Revisiting Risk Assessment Under SAS 145 Part I: Identifying Significant Risks

In January of 2022, we wrote about the fact that given some of the newly issued AICPA guidance, the differences between AICPA and PCAOB audits is increasingly diminishing. Although not convergent, there is a move within the audit industry to increase alignment. This is true within the US as well as at a more global level. Is it coincidence that AU-C 315, CAS 315, and ISA 315 all have the same number and all deal with risk assessment? As a follow-up to our previous article, we are going to explore two key elements of the new SAS 145 guidance. In this first article, we are exploring some of the renewed focus on risk assessment. In a second article, we will explore the new requirements around understanding the design and implementation of controls with a focus on further developing our knowledge of information systems and the risks they present in an audit.

In working with engagement teams, we get our fair share of consultations asking to brainstorm how to audit a specific account or transaction. Typically, the first question is, “what is the overall risk of material misstatement?” After all, doesn’t everything begin with risk assessment?

While we may all acknowledge this reality, so often, teams consider the nature of the procedures performed to determine whether something is a significant risk. And we get it. Until the new AICPA standards were released, specifically SAS 145, the previous guidance defined a significant risk as follows:

“An identified and assessed risk of material misstatement that, in the auditor's professional judgment, requires special audit consideration.”

In other words, a significant risk was determined based on the necessity for special audit consideration. In all fairness, the guidance in AU-C 315 does also provide additional considerations in paragraphs 28 and 29 regarding significant risks. All that changed however with the new SAS 145 which now defines a significant risk as:

An identified risk of material misstatement

i. for which the assessment of inherent risk is close to the upper end of the spectrum of inherent risk due to the degree to which inherent risk factors affect the combination of the likelihood of a misstatement occurring and the magnitude of the potential misstatement should that misstatement occur, or

ii. that is to be treated as a significant risk in accordance with the requirements of other AU-C sections. (i.e., fraud risks)

The new definition is still a bit “convoluted” but at least it is pointing engagement teams to the inherent risk factors as opposed to the procedures performed1.

Okay, so we have improved the definition of significant risks, but what is the big deal? The issue we are seeing in the industry is a failure of engagement teams to properly identify and document risk assessment and specifically, significant risks. Increasingly, when we support our clients on PCAOB inspections and firm’s counsel as an expert in enforcement investigations, we see the regulators challenge engagement teams on their identification of significant risks. What inspection and enforcement staff are getting at is: if the risk assessment is wrong, the audit approach is also inherently wrong.

Assessing the Overall Risk of Material Misstatement

As part of planning an audit, engagement teams develop an understanding of the entity through inquiries with management, reading press releases and interim financial statements, and performing preliminary analytics, among other procedures. Don’t forget that in the new SAS 145 guidance, teams are required to obtain an understanding of the design and implementation of internal controls. This new requirement, which has been the expectation under PCAOB standards, is required regardless of whether the team plans to rely on controls; this is a foundational part of understanding the entity. From this knowledge, teams can begin to understand the likely sources of potential misstatement which enables teams to perform a complete and robust risk assessment. Based on that understanding of the entity and the financial statements, the engagement team performs its risk assessment with the overall risk of material misstatement being predicated on the separate evaluation of inherent risk and control risk.

Inherent risk is the susceptibility of an assertion (linked to a class of transactions, an account balance, or a footnote) to misstatement that could be material, either individually or when aggregated with other misstatements before consideration of controls. The key here is to ignore controls. AICPA and PCAOB guidance provide examples of risk factors including nature and size of the account/class of transactions, volume of transactions, complexity, homogeneity, exposure to losses within an account, degree of uncertainty and subjectivity in estimates, changes from prior periods related to accounting / disclosure, related party considerations, susceptibility to misstatement due to error or fraud, as well as susceptibility to management bias and judgement. Though not exhaustive, you get the point. Inherent risk is based on the nature of the account itself.

Control risk is the risk that a misstatement could occur that could be material, either individually or when aggregated with other misstatements, will not be prevented or detected on a timely basis by the entity’s system of internal control. This part of risk assessment is simpler; to reduce high control risk, engagement teams must test the operating effectiveness of controls. In other words, is the engagement team relying on controls or not?

Based on inherent risk and control risk, the engagement team then considers the overall risk of material misstatement. The specific identification of significant risks varies from firm to firm. Some methodologies build in the identification of significant and/or fraud risks into the inherent risk assessment and some have a separate consideration. There is no right or wrong way here, but the point is to be sure that the risk assessment incorporates clear documentation around significant and fraud risk identification. When identifying significant risks, the literature places a huge emphasis on related party transactions, complex accounting, estimates (given the subjectivity, uncertainty), as well as significant unusual transactions. These items are not automatically default significant risks, but they have a much higher likelihood of being a significant risk (depending on materiality). Keep in mind that just because an account is immaterial does not inherently mean there is no risk of material misstatement; this is where understanding the nature of the account or the qualitative nature of a disclosure is important. For instance, an immaterial allowance for doubtful accounts does not mean there is no risk of material misstatement. As a reserve account, the engagement team needs to consider the risk of understatement when concluding on magnitude and whether an account poses a risk of material misstatement. The same can be said for qualitative disclosures. Materiality is not purely a quantitative consideration.

Nature, Timing, Extent of Audit Procedures

Once risk assessment is completed, the next step is to then design the nature, timing, and extent (or NTE) of the audit response.

The nature of the audit approach can be broken down into various considerations:

Control test vs. substantive test
Within control testing, the nature of the test, such as inquiry, observation, inspection or reperformance
Within substantive testing, the use of analytical procedure vs. tests of details
For both controls and substantive testing, consideration around the use of work of others and review considerations such as reliance vs. reperformance

Timing is a function of when is the testing being performed (i.e., interim vs. year-end test work) and what balance is being tested (i.e. an interim balance or the year-end balance). Generally, the higher the risk, the more we expect testing performed at year-end (i.e., with the most up to date information) and/or testing performed over year-end balances. Interim testing can certainly be useful, such as testing predictable, often low-risk prepaid balances. However, for a significant accounting estimate (i.e., a significant risk), testing the Q2 balance may not be the best approach as it would require extensive roll-forward procedures to ensure the year-end estimate is also materially correct.

Finally, the extent is the amount of test work being performed. This is most often evidenced in the sample sizes used for controls and/or substantive tests of details. However, the extent could also be found in the mix of procedures performed. For instance, while a test of detail may cover the risk related to an assertion, engagement teams may also perform analytical procedures to obtain additional comfort, adding to the extent of testing.

There is nothing terribly new here. Engagement teams build out the audit plan based on overall risk assessment. And that is the key: risk assessment is so critical because it is the starting point for designing the appropriate mix of procedures. If the risk assessment is inaccurate and/or not thoroughly documented, how can anyone conclude on the appropriateness of the audit procedures to address the risk?

Easy as this concept may be, often when we take a step back and compare the audit approach for a significant risk vs. a normal / minimal risk, in theory, the audit approach should look different. And yet, we have often seen engagement teams use a judgmental sample of five to test a low-risk account and then also use a judgmental sample of five to test a moderate or high-risk account. How does this evidence any change in NTE? The theory and concepts are not hard; it is the application of the concepts and ensuring the audit approach adequately takes risk assessment into account that is difficult.

Documentation

After talking through risk assessment in a consultation, the next question is typically “where is this documented?” Often teams have the risk assessment documented in planning, but when we look at the list of significant risks communicated to the audit committee, it does not reconcile with the planning documentation. Or, when we compare the list of significant risks in the CAM evaluation tool, again, it does not reconcile. Primarily, the risk assessment needs to be consistent throughout the audit file. Second, the risk assessment needs to be thoroughly documented. While nothing in the auditing standards requires teams to document why something is not a significant risk, if there is any question and/or professional judgment applied, that needs to be captured in the documentation. If any of the significant risk factors (AU-C 315.29 or AS 2110.70-71) are present, then engagement teams should either a) identify a significant risk or b) document why those risk factors do not represent a significant risk.

What we are seeing is that absent documentation evidencing the engagement teams’ considerations and professional judgment, the PCAOB is challenging the identification of significant risks. In other words, if there is a material account that has complex, subjective assumptions or if there is a material significant unusual transaction and the engagement team did not identify a significant risk and did not document its considerations, then the PCAOB is challenging the evaluation. So, be consistent with the risks identified and be clear in the documentation in your audit file.

Common and Potential Pitfalls

Two common pitfalls we see, aside from the inconsistency of risk identification within an audit file, include:

Forgetting about management override of controls: Most know that revenue has a presumptive fraud risk (and thus is a significant risk, by definition). However, often teams forget to document the presumptive risk of management override of controls. This risk exists, regardless of whether the engagement team is testing the operating effectiveness of controls. Journal entry testing, as required under AS 2401, is one procedure to address the risk of management override of controls, so teams often claim “it’s inherently considered a risk because we did JE testing” but this does not really demonstrate to the PCAOB how the engagement team considered the entity-specific risk of management override of controls and designed appropriate procedures to address the specific risk.

Performing a thorough evaluation and review of significant risks: While the PCAOB often challenges the under-identification of risks, I have also seen repeatedly where teams will document a significant risk and then, when the audit approach is questioned during an inspection, the engagement team will provide a list of reasons why the audit approach was sufficient. Those reasons are typically linked to inherent risk factors that support why the risk is low. In other words, the engagement team identified a significant risk during planning, but now, when being forced to defend the audit approach, the engagement team is presenting an argument that the risk is in fact low and not significant. Why was it identified as a significant risk at the time of the audit then? Most of the time, I agree with the engagement teams, but that means the risk assessment was not correctly documented during the audit and/or the risk factors changed during the audit, but the team did not revisit risk assessment.

Two potential pitfalls we could see relate to the following:

The new guidance from SAS 145 defines a significant risk as a risk that is “close to the upper end of the spectrum of inherent risk due…” While conceptually easy to understand, firms will need to make it clear to engagement teams what constitutes a significant risk and how to interpret this new definition. Does this mean all higher inherent risks are considered significant risks? What are the factors to be considered in delineating between higher risk accounts and significant risk accounts? Or perhaps firms will need to revisit methodologies and recalibrate the inherent risk scale to allow for more precise delineation so that all higher inherent risks are not automatically defaulted to significant risks.

SAS 145 also includes a requirement to perform a “stand-back” analysis to ensure the completeness of the engagement team’s identification of significant classes of transactions and significant accounts. In other words, after performing the risk assessment, the engagement team needs to stand back and evaluate the potential risk of material misstatement for all classes of transactions and accounts that were not previously in scope. Is there a risk of material misstatement in aggregate? What assertions?

The point is not to go overboard and identify 20 significant risks. We have challenged teams on over-identification as well as under-identification. The point is to be thorough and complete and to capture the relevant judgments that go into performing risk assessment. Also, if the documentation incorporates the relevant risk factors and the engagement teams’ judgments around those risk factors, then the documentation should speak for itself. That is the goal.

Key Takeaways

Remember to separately consider inherent risk and control risk.
For significant, unusual transactions, complex accounting matters, and/or subjective accounting estimates, unless the amounts are obviously immaterial, consider documenting the professional judgment around why something is or is NOT a significant risk.
Once significant and/or fraud risks have been identified, be sure the nature, timing, and extent of audit procedures are appropriately modified to address the specific risk.
Document all professional judgment applied (and considered) when evaluating risk assessment.
Risk assessment is an iterative process, so be sure to continue to update risks (as merited) throughout the audit and be sure risk assessment is consistent throughout all documentation within the audit workpapers, including audit committee communications.

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Jackson Johnson Appointed to AICPA & NASBA International Qualifications Appraisal Board (IQAB)

June 8, 2026

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.”

AI Governance Belongs in the Boardroom, Not the Server Room

May 20, 2026

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.

Joe Lynch, JGA Shareholder, to Present at 41st Midyear SEC Reporting & FASB Forum in San Francisco

May 20, 2026

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.

JGA Response to PCAOB Request for Comment on Strategic Priorities

May 15, 2026

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.

Monitoring and Remediation: Turning Engagement Deficiencies Into System Improvement

April 28, 2026

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.

What Regulators Expect to See When AI Is Used

April 28, 2026

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.

Audit Documentation: From Low-Hanging Fruit to Load-Bearing Standard

March 30, 2026

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 .

Accounting Firm Acquisitions: Why Due Diligence and Integration Determine Long-Term Success

March 30, 2026

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.

JGA to Sponsor ALI's Accountants' Liability 2026 Conference

By Jackson Johnson • February 24, 2026

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.

Joe Lynch, JGA Shareholder, to Present in AICPA & CIMA Quality Management Webcast Series

By Jackson Johnson • February 24, 2026

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®.