PCAOB Revokes Registrations of 97 Delinquent Audit Firms

The Public Company Accounting Oversight Board announced on Friday, November 6, 2026, that it had sent delinquency notices to 97 registered audit firms and is moving to revoke their registrations, the first use of a rule adopted in 2024.

The PCAOB audit meaning of the action is narrower than the headline count suggests. This is a clean-up of the public register, not a disciplinary case, and it targets firms that stopped filing and paying rather than firms accused of poor audits.

For finance teams, audit committees and accounting firm partners, the register is the list used to check whether an auditor is entitled to work on a public company. A shorter, accurate list means less checking of firms that no longer exist. It does not change who can audit an issuer today.

The board has not yet withdrawn any of the registrations, a spokesperson said. The notices start a clock, and the withdrawals come only if the firms stay silent.

What the PCAOB did and which rule it used

The PCAOB issued a Notice of Delinquency and Impending Withdrawal to each of the 97 firms under PCAOB Rule 2107(h), titled “Constructive Withdrawal Requests.” The board adopted the rule in November 2024, and the Securities and Exchange Commission approved it in January 2025.

The rule lets the board treat repeated non-filing and non-payment as a request by the firm to leave the register. It sits within the board’s registration rules, which implement the registration requirement for public accounting firms in the Sarbanes-Oxley Act of 2002. The SEC filing for the proposed rule sets out the mechanics.

The rule took effect for annual reports and annual fees that fell due in 2025. A firm that filed no annual report and paid no annual fee in both 2025 and 2026 can be treated as having asked to withdraw, which is why this autumn is the first point at which the board could act.

PCAOB chairman Demetrios (Jim) Logothetis framed the move as a matter of record keeping.

“This action provides investors and other market participants with a more accurate picture of the audit firms that remain active in the public company audit space.”

Demetrios (Jim) Logothetis, Chair, PCAOB

PCAOB audit meaning of the 60-day notice period

Each firm’s primary contact has 60 days to email the board’s registration staff and say the firm wants to stay registered. If the contact does nothing, the board may then deem the registration withdrawn.

If the notices are dated November 6, the 60 days run out in early January 2027. The announcement does not say whether every notice went out on the same day, so firm-by-firm dates may differ.

The design puts the burden on the firm. A live practice that missed its filings can remain registered by sending one email, though the rule does not waive the underlying reports and fees. A firm whose sole proprietor has died, or whose contact address no longer works, will not reply.

That is the PCAOB audit meaning of “constructive” withdrawal: silence after notice is read as consent to leave. The board does not need the firm’s agreement, only its failure to respond.

Why delinquent firms stayed on the register

Before the rule, the board had few tools to remove a firm that simply went quiet. It typically revokes registrations one at a time, often as part of sanctions for misconduct. In recent years most of those sanctions have fallen on foreign firms, especially in China and Hong Kong, and some on US firms.

When the board proposed the rule, then-chair Erica Williams said that as of August 31, 2024, 80 registered firms had filed no annual report and paid no annual fee for either the 2022 or 2023 reporting year. The PCAOB’s statement on the adoption sits on its website.

Williams described the group as including sole proprietorships that remain registered even though the sole proprietor has died, firms registered years ago that now appear to be defunct, and small firms, often in foreign countries, that cannot be reached through their designated contact. She said the number of consistently noncompliant firms rose every year.

Her stated concern was the quality of the public list. Missing filings mean the board cannot publish Form 2 information for every registered firm. They also add work for audit committees and investors choosing an auditor, and for PCAOB staff chasing firms that may not respond.

The count has moved from 80 in 2024 to 97 notices now. The two figures are not directly comparable, because the 2024 number covered a two-year window and an earlier snapshot, while the 2026 notices follow the rule’s own test. They do show the group has grown.

What the data does not yet show

The announcement does not break down the 97 firms by location. The board’s description of the problem, with sole proprietors who have died and small foreign practices that cannot be reached, points to a mix of US and overseas firms. The split has not been published.

Nor does the announcement say how many of the firms had issuer or broker-dealer audit clients. A firm that had not filed or paid for two years is unlikely to be an active auditor of public companies, but the board has not given a figure, and none is stated here.

That matters for the PCAOB audit meaning of this action. Nothing in the announcement alleges misconduct, and it names no firm for a violation. The board has not described any of the 97 as the subject of an inspection finding or an enforcement case.

Registration is also separate from permission to practise. Removal from the register ends a firm’s ability to audit issuers and broker-dealers under PCAOB rules. A firm that wants back on would register again.

What the clean-up means for firms and finance teams

Practices that are registered with the PCAOB should check that their annual report and annual fee are current, and that the primary contact on file is a person who reads that inbox. A firm that is active but missed two cycles is exactly the kind the notice process is meant to catch, and it has 60 days to answer.

Companies and audit committees should treat the register as more reliable once the withdrawals take effect. Verifying an auditor’s registration status remains part of appointing a firm, and a cleaner list shortens that check. The register is only one input, and the board’s inspection reports and enforcement orders tell a reader far more about audit quality.

The PCAOB audit meaning here is separate from the board’s disciplinary work. Compare the sanctions regulators apply to large firms, such as the Financial Reporting Council’s fine of more than £6 million on Deloitte over Go-Ahead audits, with what happens here: no penalty, no finding and no hearing. Firms that lose registration through Rule 2107(h) are leaving because they went inactive.

The same discipline applies inside a firm. Annual filings, fee payments and named contacts are the kind of routine obligations a firm tracks in an internal controls register, and this episode shows what happens when one lapses unnoticed for two years.

The PCAOB has not said whether it will publish the list of 97 firms or report how many replied. Larger US networks such as Forvis Mazars, which reported $2.32 billion in US revenue for fiscal 2026, are not the intended target of the rule.

The next date to watch is the end of the 60-day window in early January 2027, when the board can begin deeming registrations withdrawn. The register’s count will then show how many of the 97 chose to stay.