The Critical Role of Communication with the Audit Committee: Lessons from Recent PCAOB Sanctions

The Critical Role of Communication with the Audit Committee: Lessons from Recent PCAOB Sanctions

The Critical Role of Communication with the Audit Committee: Lessons from Recent PCAOB Sanctions

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  • On March 24, 2025
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In the world of financial reporting, transparency and accountability are paramount. One of the key mechanisms ensuring both is – effective communication between auditors and audit committees. Without clear and consistent communication, audit committees may lack crucial information needed for oversight, potentially leading to financial misstatements, compliance failures, and weakened investor confidence.

Why Communication with the Audit Committee Matters?

Audit committees serve as a crucial bridge between a company’s auditors and its board of directors, ensuring the integrity of financial reporting.

Effective communication enables audit committees to:

  • Oversee the Audit Process – Gain insights into key risks, audit strategies, and findings.
  • Enhance Financial Statement Reliability – Ensure investors and stakeholders receive accurate and timely financial information.
  • Strengthen Corporate Governance – Help organizations maintain compliance with regulatory requirements and uphold high ethical standards.
  • Facilitate Risk Management – Identify and address potential financial and operational risks before they escalate.

Communication Standards: What Auditors Must Adhere To?

The PCAOB’s Auditing Standard (AS) 1301, Communications with Audit Committees, establishes the framework for effective engagement between auditors and audit committees. Auditors are required to:

  • Establish Engagement Terms – The auditor must document the terms of the audit engagement in an engagement letter annually, ensuring mutual understanding with the audit committee. If such an understanding cannot be established, the auditor must decline or discontinue the engagement.
  • Disclose Other Audit Participants – Auditors must inform the audit committee about the names, locations, and planned responsibilities of other public accounting firms or professionals involved in the audit. If substantial portions of the audit are conducted by other firms, the lead auditor must justify their sufficiency as the primary auditor.
  • Communicate Audit Scope and Responsibilities – Clearly outline the scope of the audit, the responsibilities of both auditors and management, and expected deliverables.
  • Discuss Significant Risks and Findings – Provide the audit committee with an overview of significant risks identified and any major audit findings.
  • Report Critical Accounting Policies and Estimates – Discuss management’s significant assumptions, key accounting policies, and areas of heightened judgment.
  • Address Uncorrected and Corrected Misstatements – Present a schedule of uncorrected misstatements and discuss their materiality, along with any corrected misstatements that were only detected through audit procedures.
  • Highlight Significant Unusual Transactions – Inform the audit committee about any transactions that are outside the normal course of business or appear unusual in timing, size, or nature.

By ensuring compliance with these requirements, auditors provide audit committees with the necessary insights to uphold financial reporting integrity and corporate governance.

  • Audit Scope and Responsibilities – Informing the audit committee about the scope of the audit and the auditor’s responsibilities.
  • Critical Accounting Policies and Estimates – Discussing areas requiring significant judgment and estimates.
  • Audit Findings and Adjustments – Presenting audit results, including significant deficiencies in internal controls.
  • Other Participants in the Audit – Disclosing the use of component auditors, shared service centers, and specialized audit hubs, ensuring audit committees are fully aware of who is conducting the audit and where.

The Consequences of Failing to Meet These Standards

When auditors fail to meet these communication requirements, the risks to financial integrity, investor trust, and regulatory compliance increase exponentially. The US PCAOB’s recent $3 million excess in fines and remedial sanctions against nine network firms of a Big Four globally highlight the tangible consequences of inadequate audit committee communication.

In these cases, some firms failed to:

  • Disclose the participation of other accounting firms in the audit process.
  • Communicate essential audit information, hindering audit committees from performing their oversight responsibilities.
  • Accurately report on Form AP and Form 2, which provide transparency on who performed the audit work.

Such failures obstruct informed decision-making, leaving audit committees unaware of critical details that impact financial reporting reliability.

Strengthening Audit Committee Communications

Firms must prioritize clear, proactive, and complete communication with audit committees to avoid compliance failures and regulatory penalties.

Best practices include:

  • Early and Ongoing Engagement – Regularly updating the audit committee throughout the audit process.
  • Transparency in Audit Participants – Clearly identifying all firms and professionals involved in the audit.
  • Adhering to PCAOB Standards – Ensuring compliance with AS 1301 and other regulatory communication requirements.
  • Implementing Robust Quality Controls – Establishing internal review mechanisms to prevent reporting lapses.

KNAV Comments

The US PCAOB’s recent enforcement actions serve as a critical reminder that audit committee communication is not just a procedural requirement—it is an essential component of financial reporting integrity. Firms that fail to comply risk damaging their reputations, facing regulatory sanctions, and, most importantly, compromising investor trust. By upholding transparency, maintaining regulatory compliance, and ensuring consistent, clear communication with audit committees, auditors play a fundamental role in strengthening the global financial system.

By

Atul Deshmukh
Partner - International Assurance

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