XML schema below. 

The information in this specification was prepared by the staff of the Office of Information Technology at the PCAOB to be helpful to firms that intend to use XML to submit Form AP. It is not a rule, regulation, or statement of the PCAOB, and the Board has neither approved nor disapproved it. The information in this specification may change from time to time. As a result, users should check this page to ensure that the specification they are using is the most current one.

• Form AP XML Instructions (May 2020)
• Form AP XML Schema (XSD)
• Firm Data File (.txt) — The Firm Data File is a machine-readable list of firm information that is solely provided for the purpose of creating XML submissions for Form AP. This file is automatically updated once per day (overnight) to reflect changes in the PCAOB web-based registration and reporting system. By downloading this file each time they make an XML submission for Form AP, firms will ensure that the most recently available information is reflected in their XML submission.
• Form AP Sample XML Files and Related Forms (.zip) — This package of PDF and XML documents provides illustrative examples of XML-based Form AP filings and amendments.

Tutorials on Filing and Amending Form AP via XML