New PCAOB Audit Disclosure Rules

The Public Company Accounting Oversight Board (PCAOB) unanimously approved new rules on December 15 that will require audit firms to disclose the names of each engagement partner in a public company audit as well as the names of other accounting firms that contributed to the audit on a new form.


The action taken by the PCAOB culminates a project that began in 2009 to have at least some public disclosure of specific audit participants, beginning with requiring the audit engagement partner to sign his or her own name to the audit report. Since then, the board has considered several options to best provide investors with more information about the audit and the auditors who conduct them. It is the hope of the board that this new rule will increase transparency and accountability among audit firms.

Description of New Rules

Under the new rules, which are subject to approval by the Securities and Exchange Commission (SEC), auditors will be required to file a new PCAOB Form AP, Auditor Reporting of Certain Audit Participants, for each issued audit. The following information must be disclosed on the form:

  • Name of the engagement partner
  • Names, locations, and extent of participation of other accounting firms that took part in the audit if their work constituted 5% or more of the total audit hours
  • Number and aggregate extent of participation of all other accounting firms that took part in the audit whose individual participation was less than 5% of the total audit hours

To prevent confusion when engagement partners have the same names or change their names, firms will be required to assign engagement partners with unique identification numbers for disclosure on Form AP. When partners change firms, they will be assigned a new partner ID, but their previous ID number will also be reported on any new Form AP associated with them.

The information filed on Form AP will be available in a searchable database on the PCAOB website.

Filing Requirements

Filing of Form AP with the PCAOB will be required no more than 35 days after the audit firm files the audit report with the SEC. For initial public offerings, Form AP will be required to be filed no later than 10 days after the auditor’s report is first included in any document filed with the SEC.

Upon SEC approval, the new rules for engagement partner disclosure will apply to auditor’s reports issued on or after Jan. 31, 2017, or three months after SEC approval of the final rules, whichever is later. For disclosure of other involved accounting firms, the rules will apply to auditor’s reports issued on or after June 30, 2017.

Contact Us

If you have questions about the new PCOAB rules or Form AP, call us at 818-334-8623 or click here for email.