Comments of the Auditing Standards Committee of the Auditing Section of the American Accounting Association on the PCAOB’s Standard Setting Agenda
Dereck Barr-Pulliam, Sean A. Dennis, Travis P. Holt, John D. Keyser, Michelle McAllister, Aleksandra B. ZimmermanSUMMARY
On June 23, 2026, the Public Company Accounting Oversight Board (PCAOB) issued a request for comment on its standard-setting agenda (PCAOB 2026). This comment letter summarizes the views of the participating members of the Auditing Standards Committee of the Auditing Section of the American Accounting Association. We recommend that the Board assign its highest priority to data, technology, and artificial intelligence; fraud; and going concern. We also recommend that the Board add complex estimates, fair value measurements, and specialist evidence to its research agenda with moderate-to-high priority; use economic analysis to evaluate scalability, competitive effects, and unintended consequences; avoid creating de facto requirements primarily through inspection and remediation processes; and pursue alignment with IAASB and ASB standards unless PCAOB-specific differences are justified by investor-protection benefits that exceed implementation costs.