Consider changes to PCAOB rules and forms in light of the increased disclosure and demand for firm and engagement metrics.

Most Recent Action

On April 9, 2024, the Board voted to issue a proposal for amendments to its rules and reporting forms to require the reporting of specified firm-level metrics on new Form FM, Firm Metrics, and specified engagement-level metrics on an amended and renamed Form AP, Audit Participants and Metrics.

The comment period is open through June 7, 2024. 

In brief, the Board’s proposal would: 

  • Require reporting of firm-level metrics annually on a new Form FM, pursuant to a new Rule 2203C, Firm Metrics, for firms that serve as lead auditor for at least one issuer that is an “accelerated filer” or “large accelerated filer” under SEC rules;
  • Require reporting of engagement-level metrics for audits of accelerated filers and large accelerated filers on a revised Form AP; and
  • Allow, but not require, limited narrative disclosures on both Form FM and Form AP to provide context and explanation for the required metrics.

Additional information on the proposal:



On October 6, 2008, the U.S. Department of Treasury's Advisory Committee on the Auditing Profession ("ACAP") published a report detailing recommendations that would enhance the sustainability of a strong and vibrant public company auditing profession. This report contained a number of recommendations requiring action by several different organizations including regulators, professional bodies, and others. One of the ACAP recommendations suggested that the PCAOB, in consultation with auditors, investors, public companies, audit committees, boards of directors, academics, and others, determine the feasibility of developing key indicators of audit quality and effectiveness and requiring auditing firms to publicly disclose these indicators and, assuming development and disclosure of indicators of audit quality are feasible, require the PCAOB to monitor these indicators.  

In 2015 the PCAOB issued a Concept Release on Audit Quality Indicators and sought comment on 28 potential indicators.

Presently, some audit firms disclose certain firm-level level metrics publicly through their Audit Quality Reports, Transparency Reports, or other published reports. Other audit regulators either have or are considering initiatives related to the disclosure of firm metrics.



The Board issued a proposal for public comment on April 9, 2024.