A Practical Guide to the New PCAOB Reporting Requirements

Steven R. Berger, JD

The Sarbanes-Oxley Act of 2002 (SOX) requires that any accounting firm that prepares or issues an audit report with respect to a U.S. public company must register with the Public Company Accounting Oversight Board (PCAOB). Until recently, an accounting firm was required only to provide information current as of the initial registration date for the firm. Effective December 31, 2009, accounting firms registered with the PCAOB are required to file annual and current reports with the PCAOB. On August 13, 2009, the SEC approved the proposed rules with the original effective date of October 12, 2009, but on September 30, 2009, the PCAOB delayed the effective date to December 31, 2009. These rules implement the requirements of SOX section 102(d) that registered public accounting firms 1) report annual information about the firms and their audit practices, and 2) submit, as specified by the PCAOB or the SEC, more frequent information necessary to update the information previously filed with the PCAOB. Until now, the PCAOB had no requirement for annual reports or amendments to report material changes in initial registration information.