Calamitous CAMs: Clarifying Critical Audit Matters

Despite being effective for several years now, the PCAOB’s guidance around critical audit matters (CAMs) still seems to confound many audit teams. Although inherent in the label “critical audit matter,” let’s first define this term. According to AS 3101: The Auditor’s Report on an Audit of Financial Statements When the Auditor Expresses an Unqualified Opinion states:

A critical audit matter is any matter arising from the audit of the financial statements that was communicated or required to be communicated to the audit committee and that: (1) relates to accounts or disclosures that are material to the financial statements and (2) involved especially challenging, subjective, or complex auditor judgment. (emphasis added)

The objective of the CAMs guidance is to provide investors with additional insight into some of the challenges within the audit. The CAMs guidance focuses on those items that are material AND that require challenging, subjective, or complex auditor judgment. The standard then goes on to provide guidance to engagement teams on how to identify and evaluate potential critical audit matters and provides specific disclosure and documentation requirements.

Though there is auditor judgement in the final determination of what constitutes a CAM, the process outlined in AS 3101 is fairly straightforward and the recurring comments identified by the PCAOB are often not related to the judgment applied in concluding on CAMs, but rather, around auditor’s failures to follow the CAMs guidance, as prescribed. Specifically, in its most recent inspection observations, the PCAOB cited that it continues to identify recurring issues with CAMs stemming predominantly from the following:

Engagement teams failing to perform a complete evaluation over potential critical audit matters;
Engagement teams failing to sufficiently disclose (in the audit report) the principal considerations that lead the auditor to determine the matter was a CAM; and
Engagement teams failing to accurately disclose the audit procedures performed to address the critical audit matter.

As a former inspector, these types of issues are what we refer to as “low-hanging fruit.” Said differently, these are easy issues for the PCAOB to identify because they’re objective and don’t incorporate judgment; either the engagement team followed the guidance in the standard or they didn’t.

We provide further definition, insight on the effectiveness, and preparedness guidance for CAMs, in our initial JGA blog on critical audit matters here to supplement the information presented in this article.

Completeness of CAMs

The first major issue (which we have seen across the industry on clients of all sizes) is the completeness of the evaluation of potential CAMs. According to AS 3101, the guidance requires that the auditor document its evaluation of all matters that “[were] communicated or [were] required to be communicated to the audit committee” AND “relates to accounts or disclosures that are material to the financial statements.”

At first glance, this sounds easy enough. However, let’s not forget that there are extensive audit committee communication requirements, as outlined in AS 1301: Communications with Audit Committees. When starting to perform the CAM evaluation and analysis, many engagement teams default to the simple or more obvious communications such as the communication of significant risks and fraud risks, but if you dig into the guidance, audit committee communications incorporate much more than just the significant risks. For instance, engagement teams are required to communicate critical accounting policies and practices, critical accounting estimates, significant unusual transactions, new accounting pronouncements, and alternative accounting treatments, to name just a few. Many of these items will not be a significant risk and may feel routine or ostensibly non-complex, so auditors leave these items out of the CAM analysis. But if you go back to the guidance in AS 3101, these are required communications that typically relate to material accounts or disclosures, which means the evaluation of whether these are CAMs must be documented.

In working with teams through PCAOB inspections or through in-flight or other practice monitoring reviews, we often find that auditors are inherently performing the CAM analysis in their heads but they are not documenting the evaluation, as required. Yes, the A/R allowance might be non-complex, but it’s an estimate and is typically grouped in the accounting policies and/or critical accounting estimates footnote disclosures. This means it’s a required communication to the audit committee and if it’s material, the auditor is required to document its evaluation of whether it is a CAM.

To address this issue, we recommend that firms use a CAMs evaluation tool. A tool that is implemented across the public company audit practice will help ensure that all audit committee communications are considered. In addition, a tool will ensure that all considerations are consistently applied for all matters (e.g. material, challenging, subjective, or requires complex auditor judgment). If an item is not material, then the rest of the tool is relatively easy to complete. If it is material, then the tool will help guide teams in documenting its evaluation taking into account the relevant criteria (refer to AS 3101.12 for specific considerations). There’s no one right way to ensure the evaluation is complete, but a tool will ensure completeness of the potential CAMs and lays out the relevant considerations that support the engagement team’s conclusion on what is and is not a CAM.

Sufficiency of CAMs Disclosure

Once the auditors have concluded on what matters constitute a CAM, the next step is to draft the CAM disclosure language. The guidance in AS 3101 gives specific disclosure requirements including the following:

.14 For each critical audit matter communicated in the auditor's report the auditor must:

a. Identify the critical audit matter;

b. Describe the principal considerations that led the auditor to determine that

the matter is a critical audit matter;

c. Describe how the critical audit matter was addressed in the audit; and

Note: In describing how the critical audit matter was addressed in the audit, the auditor may describe: (1) the auditor's response or approach that was most relevant to the matter; (2) a brief overview of the audit procedures performed; (3) an indication of the outcome of the audit procedures; and (4) key observations with respect to the matter, or some combination of these elements.

d. Refer to the relevant financial statement accounts or disclosures that relate

to the critical audit matter.

While the PCAOB is not often challenging (or at least not taking issue with) the audit team’s conclusion of what constitutes a CAM, the regulator is taking issue with the sufficiency of the CAMs disclosures. Specifically, the PCAOB is finding that audit reports do not provide sufficient discussion around the principal considerations that support the auditor’s conclusion that a matter is a CAM. In other words, the key considerations that are documented in the CAMs evaluation template (i.e. what makes something especially challenging, complex, or subjective, requiring auditor judgment) are not making it to the audit report. The PCAOB has made abundantly clear that CAMs are not intended to use standardized language and that each CAM disclosure should be tailored to the specific audit. However, firms should have draft opinions that include the four bullets cited above so that when the CAM disclosure is drafted, it includes all items required to be disclosed. Again, the PCAOB is not challenging the judgment itself; they’re challenging the lack of disclosure evidencing the auditor’s judgement.

Accuracy of the CAMs Disclosure

In addition to the sufficiency of the disclosure, the PCAOB is also taking issue with the accuracy of the CAMs disclosure in the audit report. Specifically, the PCAOB is finding that CAMs disclosures often cite inaccurate procedures when discussing how the critical audit matter was addressed. Though we haven’t performed a root cause analysis, two of the main issues we’ve seen stem from the following:

Use of boiler plate language: Some firms have drafted standard language for CAMs disclosures. These drafts are typically intended to provide an example. However, some teams don’t tailor this language and as a result, include irrelevant and/or inaccurate procedures.
Use of CAMs from other audits: Similar to the boiler plate discussion above, some teams pull sample CAM disclosures from other audits and don’t tailor the language so that it is client specific.
Drafting CAMs based on planned procedures as opposed to executed procedures: Many teams perform the CAMs evaluation prior to the wrap up the audit procedures. As a result, teams are drafting the CAMs, including referencing the procedures performed to address the critical audit matter, based on the planned audit approach. While we encourage accelerating the audit and applaud early completion of the CAMs documentation, it’s important that the final disclosure mirror the actual audit procedures performed.

Review and Supervision

Although templates and tools help guide teams through the analysis/evaluation and example CAM disclosures can help teams draft the audit report, let’s not forget the importance of the review process. Most firms already have multiple reviews in place for each opinion issued. Despite these elements, the PCAOB is still finding these non-judgmental issues. Thus, certainly, some element of these failures goes back to the timing and quality of the review and supervision.

When I perform inspections, one of the first things I do when reviewing CAMs is to reconcile the CAMs evaluation documentation to the list of significant risks (documented in planning), the planning/interim audit committee communications and the year-end audit committee communications. Often, because there are multiple drafts that go through various team and client reviews, I ensure I am looking at the final audit committee communications.

Similar to the CAMs evaluation tool, when I read the CAMs disclosure in the audit report, the first thing I do is a) reconcile the disclosure to the CAMs evaluation tool to ensure the relevant considerations giving rise to the CAM are adequately discussed in the audit report and b) review the relevant audit steps to ensure the procedures disclosed in the audit report represent the actual executed procedures.

Engagement teams, but especially managers, partners, and engagement quality reviewers should be performing more robust reviews to ensure the completeness of the CAMs evaluation tool and the sufficiency and accuracy of the CAMs disclosures, even if it means performing detailed reconciliations, as discussed above; this is exactly what the PCAOB is doing and if they’re finding the issues, a thorough internal review should also identify these matters. To facilitate these reviews, firms could consider developing a review template (i.e. similar to an EQR checklist) specifically asking about each requirement in AS 3101.

In addition, firms could consider implementing additional “targeted reviews” or require consultations over CAMs. This would ensure an extra layer of review on top of the engagement team, though for any review to be effective, it’s also important that sufficient time be built into the review process; nothing new here – it’s just a matter of planning appropriately.

In December 2022, the PCAOB released an interim analysis report discussing some of its findings around the effectiveness of the new CAMs guidance. Though the evaluation is still ongoing, the goal of the CAMs standard was to provide investors with more specific information related to the audit. That information is only as useful as it is complete and accurate. Thus, the PCAOB’s comments stem largely from the incomplete evaluation of CAMs and the inaccurate/insufficient disclosures related to CAMs. In this, the information age, completeness and accuracy are paramount, whether applying these principles to the data used in audit test work or to the relatively short audit report that sums up the entire audit conclusion.

Key Takeaways

Consider developing a standardized CAMs evaluation tool that includes categories for all required audit committee communications. As part of review, perform a reconciliation from the CAMs evaluation tool to the audit committee communications and to the planning documentation.
Review all CAM disclosures and ensure the disclosures mirror the relevant factors /considerations that lead to the auditor’s conclusion about a CAM.
Reconcile CAM disclosures to the relevant audit workpapers, ensuring the procedures performed to address a CAM are accurately described in the audit report.
Don’t underestimate the PCAOB’s attention detail. Managers, partners, and EQRs need to perform timely, detailed reviews over the CAMs evaluation documentation as well as the CAMs disclosures.
As is always the case, document ANY and ALL judgments applied when evaluating critical audit matters.

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Rethinking Engagement Acceptance: Why “Yes” Isn’t Always the Right Answer

By Jackson Johnson • July 30, 2025

Introduction In today’s regulatory climate, audit firms must take a fresh look at how they evaluate engagement acceptance and client continuance. The stakes have never been higher. With the PCAOB’s newly adopted QC 1000 standard and the AICPA’s SQMS 1 framework now in effect , firms are expected to demonstrate a more rigorous, risk-based approach to quality control—starting with the very first decision: "Should we take this engagement?" The PCAOB recently released a new Audit Focus: Engagement Acceptance on this topic (Audit Focus). At the same time, we’ve been speaking, writing, and helping firms improve their process in this area. On the steps of PCAOB’s recent and timely guidance, this article explores the evolving risk landscape and offers practical guidance for firms to strengthen their engagement acceptance protocols in line with new regulatory expectations and JGA’s quality management insights. The New Risk Landscape: What QC 1000 and SQMS 1 Require The PCAOB’s QC 1000 standard introduces a scalable, risk-based framework that applies to all firms performing PCAOB engagements. It emphasizes that engagement acceptance is not just a procedural checkpoint, it’s a critical quality control decision that must reflect the firm’s risk profile, independence safeguards, and capacity to deliver a high-quality audit. Key risks highlighted in QC 1000 include: Independence and ethics violations: Firms must have systems to identify and escalate potential conflicts, including automated tracking of financial interests. Monitoring of in-process engagements: Firms are expected to assess quality risks before and during engagements, not just after the fact. Scalability and oversight: Larger firms face enhanced requirements, including external oversight and formal complaint tracking mechanisms. Similarly, SQMS 1 requires firms to design and implement a system of quality management that includes robust procedures for engagement acceptance and continuance. These procedures must consider: integrity and reputation of the client firm competence and resources ethical and legal requirements, and risks to audit quality and compliance. Issues arising from poor or inconsistent client or engagement acceptance policies and procedures isn’t new, but is being looked at in new ways by firms and their regulators with the: decrease in public company auditors qualified or going to market on conducting public company audits increasing number of firms that have been stripped of their privilege to conduct public company audits, and movement of companies to different auditors (think BF Borgers as the most egregious example, but your typical attrition in the most common case). The PCAOB, AICPA, and other regulators around the world, will take these business risks and apply them in a new lens in their inspection, peer review, and enforcement processes as they look at how firms have identified and addressed risks when implementing their QC system when it comes to client acceptance. Improving Communications: Predecessor Auditors & Audit Committees Recent PCAOB inspection findings and the Audit Focus document emphasize that engagement acceptance decisions are under increasing scrutiny. Deficiencies in areas like AS 1301 (Communications with Audit Committees) and AS 2610 (Successor Auditor Communications) often stem from weak or incomplete risk assessments at the outset of the engagement. Firms must be prepared to engage in transparent, candid conversations with audit committees, especially when the going gets tough. Whether it’s disclosing an unanticipated CAM , identifying a material weakness in internal control , or explaining a shift in audit scope, the ability to communicate openly and credibly is a hallmark of audit quality. Similarly, in our article on audit committees , we emphasized that audit committees are becoming more sophisticated and assertive. They expect auditors to be proactive, risk-aware, and ready to explain their judgments—not just their procedures. The Audit Focus does a great job of asking questions for firms to consider in assessing the quality of both management and the AC. As part of your engagement acceptance process, assess not only the technical risks of the engagement, but also the firm’s ability to maintain transparency and trust with the audit committee. Ask: Will we be able to have frank conversations with this client’s governance team? Are we prepared to deliver difficult messages if needed? Do we have the right people and protocols in place to support those conversations Internal Inspections: Engagement Acceptance as a Root Cause The Audit Focus also highlights how engagement acceptance decisions can directly impact audit quality and inspection outcomes. We encourage firms to examine their internal inspection programs to see how/whether outcomes can inform or rise to potential root causes targeting the firm’s engagement/client acceptance process. For example, a risk-based selection for the annual internal inspection process should include certain jobs tied specifically to new client and new engagements:

Innovative Solutions for QC 1000, SQMS 1, & ISQM 1: Quality Management tools in the Marketplace

By Jackson Johnson • July 15, 2025

Introduction As explored in previous JGA Advisor articles, the implementation of quality management standards such as ISQM 1, SQMS 1, and QC 1000 has reshaped how audit firms approach compliance, risk, and continuous improvement. These standards demand a proactive, risk-based, and firm-wide system of quality management (SoQM) that is both scalable and adaptable to local jurisdictions. We have seen through our work with firms that a tech solution is just part of the equation. Of course, having the right human capital with the capacity, drive, skills, and leadership to influence implementation across so many functions of the firm is critical. Also, understanding a baseline of risks and controls – beyond the minimum explained in the standards – will go a long way for smoother implementation. We recommend taking a look at the AICPA Practice Aid and many other AICPA resources for firms embarking on their implementation journey. While the standards themselves are rigorous, the complexity of implementation—especially across multiple jurisdictions—has led many firms to look to ways to document their system with reliable workflows in a database or other system. What we have seen is that – at a minimum – an excel solution, especially coupled with other tools like smart sheets, is the easiest entry point for a tech solution for implementation. Other more advanced tools not only streamline compliance but also enhance documentation, accountability, and real-time monitoring. In this article, we explore how three platforms—Inflo, Caseware, and QMCore—are helping firms meet these challenges and elevate their quality management systems. Why Software Matters for Quality Management Successfully implementing a SoQM under ISQM 1, SQMS 1, QC 1000, or other jurisdictional standards requires more than policies and procedures—it requires leadership, training, communication, and a culture of quality. But most importantly, it requires technology. Software platforms like QMCore, Inflo, and Caseware offer firms the ability to: Assign and track ownership of quality tasks across the firm, ensuring accountability, and transparency. Streamline risk assessment, monitoring, and remediation, which are core to all modern quality management standards. Provide real-time reporting and dashboards that allow leadership to monitor compliance and identify deficiencies early. Adapt to evolving regulatory requirements across jurisdictions, including CSQM 1 (Canada), SSQM 1 (Singapore), ASQM 1 (Australia), and PES 3 (South Africa). Educate and enable staff through embedded guidance, links to standards, and intuitive workflows. For firms evaluating whether to adopt software, the key considerations should include: scalability, jurisdictional adaptability, ease of implementation, audit trail integrity, and the ability to evolve with regulatory changes. We strongly suggest taking a look at our previous guidance on adoption of software audit tools as well. There are other applications being developed for the market as well. Inflo: A Centralized Platform for Quality Management Oversight Inflo’s Quality Management solution is designed to help firms implement and maintain a System of Quality Management (SoQM) that aligns with ISQM 1 and other global standards. Unlike traditional tools that focus solely on audit execution, Inflo’s platform provides a centralized environment for managing the entire quality lifecycle—from risk assessment to monitoring and remediation. Key Features of Inflo’s Quality Management Platform: Centralized Oversight: Inflo consolidates all quality management activities into a single platform, giving firm leadership real-time visibility into the status of quality objectives, risks, and responses. Customizable Risk Assessment: Firms can tailor their risk identification and assessment processes to reflect their unique service lines, geographies, and regulatory environments. Automated Monitoring & Remediation: Inflo streamlines the tracking of deficiencies and corrective actions, ensuring that issues are addressed promptly and transparently. Evidence of Compliance: The platform maintains a complete audit trail of all quality management activities, supporting both internal reviews and external inspections. Scalable Across Jurisdictions: Inflo’s solution is adaptable to various regulatory frameworks, making it suitable for firms operating in multiple countries or under different standard-setting bodies. By integrating quality management into a digital workflow, Inflo helps firms move beyond static documentation and toward a dynamic, data-driven approach to compliance and continuous improvement. Caseware: Integrated Methodology and Real-Time Collaboration Caseware’s cloud-based platform, particularly through its Dynamic Audit Solution (DAS), offers a comprehensive approach to quality management. Built in collaboration with CPA.com and the AICPA, Caseware provides: End-to-End Audit Workflow: Integrating methodology, workpapers, and execution tools in a single environment. Real-Time Collaboration: Enabling teams to work simultaneously on engagements, improving efficiency and reducing version control issues. Data-Driven Risk Assessment: Supporting a risk-focused audit approach aligned with ISQM 1 and SQMS 1. Caseware is especially effective for firms embedding quality management into daily audit operations while maintaining compliance with evolving standards. QMCore (FinReg): Purpose-Built for Global Quality Management Standards QMCore, developed by FinReg, is a purpose-built platform designed to help firms implement and maintain a System of Quality Management (SoQM) in compliance with ISQM 1, SQMS 1, QC 1000, and their global counterparts. It is powered by the FinReg GRC platform and has received technology accreditation from the ICAEW. Key Benefits of QMCore: Comprehensive Coverage: Seamlessly integrates all eight components of ISQM 1 and SQMS 1, including governance, risk assessment, monitoring, and remediation Task Ownership and Accountability: Allows firms to assign responsibilities clearly and track progress with ease Monitoring & Remediation: Embedded tools provide high visibility into deficiencies and corrective actions, with real-time dashboards and drill-down analytics Jurisdictional Flexibility: Adaptable to regional standards such as CSQM 1, SSQM 1, ASQM 1, and PES 3 Audit Trail Integrity: Tracks all inputs and changes, ensuring transparency and defensibility; and User Enablement: Educates staff on the standards, enables them to act, and evidences compliance through structured workflows and embedded guidance. QMCore is securely hosted on AWS and accessed via the internet, making it easy to implement and scale across firms of varying sizes and geographies. Conclusion The shift to modern quality management standards is not just a compliance exercise—it’s an opportunity to enhance audit quality, improve operational efficiency, and build a culture of continuous improvement. Software platforms like Inflo, Caseware, and QMCore are proving essential in helping firms navigate this transformation. Other players may be entering the market, and we encourage a discussion to understand the latest and compare benefits and what’s best for your firm. At Johnson Global Advisory, we support firms in selecting, implementing, and optimizing these tools to meet their unique needs. For more insights, visit our blog or contact us to learn how we can help your firm AmplifyQuality®. For more information, please contact your JGA audit quality expert .

Navigating AI Governance: JGA Authors Governance & Compliance Chapter of the Accounting AI Playbook

By Jackson Johnson • June 30, 2025

This is an exert of the AI Accounting Playbook . Building Trust in AI Accounting As accounting firms adopt AI tools in audits, they face new questions about reliability, transparency, and compliance. Regulators like the PCAOB have made clear that if AI outputs can’t be explained or reproduced, they could violate existing standards. Yet formal guidance on AI use in audits remains limited, leaving firms unsure about how to move forward. Some firms have responded by limiting AI to non-public clients, but this caution also presents a chance to lead. Firms that build strong AI governance practices now can stay ahead of future regulation and establish trust in their use of AI. This chapter covers key compliance barriers, governance best practices, and steps to create a trusted control environment. Key Compliance Barriers Accountants face several key compliance barriers when using AI, particularly as regulators such as the PCAOB, AICPA, and SEC increase their scrutiny. Explainability One major challenge is explainability. Many AI models, especially machine learning and generative AI, don’t clearly show how they reach conclusions. This is a problem for auditors who need to support their findings. This lack of clarity makes it harder to meet audit evidence requirements, which must be sufficient, appropriate, and easy to understand, as outlined in PCAOB standard AS 1105. Poor Documentation Poor documentation is another major issue. This includes inadequate records of data inputs and outputs, training data, model logic, and controls over changes. Such deficiencies may violate documentation and risk assessment requirements, as seen when audit teams use AI for journal entry testing without documenting the rationale for flagged entries or threshold settings. Data Privacy Data privacy becomes a concern as firms use AI to handle large amounts of sensitive financial and personal information. This can lead to violations of laws like GDPR and CCPA, especially when client data is processed in cloud or third-party systems. Firms often struggle to maintain consistent policies for data classification, encryption, and access. Auditor independence may also be at risk if AI tools are built by a firm’s advisory armor are deeply integrated with a client’s systems. For instance, if both the firm and client use the same predictive AI tool for forecasting, it could lead to a self-review threat. AI Skills Gap A skills gap and overreliance on AI further complicate compliance. Many auditors lack the training needed to critically evaluate AI outputs or to recognize when human judgment should override algorithmic conclusions. This can lead to audit failures, such as misinterpreting a false negative from an AI-driven risk assessment as a clean result. Validation and Testing Testing and validating AI tools is another challenge, especially for tools that keep learning over time. Firms need to test tools when they’re first used and then on a regular basis, just like they do when relying on third-party service providers. But this is hard to do if the AI vendor doesn’t offer enough detail about how the tool works or the controls in place. Change Management Managing updates and changes to AI models is a concern. If a tool is updated or retrained without documentation, it can lead to inconsistent results. For example, a model may flag different transactions in different quarters without any clear reason why. Many firms also lack a formal AI governance plan tied to their quality management systems, which causes inconsistent control practices and unclear responsibilities. Lack of Guidance Regulators have been slow to issue formal guidance on how AI should be integrated into the audit process, leaving many firms in a state of uncertainty. The good news is that momentum is building. PCAOB Board Member Christina Ho has publicly emphasized the transformative potential of AI in auditing, particularly in automating routine tasks such as cross-referencing data, extracting key contract terms, and documenting interviews. She has advocated for the PCAOB to evolve its standards to promote responsible AI use, calling for transparency, bias mitigation, and auditability in AI tools. Similarly, the International Auditing and Assurance Standards Board (IAASB) has demonstrated its commitment to supporting firms by releasing its Technology Position, which is a strategic framework that outlines how the board will adapt auditing standards to align with emerging technologies, including AI. Until these guardrails are firmly in place, firms should proactively develop internal AI frameworks modeled on established control standards. COBIT can support firms in assessing and governing AI systems, including data and system integrity. COSO can be applied to evaluate AI governance, model risk, and internal control implications, particularly when AI impacts financial reporting or ICFR. NIST provides guidance to help firms build trustworthy AI systems and establish appropriate cyber security and governance protocols. Best Practices for Governance To use AI confidently and compliantly in accounting, especially in regulated environments like audit and assurance, firms should implement strong governance practices that align with both regulatory expectations and ethical standards. 1. Test AI Internally Before Use In Engagements Before you bring AI into your audits, you’ll need to put it through its paces. The starting point is an internal review and certification process, ideally led by your firm’s risk or national office. They should evaluate the AI tool’s design, logic, and controls, and may require your vendor to share documentation, control reports, and allow independent testing. A great way to do this is by running the AI on historical data from past audits with known results. That helps confirm whether the AI delivers the same conclusions auditors already reached. Scenario analysis is another smart move. Challenge the AI with tricky edge cases like known fraud or anomalies. This can expose blind spots or bias in the model. Be sure to maintain a complete audit trail of how the tool was tested and what controls were in place. If any issues pop up during testing, document and resolve them. And before you roll it out firm-wide, get an independent review of the tool. Think of it like a second set of eyes, similar to a concurring partner review. Only once your firm is fully confident in the tool should it be used in your accounting processes. 2. Develop AI Governance Policies Strong policies lay the foundation for responsible AI use. These should outline your standards for data inputs, risk reviews, decision-making responsibilities, and transparency. Deloitte recommends a universal governance policy that applies to all AI technologies across the firm. This policy should define acceptable (and prohibited) use cases, require approval for new AI tools, and establish review intervals. Ethical usage also needs to be a priority. That means clear guidelines around privacy, bias, and legal compliance — with transparency as a core value. Internally and externally, stakeholders should understand when and how AI is being used in order to build trust in AI usage. To oversee this, consider forming a dedicated AI GRC (Governance, Risk, Compliance) team. Roles might include a Chief AI Risk Officer, Data Protection Manager, AI Project Manager, and an AI Governance Committee. Need help building your framework? Look to proven models like NIST AI RMF and ISO 42001. COSO’s recent guide Realize the Full Potential of AI shows how to extend COSO’s ERM framework to AI, and it’s a great place to start. 3. Implement Data Quality Controls AI tools are only as reliable as the data they process. The old adage “garbage in, garbage out” underscores the importance of data quality in AI-driven accounting. To minimize the risk of inaccurate or biased AI outputs, firms should implement data validation, cleansing, and standardization processes. High-quality data improves AI performance and supports more reliable audit conclusions. Protecting sensitive data is also crucial. Firms should limit access to confidential information using role-based access controls (RBAC) and multi-factor authentication (MFA). Audit logs tracking data access provide an added layer of oversight, helping firms monitor and secure critical information. Data lifecycle management is equally important. Retention and deletion policies should be in place to ensure outdated data does not become a liability. While GDPR is an EU regulation, it sets a high standard for data management and serves as a strong benchmark for firms looking to enhance their data governance practices

JGA Makes First Contribution to The Daughters of The American Revolution

May 28, 2025

WASHINGTON, D.C.: Johnson Global is proud to announce our first charitable contribution in support of the daughters of the American Revolution (DAR) —a historic nonprofit organization founded in 1890 and dedicated to historic preservation, education, and patriotism. With over 130 years of tradition and more than one million members since its founding, the DAR continues to make a meaningful impact through local, national, and global initiatives. "We are honored to support an organization whose enduring mission aligns with our values and commitment to community" said Jackson Johnson, JGA President. "This partnership marks a significant milestone for Johnson Global Advisory as we expand our philanthropic efforts and invest in organizations creating lasting, positive change". "Thank you JGA for this impactful donation will allow our chapter to continue our mission" said Jill Mathieu, Regent of DAR. To explore more about the impact of DAR, visit: www.dar.org/discover About Johnson Global Advisory Johnson Global partners with leadership of public accounting firms, driving change to achieve the highest level of audit quality. Led by former PCAOB and SEC staff, JGA professionals are passionate and practical in their support to firms in their audit quality journey. We accelerate the opportunities to improve quality through policies, practices, and controls throughout the firm. This innovative approach harnesses technology to transform audit quality. Our team is designed to maintain a close pulse on regulatory environments around the world and incorporate solutions which navigate those standards. JGA is committed to helping the profession in amplifying quality worldwide. Visit www.johnson-global.com to learn more about Johnson Global.

Joe Lynch to speak at 40th Midyear SEC Reporting & FASB Forum

May 28, 2025

Johnson Global Advisory ("JGA") is proud to announce that Joe Lynch, Shareholder and Managing Director, will be speaking on a panel at the 40th Midyear SEC Reporting & FASB Forum . Joe will deliver the PCAOB update on June 6, with attendance available both in person and virtually. This panel will summarize the activities of the PCAOB including: • Understand the current regulatory landscape and emerging issues under new SEC leadership • Summarize rulemaking from the FASB’s technical agenda, including segment reporting and disaggregation of income statement expenses • Anticipate accounting and reporting issues incurred with income taxes, including ASU 2023-09 “Improvements to Income Tax Disclosures” • Identify changes from the FASB on accounting for financial instruments • Prepare for disclosure requirements on ESG and climate change, including the EU’s Corporate Sustainability Reporting Directive (CSRD), the requirements of California’s ESG disclosures legislation and the status of the SEC final rule • Recall recent developments and the most frequent comment areas in the SEC review process Click here to register and learn more. About Johnson Global Advisory Johnson Global partners with leadership of public accounting firms, driving change to achieve the highest level of audit quality. Led by former PCAOB and SEC staff, JGA professionals are passionate and practical in their support to firms in their audit quality journey. We accelerate the opportunities to improve quality through policies, practices, and controls throughout the firm. This innovative approach harnesses technology to transform audit quality. Our team is designed to maintain a close pulse on regulatory environments around the world and incorporate solutions which navigate those standards. JGA is committed to helping the profession in amplifying quality worldwide. Visit www.johnson-global.com to learn more about Johnson Global.

QC 1000 Implementation: Key Themes and Guidance from the PCAOB Workshop

May 28, 2025

On May 13th, 2025, the PCAOB held a QC 1000 workshop in Washington, DC, providing critical insights into the upcoming quality control standard. With the effective date of December 15th, 2025 , firms must proactively identify and manage quality risks by setting quality objectives, assessing risks, and implementing responses. Examples and case studies with breakout groups played a crucial role to help firms understand and apply each stage of the implementation process, from risk assessment to monitoring and remediation. Many attendees are still early in their understanding of the standard, highlighting the need for clear guidance and support. In a live poll, a significant portion of the workshop attendees indicated they have not yet started implementation. The inspection approach of QC 1000 has not been finalized. As such, they did not take any questions regarding how this would be inspected in its formative years. However, we did read between the lines from a different question around audit documentation, that it’s possible they may select components on a test basis during an inspection. Background of the Standard The QC 1000 standard emphasizes the integration of eight components: the risk assessment process, governance and leadership, ethics and independence, acceptance and continuance of engagements, engagement performance, resources, information & communication, and monitoring and remediation process. For more background information on QC 1000, please see these JGA resources: Applying the QC 1000 and Other Standards to Your Firm Understanding the Broader Benefits of ISQM 1 and SQMS 1 Applying the Benefits of ISQM 1 & SQMS 1 Across the Firm Key Topics from the Workshop Key terms such as applicable professional and legal requirements (APLR), firm personnel, other participants, and third-party providers were defined to clarify roles and responsibilities within the firm's QC system. The workshop included a walkthrough of Appendix A2 of the standard. The firm’s system must consider the APLRs that are applicable to the firm, which is unique to each firm. APLR is defined in the standard as: Professional standards, as defined in PCAOB Rule 1001(p)(vi); Rules of the PCAOB that are not professional standards; and To the extent related to the obligations and responsibilities of accountants or auditors in the conduct of engagements or in relation to the QC system, rules of the SEC, other provisions of U.S. federal securities law, ethics laws and regulations, and other applicable statutory, regulatory, and other legal requirements. It is important to be able to clearly identify the type of resource in your QC 1000 implementation journey. Paragraph .05 also discusses the terms firm personnel, other participants and third-party providers. These are defined in Appendix A.5 (firm personnel), A.7 (other participants) and A.13 (third -party providers). 1. Firm personnel include: EQR (inside the firm), Staff at shared service centers, secondees and leased staff, specialists employed by the firm. 2. Other participants include other auditors, EQR (outside the firm), internal auditors of the client that provide direct assistance to the auditors, specialists engaged by the firm, Networks, and external QC function. 3. Third-party providers include audit software providers, system security vendor, audit methodology provider, confirmation intermediary, pricing services, and broker-dealer monitoring systems. There are four distinct roles and responsibilities as described in paragraphs .11 -.17 of the QC standard. The first two roles are the certifiers of the Firm’s QC results: 1. The principal executive officer and 2. Individual responsible for the operational responsibility and accountability for the QC system as a whole. The principal executive officer (PEO) is ultimately responsible for the design, implementation, operation, and evaluation of the firm’s QC system. Only firm personnel are permitted to fill the roles required by QC 1000 . JGA Insights: 1. Not all “participants” of a firm’s structure must be included in a firm's quality control policies and procedures, which is especially important for shared service centers and outsourced staffing arrangements. These roles must be clearly defined and applied as the different levels of participants within an organization are considered differently by the standard. 2. PCAOB-registered firms of all sizes – regardless of whether the firm currently audits issuers – must adhere to these components, ensuring consistency with international quality control frameworks. 3. While it was expressed in the session by PCAOB Staff that firms are not expected to reengineer their process (e.g. more than 1 set of QC documentation), firms may need to align or “top-up” their processes with multiple standards to ensure comprehensive compliance. Keep in mind here that the top-up may not just be for QC 1000. In fact, a system in compliance with QC 1000 may need top-up considerations for SQMS 1 and/or ISQM 1. Risk Assessment Principles There were several examples and case studies to go through among table groups during the session. These activities helped illustrate the importance of getting risk assessment right, since this drives what the firm focuses on for an effective system. When it comes to implementing QC 1000, there are some key takeaways from the risk assessment process that can really guide firms in the right direction. JGA Insights: Here are a few important points to keep in mind as you work through identifying and assessing quality risks 1. The QC 1000 standard does not prescribe a specific method for identifying and assessing quality risks. This gives firms flexibility but also places responsibility on each firm individually based on their circumstances. It’s more work upfront from a “cookie-cutter” approach but ensures the design of a process that fits a firm’s unique context. 2. Quality risks should not be viewed as the opposite of quality objectives . Instead, they are factors that could potentially hinder the achievement of those objectives. 3. The threshold of “reasonable possibility of occurring” applies to all risks, including risks of intentional misconduct by firm personnel and other participants. This means that firms must consider the likelihood of risks occurring and their potential impact on the quality objectives. The PCAOB staff shared during the workshop that the concept of reasonably possible follows the same definition as used in FASB ASC Topic 450 on Contingencies. Ethics and Independence Considerations The QC 1000 standard does not alter existing ethics and independence requirements under PCAOB or SEC standards. Firms must continue to comply with those as currently written. Compared to other standards like ISQM 1 and SQMS 1, QC 1000 is more stringent in certain areas. For example, it requires: 1. Creating and maintaining a restricted entity list; 2. Periodic review of the list to ensure accuracy; 3. Appropriate certifications related to independence; and 4. Audit committee approvals where applicable. Register for the next workshop and get going on implementation To gain a deeper understanding of the QC 1000 standard and its implementation, we strongly encourage you to attend the PCAOB Smaller Firm Workshop on June 17, 2025, in Irving, Texas. This in-person-only session will provide valuable insights and practical guidance for firms navigating the new quality control standard. Register now to secure your spot. As always, reach out to your JGA Expert with any questions. About Johnson Global Advisory Johnson Global partners with leadership of public accounting firms, driving change to achieve the highest level of audit quality. Led by former PCAOB and SEC staff, JGA professionals are passionate and practical in their support to firms in their audit quality journey. We accelerate the opportunities to improve quality through policies, practices, and controls throughout the firm. This innovative approach harnesses technology to transform audit quality. Our team is designed to maintain a close pulse on regulatory environments around the world and incorporate solutions which navigate those standards. JGA is committed to helping the profession in amplifying quality worldwide. Visit www.johnson-global.com to learn more about Johnson Global.

Joe Lynch, JGA Managing Director to Speak at AICPA® & CIMA® ENGAGE 25+

April 25, 2025

WASHINGTON, D.C.: Johnson Global is pleased to announce that Joe Lynch, JGA Managing Director will speak at the AICPA® & CIMA® ENGAGE+ 25 on May 15, 2025, and will be attending the full conference on June 9–12, 2025, at the ARIA Resort & Casino in Las Vegas, NV and live online. This CPE-eligible event is the premier annual event for accounting and finance professionals, bringing together thousands of peers, experts, and industry leaders for top-tier learning, networking, and career growth opportunities. Register by May 1, 2025, to take advantage of Early Bird rates— $1,995 for members ( regularly $2,095 ) and $2,445 for nonmembers ( regularly $2,545 ). *PCPS, Tax and PFP section members and CITP®, PFS™, CGMA® credential holders save an additional $150 . Discount reflected in section member/credential pricing during checkout. Register Today ! About Johnson Global Advisory Johnson Global partners with leadership of public accounting firms, driving change to achieve the highest level of audit quality. Led by former PCAOB and SEC staff, JGA professionals are passionate and practical in their support to firms in their audit quality journey. We accelerate the opportunities to improve quality through policies, practices, and controls throughout the firm. This innovative approach harnesses technology to transform audit quality. Our team is designed to maintain a close pulse on regulatory environments around the world and incorporates solutions which navigates those standards. JGA is committed to helping the profession in amplifying quality worldwide. Visit www.johnson-global.com to learn more about Johnson Global.

JGA to Sponsor 2025 ALI-CLE Accountants' Liability Conference

March 21, 2025

WASHINGTON, D.C.: Johnson Global Advisory (JGA) is proud to sponsor the Accountants' Liability Conference hosted by ALI-CLE. This two-day event will take place in Washington, D.C. and virtually on June 2nd and 3rd. This is an excellent opportunity to gain valuable insights into a wide range of critical issues. The 2025 conference will focus on audits and oversight, providing essential guidance to help you navigate the evolving landscape of regulatory compliance and better protect your firm and clients. “We are pleased to sponsor this conference for the last several years. This event brings together top law firms, internal counsel, and risk experts for dynamic discussions on trending topics such as accounting liability and other important issues affecting the profession,” said Jackson Johnson, JGA President. “I look forward to personally engaging with participants, presenters, and stakeholders at this conference.” This year’s program is still being finalized but planned topics include: Recent Trends in Accounting Litigation Living in a post- Jarkesy world The future of enforcement PCAOB inspection program update SEC perspectives on gatekeeper liability AI and emerging technologies in the accounting industry Accounting firms entering the legal space International firm considerations Alternative practice structures and AICPA independence rules Register by April 25 to attend in-person and use the code “ JGA ” to save $250 off . OR, for webcast attendance, use the code " JOHNSON " to save $125 off the tuition. Click here to register. About Johnson Global Advisory JGA is dedicated to helping public accounting firms around the globe achieve the highest level of audit quality. All CPAs and former PCAOB inspection staff, JGA professionals are passionate and practical about working alongside firm leadership to ensure the right controls, policies, and practices are implemented throughout the organization. Visit www.johnson-global.com to learn more about Johnson Global.

JGA Makes Third Annual Contribution to The Boys & Girls Club of Greater Kansas City

March 21, 2025

WASHINGTON, D.C.: Johnson Global Advisory (JGA) makes third annual contribution to the Boys & Girls Club of Greater Kansas City. The 29th Annual Kids Night Out is scheduled for Saturday, April 26, 2025, and promises to be an unforgettable evening, bringing together over 1,500 guests to support the children served by Boys & Girls Clubs of Greater Kansas City. “We’re thrilled to continue our support for the Boys & Girls Club of Greater Kansas City. This marks our third year backing this chapter, and I know that many of our JGA employees have personally benefited from the programs the Boys & Girls Clubs offer nationwide,” said Jackson Johnson, JGA President. “Kids Night Out is Boys & Girls Clubs of Greater Kansas City’s biggest fundraiser each year– and all dollars raised stay right here in Kansas City”, said Andy Burczyk, Board Member and Chair of Kids Night Out. “This organization is doing extraordinary things, and it is because we as a community invest in their impact.” For over 100 years, Boys & Girls Clubs of Greater Kansas City has provided a safe, supportive environment for youth. Serving over 8,000 kids and teens annually across 11 locations, the organization helps young people achieve their full potential through programs that promote academic success, healthy lifestyles, and character development. Through mentoring and leadership training, they equip members with the skills needed for success now and in the To learn more information on the Boys & Girls Club of Greater Kansas City and their work with the youth, please visit www.bgc-gkc.org . About Johnson Global Advisory JGA is dedicated to helping public accounting firms around the globe achieve the highest level of audit quality. All CPAs and former PCAOB inspection staff, as well as JGA professionals, are passionate and practical about working alongside firm leadership to ensure the right controls, policies, and practices are implemented throughout the organization. Visit www.johnson-global.com to learn more about Johnson Global.

Johnson Global Advisory Supports Sustainable Harvest International

March 21, 2025

WASHINGTON, D.C.: Johnson Global Advisory (JGA) is proud to provide a financial contribution to Sustainable Harvest International (“SHI”). SHI is a nonprofit helping Central American farmers adopt sustainable farming practices for over 27 years. Their mission is to address the destruction of tropical forests caused by slash-and-burn farming and logging. SHI’s mission benefits both current and future generations by equipping farmers with the knowledge to farm sustainably. “We’re proud to partner with Sustainable Harvest International in their important work,” said Jackson Johnson, JGA President. “This collaboration helps drive lasting, positive changes and by backing such vital organizations, we stay true to our mission of giving back and making a real difference. JGA’s philanthropic efforts focus on supporting organizations that are important to our people. I appreciate Vernon sharing his experience as a board member and we are grateful to work with him to amplify this organization.” Vernon Johnson, JGA Director, is a Board Member and Treasurer for SHI. He is actively involved in this organization. "My nonprofit work has helped me maintain perspective in both life and at work,” said Vernon. “It’s taught me to stay calm during challenges and focus on the bigger picture. This experience has improved my relationships and made me more resilient in stressful situations. My advice to busy professionals is to step back, appreciate the simple things, and not sweat the small stuff—being thankful and present can make a big difference." To learn more about SHI, visit www.sustainableharvest.org/donate . About Johnson Global Advisory JGA is dedicated to helping public accounting firms around the globe achieve the highest level of audit quality. All CPAs and former PCAOB inspection staff and JGA professionals are passionate and practical about working alongside firm leadership to ensure the right controls, policies, and practices are implemented throughout the organization. Visit www.johnson-global.com to learn more about Johnson Global.