The issue

Firm ownership models are grow more complex with the inclusion of private equity, technology investors, sovereign wealth funds, and other capital structures. The National Association of State Boards of Accountancy (NASBA) is evaluating if these investments have an effect on the public interest, firm independence, governance structures, and audit quality. NASBA's Private Equity Task Force White Paper on Alternative Practice Structures (APS) and Private Equity signals increased regulatory attention.

Our position

The PICPA submitted a formal response to the white paper (see below) with a clear message: we support regulation that protects the public but oppose changes that create unnecessary burden or inconsistent rules.

Support for Modern, National Standards—Not a Patchwork of State Rules

The PICPA urges NASBA to pursue nationally consistent standards through existing standard-setting and regulatory bodies. State-by-state regulation cannot kept pace. Patchwork rules increase costs, risks, and administrative burdens.

Opposition to State-Specific Independence, Disclosure, or Oversight Requirements

Current frameworks—the AICPA Code of Professional Conduct, Quality Management standards, and the national peer review program—already provide strong safeguards for audit quality and independence. New state-level rules would add operational burden without improving audit quality or public protection.

Framing Alternative Practice Structures (APS) as “Complex Ownership Structures,” Not Private Equity

APS encompasses a wide range of ownership and financing arrangements beyond private equity. Any regulation should reflect the full scope of complex ownership structures. A private-equity-only focus risks outdated or ineffective regulation and fails to address broader shifts in the profession.

The PICPA advocates for regulation that protects the public while recognizing the evolving reality of firm ownership:

• Regulation that keeps pace with changing ownership models, not just private equity.
• Changes should be within existing national standard-setting and regulatory frameworks.
• Audit quality and ethical standards remain paramount.

More Details:

• PICPA Comment Letter on the AICPA Professional Ethics Executive Committee Exposure Draft - Proposed Revisions Related to Alternative Practice Structures - April 30, 2026
• PICPA comments on the NASBA Private Equity Task Force White Paper - Alternative Practice Structures & Private Equity: Considerations and Questions - Jan. 29, 2026.

Reviewed June 2026