Thursday Feb 2 2023
IIA Call to Action
Stop the PCAOB Attack on Internal Audit
▪ On December 22, 2022, the Public Company Accounting Oversight Board (PCAOB) published, for
public comment, a proposed auditing standard entitled: “The Auditor’s Use of Confirmation, and
Other Proposed Amendments to PCAOB Standards.”
▪ The proposed standard, in relevant part, bars external auditors from utilizing an internal audit
function to provide direct assistance in the confirmation process (selecting, sending and receiving
confirmations).
▪ The IIA encourages all chapter leaders and members to request their employer and/or board of
directors submit a public comment letter to the PCAOB supporting the internal audit profession and
opposing this change.
▪ If your employer is unable or unwilling to send a letter, we ask that you seek permission from your
employer to send a letter in your own capacity as an internal auditor.
▪ Such a letter is intended to provide objective support for the internal audit profession from relevant
stakeholders. The letter should focus, in part, on the following themes:
o General and/or specific examples of the contributions an internal audit function brings to an
organization
o Stress that internal auditors provide boards of directors and/or audit committees with
objective assurance that is independent from management
o Reiterate that internal auditors are required to comply with mandatory professional standards
and a code of ethics
o Highlight the fact that internal auditors and external auditors maintain the same reporting
relationship to an organization’s audit committee
o Call for the PCAOB to continue with its existing standard, AS 2605, which allows external
auditors to assess internal auditors for objectivity and competence and then decide whether
or not to seek the assistance of the internal audit function
▪ Stakeholders may also utilize the enclosed one-pager as an additional resource in developing
language refuting the PCAOB’s assertions. The document contains more information on the proposed
rule and outlines key characteristics of internal audit seemingly neglected by the PCAOB. Please do
not use the text verbatim. Rather, place the message in your own words.
▪ The IIA will host a virtual meeting with chapter leadership/members on February 9, 2023, at 3:00
PM EST to further review the process for obtaining an employer letter of support.
o If you are interested in participating in the IIA’s virtual meeting, please register your
attendance by clicking here.
▪ Public comment letters drafted in support of the internal audit profession must be submitted to the
PCAOB via the online rulemaking docket or by email at comments@pcaobus.org (referencing “PCAOB
Rulemaking Docket Matter No. 028). Public comments are due no later than February 20,
2023.
▪ Please also send a copy of any external PCAOB letters of
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