Staff Guidance or Standard Setting: AI in the PCAOB's Request for Comment on Standard Setting, June 2026

On June 23, 2026, the Public Company Accounting Oversight Board issued PCAOB Release No. 2026-005, a "Request for Public Comment on PCAOB Standard Setting." The board seeks, in its words, to establish and maintain "high-quality auditing and related professional practice standards for audits of public companies and registered broker-dealers." The release sought comment on updating its standard-setting and research agendas, on revisiting its approach to standard setting, and on the impact of a recent proposal by the U.S. Securities and Exchange Commission on semiannual reporting. Comments were to be submitted no later than August 7, 2026. Parts of the release follow, not the whole.

The release follows an earlier request for comment, on the board's strategic priorities, issued on March 31, 2026. In a table of potential focus areas it identified after considering those comments, the board's view on data and technology is to "Consider changes related to data and technology, including artificial intelligence and digital assets, as a critical emerging issue relevant to the development of the PCAOB's strategic priorities." A footnote says more than 40 comment letters included discussion of one or more aspects of technology.

What the Commenters Said

"In response to the Strategic Priorities RFC, AI-related views were provided by a wide range of commenters including academics, auditors, investors, preparers, and professional groups." The commenters, the board says, "noted that AI is changing how audits are performed, including how audit evidence is generated and evaluated," and recommended that the PCAOB address it.

Commenters suggested addressing, for example, the impact of the company's use of AI on identifying and assessing the risk of material misstatement, auditing internal controls, and determining what constitutes sufficient appropriate audit evidence. They also suggested addressing "documentation of AI-assisted audit procedures and the extent of human involvement in and supervision of such work," and "they also cautioned against deploying AI-enabled audit tools without the necessary governance and relying on the output of such tools without appropriate human review."

"There was no consensus about whether AI-related developments should be addressed through staff guidance or standard setting."

The Board's Research Project

The board is soliciting further input, in Questions 8 through 10, on certain aspects of potential standard-setting and research activities relating to AI. Additional detailed input, it says, "would enable the PCAOB to more precisely calibrate the scope of our activities in this area." It has an existing data and technology research project, designed, in its words, "to assess whether there is a need for guidance, changes to PCAOB standards, or other regulatory actions in light of the increased use of technology-based tools by auditors and preparers." It plans to consider relevant AI-related developments in that project.

If the answer is guidance rather than a standard, what would an audit file have to show about who reviewed an AI tool's output, and how?

Three Questions

Question 8 asks whether the PCAOB should pursue standard setting and research to address the matters commenters raised, among them "documentation, supervision, and governance of AI-enabled tools," or, alternatively, whether they are "best addressed through the issuance of staff guidance." Question 9 asks whether, "in light of rapid advancements in data and technology, including AI," there are additional matters the board should consider.

And Question 10: "Are there specific areas of the PCAOB's current standards that you believe are not fit for purpose in an AI environment? If so, what are those areas and what changes may be necessary to address the impact of AI on auditing?"