Additional Comments of the American Accounting Association Auditing Section Auditing Standards Committee on the PCAOB’s Amendments to PCAOB Auditing Standards Related to a Company’s Noncompliance with Laws and Regulations and Other Related Amendments

SUMMARY In June 2023, the Public Company Accounting Oversight Board (the Board or PCAOB) issued a request for comment on its Amendments to PCAOB Auditing Standards Related to a Company’s Noncompliance with Laws and Regulations and Other Related Amendments (“NOCLAR”; PCAOB 2023a). On February 26, 2024, the PCAOB (2024) reopened the comment period for additional feedback, in conjunction with a March 2024 public roundtable about the proposal. This commentary summarizes the participating committee members’ views on the proposal that are incremental to our original comments provided previously (Boland et al. 2024). Due to ongoing fundamental concerns, as well as new evidence of extraordinarily different interpretations of the proposed standard, our lack of support for the proposal remains unchanged. We strongly encourage the PCAOB to issue a revised proposal for public comment before any final standard is issued or to consider other alternatives.