Several proposals from the Securities and Exchange Commission (SEC) as well as new leadership changes at the Public Company Accounting Oversight Board (PCAOB) could meaningfully reshape audit committee oversight and financial reporting standards in the years ahead. I recently led a board briefing hosted by the CBM Network alongside Tony Anderson, Audit Committee Chair at Marsh and former Vice Chair and Midwest Area Managing Partner of Ernst & Young, to unpack three developments every audit committee should have on its radar.
1. The Semiannual vs. Quarterly Reporting Discussion
The SEC’s proposal to permit semiannual reporting aims to encourage more companies to enter the public markets by easing reporting burdens. During the conversation, Anderson noted that companies would have flexibility to determine what reporting cadence makes sense for their individual circumstances based on the needs of stakeholders.
The proposal has generated extensive feedback, including comment letters from the Audit Committee Council (ACC), an independent advisory council to the CAQ, and the CAQ. Both letters emphasized the choice to elect semiannual reporting rests with management, guided by input from investors, boards of directors and audit committees. Further, financial information provided to the investing public—such as an earnings release furnished on Form 8-K—must be reliable.
In other comment letters, stakeholders expressed concern that, if companies have the option, investors will receive less transparency and insight to help make investment decisions. Supporters argue that semiannual reporting would improve the quality of corporate decision-making and cost effectiveness.
There are plenty of questions for audit committees to consider as the proposal moves forward:
- How is your company thinking about its interim financial information reporting cadence?
- Would semiannual reporting be the right choice if the proposal is adopted?
- What do your investors expect and what are the implications to items including: Financial information provided in the off quarters? Debt covenants? Quarterly control processes? Internal and external audit plans? Committee operations?
The CAQ is closely monitoring this proposal and whether it will be adopted as proposed by the SEC.
2. Filer Status Changes and the 404(b) Question
Another SEC proposal would raise the public float threshold for large accelerated filer status from $700 million to $2 billion. Other public companies would be categorized as non-accelerated filers and would not be required to obtain an auditor attestation on internal control over financial reporting under Section 404(b). Anderson described his perspective, saying 404(b) has led to better quality internal controls since its implementation.
Under the new proposal, 19 percent of public companies would be large accelerated filers, while accounting for approximately 93.5 percent of total public float. The remaining 81 percent of companies would generally be exempt from the auditor attestation requirement for internal control over financial reporting. The SEC sees this proposal as encouragement for more companies to go public, but Anderson warned that the five-year requirement to become a large accelerated filer could be too lengthy for large companies.
Audit committees and other stakeholders who have a view on the ramp provision or the threshold changes more broadly are encouraged to submit comments before the period closes on July 20.
3. The PCAOB’s New Direction
The PCAOB appointed four board members in 2026, including its new Chairman Demetrios (Jim) Logothetis, former EY audit partner, who is focused on evolving the PCAOB to support the capital markets. In response to the PCAOB’s request for comment on its strategic priorities, the ACC recommends prioritization in three key areas:
- Strengthen the PCAOB inspections program to prioritize improvements to the focus, consistency and timeliness of inspections;
- Promote regulatory efficiency and durable standards that deliver clear benefits relative to their costs and are applied consistently across firms; and
- Prioritize initiatives with the greatest impact rather than an overly expansive agenda.
The PCAOB has also posted a request for public comment on its standard-setting agenda, with comments due August 7. This provides audit committees with an opportunity to share their perspectives on the areas that warrant the Board’s attention. As regulatory proposals and standards continue to emerge, we will monitor how changes impact the role of the audit committee in effectively overseeing financial reporting that supports trust in U.S. capital markets.


