STAFF GUIDANCE
FORM AP, AUDITOR REPORTING OF CERTAIN AUDIT PARTICIPANTS
AND RELATED VOLUNTARY AUDIT REPORT DISCLOSURE UNDER
AS 3101, REPORTS ON AUDITED FINANCIAL STATEMENTS
JUNE 28, 2016
This implementation guidance was prepared by PCAOB staff to help firms file reports on
Form AP and include voluntary information in their audit reports. This staff guidance
document sets forth the staff's views on issues related to the implementation of the rules
and standards of the PCAOB. It does not constitute rules of the Board, nor has it been
approved by the Board. It supplements PCAOB Release No. 2015-008, Improving the
Transparency of Audits: Rules to Require Disclosure of Certain Audit Participants on a
New PCAOB Form and Related Amendments to Auditing Standards (Dec. 15, 2015)
and the instructions to Form AP, which can be found on the PCAOB's website.
Staff Guidance
June 28, 2016
Page i
TABLE OF CONTENTS
I. Overview of the Requirements Relating to Audit Participant Reporting on
Form AP ......................................................................................................................... 1
A. Filing Requirements .............................................................................................. 1
1. General Requirements .................................................................................... 1
2. Other Filing Considerations ............................................................................ 3
B. Amendments to Form AP ..................................................................................... 4
1. General Requirements .................................................................................... 4
2. Situations Where an Amendment Is Not Appropriate or Not Required ........... 5
II. Engagement Partner Disclosure on Form AP ...................................................... 6
A. Name .................................................................................................................... 6
B. Partner ID ............................................................................................................. 6
C. Dual-dated Audit Reports ..................................................................................... 7
III. Other Accounting Firm Disclosure on Form AP .................................................. 8
A. General Requirements ......................................................................................... 8
B. Exclusions from Disclosure and the Computation of Total Audit Hours ................ 9
C. Computation of Total Audit Hours, Using Estimated Audit Hours, and Specific
Scenarios ................................................................................................................... 11
1. Elements of Total Audit Hours ...................................................................... 11
2. Using Estimated Audit Hours ........................................................................ 13
3. All Periods Presented Were Audited During a Single Audit Engagement ..... 13
4. Dual-dated Audit Reports .............................................................................. 14
D. Other Accounting Firms Individually Contributing 5% or More of Total Audit Hours
........................................................................................................................... 14
1. Legal Name .................................................................................................. 15
2. Headquarters' Office ..................................................................................... 15
3. Firm ID .......................................................................................................... 16
E. Other Accounting Firms Individually Contributing Less Than 5% of Total Audit
Hours ......................................................................................................................... 16
F. Responsibility for the Audit is Divided ................................................................. 17
IV. Voluntary Disclosure in the Audit Report under AS 3101 ................................ 18
V. Illustrative Example ............................................................................................. 19
Staff Guidance
June 28, 2016
Page ii
A. Background ........................................................................................................ 19
B. Computation of Total Audit Hours ....................................................................... 20
C. Disclosure on Form AP ....................................................................................... 22
1. Engagement Partner ..................................................................................... 22
2. Other Accounting Firms ................................................................................ 22
D. Disclosure in the Audit Report ............................................................................ 23
VI. Mechanics of Reporting Through the PCAOB System ..................................... 23
A. Filing Form AP .................................................................................................... 23
1. Filing Using a Web Form .............................................................................. 24
2. Filing in Batches Using the XML Schema ..................................................... 24
3. Signing Form AP Filings (Part VI of Form AP) .............................................. 24
4. Firm ID on Form AP ...................................................................................... 24
B. Process for Amending a Form AP Filing ............................................................. 25
1. Amending a Form Initially Filed Using a Web Form ...................................... 25
2. Amending a Form Initially Filed via XML ....................................................... 25
VII. Phased Effectiveness and Transition Guidance ............................................... 25
VIII.Contact Information ............................................................................................. 26
Staff Guidance
June 28, 2016
Page 1
I. Overview of the Requirements Relating to Audit Participant Reporting on
Form AP
A. Filing Requirements
1. General Requirements
General. Each registered public accounting firm must provide information about
engagement partners and accounting firms that participate in audits of issuers by filing a
Form AP, Auditor Reporting of Certain Audit Participants ("Form AP"), for each audit
report issued by the firm for an issuer.
1
Form AP is due by the 35th day after the date
the audit report is first included in a document filed with the Securities and Exchange
Commission ("SEC" or "Commission"),
2
subject to the shorter filing deadline that applies
when the audit report is first included in a Securities Act registration statement
(described below).
Example: A registered firm issues its audit report on the financial
statements of Company A on February 28. Company A files its annual
report on Form 10-K (the first SEC filing to include the audit report) on
March 1. Form AP is due not later than April 5 (35 days after March 1).
3
Securities Act Registration Statements. If the audit report is first included in a
registration statement filed with the SEC under the Securities Act, the firm is required to
file Form AP by the 10
th
day after the date the audit report is first included in a document
filed with the SEC.
4
1
All requirements are subject to the effective dates discussed in Section
VII. See Rule 3211(a). Issuers, in general, are entities that are required to file periodic
reports with the SEC under the Securities Exchange Act of 1934 ("Exchange Act") or
that file or have filed a registration statement that has not yet become effective under
the Securities Act of 1933 ("Securities Act"), and that has not been withdrawn. See Rule
1001(i)(iii). In addition to companies that are required to file annual reports on Forms
10-K, 20-F, and 40-F, issuers include certain employee stock purchase, savings, and
similar plans; unit investment trusts; and registered investment companies.
2
See Rule 3211(b)(1).
3
The examples in this document are provided for illustrative purposes only.
Pursuant to Rule 1002, if the filing deadline falls on a Saturday, Sunday, or federal legal
holiday, the deadline for filing would be the next day that is not a Saturday, Sunday, or
federal legal holiday.
4
See Rule 3211(b)(2).
Staff Guidance
June 28, 2016
Page 2
Example—IPO: On March 20, Company B, an emerging growth company
("EGC"), confidentially submits a draft Securities Act registration
statement for SEC staff review.
5
The firm is not required to file Form AP in
connection with such a submission. On July 18, Company B files a
Securities Act registration statement that is the first SEC filing to include
the audit report on the financial statements. The firm is required to file
Form AP by July 28.
Example—Mutual Fund Formation: On June 6, a Securities Act
registration statement is filed in connection with the formation of Fund C,
an open-end mutual fund. The registration statement is the first SEC filing
to include the audit report on the financial statements of Fund C. The firm
is required to file Form AP by June 16.
Application of Filing Deadline in Other Circumstances.
Example—Contemporaneous Filing of Annual Report and Registration
Statement: On March 1, Company D files both its annual report on Form
10-K, containing ABC Audit Firm's audit report, and a registration
statement on Form S-3, incorporating the Form 10-K by reference.
Because of the incorporation by reference, the Form 10-K would be
considered to be filed prior to the registration statement for purposes of
Rule 3211 deadlines, and the filing deadline applicable to Form AP would
be 35 days after the filing of Form 10-K, not 10 days after the filing of
Form S-3.
Example—Reverse Merger: Company E, a shell company, acquires
Operating Company X, a private company, on October 14 and files a
current report on Form 8-K, including the audited financial statements of
Operating Company X, on October 18. There is no requirement for the
auditor of Operating Company X to file Form AP in connection with the
filing of Form 8-K because Operating Company X is not an issuer. Form
AP would be due in connection with the next filing of an audit report for
Company E, for example, with the filing of Company E's annual report on
Form 10-K.
5
Prior to its IPO, an EGC may confidentially submit to the SEC a draft
registration statement for confidential nonpublic review by the staff of the SEC prior to
public filing. The confidential submission is not considered to be a filing with the SEC.
See Securities Act Section 6(e).
Staff Guidance
June 28, 2016
Page 3
2. Other Filing Considerations
Audit report first included in a document filed with the Commission. Rule 3211
requires the filing of a report on Form AP regarding an audit report only the first time the
audit report is included in a document filed with the SEC. Subsequent inclusion of
precisely the same audit report in other documents filed with the SEC does not give rise
to a requirement to file another Form AP. In the event of any change to the audit report,
including any change to the audit report date, Rule 3211 requires the filing of a new
Form AP the first time the revised audit report is included in a document filed with the
SEC.
6
Example—Reissued Audit Reports, Including Consents. If the firm issues
an audit report that is included in an issuer's Form 10-K filing and the firm
subsequently consents to inclusion of that same audit report in the issuer's
Form S-3 filing, the firm is not required to file a new Form AP in
connection with the Form S-3 filing.
Example—Dual-dated Audit Reports. If a previously-issued audit report is
reissued and dual-dated to refer to the addition of a subsequent events
note in the financial statements, a new Form AP would be required stating
the original date of the audit report and the date of the dual-dated
content.
7
Referred-to auditors. When a principal auditor divides responsibility for the audit
with one or more other public accounting firms ("referred-to auditor") in accordance with
AS 1205 (currently AU sec. 543), Part of the Audit Performed by Other Independent
Auditors,
8
the principal auditor is required to identify on Form AP each referred-to
6
See Note 2 to Rule 3211(a).
7
See also Section III.C.4.
8
On March 31, 2015, the PCAOB adopted the reorganization of its auditing
standards using a topical structure and a single, integrated numbering system. See
Reorganization of PCAOB Auditing Standards and Related Amendments to PCAOB
Standards and Rules, PCAOB Release No. 2015-002 (Mar. 31, 2015). On September
17, 2015, the SEC approved the PCAOB's adoption of the reorganization. See Public
Company Accounting Oversight Board; Order Granting Approval of Proposed Rules To
Implement the Reorganization of PCAOB Auditing Standards and Related Changes to
PCAOB Rules and Attestation, Quality Control, and Ethics and Independence
Standards, Exchange Act Release No. 34-75935 (Sept. 17, 2015), 80 FR 57263 (Sept.
22, 2015). The reorganized amendments will be effective as of December 31, 2016, and
nothing precludes auditors and others from using and referencing the reorganized
standards before the effective date. See PCAOB Release No. 2015-002, at 21.
Staff Guidance
June 28, 2016
Page 4
auditor with its Firm ID, when applicable, and the magnitude of its participation.
9
The
referred-to auditor is not required to file Form AP.
10
Mutual funds with multiple series of the same issuer. When multiple audit
opinions are issued on the same day for a mutual fund with more than one series (either
within a single audit report or in multiple audit reports), the firm may file a single
Form AP covering all of the audit opinions, so long as all of the information elicited by
Form AP is identical for each series except for the Series identifier.
11
If, however, any of
the information called for on Form AP varies among any of the series of the mutual
fund, Rule 3211 requires a separate Form AP filing for any series with differing Form AP
information. For example, if different engagement partners are responsible for certain of
the series, separate Form APs must be filed for each engagement partner, covering the
audit opinions for the funds which he or she served as engagement partner.
Situations where filing is not required. Situations where filing a Form AP is not
required include—
Attestation engagements, for example, compliance with servicing
criteria pursuant to Exchange Act Rules 13a-18 and 15d-18—
Regulation AB;
Reports issued for interim reviews; and
Non-issuer audits conducted in accordance with PCAOB standards,
including audits of brokers and dealers reporting under Exchange Act
Rule 17a-5.
12
B. Amendments to Form AP
1. General Requirements
Amendments to Form AP are required to:
13
Correct information that was incorrect at the time the form was filed, or
9
See Item 3.3 and Item 5.1 of Form AP.
10
See Note 1 to Rule 3211(a).
11
The Series identifier for each series must be indicated in Item 3.1.a.2 of
Form AP.
12
If a broker or dealer were an issuer, the requirements would apply.
13
See Rule 3210 and General Instruction 4 of Form AP.
Staff Guidance
June 28, 2016
Page 5
Provide information that was omitted from the form and was required to
be provided at the time the form was filed.
Inaccuracies or omissions could form the basis for disciplinary sanctions for
failing to comply with the reporting requirements, and it is therefore in a firm's interest to
correct such errors as soon as possible. A firm may do so by filing an amendment
pursuant to Rule 3210 and the Form AP instructions.
For example, if the wrong engagement partner was identified on Form AP, the
firm is required to amend the filing to identify the correct engagement partner. Similarly,
if an other accounting firm was required to be disclosed at the time of the initial filing but
was not,
14
the firm is required to amend the filing to include the omitted other accounting
firm.
2. Situations Where an Amendment Is Not Appropriate or Not Required
Amendments are appropriate only to correct information that was incorrect at the
time of the filing or to supply omitted information that should have been supplied at the
time of the filing. The amendment process should not be used to update information
reported on Form AP that was accurate or based on a reasonable estimate at the time
of the initial filing.
Differences between estimated and actual audit hours. In calculating total audit
hours, actual audit hours should be used if available. If actual audit hours are
unavailable, the firm may use a reasonable method to estimate audit hours. No
amendment to Form AP is needed solely to reflect changes in the identification of firms
or their percentage participation in the audit that would result from differences between
reasonably estimated hours and actual hours, in the event such information becomes
available after the Form AP filing deadline.
Changes subsequent to the issuance of an audit report.
Engagement partner change. If after an audit report is issued, another
engagement partner is assigned to the issuer's audit, the amendment
process should not be used to update the previously filed Form AP. The
new engagement partner would instead be identified on the Form AP filed
when the next audit report is first included in a filing with the SEC.
Withdrawn audit reports. The amendment process should not be used to
update a previously filed Form AP in connection with an audit report that is
subsequently withdrawn.
14
See Item 4.1 of Form AP.
Staff Guidance
June 28, 2016
Page 6
II. Engagement Partner Disclosure on Form AP
Form AP requires the following information about the engagement partner on the
most recent period's audit—
15
Name (that is, first and last name, all middle names and suffix, if any),
and
Partner ID, and any other Partner IDs previously reported on a Form AP
(i.e., any other Partner IDs by which he or she has been identified on a
Form AP filed by a different registered public accounting firm or on a
Form AP filed by the firm at the time when it had a different Firm ID).
A. Name
The engagement partner's name is required to be reported consistently on all
Form APs filed with the PCAOB, unless the individual has changed his or her name. All
Form APs filed subsequent to a name change are required to consistently use the new
name.
Example—Name Change: Engagement partner Jane Anne Smith changes
her name to Jane Smith Jones after the firm files Form AP for its 20X5
audit report and she continues to serve as engagement partner on the
20X6 audit. The amendment process should not be used to update the
Form AP for the 20X5 audit report. Instead, the Form AP for the 20X6
audit report would reflect her new name, while her Partner ID remains the
same.
B. Partner ID
The firm must disclose the Partner ID, a unique ten-digit identifier assigned by
the firm to each partner who serves as engagement partner for issuer audits, and any
Partner IDs previously associated with the engagement partner, on Form AP.
16
The firm
would disclose each engagement partner's Partner ID consistently on all Form APs it
files with the PCAOB.
For each engagement partner that is responsible for a firm's issuance of an
issuer audit report, the firm must assign a ten-digit Partner ID number, beginning with
15
Item 3.1.a.6 of Form AP.
16
See General Instruction 7 and Items 3.1.a.6 and 3.1.e of Form AP.
Staff Guidance
June 28, 2016
Page 7
the firm's Firm ID
17
—a unique five-digit identifier based on the number assigned to the
Firm by the PCAOB—followed by a unique series of five digits assigned by the firm. The
unique series element can be any series of numbers of the firm's choosing that is
unique to the engagement partner. For example, the unique series element could be
sequential numbers, numbers based on the year the partner was admitted into the
partnership, or random numbers. Until the engagement partner is no longer associated
with the firm, the firm must use the same Partner ID for that engagement partner in
every Form AP filed by the firm that identifies that engagement partner. When an
engagement partner is no longer associated with the firm, the firm must retire his/her
Partner ID and not reassign it.
If an engagement partner previously associated with one registered public
accounting firm associates with a new firm, the new firm must assign a new Partner ID
to the engagement partner. If the engagement partner was previously identified on Form
AP by a different Partner ID, the new firm must report on a Form AP the new Partner ID
and all Partner IDs previously associated with the engagement partner.
18
Example—Assigning Partner IDs: Firm A has 200 partners that serve as
engagement partners for audits of issuers. Its Firm ID is 98715. The firm
assigns Partner IDs using sequential numbers starting at 00001. Partner
IDs will range from 9871500001 to 9871500200.
Example—Associating with a Different Firm: An engagement partner
(Partner ID 9871500199) leaves Firm A to associate with Firm B. Firm B is
required to assign her a new Partner ID based on its Firm ID (99716) and
the next partner number under its methodology. Firm B must report on
Form AP her current Partner ID (9971601234) and the previously used
Partner ID (9871500199). Firm A must retire and not reassign the Partner
ID (9871500199) to another partner.
C. Dual-dated Audit Reports
When an audit report is reissued and dual-dated, a new Form AP filing is
required. If the engagement partner has changed after the original audit report is issued,
Form AP will disclose both the name of the engagement partner who was responsible
17
This number can be found by viewing the firm's summary page on the
PCAOB website. It is generally displayed next to the name of the firm—firm name
(XXXXX). For identifiers with fewer than five digits, leading zeroes should be added
before the number to make five digits, e.g., 99 should be presented as 00099.
18
See General Instruction 7 and Item 3.1.a.6 of Form AP.
Staff Guidance
June 28, 2016
Page 8
for the original audit report and the name of the engagement partner responsible for the
dual-dated content.
19
Example—Audit Report Reissued and Dual-dated and the Engagement
Partner Changed: An engagement partner (Partner ID 9865400013) on
the audit of F Company for the 20x0 audit has since left the firm. Another
partner (Partner ID 9865400025) became the engagement partner for the
20x1 audit. Subsequently, the audit report for the 20x0 audit was reissued
and dual-dated for a subsequent events note. A Form AP filing is required
for the reissuance of the 20x0 audit report. The new Form AP continues to
show the engagement partner for the 20x0 audit (Partner ID 9865400013)
as the engagement partner
20
and shows the other partner (Partner ID
9865400025) as the engagement partner for the dual-dated content.
21
Even if the engagement partner who left has been assigned a new Partner
ID by a different firm, the Form AP for the 20x0 audit report reflects the
Partner ID at the time he or she served as engagement partner on the
20x0 audit of F Company and there is no need for the firm reissuing the
audit report to obtain and report the new Partner ID that was subsequently
assigned to the partner by the different firm.
III. Other Accounting Firm Disclosure on Form AP
A. General Requirements
Form AP requires information to be reported if one or more "other accounting
firms" participated in the audit. Sections III.D and E below discuss the information
required to be disclosed. "Other accounting firm" means—
a. A registered public accounting firm other than the firm filing Form
AP, or
b. Any other person or entity that opines on the compliance of any
entity's financial statements with an applicable financial reporting
framework.
22
An other accounting firm participated in the audit if—
19
See Items 3.1.a.6 and 3.1.e of Form AP.
20
See Item 3.1.a.6 of Form AP.
21
See Item 3.1.d-e of Form AP.
22
See General Instruction 2 of Form AP.
Staff Guidance
June 28, 2016
Page 9
a. The principal auditor assumes responsibility for the work and report
of the other accounting firm as described in paragraphs .03-.05 of
AS 1205 (currently AU sec. 543), Part of the Audit Performed by
Other Independent Auditors, or
b. The other accounting firm or any of its principals or professional
employees was subject to supervision under AS 1201 (currently
Auditing Standard No. 10), Supervision of the Audit Engagement.
23
Alternatively, where the firm divides responsibility for the audit with another public
accounting firm in accordance with AS 1205 and makes reference to another public
accounting firm in the auditor's report, Form AP requires certain information to be
disclosed regarding the other accounting firm's audit.
24
Disclosure of other accounting firms is required irrespective of the other
accounting firm's affiliation with the firm filing Form AP. Accordingly, other accounting
firms include affiliated firms, such as firms in a global network, and nonaffiliated firms.
Example—Affiliated Firms: ABC Audit Firm US is the principal auditor of
Company G. Company G has operations in the United States, France,
Germany, and Italy. ABC Audit Firm US assumes responsibility for work
performed by its affiliated firms in France, Germany, and Italy on
Company G's subsidiaries in these jurisdictions. ABC Audit Firm France,
ABC Audit Firm Germany, and ABC Audit Firm Italy are other accounting
firms that participated in the audit of Company G. ABC Audit Firm US
would disclose the extent of participation of these other accounting firms
as required in Part IV of Form AP.
B. Exclusions from Disclosure and the Computation of Total Audit Hours
Exclusions from all requirements of Form AP. Excluded from Form AP's
disclosure requirements and computation of total audit hours in the most recent period's
audit are hours attributable to:
25
a. The engagement quality reviewer;
26
23
See Item 3.2 and Part IV of Form AP.
24
See Item 3.3 and Part V of Form AP.
25
See Part IV of Form AP.
26
See AS 1220 (currently Auditing Standard No. 7), Engagement Quality
Review.
Staff Guidance
June 28, 2016
Page 10
b. The person who performed the review pursuant to SEC Practice Section
("SECPS") 1000.45 Appendix K;
27
c. Specialists engaged, not employed, by the auditor;
28
d. An accounting firm performing the audit of the entities in which the issuer
has an investment that is accounted for using the equity method;
29
e. Internal auditors, other company personnel, or third parties working under
the direction of issuer management or the audit committee who provided
direct assistance in the audit of internal control over financial reporting;
30
and
f. Internal auditors who provided direct assistance in the audit of the
financial statements.
31
27
See SECPS Section 1000.45 Appendix K, SECPS Member Firms With
Foreign Associated Firms That Audit SEC Registrants. The Board adopted Appendix K
as part of its interim standards. See Rule 3400T(b), Interim Quality Control Standards;
SECPS Section 1000.08(n). Appendix K requires accounting firms associated with
international firms to seek the adoption of policies and procedures consistent with
certain objectives, including having policies and procedures for certain filings of SEC
registrants which are the clients of foreign associated firms to be reviewed by persons
knowledgeable in PCAOB standards.
28
AS 1210 (currently AU sec. 336), Using the Work of a Specialist,
describes a specialist as a person (or firm) possessing special skill or knowledge in a
particular field other than accounting or auditing. Examples of specialists include, but
are not limited to, actuaries, appraisers, engineers, environmental consultants, and
geologists. Income taxes and information technology are specialized areas of
accounting and auditing and, therefore, persons or firms possessing such skills are not
considered specialists. See AS 1210.01-.02.
29
See Financial Accounting Standards Board ("FASB") Accounting
Standards Codification ("ASC") Topic 323, Investments—Equity Method and Joint
Ventures.
30
See paragraph .17 of AS 2201 (currently Auditing Standard No. 5), An
Audit of Internal Control Over Financial Reporting That Is Integrated with An Audit of
Financial Statements.
31
See paragraph .27 of AS 2605, Consideration of the Internal Audit
Function (currently AU sec. 322, The Auditor's Consideration of the Internal Audit
Function in an Audit of Financial Statements).
Staff Guidance
June 28, 2016
Page 11
When the firm is determining which audit participants to disclose on Form AP,
these participants would not be identified on Form AP and their time is not included in
the computation of total audit hours.
C. Computation of Total Audit Hours, Using Estimated Audit Hours, and
Specific Scenarios
If other accounting firms participated in the audit, the firm filing Form AP is
required to compute the extent of participation of each other accounting firm in the most
recent period's audit as a percentage of total audit hours.
1. Elements of Total Audit Hours
32
Total audit hours in the current period's audit are comprised of hours attributable
to:
(1) The financial statement audit;
(2) Reviews pursuant to AS 4105, Reviews of Interim Financial
Information (currently AU sec. 722, Interim Financial Information)
for the fiscal year covered by the audit; and
(3) The audit of internal control over financial reporting pursuant to AS
2201 (currently Auditing Standard No. 5), An Audit of Internal
Control Over Financial Reporting That Is Integrated with An Audit of
Financial Statements.
In general, total audit hours will be comprised of the hours of the principal
auditor, other accounting firms participating in the audit with whom the principal auditor
does not divide responsibility for the audit, and nonaccounting firm participants that
assist the principal auditor or other accounting firms. Total audit hours exclude hours
incurred by certain persons and entities as discussed in Section III.B.
Hours of nonaccounting firm participants. Nonaccounting firms are entities that
participate in the audit that do not meet the definition of "other accounting firm" for
purposes of Form AP. Offshore service centers, tax consulting firms, or other types of
entities may be nonaccounting firms if they do not meet the definition of "other
accounting firm."
Nonaccounting firms are not identified on Form AP. However, the hours incurred
by nonaccounting firm participants in the audit should be included in the computation of
total audit hours and allocated among the principal auditor and the other accounting
32
See Part IV of Form AP.
Staff Guidance
June 28, 2016
Page 12
firms participating in the audit on the basis of which accounting firm commissioned and
directed the applicable work of the nonaccounting firm.
33
Example—Shared Service Center: A principal auditor located in the United
States and an affiliate of the principal auditor located in the United
Kingdom (a participating other accounting firm) use the same shared
service center, a nonaccounting firm. The principal auditor used the
shared service center to test the mathematical accuracy of issuer
prepared schedules, while the UK affiliate used the shared service center
to send accounts receivable confirmations for the audit of the UK
subsidiary. The shared service center is not identified on Form AP.
However, the shared service center's hours are included in the
computation of total audit hours. The hours incurred by the shared service
center to test the mathematical accuracy of issuer-prepared schedules are
allocated to the principal auditor. The hours incurred by the shared service
center to send accounts receivable confirmations are allocated to the UK
affiliate.
Hours related to the audit of an equity method investee. In some cases, the
issuer's financial statements include an investment accounted for using the equity
method.
34
The hours incurred by an accounting firm in auditing an entity in which the
issuer has such an investment are excluded from total audit hours. If, however, that
same accounting firm performed or participated in the audit of the issuer, the hours
incurred for the portion of its work not related to the audit of the equity method investee
would be included in total audit hours. Hours incurred by the principal auditor to audit
the issuer's application of the equity method are also included in total audit hours.
Documentation. The firm filing Form AP should document in its files the
computation of total audit hours on a basis consistent with AS 1215 (currently Auditing
Standard No. 3), Audit Documentation.
35
Under AS 1215, the audit documentation
should be in sufficient detail to enable an experienced auditor, having no previous
connection with the engagement, to understand the computation of total audit hours and
the method used to estimate hours when actual hours were unavailable.
33
See Id.
34
See FASB ASC Topic 323, Investments—Equity Method and Joint
Ventures.
35
See Part IV of Form AP.
Staff Guidance
June 28, 2016
Page 13
2. Using Estimated Audit Hours
Actual audit hours should be used if available. If actual audit hours are
unavailable, the firm may use a reasonable method to estimate the components of this
calculation. For example, a firm may know all the audit hours (based on its timekeeping
system) for the audit up until the last month before Form AP is required to be filed and
may estimate the remaining month's hours based on its experience from prior years on
this audit or experience on similar audits. The firm filing Form AP should document in its
files on a basis consistent with AS 1215 (currently Auditing Standard No. 3) the
computation of total audit hours and the method used to estimate hours when actual
audit hours are unavailable.
36
Other Accounting Firm Participants That Also Perform Statutory
a.
Audits
Other accounting firms that participate in audits of multinational issuers often
perform local statutory audits of subsidiaries in addition to participating in the issuer's
audit. The materiality threshold and legal requirements for the statutory audit may
necessitate a different level of work than would have been required for the issuer's
audit. In these cases, it may be difficult for the auditor to determine how much work
performed at the subsidiary relates solely to the participation in the issuer's audit. If
actual hours are unavailable, a reasonable method to estimate may be used.
The firm filing Form AP can develop reasonable methods that its engagement
teams may use when estimating audit hours. Reasonable methods could include,
among others:
Using 100% of actual hours incurred by other accounting firms during
the issuer's audit, without separating hours incurred for the statutory
audit; or
Estimating the hours incurred by other accounting firms to perform
work necessary for the issuer's audit, based on the audit procedures
required for the issuer's audit in relation to all procedures performed.
3. All Periods Presented Were Audited During a Single Audit Engagement
Sometimes multiple periods presented in the financial statements are audited
during a single audit engagement (for example, in an IPO or re-audit of multiple
periods). In these situations, total audit hours and hours of other accounting firms are
calculated for the single audit engagement. The firm would not separate the hours
36
See Id.
Staff Guidance
June 28, 2016
Page 14
related to the current year's audit from the hours related to audits of prior periods if they
were incurred in the same audit engagement, even if the information were available.
37
Example: Company H engages ABC Audit Firm US to audit its financial
statements for the three years ended December 31, 20x2 for inclusion in a
registration statement for an IPO. Since this is a single audit engagement,
total audit hours, and the extent of participation of the other accounting
firms, are calculated using the hours incurred for auditing all three periods.
ABC Audit Firm US would also identify that multiple periods were audited
during a single audit engagement and would specify the periods in a
single Form AP.
38
4. Dual-dated Audit Reports
Sometimes the firm filing Form AP reissues and dual-dates its audit report.
39
In
these situations, total audit hours and hours of other accounting firms are computed
through the latest audit report date. For example, if a previously-issued audit report is
reissued and dual-dated to refer to the addition of a subsequent events note in the
financial statements, the firm filing Form AP would recalculate total audit hours and the
extent of participation of the other accounting firms as of the latest audit report date
based on the cumulative audit hours for the periods identified on Form AP.
40
D. Other Accounting Firms Individually Contributing 5% or More of Total Audit
Hours
For each other accounting firm that participated in the audit that individually
contributed 5% or more of total audit hours, the firm filing Form AP is required to report
the other accounting firm's:
37
The requirement to use the aggregate hours for multiple periods audited
during a single audit engagement for purposes of responding to Part IV of Form AP
should not be understood to mean that these periods should be considered one audit
for purposes of the auditor independence requirements under U.S. federal securities
laws and the rules and regulations of the SEC and the PCAOB, for example the
requirements for audit partner rotation in Rule 2-01(c)(6) of Regulation S-X.
38
See Items 3.1.b and 3.1.c of Form AP.
39
See Item 3.1.d of Form AP.
40
Actual audit hours should be used if available. If actual audit hours are
unavailable, the firm may use a reasonable method to estimate the components of this
calculation. See Items 3.1.a.4 and 3.1.e of Form AP.
Staff Guidance
June 28, 2016
Page 15
Legal name;
City and state (or, if outside the United States, city and country) of the
headquarters' office;
Firm ID, when applicable;
41
and
Percentage of total audit hours (which is required to be presented
consistently for all other accounting firms either as a specific percentage
or within the range of percentages listed in the form instructions).
42
1. Legal Name
The other accounting firm is required to be identified by its legal name (and not,
for example a "doing business as" name). As the other accounting firm may perform
audit procedures for more than one principal auditor, using the firm's legal name
ensures consistency in how the other firm's name is reported on Form AP.
Example—"Doing Business As" Name. Gold Accountants Limited, doing
business as ABC Audit Firm Gold contributed 5% or more of the total audit
hours in an issuer audit under arrangements pursuant to either AS 1205 or
AS 1201. The principal auditor's Form AP is required to reflect the legal
name, Gold Accountants Limited, rather than the "doing business as"
name.
2. Headquarters' Office
The city and state (or, if outside the United States, city and country) of the
headquarters' office of the other accounting firm is reported on Form AP, even if the
other firm performs work on the audit in a different city, state, or country.
Example—Work Performed in a City Other Than the Headquarters' Office
Location. Multiple offices of GHI Audit Firm US, headquartered in New
York, New York, participated in the audit of an issuer, including the Dallas,
Texas; Chicago, Illinois; and Los Angeles, California offices. The firm filing
Form AP would aggregate all hours incurred by the offices of GHI Audit
Firm US and, if GHI Audit Firm US contributed 5% or more of total audit
hours, would report New York, New York as the location of GHI Audit Firm
US.
41
See Section III.D.3., Firm ID, Other Accounting Firm Without a Publicly
Available Firm ID.
42
See Part IV of Form AP.
Staff Guidance
June 28, 2016
Page 16
Example—Work Performed in Another Country. An other accounting firm
headquartered in London, United Kingdom performs audit procedures in
Tel Aviv, Israel for the audit of an issuer, contributing 5% or more of the
total audit hours. The firm filing Form AP is required to disclose London,
United Kingdom and not Tel Aviv, Israel as the location of the other firm's
headquarters' office on Form AP.
3. Firm ID
Publicly Available Firm ID. The Firm ID is a five-digit unique identifier based on
the number assigned to the firm by the PCAOB when it requests access to the
PCAOB's web-based Registration, Annual, and Special Reporting system ("RASR" or
"web-based system"). The Firm ID becomes publicly available when registration with
the PCAOB is approved by the Board. The Firm ID remains publicly available (and must
be reported) thereafter, even if the firm's PCAOB registration is later withdrawn or
revoked. This number can be found by viewing the other accounting firm's summary
page on the PCAOB website. It is generally displayed next to the name of the firm—firm
name (XXXXX). For identifiers with fewer than five digits, leading zeroes should be
added before the number to make five digits when completing Form AP, e.g., 99 should
be presented as 00099. When completing information about other accounting firms that
meet the 5% threshold, the firm filing Form AP must report the Firm IDs of the other
accounting firms that have a publicly available Firm ID.
43
Other Accounting Firm Without a Publicly Available Firm ID. When an other
accounting firm does not have a publicly available Firm ID, the firm filing Form AP
indicates this by checking a box in Item 4.1 on Form AP.
E. Other Accounting Firms Individually Contributing Less Than 5% of Total
Audit Hours
For other accounting firms that participated in the audit
44
that individually
contributed less than 5% of total audit hours, Form AP requires disclosure of:
45
The total number of other accounting firms that individually contributed
less than 5% of total audit hours, and
43
See Item 4.1.b of Form AP.
44
See Section III.A, General Requirements.
45
See Item 4.2 of Form AP.
Staff Guidance
June 28, 2016
Page 17
The percentage of total audit hours that all such firms contributed,
expressed as either a specific percentage or within the range of
percentages listed in the form instructions.
Example: Eight other accounting firms individually contribute 3% of total
audit hours (collectively 24% of total audit hours) to the audit of an issuer.
The firm filing Form AP would aggregate all hours incurred by these firms
and disclose that eight other accounting firms that individually contributed
less than 5% of total audit hours collectively contributed 24% of total audit
hours (if disclosing using ranges, 20% to-less-than 30% of total audit
hours).
F. Responsibility for the Audit is Divided
When the firm filing Form AP divides responsibility for the audit with another
public accounting firm and makes reference to another public accounting firm in the
audit report, Form AP requires the firm to identify the referred-to auditor and state the
magnitude of the portion of the financial statements audited by the referred-to auditor.
46
The magnitude disclosed on Form AP should be the same as the magnitude required to
be disclosed in the audit report under applicable PCAOB standards.
47
The referred-to
auditor must be disclosed regardless of the percentage of its participation in the audit—
i.e., the 5% threshold from Part IV of Form AP does not apply to Part V of Form AP. The
firm filing Form AP should not include hours of the referred-to auditor in its computation
of total audit hours for Part IV.
In addition, Form AP requires disclosure of the referred-to auditor's:
48
Legal name;
City and state (or, if outside the United States, city and country) of the
office of the other public accounting firm that issued the other audit report;
and
Firm ID, when applicable.
46
See Item 3.3 and Item 5.1 of Form AP.
47
AS 1205.07 (currently AU sec. 543.07) provides that the magnitude of the
portion of the financial statements audited by the referred-to auditor should be stated as
the dollar amounts or percentages of one or more of the following: total assets, total
revenues, or other appropriate criteria, whichever most clearly reveals the portion of the
financial statements audited by the other auditor.
48
See Item 5.1 of Form AP.
Staff Guidance
June 28, 2016
Page 18
Example: ABC Audit Firm divided responsibility for the audit of Company
Y with XYZ Audit Firm (Firm ID 99875). XYZ Audit Firm is headquartered
in Los Angeles, California, while the New York, New York office of the firm
issued the audit report referred to by ABC Audit Firm. On Form AP, ABC
Audit Firm must report in Item 5.1 of Form AP XYZ Audit Firm (the legal
name of the referred-to auditor), XYZ Audit Firm's Firm ID, New York, New
York (the city and state of the office of the referred-to auditor that issued
the other audit report), and the magnitude of the financial statements
audited by XYZ Audit Firm.
IV. Voluntary Disclosure in the Audit Report under AS 3101
In addition to filing Form AP, the auditor may also include in the audit report
information regarding the engagement partner and/or other accounting firms
participating in the audit that is required to be disclosed on Form AP.
49
The auditor is
permitted to include information about the engagement partner, information about the
other accounting firms, or both. If the auditor includes information about the other
accounting firms in the audit report, all other accounting firms required to be disclosed
on Form AP must be included.
If the auditor decides to provide information about the engagement partner, other
accounting firms participating in the audit, or both, the auditor must disclose:
50
a. Engagement partner—the engagement partner's full name as required
on Form AP; or
b. Other accounting firms participating in the audit—
i. A statement that the auditor is responsible for the audits or audit
procedures performed by the other public accounting firms and
has supervised or performed procedures to assume
responsibility for their work in accordance with PCAOB
standards;
ii. Other accounting firms individually contributing 5% or more of
total audit hours—for each firm, (1) the firm's legal name, (2) the
city and state (or, if outside the United States, city and country)
49
See paragraph .09A of AS 3101, Reports on Audited Financial
Statements. Disclosure concerning other accounting firms is also required in the audit
report under AS 1205.07 when the auditor divides responsibility with a referred-to
auditor.
50
See AS 3101.09A.
Staff Guidance
June 28, 2016
Page 19
of the headquarters' office, and (3) percentage of total audit
hours as a single number or within an appropriate range, as is
required to be reported on Form AP; and
iii. Other accounting firms individually contributing less than 5% of
total audit hours—(1) the number of other accounting firms
individually representing less than 5% of total audit hours and
(2) the aggregate percentage of total audit hours of such firms
as a single number or within an appropriate range, as is
required to be reported on Form AP.
Voluntary disclosure in the audit report need not include Partner ID and Firm ID,
which are available on Form AP. The language the auditor uses in the audit report to
voluntarily disclose information about the engagement partner and other accounting
firms participating in the audit is required to be consistent with PCAOB standards. In
particular, any language that could be viewed as disclaiming, qualifying, restricting, or
minimizing the auditor's responsibility for the audit or the audit opinion on the financial
statements and, if applicable, internal control over financial reporting is not appropriate
and may not be used.
51
V. Illustrative Example
A. Background
ABC Audit Firm US located in the United States is the firm signing the audit
report for Company Z. John James Smith (Partner ID 9987600224) is the engagement
partner. Company Z has operations in the United States, France, Germany, Italy, and
China. ABC Audit Firm US uses work performed by its affiliates in France, Germany,
Italy, and China. These affiliates also perform statutory audits of Company Z's
subsidiaries in these jurisdictions. ABC Audit Firm US did not make reference to another
public accounting firm in its audit report. Because time is not tracked separately by the
French or German affiliates for work on the issuer audit as distinguished from work on
the statutory audits, the actual number of audit hours incurred related to Company Z's
audit is not known for these firms.
Also involved in the audit was an engagement quality reviewer, a specialist
engaged by ABC Audit Firm US, and a shared service center in India that assisted the
US and Chinese firms. The chart below summarizes the audit hours of all participants
involved in the audit.
51
See Section V for an example of voluntary disclosure in an audit report
under AS 3101.
Staff Guidance
June 28, 2016
Page 20
Audit Participants and Audit Hours
Audit Participant
Firm ID (if
applicable)
Audit Hours
Incurred
Hours Attributed to
Company Z's Audit
ABC Audit Firm US 99876 2,500 2,500
ABC Audit Firm France 97654 1,200 unknown
ABC Audit Firm China Not registered 800 250
ABC Audit Firm Italy 98012 500 125
ABC Audit Firm Germany 99125 500 unknown
Shared Service Center n/a 500 500
Engagement Quality Reviewer n/a 80 80
Specialist Engaged by ABC Audit Firm US n/a 300 300
B. Computation of Total Audit Hours
Exclusions from total audit hours. Hours incurred by the engagement quality
reviewer and the engaged specialist are excluded (excludes 80 and 300 hours,
respectively).
Shared service center. Because the shared service center is not a registered
public accounting firm or a person or entity that opines on the compliance of any entity's
financial statements with an applicable financial reporting framework, it is not an "other
accounting firm," as defined in General Instruction 2 to Form AP. It is instead a
"nonaccounting firm participant" (that is, a person or entity other than the firm filing Form
AP or any other accounting firm that participates in the audit). The hours incurred by
nonaccounting firm participants in the audit are included in the calculation of total audit
hours and should be allocated among ABC Audit Firm US and ABC Audit Firm China on
the basis of those firms that commissioned and directed the applicable work of the
nonaccounting firm participant.
Hours incurred by the shared service center directly benefit the US and Chinese
firms and are allocated between both firms on that basis. The shared service center
tracked hours incurred associated with the work commissioned by the US and Chinese
firms separately and reported the actual hours.
52
Audit Participant
ABC Audit Firm
US
ABC Audit Firm
China
Hours Related to Company Z's Audit 2,500 250
Shared Service Center 350 150
Hours to Include in Total Audit Hours 2,850 400
Statutory audit hours. Audit hour calculations are based on actual audit hours
where available. Since actual audit hours incurred on Company Z's audit are known for
52
If actual hours of the nonaccounting firm participant were unavailable,
ABC Audit Firm US could have estimated audit hours.
Staff Guidance
June 28, 2016
Page 21
ABC Audit Firm China and ABC Audit Firm Italy, these hours should be used in the
computation.
Actual audit hours incurred on Company Z's audit are unknown for ABC Audit
Firm US's affiliates in France and Germany. ABC Audit Firm US could include 100% of
the hours incurred by the affiliates in France and Germany or use a reasonable method
to estimate the hours incurred by those affiliates related to Company Z's audit. Based
on its review of the French and German affiliates' estimates of the time required to
perform the procedures assigned to them as part of Company Z's audit in relation to
other work performed on the statutory audits and the method used to make those
estimates, ABC Audit Firm US estimates that approximately 45% and 15% of their total
time incurred, respectively, is attributable to Company Z's audit.
53
Audit Participant
Audit Hours
Incurred
Approximate
Percentage of Work
Related to Company
Z's Audit
Hours to Include in
Total Audit Hours
ABC Audit Firm France 1,200 45% 540
ABC Audit Firm Germany 500 15% 75
Total audit hours and extent of participation. The table below shows the
calculation of total audit hours and the extent of participation.
54
Audit Participant
Audit Hours
Incurred
Extent of
Participation
ABC Audit Firm US 2,850 71.4%
ABC Audit Firm France 540 13.5%
ABC Audit Firm China 400 10.0%
ABC Audit Firm Italy 125 3.2%
ABC Audit Firm Germany 75 1.9%
Total Audit Hours 3,990 100%
53
ABC Audit Firm US should document in its files the method used to
estimate hours for the French and German affiliates and the computation of total audit
hours on a basis consistent with AS 1215.
54
If the firm chose a different method of estimation or used 100% of audit
hours where actual audit hours incurred on Company Z's audit are unknown in
performing the computation, the extent of participation would have varied from that
computed above.
Staff Guidance
June 28, 2016
Page 22
C. Disclosure on Form AP
1. Engagement Partner
ITEM 3.1—AUDIT REPORT
a. Provide the following information concerning the issuer for which the Firm issued the audit report –
6. The name (that is, first and last name, all middle names and suffix, if any) of the engagement partner on the most
recent period's audit, his/her Partner ID, and any other Partner IDs by which he/she has been identified on a Form AP
filed by a different registered public accounting firm or on a Form AP filed by the Firm at the time when it had a
different Firm ID
Family name (last name) Given name (first name) Middle name Suffix
Smith John James
Partner ID
9987600224
Previously reported Partner ID(s)
Not applicable
2. Other Accounting Firms
ABC Audit Firm US assumed responsibility for the work and reports of its
affiliates in France, Germany, Italy, and China. The French and Chinese affiliates each
individually contributed more than 5% of total audit hours and are individually disclosed
on Form AP. The Chinese firm does not have a publicly available Firm ID, while the
French firm does. The Italian and German affiliates each individually contributed less
than 5% to the audit and are aggregated for disclosure on Form AP. If ABC Audit Firm
US elects to disclose using ranges rather than single numbers, the disclosure on Form
AP would be as follows:
Firm ID 97654
Check here if no
Firm ID is available
% or range 10% to less than 20%
Legal name
Headquarters' Office Location
Country France
City Paris State
Percentage participation
ABC Audit Firm France
ITEM 4.1—
OTHER ACCOUNTING FIRM(S)
INDIVIDUALLY 5% OR GREATER OF TOTAL
AUDIT
HOURS
Firm ID
Check here if no
Firm ID is available
% or range 10% to less than 20%
Legal name
Headquarters' Office Location
Country China
City Beijing State
Percentage participation
ABC Audit Firm China
X
Staff Guidance
June 28, 2016
Page 23
2
Aggregate percentage of participation % or range 5% to less than 10%
ITEM 4.2—
OTHER ACCOUNTING FIRM(S)
INDIVIDUALLY LESS THAN 5% OF TOTAL
AUDIT
HOURS
a. State the number of other accounting firm(s) individually representing less than 5% of total audit hours.
b. Indicate the aggregate percentage of participation of the other accounting firm(s) that individually represented less than 5% of total
audit hours by filling in a single number or by selecting the appropriate range:
D. Disclosure in the Audit Report
ABC Audit Firm US also voluntarily disclosed the information about the
engagement partner and other accounting firms in the audit report, as follows:
VI. Mechanics of Reporting Through the PCAOB System
A. Filing Form AP
Firms must file Form AP through the PCAOB's existing web-based system using
the username and password they were issued in connection with the registration
process.
55
Since Form AP, like other PCAOB reporting forms, is filed by the accounting
55
Registered firms may email [email protected] for assistance
with login information. Firms that are already registered with the Board should not
The engagement partner on our audit for the year ended December 31,
20X2, was John James Smith. In this audit, the other accounting firms
listed below performed audits or audit procedures. We are responsible for
the audits and audit procedures performed by these other accounting firms
and, accordingly, supervised or performed procedures to assume
responsibility for their work in accordance with PCAOB standards. The
portion of the total audit hours attributable to audits and audit procedures
performed by these firms in our audit was:
Other Accounting Firms Individually 10% to less-than-20%:
ABC Audit Firm France (Paris, France)
ABC Audit Firm China (Beijing, China)
Other Accounting Firms Individually less than 5%:
Two other firms, whose individual extent of participation was
less than 5% of the total audit hours, participated in the audit.
Their aggregate extent of participation was within the range
of 5% to less-than-10%.
Staff Guidance
June 28, 2016
Page 24
firm, usernames and passwords will not be issued for individual engagement partners to
log into the system and submit the form. To properly communicate with the web-based
system, the firm will need Internet Explorer 8.0 or later. To complete Form AP, the firm
may fill it out online as a web form or submit it using XML, which is a computer
language. Form AP is deemed to be filed on the date that the firm submits a Form AP in
the web-based system in accordance with Rule 3211 that includes the certification in
Part VI of that form.
1. Filing Using a Web Form
When submitting Form AP using a web form, the firm must complete one Form
AP for each issuer audit report issued. The firm logs into RASR and selects the Form
AP web form option. The firm will complete the form using the web interface. The
Board's system allows the firm to view its Form AP as a PDF prior to final submission.
The firm can then submit another Form AP for a different audit report following the same
process.
2. Filing in Batches Using the XML Schema
If the firm has multiple Form APs to file simultaneously, the firm may find that
XML is a more convenient way to submit the forms because the firm would be able to
load the data for multiple Form APs into an XML file directly or indirectly from other
databases. If the firm would like to make its submission in XML, it must download the
XML Schema from the PCAOB's website. Using XML will likely require the assistance of
a programmer who is versed in that computer language. Additional information on using
the XML Schema is available on the PCAOB’s website.
3. Signing Form AP Filings (Part VI of Form AP)
The firm is required to certify and electronically sign all Form AP submissions, by
typing the name of the authorized signer in the signature block (either on the web form
or when using XML). A manual signature is not required to be retained for Form AP
submissions.
4. Firm ID on Form AP
When completing Form AP using the web form, the firm will populate the Firm ID
of the other accounting firm, if available, and Form AP will automatically complete the
name of the other accounting firm and its headquarters' office location using information
on file with the PCAOB. When responsibility for the audit is divided, the firm will
request a new user name and password through the Board’s website—this functionality
is for firms seeking to register with the Board and is not appropriate for registered firms
needing login assistance.
Staff Guidance
June 28, 2016
Page 25
populate the Firm ID and the city and state (or, if outside the United States, city and
country) of the office of the referred-to auditor that issued the other audit report. Form
AP will automatically complete the name of the referred-to auditor. If the firm is filing
Form AP via XML, a machine-readable list of accounting firms with publicly available
Firm IDs will be available for the firm to complete its submission file.
B. Process for Amending a Form AP Filing
If Form AP was originally filed using a web form, it can be amended using the
web form. If Form AP was originally filed using XML, it can be amended using the web
form or using an XML file.
1. Amending a Form Initially Filed Using a Web Form
To amend the form using a web form, the firm will log into RASR and navigate to
the form that needs to be amended and select "amend." The firm will identify in Item 2.1
the fields to be amended and the form will allow updating of only these items and Part
VI, Certification. After updating the form and completing Part VI, the firm will be able to
preview the form and file the amended Form AP.
2. Amending a Form Initially Filed via XML
When Form APs have been filed using XML, the firm has the option of amending
using a web form or XML. If XML is used, the firm will identify all forms to be amended
simultaneously. After selecting these forms, the firm will download a new XML file that
includes the original submission from RASR. The firm will update the fields in the
downloaded XML file that require amending. After this process has been completed, the
firm will submit the updated XML file using a process similar to the original XML
submission.
VII. Phased Effectiveness and Transition Guidance
Rule 3211 and the amendments to PCAOB auditing standards are effective for:
• Engagement partner: audit reports issued on or after January 31, 2017
• Other accounting firms: audit reports issued on or after June 30, 2017.
Form AP submissions will not be accepted until January 31, 2017. Also, Form AP
has been programmed not to accept information pertaining to other accounting firms
(Parts IV and V of Form AP) for audit reports issued before June 30, 2017. When
completing Form APs to disclose the name of an engagement partner prior to the
effective date for required disclosures for other accounting firms, Items 3.2 and 3.3 and
their corresponding form parts—Parts IV and V—will not be available until June 30,
2017.
Staff Guidance
June 28, 2016
Page 26
Issuer audit reports issued before effectiveness of the new reporting
requirements and reissued and dual-dated after effectiveness will require a Form AP
filing in connection with the reissued report. For example, an audit report first issued
before January 31, 2017, the effective date for engagement partner disclosure, would
not trigger a Form AP filing, but if that audit report were reissued and dual-dated on or
after January 31, 2017, a Form AP filing would be required.
The amendments to PCAOB auditing standards allowing for voluntary disclosure
in the audit report are effective as noted above. Voluntary disclosure of the name of the
engagement partner is not prohibited under current standards and may also be made
under the amended standards on or after January 31, 2017, while voluntary disclosures
about other accounting firms may occur on or after June 30, 2017.
VIII. Contact Information
Questions pertaining to Rule 3211 and Form AP may be directed to the staff in
the PCAOB's Office of the Chief Auditor via the standards' help line at (202) 591-4395
or may be submitted through a web form.
56
Questions pertaining to system requirements or the PCAOB's web-based system
may be directed to the PCAOB’s registration staff via the registration staff’s help line at
(202) 207-9329 or via email at re[email protected].
56
Web form is available at http://pcaobus.org/About
/Pages/ContactUsWebForm.aspx?Contact=Standard-related%20Inquiries.
