Back in April, I blogged about the PCAOB’s request for public comment seeking input regarding the PCAOB’s strategic priorities. The Council of Institutional Investors (CII) recently submitted a comment letter in response to this request, expressing varying levels of support for the strategic priorities outlined in the PCAOB’s request. For example, on the topic of how the PCAOB should consider deploying technology, including AI, to help further its investor-protection mission, CII notes:

CII continues to strongly support as a strategic objective of the Board the ongoing evaluation of developments in technology, including AI, and the consideration of the need for guidance, changes to PCAOB standards, or other action in light of the increased use of technology by registered audit firms and financial statement preparers and in furtherance of the Board’s investor protection mission.

We generally share the following view expressed by IAG Member Jen Sisson, CEO of the International Corporate Governance Network, in connection with the April 2026 IAG meeting discussion of the agenda item on “Artificial Intelligence”:

“AI means ‘the mechanics of how audits get done are going to change,’ . . . and the PCAOB needs to think about what it needs to do differently to respond.”

In addition, CII generally believes, consistent with our policy on Audit Committee Responsibilities Regarding Independent Auditors, that the PCAOB could also help further its investor protection mission by deploying technology, including AI, to make more accessible the public information they currently maintain about registered auditing firms. In that regard, we generally support the views of the Members of the IAG in their comment letter in response to this question:

“[W]e propose that the Board consider using AI to create an “answer-bot” or an AI search function so that investors and members of the public might be able to query the public database of inspection reports and other valuable information the PCAOB already possesses. AI has reached the point now where it can access and analyze structured and unstructured data. It also can embed necessary confidentiality restrictions. This use of AI could free up PCAOB staff time in responding to requests and trying to figure out what investors and the public want. In addition, it could unleash the power of crowds to identify interesting and impactful questions.”

– Dave Lynn