Remediation in a World of Repeat Findings: PCAOB Guidance for the Remediation Process
It has been more than 20 years since the formation of the PCAOB. Over time, the inspections process has transformed and along with it, the reporting and remediation processes. In February of 2023, the PCAOB published its Spotlight: Additional Insights on the Remediation Process. In light of the new guidance as well as considering the fact that the new quality management standards will require all audit firms (international or domestic, public or private company audits) to remediate both engagement and firm-level deficiencies, it’s clear that there is a renewed emphasis on the remediation process within the industry.
The spotlight provides much of the same information previously released through various publications, such as the PCAOB Staff Guidance from November 2013, which highlights the main considerations that the Board reviews when evaluating the effectiveness of remedial efforts. Specifically, the Board reviews the following criteria:
- Change: Is the remedial action a change from the current quality control (QC) system? In what ways?
- Relevance: Does the action specifically address the deficiency? Both in terms of subject but also in terms of causal factors? Design: Is the remedial action, as designed, appropriate to address the QC failures?
- Implementation: Was the remedial action implemented in the remediation period?
- Execution and Effectiveness: How effective was the remedial action? How does the auditing firm evidence that?
While we’ve touched on many of these items in previous remediation articles, let’s explore some of the new insights from the February 2023 Spotlight below:
Repeat Criticisms
Most firms have at some point probably had some sort of repeat finding. For many, the EQR deficiency seems to recur in every inspection report, but I imagine many firms are also seeing repeat findings in ICFR (think of management review controls or MRCs) and estimates, two of the most commonly cited deficiencies for many years running now. When firms have repeat findings (i.e. same or similar deficiencies in consecutive inspection reports), the PCAOB critically assesses the remedial actions to understand how these actions will resolve the issue. We like to use the word “incremental.” How is the remedial action incremental, or “meaningfully different” in the words of the PCAOB. For instance, if you develop and deliver a training on auditing estimates, but then have a repeat finding in your subsequent inspection report, the PCAOB will challenge whether another training is an effective remedial action. The question will be asked “how is that additional training meaningfully different to what was delivered previously?” What other incremental actions could be implemented to address the criticism? We’ll delve more into training later, but the point is that just because a remedial action was considered effective in the past does not mean it will be considered effective today. And if it was truly effective in the past, why then is there a deficiency today?
Root Cause Analysis
This leads well into the next concept: root cause analysis. If you are seeing repeat findings in your inspections, it’s an indication that the root cause for the deficiency has not yet been addressed OR there could also be a new root cause that requires specific attention. The new quality management standards require firms to perform a root cause analysis. A thorough root cause analysis helps firms to understand the causal factors contributing to the overall deficiency. From these causal factors, the firm can then appropriately design remedial actions. Think of it like going to the doctor; a doctor could prescribe medications to treat symptoms, but a root cause will direct the doctor in how to prescribe the right medication to treat the causal illness and thereby eliminating all symptoms.
Firms need to start performing robust root cause analyses to understand what is giving rise to the deficiencies. The PCAOB warns that there may be multiple causes so don’t jump to the most obvious conclusion. If you don’t address all causal factors, while you may be able to pass remediation, you risk having the deficiency occur yet again and the remediation process will only get more stringent.
As well, while root cause analysis is typically focused on deficiencies (negative audit quality), the PCAOB has indicated that many firms are starting to perform root cause analyses for “clean” audits (positive audit quality) so as to identify what worked well. These success factors could be fodder for new remedial actions implemented at a firm-wide level.
Training
Training is the most common remedial response we see in the industry. And that makes sense; awareness is certainly the first step in driving change. However, after 20 years of inspections and remediation, training is proving less effective given the number of recurring deficiencies.
When the PCAOB evaluates the sufficiency of training for remediation purposes, it considers the following:
- Is the training specifically tailored to the company? Does the training speak to the specific deficiency? At what level of granularity? Buying an off-the-shelf training that summarizes the requirements of AS 2501 is different than engaging a consultant with audit expertise to specifically design a tailor-made training on AS 2501, pulling in PCAOB inspection results, identifying common PCAOB failures, and crafting case studies from the firm’s specific findings.
- What is the format of the training? Live webinars and in-person trainings are typically viewed as more effective than e-learning self- studies.
- Who is delivering the training? What are the qualifications and experience of the presenters?
- Who is the audience and how was participation monitored/enforced? The PCAOB generally expects that firms identify their target audience. However, if the training is covering something such as inventory observations, it probably makes sense that all staff levels attend the training since the procedures are typically performed by more junior associates and by the time a manager is reviewing, it might be too late to effectuate real change (we rarely go back to perform a second inventory count). How does the firm ensure those absent from the training get “caught up?” Even if the firm offers a make-up session or records the training for future reference, there’s an implicit attitude when only 50% attend live and the rest make-up the training later. It’s an indication of tone-at-the-top and a lack of regard for the importance of that training. Training that is designed for remediation should be attended by all required professionals; truants should be the exception.
- Is there a post-course knowledge check? Is the course CPE eligible? Both factors elevate the significance of the training. Post-course knowledge checks are especially important as they help evidence knowledge retention, which helps demonstrate the effectiveness of the remedial action (i.e. refer to the five criteria above). We’ve seen firms fail remediation because they didn’t do knowledge checks, so don’t underestimate its significance.
Guidance and Tools
The other most common remedial action is the development of new guidance and tools/templates to guide teams through various auditing requirements. We’ve helped numerous firms develop templates for auditing ICFR (or even more specifically, auditing management review controls), auditing estimates, evaluating CAMS, etc. When evaluating the sufficiency of tools and templates, the Board considers the following:
- Design of the tool: Does the template pull guidance directly from the standard? Does it specifically address the deficiency cited in the inspection report?
- Effective date: When was the guidance/tool implemented and effective?
- Required use: When is the template applicable? Is it required in all circumstances? Generally, the PCAOB will expect tools to be required to be used on all audits where there is potential for a failure.
- Communications: How was the guidance/tool communicated within the firm? Again, tone at the top matters. Did the firm provide any education around the guidance / templates?
- Implementation and monitoring: How did the firm go about implementing the tool? Were there required consultations in the first year? Were there targeted inspections to ensure teams are complying with the new guidance and/or effectively completing the templates?
Subsequent Inspections
We have started to see an acceleration of inspections and many clients are being inspected every two years instead of every three years as they were accustomed to. Considering that PCAOB reports are sometimes issued a year or more after the inspection and by the time you add another year for the remediation process, many firms are now being inspected while they still have open remediation periods. So, what’s the big deal? It means that the PCAOB will be in the midst of evaluating the effectiveness of remedial actions while also performing a subsequent inspection. Results of that subsequent inspection could have a direct impact on the remediation assessment.
The Board did clarify that a subsequent inspection finding is not automatically a failure. Rather, the PCAOB looks to see how proactive the firm is in monitoring and addressing known deficiencies. As well, the PCAOB looks to see whether there were multiple actions to address a deficiency or just one and how broad the remedial actions were (i.e. training over inventory estimates vs. training over all accounting estimates). Finally, there’s this concept of continual improvement. If a firm had six ICFR findings in one inspection report, but only had one ICFR finding in the subsequent inspection, that could be a sign of improvement. Of course, it’s always facts and circumstances specific and numbers can be deceiving. If there was only one audit with ICFR, then one finding would result in a 100% hit rate. If there were eight integrated audits and only one with an ICFR deficiency, that tells a different story.
The point is, be aware of the timelines and understand that the results of PCAOB inspections will impact any open remediation assessments. This is why it’s important to understand root causes and map remedial actions to causal factors. While a firm might have ICFR deficiencies recur in multiple inspection periods, if the firm can identify different root causes and thus different remedial actions, it helps demonstrate how and why the firm responded as it did.
The point is to acknowledge subsequent inspection findings and incorporate them into your remediation response, demonstrating how the firm has analyzed the results, what they are proactively doing to address the new findings and how the results impact (or do not impact, and why) any open remediation responses.
Timing and Dialogue
Finally, we can’t emphasize this enough, but start dialogue in the 12-month remediation period early! In its letter that accompanies inspection reports, the PCAOB has now indicated that it expects firms to initiate a dialogue within 60 days of receiving the report. Remember, the remediation period only lasts for one year and firms need to demonstrate how their remedial actions fulfilled the five criteria during that time; this means, demonstrating the effectiveness of remedial actions which often is validated through internal firm monitoring procedures which take time!
Start the conversation early. Explain the intended remedial responses. Begin implementing the actions and continue dialoguing with the PCAOB to understand their concerns or feedback. Firms are able to have as many conversations as they would like with the PCAOB remediation staff during the one-year timeline, but each submission and review takes several weeks for the PCAOB and PCAOB feedback sometimes requires changing course or entirely altering the intended actions. Allow time to modify your response without being rushed.
Understandably, some remedial actions will take longer than a year to fully implement and/or see the improvement. That doesn’t mean wait until the last minute to implement. In these circumstances, break down your response into milestones to demonstrate progress and help define various measures of success.
Key Takeaways
- Consider how remedial actions are incremental and “meaningfully different” from previous remedial actions, especially if there are repeat findings.
- Start performing root cause analyses and build the results into your remediation response.
- Ensure training is designed appropriately. Consider content modification, expertise of the presenters, delivery methods, target audience, and don’t overlook knowledge checks (an effective tool to demonstrate effectiveness).
- Design robust new tools and templates and intentionally communicate the new requirements.
- Consider results of subsequent inspections and specifically address them in your remediation response. Some results may indicate a need to perform additional actions. Some results may indicate a nuanced finding that tells a different story.
- Start early! Engage in dialogue and keep the process moving.
Johnson Global Advisory is pleased to announce that Jackson Johnson, CPA, President, has been appointed to serve on the AICPA & NASBA International Qualifications Appraisal Board (IQAB). The IQAB is responsible for evaluating international accounting qualifications and facilitating mutual recognition agreements between the United States and other countries, helping to support global mobility and consistency in professional standards. “It’s an honor to serve on the IQAB and contribute to efforts that strengthen the global accounting profession,” said Johnson. “As the profession continues to evolve, collaboration across jurisdictions is critical to maintaining high standards and enabling greater mobility for accounting professionals worldwide.”
Few technologies have generated as much excitement—and as much promise—for accounting firms as artificial intelligence (“AI”). The potential to streamline audit execution, reduce hours, and enhance firm profitability is real and already being realized. However, AI does not simply change how audits are performed; it fundamentally alters how firms must think about oversight, responsibility, and quality management. As regulators sharpen their focus on AI‑enabled audits, firm leadership must move beyond adoption and address a more complex challenge: establishing clear and scalable AI governance. This article outlines why AI governance is now a strategic imperative for accounting firm leadership. As discussed in JGA’s article What Regulators Expect to See When AI is Used , inspectors do not evaluate AI tools in isolation. They evaluate whether the engagement team obtained sufficient appropriate audit evidence, exercised professional skepticism, and applied appropriate supervision and review when AI was used. Those expectations are grounded in existing auditing standards and apply regardless of whether AI was used for risk assessment, testing, or documentation support. Against that backdrop, AI governance is not simply about approving tools or managing technology risk. It is about ensuring the firm’s system of quality management supports consistent, supervised, and well-documented use of AI that aligns with audit objectives and withstands inspection scrutiny. When firms treat AI as an IT matter, governance discussions tend to center on 1) Data security, 2) System access, 3) Vendor due diligence, and 4) Infrastructure controls. Those topics matter—but they are only the baseline. Inspectors do not evaluate whether AI systems are well engineered; they evaluate whether AI enabled audit work complies with standards, supports professional judgment, and is governed within the firm’s system of quality management. In short, AI governance is a firmwide audit quality issue, not a back office technology function. Using AI does not change the auditor’s responsibilities. Requirements still apply when AI is used for 1) Audit evidence, 2) Professional skepticism, 3) Supervision and review, 4) Engagement partner accountability and 5) Firm level quality controls. From an inspection standpoint, AI introduces new audit quality risks, including: Over reliance on automated outputs Reduced professional skepticism (automation bias) Inconsistent application across engagements Insufficient documentation of judgment Lack of transparency around how conclusions were reached These are not IT risks—they are audit quality risks. AI Touches Nearly Every Component of a QC System Under modern quality management frameworks (including PCAOB QC 1000 , AICPA SQMS No. 1, IAASB ISQM 1), AI affects nearly every component of a firm’s QC system, not just technology or data governance.
Johnson Global Advisory ("JGA") is proud to announce that Joe Lynch, Shareholder, will be speaking on a panel at the 41st Midyear SEC Reporting & FASB Forum . Joe will deliver the PCAOB update on June 5, with attendance available both in person and virtually. This panel will summarize the activities of the PCAOB including: Recite new requirements for the lead auditor’s use of other auditors Anticipate the new standard, “The Auditor’s Use of Confirmation” Enumerate the new requirements of QC 1000, “A Firm’s System of Quality Control” Recall the guidance of the new auditing standard “General Responsibilities of the Auditor in Conducting an Audit” Understand the amendments addressing aspects of audit procedures that involve technology-assisted analysis of information in electronic form Learn about the proposal to replace existing auditing standards related to an auditor’s use of substantive analytical procedures Anticipate other Standard-Setting and Research Projects Summarize PCAOB inspection findings and enforcement activities Understand recent PCAOB publications, including: Spotlight Publications Audit Focus Publications Data Points Publications Click here to register and learn more. Johnson Global partners with leadership of public accounting firms, driving change to achieve the highest level of audit quality. Led by former PCAOB 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.
Johnson Global Advisory (JGA) has submitted its response to the PCAOB’s request for input on its 2026–2030 strategic priorities. Drawing on extensive experience supporting firms subject to PCAOB oversight, JGA’s comments emphasize a more modern, risk-based approach to regulation focused on audit quality, scalability, and transparency. View JGA's comments here. Johnson Global partners with leadership of public accounting firms, driving change to achieve the highest level of audit quality. Led by former PCAOB 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.
In our work with firms, we have seen a clear shift in how monitoring and remediation are viewed under modern quality management frameworks. They are no longer treated as retrospective compliance exercises. Instead, engagement deficiencies are increasingly used as meaningful inputs into an ongoing, risk-based system designed to identify issues early, address them thoughtfully, and reduce the likelihood of recurrence. Regulatory messaging reinforces this evolution. Oversight bodies are signaling a shift in focus from isolated engagement outcomes and more on whether firms have a system of quality management that consistently detects quality risks, responds appropriately, and demonstrates that remediation is working in practice. Based on our experience, while individual engagement deficiencies remain important, the more critical question is becoming how firms analyze, respond to, and learn from those issues over time. Engagement Deficiencies Are Signals, Not Endpoints Engagement deficiencies can surface through many channels, including pre-issuance reviews, internal inspections, post-issuance reviews, peer reviews, and regulatory inspections. Regardless of source, firms benefit most when these findings are evaluated through a consistent quality management lens. In practice, we encourage firms to look beyond whether a single engagement fell short . The more meaningful consideration is whether the deficiency points to potential weaknesses in governance, methodology, training, supervision, resourcing, or monitoring activities. We often observe that when issues are quickly labeled as engagement-specific, without assessing whether they reflect broader quality risks, valuable insight is lost. Modern quality management frameworks are designed to use these signals to strengthen the system, not simply close individual findings. What Effective Monitoring and Remediation Looks Like in Practice Firms that navigate this environment effectively tend to apply a disciplined and repeatable approach when deficiencies are identified. Based on our experience supporting firms across a range of practice areas, several elements consistently make a difference: Assess whether the issue may be systemic Recurring observations across engagements, service lines, or time periods often indicate system-level risk. Similar documentation gaps, inconsistent application of methodology, or supervision challenges rarely arise in isolation. Perform meaningful root cause analysis Effective root cause analysis typically moves beyond surface explanations. Firms benefit from evaluating whether policies and procedures were designed appropriately, implemented as intended, and supported by sufficient training, time, and resources. Design remediation that directly responds to the quality risk Remediation is most effective when it is clearly linked to the underlying risk. Depending on the circumstances, this may include enhancements to methodology, targeted training, revised review requirements, or changes to engagement acceptance, staffing, or oversight processes. Validate remediation through timely monitoring Implementing corrective actions is only part of the process. In our experience, firms are most successful when they also confirm that remediation operates as intended. Follow-up monitoring performed early enough to prevent recurrence is a critical component of this step. Failure to validate remediation remains one of the most common and consequential weaknesses we observe across firms. Case Study: When Remediation Is Not Validated In one situation we encountered, a firm identified engagement deficiencies through post-issuance reviews. The issues mirrored observations that had previously been noted during peer review and were communicated as having been addressed by the group responsible for report issuance. However, responsibility for validation was not clearly assigned, and no follow-up procedures were performed to evaluate whether the revised processes were effective. Subsequent post-issuance reviews, triggered by an organizational change, revealed that similar and additional deficiencies had re-emerged. From a quality management perspective, this was not an engagement execution failure. It reflected a breakdown in monitoring and remediation. The firm had information indicating quality risk but did not adjust its monitoring activities to confirm that remediation was working. Viewed through a system lens, this represents a system-level deficiency rather than an isolated engagement issue. Quality Management Applies Across All Engagement Types Modern quality management frameworks apply across a firm’s assurance and attestation practice, including private company audits, public company audits, SOC engagements, nonprofit audits, and other services. Deficiencies identified in any practice area may signal broader weaknesses in: Governance and leadership Methodology and training Monitoring activities Remediation processes In our experience, firms struggle to maintain an effective system of quality management when certain practices are treated as exempt from system-level evaluation. Key Takeaways Engagement deficiencies are inputs into the system, not endpoints. Recurring issues often indicate systemic quality risk. Remediation should be validated, not assumed. Monitoring activities should evolve as risks emerge. Quality management applies across all engagement types. Firms that treat monitoring and remediation as a continuous feedback loop, rather than a periodic exercise, are typically better positioned to improve engagement quality and respond to evolving regulatory expectations. Looking for an independent perspective on whether engagement deficiencies have been fully addressed? Based on our experience working with firms across assurance and attestation practices, Johnson Global Advisory supports clients by performing independent reviews, validating remediation efforts, and strengthening monitoring processes. If you would like support refining policies, training, workflows, or documentation standards, or would benefit from an objective assessment ahead of regulatory, peer, or internal inspections, contact your JGA audit quality advisor to discuss your needs.
Artificial intelligence (“AI”) is no longer experimental in public company audits. From risk assessment and scoping decisions to population testing, anomaly detection, and documentation support, AI enabled tools are increasingly embedded in audit execution and workflow. As use expands, the auditor’s core obligations do not shift to the technology, they remain with the engagement team. If AI is used to inform judgments, influence the nature, timing, or extent of procedures, or summarize and interpret information, auditors must still demonstrate that they obtained sufficient appropriate audit evidence and applied professional skepticism throughout. In practice, auditors must understand what the tool is doing, confirm that inputs are complete and accurate, and evaluate whether the outputs are reliable and fit for purpose in the specific audit context. While the auditing standard devoted solely to AI have not been issued, our experience is that inspectors have been increasingly direct—through staff publications, questions from inspectors in the field, and public remarks—about what they expect to see when AI is used. The expectations are grounded in existing standards and longstanding inspection focus areas: audit evidence, supervision and review, professional skepticism, and firm quality control (now quality management). In other words, AI does not create a “new” audit; it amplifies the need to show your work. Firms that treat AI as a “shortcut”, rely on outputs that cannot be explained or reproduced, or fail to govern and document how tools were selected, configured, and monitored are inviting new risks to support their audit conclusions. Conversely, firms that can clearly articulate the purpose of the tool, how it aligns to audit objectives, how inputs and outputs were validated, and how experienced personnel supervised and challenged the results will be far better positioned during inspection. The table below summarizes what inspectors typically expect to see documented when AI is used in a public company audit. Firms can use these themes to evaluate whether their engagement documentation tells a complete story that an experienced auditor (and an inspector) can follow from objective, to procedure, to results, to conclusion.
In a previous article, Back to Basics: Audit Documentation Failures Have Become Dangerous Low Hanging Fruit , we highlighted how audit documentation had quietly re-emerged as a source of regulatory risk after years of relative deprioritization. While PCAOB Auditing Standard 1215, Audit Documentation (AS 1215), has historically been cited less frequently than other standards, our direct experience from recent inspection activity, enforcement actions, and internal inspection results, demonstrate that documentation failures are increasingly treated as indicators of deeper execution, supervision, and quality management breakdowns. In today’s environment, audit documentation is no longer merely a record of work performed. It is the primary evidence inspectors rely on to evaluate whether an engagement was properly planned, executed, and supported at the time the auditor’s report was issued. What has been low-hanging fruit now requires firms to close these gaps and transform them into a load-bearing foundation for audit quality. From Rare Enforcement to Systemic Inspection Risk AS 1215 establishes clear requirements regarding what must be documented, when documentation must be completed, and how engagement files must be assembled and retained. As discussed in our prior article, failures to comply with these requirements were historically viewed as technical or secondary issues, often resulting in inspection comments rather than enforcement action. That distinction is no longer meaningful. Recent enforcement actions involving backdating, improper (both intentionally, and inadvertent) modification of workpapers, and failure to timely assemble a complete audit file reflect an evolving regulatory view. Documentation failures do not simply violate procedural requirements; they call into question the credibility of the audit opinion itself. More importantly, beyond enforcement, documentation deficiencies are increasingly cited as core inspection findings. Inspectors are challenging situations where engagement teams assert that work was performed but cannot demonstrate that work within the archived file. In these cases, the absence of timely, complete, and clear documentation is no longer treated as a formality. It is treated as evidence that the engagement may not have been properly executed, supervised, or supported in accordance with PCAOB standards. This represents a fundamental shift. Documentation is no longer “low-hanging fruit.” It is a systemic inspection risk that cuts across execution, supervision, and firm-level quality management. From Misconduct to Execution Failures Pervasive documentation failures that do not involve intentional misconduct but still result in non-compliance are increasingly observed. For example, reviewer signoffs occurring near the documentation completion date, rather than contemporaneously with the performance of audit procedures, raise questions about whether effective supervision occurred during the audit or was deferred to meeting archiving deadlines. Similarly, engagement teams may assert that key judgments can be explained verbally, even when those judgments are not clearly documented in the audit file. In today’s environment, the distinction between “we can explain it” and “it is clearly documented” is critical. If procedures, judgments, and conclusions are not evident in the documentation itself, inspectors increasingly conclude that the work was not performed in accordance with PCAOB standards. The issue is not whether the engagement team can explain what they did after the fact. The issue is whether the archived documentation allows an experienced auditor, with no prior connection to the engagement, to understand the procedures performed, evidence obtained, and conclusions reached at the time of the auditor’s report. When documentation fails to reach that standard, inspectors are increasingly concluding that the audit itself was not properly executed, regardless of intent. This reflects an important shift. Documentation failures are no longer viewed primarily as misconduct. They are viewed as symptoms of execution breakdowns, including delayed supervision, compressed review cycles, and audit workflows that defer documentation until the end of the engagement. As a result, AS 1215 has become a direct proxy for how audits are actually performed in practice. How the 14-Day Documentation Completion Requirement Changes the Risk Profile The execution risks are further amplified by the PCAOB’s shortened documentation completion timeline. Recent amendments to AS 1215 reduce the timeframe to assemble a complete and final audit file from 45 days to 14 days after the report release date. While this change may appear procedural, its implications are operational. Under this accelerated timeline, engagement teams no longer have a meaningful post-issuance window to resolve review notes, complete documentation, or finalize supervisory evidence. What were once viewed as “clean-up” activities are now more likely to result in timing violations and non-compliance. This shift places increased emphasis on: Contemporaneous documentation Real-time supervision Realistic workload and staffing models Audit Documentation as a Cornerstone of Audit Quality Audit documentation has long been described as low-hanging fruit in the inspection process. That characterization no longer reflects its role in today’s regulatory environment. Documentation now serves as the primary lens through which regulators assess whether an engagement was properly executed, supervised, and supported. With shortened timelines, expanded quality management expectations, and increased regulatory scrutiny, firms can no longer treat documentation as a downstream activity. It must be embedded into how engagements are planned, staffed, reviewed, and completed. In an environment where inspection conclusions are driven by what is, and what is not, in the audit file, strong documentation is not merely defensive. It is foundational to audit quality. 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 .
Mergers and acquisitions within the accounting firm industry continue to accelerate, driven by succession planning needs, technology investment, talent constraints, geographic expansion, and the pursuit of new service lines. The pace and volume of transactions is being fueled, in large part, by private equity investment in the accounting firm space. Yet as deal activity accelerates, so does a critical reality: the long term success of an acquisition is determined well before the transaction closes—and long after the announcement is made. Experience across the profession shows that insufficient due diligence and poorly executed post acquisition integration are the most common sources of value erosion in accounting firm transactions. What the Regulator is saying and How JGA sees it At the AICPA December 2025 conference on Current SEC and PCAOB Developments, common topics were the presence of private equity in the accounting firm space and the opportunities and challenges that come with this investment. As it relates to private equity, then-acting PCAOB Chair George Botic noted that while these investments have the potential to enhance audit quality by increasing firm capacity and modernizing audit tools with advanced technologies, the presence of private equity presents a risk that firms shift incentives to prioritize profitability over audit quality. Mr. Botic stated, “Both AI and private equity investments in accounting firms carry the potential to truly reshape the profession. Yet these opportunities come with clear challenges to ensure that overreliance on AI and the pressures of private equity do not jeopardize audit quality.” At JGA, we expect the PCAOB to increase its inspection focus on a firm’s system of quality management. To the extent that acquisitions present quality risks to a firm, we expect increased attention from the PCAOB in terms of how firms are managing these risks. Due Diligence: Looking Beyond the Numbers Financial performance, partner buy ins, and deal structure naturally receive significant attention during an acquisition. However, professional services firms—particularly those providing audit and assurance services—certain of the greatest risks often reside outside the financial statements. Effective accounting firm due diligence must assess not only what the target firm has earned, but how it has earned it—and whether that performance is sustainable. This includes gaining a deep understanding of: Audit quality history, including inspection and peer review results, Independence, ethics, and regulatory compliance practices, Industries served, industry concentration and related expertise, Client concentration, retention trends, and engagement risk profiles, Partner governance, compensation alignment, and succession readiness, Technology platforms, data security, and scalability, and Firm culture, leadership dynamics, and decision making processes. When these areas are not rigorously evaluated, issues frequently surface after the transaction closing—when remediation is more disruptive, more expensive, and far more visible to regulators, clients, and staff. The Risks of Inadequate Due Diligence Inadequate diligence often leads to unanticipated post transaction challenges, including: Regulatory findings related to legacy engagements, Independence violations requiring retroactive remediation, Client attrition driven by service disruption or cultural misalignment, Talent loss stemming from unclear expectations or compensation inequities, and Technology incompatibilities that impair efficiency and data integrity. Deficiencies inherited through acquisition can affect inspection outcomes, firm reputation, and overall audit quality long after the transaction closes. Integration: Where Value Is Created—or Lost Even when due diligence is performed thoughtfully, post acquisition integration remains the most common point of failure. Integration is often underestimated, treated as an operational exercise rather than a strategic initiative requiring sustained leadership attention. Successful integration goes far beyond combining systems or standardizing branding. It requires deliberate alignment across how the firm operates, governs itself, and delivers quality—particularly in areas such as: Audit methodology and documentation standards Quality management systems and monitoring processes Partner roles, authority, and accountability Talent development, evaluation, and retention Communication with clients, regulators, and staff Absent a structured integration plan, firms risk operating as a collection of semi independent practices rather than a cohesive organization. This fragmentation can undermine consistency, weaken accountability, and complicate regulatory compliance. A Strategic Imperative in a Changing Profession As consolidation continues and regulatory scrutiny intensifies, rigorous due diligence and disciplined integration are no longer optional. They are essential to managing risk, sustaining quality, and realizing the full value of a transaction. For accounting firm leaders, the message is clear: growth through acquisition can be a powerful strategy—but only when supported by a comprehensive understanding of what is being acquired and a deliberate plan for how the combined firm will operate as one. Firms that treat diligence and integration as leadership imperatives—rather than transactional steps—are better positioned to protect audit quality, retain talent, and preserve client trust while achieving growth objectives. JGA’s Role Guiding Firms through these Opportunities For firms seeking to grow through acquisition without sacrificing quality, control, or visibility, JGA is a solution. JGA is uniquely qualified with deep experience working with accounting firms on quality management, governance, and operational transformation. We have proven due-diligence tools built that are designed to be practical, adaptable, and immediately usable—while also supporting long term consistency as firms pursue multiple acquisitions over time. Ready to get started or need help refining your acquisition activities? Contact your JGA audit quality expert today to schedule a consultation and ensure acquisition activities are tailored to your firm’s needs.
WASHINGTON, D.C.: — Johnson Global Advisory (JGA) is proud to sponsor the ALI’s Accountants’ Liability 2026 conference hosted by the American Law Institute (ALI). The two‑day program will take place May 14–15, 2026, in Washington, D.C., with a live webcast option available for remote attendees. This annual conference is a premier forum for accounting firm leaders, in‑house counsel, litigators, and regulators to examine the evolving landscape of accountants’ liability, enforcement priorities, and risk management. The 2026 program will explore how recent regulatory, litigation, and technological developments are reshaping the profession and what firms can do to proactively respond. “We are pleased to once again sponsor the ALI Accountants’ Liability Conference,” said Jackson Johnson, President of Johnson Global Advisory. “This event consistently brings together leading regulators, practitioners, and risk professionals to discuss the most pressing liability and oversight issues facing accounting firms today. We value the opportunity to engage with participants and contribute to these important conversations.” The program will feature nationally recognized panels of practitioners, general counsel, industry professionals, and government officials. Planned discussions will address current and emerging challenges facing accounting firms, including: Regulatory and enforcement priorities impacting the accounting profession Recent trends in accounting‑related litigation PCAOB and SEC perspectives on audits, inspections, and gatekeeper liability The impact of AI, cryptocurrency, and emerging technologies on audit quality and firm risk Best practices for navigating an evolving and uncertain regulatory environment Register by April 13, 2026, to attend in-person and use the code “ JGA2026 ” to save $250 off . OR, for webcast attendance, use the code " JOHNSON " to save $125 off the tuition. Click here to register. To learn more about how Johnson Global partners with in-house and outside counsel to support public accounting firms, we invite you to explore our latest brochure. This resource outlines our approach to independent monitoring and consulting, including how we assist firms in navigating PCAOB and SEC investigations, implementing quality control improvements, and responding to regulatory findings. Download the brochure below to see how our experienced team can help your firm meet today’s compliance challenges and build a stronger foundation for the future. Get a copy of our brochure here . 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.
We’re pleased to share that Joe Lynch , JGA Shareholder, will be presenting in a series of AICPA & CIMA webcasts focused on practical considerations for Quality Management. These sessions are designed to provide guidance in your QM journey. They support key elements such as engagement quality reviews, root cause analysis, and ongoing monitoring and remediation. Register for Upcoming Sessions Session 1 — Quality Management: Engagement Quality Reviews What you’ll learn: Practical considerations for your firm's responsibilities for engagement quality reviews and the reviewers requirements when executing engagement quality reviews under the updated quality management standards, including how to make EQRs scalable and effective. Register for this session here . Session 2 — Quality Management: Performing a Root Cause Analysis What you’ll learn: How root cause analysis supports remediation by identifying underlying drivers of the findings and deficiencies; supporting the design of corrective actions that prevent recurrence. Register for this session here . Session 3 — Quality Management: My System is Set Up — Now What? What you’ll learn: Post-implementation requirements of SQMS No. 1, which include monitoring activities, evaluating findings and deficiencies, remediation, and the annual evaluation process—so your system stays responsive and effective. Register for this session here . These sessions are included with a current Webcast Pass. 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®.
