Standard-Setting, Research, Rulemaking, and Related Activities

This page explains the PCAOB’s active standard-setting, research, and rulemaking initiatives. It also provides information related to each project on the agendas, and other activities performed in support of standard-setting and research.

Standard-Setting and Research Projects

The PCAOB seeks to establish and maintain high-quality auditing and related professional practice standards for audits of public companies, as well as of registered broker-dealers, in support of the PCAOB’s mission to protect investors and further the public interest in the preparation of informative, accurate, and independent audit reports. The PCAOB’s Office of the Chief Auditor, in collaboration with other PCAOB offices and divisions, assists the Board in establishing and maintaining PCAOB standards.

The PCAOB’s standard-setting and research agendas are informed by the organization’s strategic plan, which sets forth the goals and objectives that support the PCAOB’s statutory mission. The agendas translate those goals and objectives into specific standard-setting and research initiatives, helping ensure that PCAOB resources are focused on areas where regulatory action, research, or other activities can meaningfully improve audit quality and investor protection.

In developing the agendas, the PCAOB considers current and emerging audit issues, including advances in technology; the results of PCAOB oversight activities; engagement with investors and other stakeholders, including through the PCAOB’s advisory groups; discussion with U.S. Securities and Exchange Commission staff; activities of other regulators and standard setters; and other relevant inputs and developments. The PCAOB is committed to a transparent standard-setting process, including, for example, seeking public input on the development of its standard-setting and research agendas.1 The High-Level Summary of Public Comments on PCAOB Standard Setting maps comments received on the Strategic Priorities RFC and the Standard Setting RFC to the standard-setting and research agendas.

The standard-setting and research agendas are dynamic and may evolve as the PCAOB gains new insights from our oversight activities or as circumstances change. The Office of the Chief Auditor will generally update this webpage at least quarterly to reflect changes driven by the types of factors discussed above and project developments.

Recently Completed Standard-Setting Projects

ProjectEffective DateDate of Board AdoptionDate of SEC Approval

Quality Control – Amendments to QC 1000

Effective on December 15, 2026.

September 9, 2026 Pending

Current Standard-Setting Projects

The standard-setting agenda focuses the PCAOB’s resources on matters where improvements to PCAOB standards could provide the greatest overall benefit to audit quality, investors, and the public interest.

Standard-setting projects listed below are being actively developed by the staff. Additional standard-setting projects will be considered at a later date as we progress work on the current agenda and may include amendments to additional interim standards.2

ProjectProject DescriptionAnticipated Next Steps

Negative Assurance related to Comfort Letter Engagements

  • Consider targeted amendments to AS 6101, Letters for Underwriters and Certain Other Requesting Parties, related to the auditor’s ability to provide negative assurance on subsequent changes to specified financial statement line items.

Staff is developing a proposal for Board consideration in Q4 2026 

Auditor Independence 
  • Consider whether the interim ethics and independence standards, as adopted upon the establishment of the PCAOB, are necessary to retain in their current form given the potential overlap with provisions in SEC’s Rule 2-01 of Regulation S-X.
  • Consider whether amendments are necessary to the PCAOB’s independence standards and rules as a result of changes to the audit environment since the standards and rules were adopted.

Staff is developing a proposal for Board consideration in Q1 2027

Fraud
  • Consider amendments to AS 2401, Consideration of Fraud in a Financial Statement Audit, to better align an auditor’s responsibilities for addressing intentional acts that result in material misstatements in financial statements with the auditor’s risk assessment, including addressing matters that may arise from developments in the use of technology.
  • Consider alignment, as appropriate, with the requirements of ISA 240 (Revised), and with SAS No. 151, both of which are titled The Auditor’s Responsibilities Relating to Fraud in an Audit of Financial Statements.
Staff is evaluating feedback3 and developing a project plan
Noncompliance with Laws and Regulations
  • Consider amendments to modernize AS 2405, Illegal Acts by Clients, by integrating a scalable, risk-based approach aligned with the Board’s risk assessment standards and considering other relevant developments.
  • Consider alignment of the standard with the requirements of Section 10A of the Securities Exchange Act of 1934.
  • Consider alignment, as appropriate, with the requirements of ISA 250 (Revised), and AU-C 250, both of which are titled Consideration of Laws and Regulations in an Audit of Financial Statements. 
Staff is evaluating feedback4 and developing a project plan
Going Concern
  • Consider targeted amendments to AS 2415, Consideration of an Entity's Ability to Continue as a Going Concern, to (i) better coordinate the auditor’s responsibilities related to going concern evaluation with those of management under the applicable financial reporting frameworks, and (ii) respond to changes in investor needs.
  • Consider alignment, as appropriate, with ISA 570 (Revised 2024), Going Concern, and AU-C 570, The Auditor’s Consideration of an Entity’s Ability to Continue as a Going Concern.
Staff is evaluating feedback5 and developing a project plan

Research Projects

Research projects explore matters that may affect audit quality, investor protection, or the continued relevance and effectiveness of PCAOB standards. The nature, scope, and duration of research projects may vary. Some research projects examine a defined issue to determine whether a specific regulatory response is warranted, while others address foundational or cross-cutting developments and may evolve as the staff’s understanding of the topic and the topic itself develop. Research may lead to one or more of the following outcomes:

  • a new standard-setting project,
  • changes to the scope or direction of an existing project,
  • development of staff guidance,
  • another appropriate regulatory response, or
  • continued research and stakeholder outreach. 

To help expedite the research phase, the PCAOB welcomes stakeholders to email relevant data, analyses, or observations to [email protected].

Research projects listed below are being actively pursued by the staff.

ProjectProject Description
Data and Technology
  • Conduct centralized research on how auditors and companies are using new technologies and how those technologies may affect audit quality. Because technology continues to evolve quickly, the scope and outputs of this research project may change over time.
Firm and Engagement Performance Metrics
  • Perform additional research, including outreach with audit firms, to further understand metrics that could be useful in monitoring aspects of audit quality, including metrics that may currently be developed and monitored by firms themselves.
  • Perform additional outreach with audit committees and investors to determine what specified metrics, if any, about audit firms and individual audits that they would find useful in better understanding the state of audit quality.
  • Consider how the identified metrics could be leveraged in the PCAOB’s oversight activities, including quality control-informed inspections and related reporting, to advance investor protection and promote public interest. 
Communications with Audit Committees
  • Perform research and outreach with stakeholders on communications to audit committees to enhance their oversight activities.

Importance of Data and Technology Research

Technology is an important consideration across the PCAOB's standard-setting and research activities. As auditors, public companies, and broker-dealers increasingly use data analytics, automation, artificial intelligence, and other technologies, the PCAOB is examining how these developments affect audits and whether amending PCAOB standards or developing staff guidance may be appropriate.

The Data and Technology research project helps the PCAOB to monitor technological developments and consider whether they affect PCAOB standard-setting and related activities. Through its research activities, the PCAOB has gathered input from investors, auditors, preparers, software developers, and other stakeholders. This research and outreach have informed the PCAOB’s broader consideration of technology-related standard setting and guidance, including work involving technology-assisted analysis, confirmations, external audit evidence, and generative artificial intelligence. 

Technology considerations are embedded throughout the current agenda. For example, the Fraud and Going Concern projects may examine how technology affects auditor identification of misstatements and evaluation of an entity’s ability to continue as a going concern. Separately, the staff plans to develop guidance on considerations relating to the use of artificial intelligence by companies and auditors, and guidance on certain matters relating to digital assets.

As this work progresses, the staff will continue to examine existing standards to determine whether targeted amendments are needed to address technological developments and will keep this webpage updated to reflect any relevant changes. The PCAOB also welcomes stakeholders to email relevant data, analyses, or observations about the use of technology in audits to [email protected].

Activities Supporting Standard Setting and Research

Conceptual Framework for Standard Setting

The PCAOB is developing a conceptual framework for standard setting to promote transparency, consistency of standards, and efficient use of our resources. A conceptual framework can articulate a structured, principles-based approach to standard setting while remaining firmly grounded in the PCAOB’s statutory mandate to protect investors and further the public interest in the preparation of informative, accurate, and independent audit reports.

The PCAOB supports the objective of increased transparency of the standard-setting process. A conceptual framework may also address alignment of our standards with those of other standard setters. Development of the conceptual framework will be conducted in parallel with the above standard-setting and research projects.

Post-Implementation Review for Critical Audit Matters

Feedback obtained by the PCAOB through our requests for public comment during 2026 indicates there are differing views by stakeholders about the usefulness of critical audit matters (CAMs) disclosures and the need for further standard-setting actions. The staff plans to conduct a further post-implementation review of CAMs prior to determining whether to pursue further research, standard setting, or guidance. Additional information about this process can be found at Post-Implementation Review.

Staff Guidance

The staff regularly assesses whether issuing topic-specific staff guidance could be beneficial to auditors in applying one or more PCAOB standards or rules. As part of performing this assessment, the staff monitors requests and recommendations of stakeholders for guidance, and considers emerging audit issues, matters arising through PCAOB oversight activities, firm consultations, and activities of other regulators and standard setters. The staff is currently considering guidance on the following topics:

TopicDescription
Use of Artificial Intelligence

Develop staff guidance for auditors on considerations regarding (i) impacts on the audit of the company’s use of artificial intelligence (AI) in financial reporting and (ii) use of AI by the auditor.

Digital Assets

Develop staff guidance for auditors of entities that hold or issue digital assets regarding certain matters affecting the relevance and reliability of audit evidence. 

Accumulating Identified MisstatementsDevelop staff guidance on the considerations for determining a threshold when accumulating identified misstatements that are not “clearly trivial” in accordance with AS 2810, Evaluating Audit Results.

Rulemaking Projects

In addition to standard-setting and research projects, the Board is considering the following rulemaking project. Proposed changes to PCAOB rules generally undergo a public notice-and-comment process to gather input from investors and other stakeholders.

ProjectProject DescriptionAnticipated Next Steps
Permanent Broker-Dealer Inspection Program

Consider amendments to establish a permanent program of inspection related to audits of brokers and dealers.

 

Staff is developing a proposal for Board consideration in Q4 2026 

1 The agendas reflect feedback received via the two requests for public comment issued in 2026 – PCAOB Release No. 2026-001, Request for Public Comment on PCAOB Strategic Priorities (“Strategic Priorities RFC”) and PCAOB Release No. 2026-005, Request for Public Comment on PCAOB Standard Setting (“Standard Setting RFC”). Comments received on the Strategic Priorities RFC (issued March 31, 2026) informed the potential focus areas identified in the Standard Setting RFC (issued June 23, 2026). Through the Standard Setting RFC, the Board sought additional stakeholder feedback on standard-setting and research priorities.

2 In April 2003, the Board adopted, on an interim basis, certain standards of the American Institute of Certified Public Accountants (collectively, the “interim standards”). A number of these standards have since been updated or replaced through the Board's standard-setting initiatives. The remaining interim standards continue to be in effect substantially in the form adopted.

3 Refers to feedback from the Standard-Setting RFC and Strategic Priorities RFC among other considerations.

4 Id.

5 Id.