The Development of Auditing Standards at the PCAOB and Related Audit Practitioner Input

The Public Company Accounting Oversight Board (PCAOB; Board) maintains that constituent feedback plays an essential and dynamic role in its audit standard-setting process. We examine a major source of constituent feedback, responses to standard-setting questions, using a sample drawn from the original proposals of fourteen PCAOB auditing standards. We find that after receiving comment letter feedback to the standard-setting questions, the Board revises approximately half of its guidance tied to those questions before it finalizes auditing standards-a finding consistent with the Board's assertion that it carefully considers constituent perspectives as it develops new regulation. We also explore the related comment letters of eight professional auditing firms subject to the PCAOB's annual inspection program and discover varying levels of opposition to and support for the PCAOB's proposed authoritative guidance. We observe PCAOB revision to authoritative guidance highly contested by the firms in more than three-fourths of cases of standard-setting questions and PCAOB non-revision to guidance highly supported by the firms in more than ninety percent of cases.