The Issue

The Public Company Accounting Oversight Board (PCAOB) issued its Draft 2026–2030 Strategic Plan Goals and Objectives, outlining priorities that could significantly shape public company audit regulation over the next several years. The plan focuses on modernizing standard-setting and inspections, sharpening enforcement priorities, strengthening stakeholder engagement, expanding the use of technology and data, and improving organizational effectiveness.

PICPA generally supports this direction, particularly the emphasis on high-quality and implementable standards, quality-control-focused inspections, clearer regulatory expectations, risk-focused enforcement, and improved stakeholder engagement. However, the strategic plan also presents an important opportunity to ensure that PCAOB oversight remains scalable, proportionate, transparent, and responsive to firms and public companies of different sizes and risk profiles.

Our Position

PICPA submitted comments supporting the PCAOB’s overall direction while recommending that scalability, proportionality, due process, implementation discipline, and measurable accountability be more explicitly incorporated throughout the final strategic plan. We emphasized that maintaining a diverse audit firm marketplace is important to investor choice and capital formation and that the PCAOB should consider whether cumulative regulatory costs and operational demands create unintended barriers for small and midsize firms.

Among PICPA’s key recommendations, we urged the PCAOB to:

• Modernize standard-setting by emphasizing evidence-based rulemaking, field testing, scalability, professional judgment, timely implementation guidance, and greater alignment with international standards. We also encouraged the PCAOB to address AI and the integration of emerging technologies into the audit process.
• Make inspections more risk-based and focused on improving audit quality, including greater emphasis on firms’ systems of quality control and remediation rather than simply identifying noncompliance.
• Adopt a differentiated approach to broker-dealer inspections. We support continued PCAOB inspection of auditors of higher-risk carrying broker-dealers but encouraged consideration of AICPA Peer Review and state accountancy regulation for lower-risk, non-carrying broker-dealer engagements.
• Focus enforcement resources on conduct that meaningfully threatens investors. Technical, administrative, or isolated matters that do not create meaningful investor harm should generally be addressed through guidance, inspections, or remediation rather than public enforcement.
• Strengthen engagement with small and midsize firms and other stakeholders early enough in the regulatory process for their perspectives to influence decisions.
• Increase transparency and accountability by establishing measurable performance indicators for areas such as inspection and standard-setting timeliness, regulatory costs, remediation, stakeholder understanding, technology modernization, and changes in the diversity of firms participating in the public company audit market.
• Promote responsible fiscal stewardship by considering meaningful benchmarks for PCAOB spending and investments and embedding accountability mechanisms that remain effective as Board leadership and regulatory priorities change.
• Bring practical small-firm experience into the inspection process by ensuring inspectors assigned to smaller firms understand how PCAOB standards are applied in smaller and less-complex practice environments.

Ultimately, PICPA believes investor protection, high audit quality, and proportionate regulation are complementary goals. A modern PCAOB oversight framework should protect investors while encouraging responsible innovation, preserving a diverse audit firm marketplace, and ensuring companies of all sizes continue to have access to qualified public company auditors.

Read the PICPA Comment Letter on PCAOB Draft 2026-2030 Strategic Plan