Association of International Certified Professional Accountants–AICPA

With the Public Company Accounting Oversight Board (PCAOB) responsible for inspections of registered firms auditing issuers and Securities and Exchange Commission-registered brokers and dealers, the role of the American Institute of Certified Public Accountants (AICPA) is to maintain and develop the quality assurance review system for firms performing nonissuer engagements. The AICPA continues to operate its peer review program through authorized administering entities and maintains standards and oversight arrangements for the performance and reporting of peer reviews.

Since the previous assessment, the AICPA has updated its peer review framework to align with the new quality management standards. In November 2024, the Peer Review Board approved Peer Review Standards Update No. 2, and the quality management-related revisions are effective for peer reviews with years ending on or after December 31, 2025. The AICPA has also issued implementation support for firms and reviewers, including quality management resources, peer review considerations, pilot checklists, articles, and other guidance to help firms establish and operate their systems of quality management.

Recent jurisdiction-level developments also affect fulfillment. For audits within the PCAOB remit, QC 1000, A Firm’s System of Quality Control was approved by the Securities and Exchange Commission in 2024, but its effective date was deferred to December 15, 2026. As a result, the public company audit segment is still transitioning to the new quality control framework, while the AICPA has continued to support firms in the nonissuer segment through implementation and peer review alignment activities.

The AICPA has demonstrated an ongoing process to maintain its fulfillment of SMO 1 through operation of the peer review program, continuous revision of peer review standards, and substantial implementation support for members and firms in connection with the new quality management standards. Sustain.

Current Status: Sustain

Initial professional development and continuing professional development requirements in the United States continue to be established primarily by the state boards of accountancy, while the American Institute of Certified Public Accountants (AICPA) supports implementation through the Uniform CPA Examination, member requirements, curriculum resources, and continuing education guidance. Since the previous assessment, the most significant development has been the launch of the CPA Evolution licensure model and redesigned Uniform CPA Examination in January 2024, developed jointly by the AICPA and the National Association of State Boards of Accountancy (NASBA) to reflect changing competency needs for newly licensed Certified Public Accountants.

The AICPA has continued to support implementation through updated examination blueprints, candidate and academic resources, and the CPA Evolution-aligned model curriculum. It also continues to maintain member continuing professional development requirements of 120 hours over a three-year period, while providing extensive continuing education offerings and implementation materials to support competency development in practice.

Although jurisdiction-level requirements still vary across state boards of accountancy, the AICPA continues to play a central and active role in supporting education, licensure readiness, and professional development across the profession. Its ongoing activities demonstrate continued fulfillment of its responsibilities under SMO 2.

Current Status: Sustain

The American Institute of Certified Public Accountants (AICPA) continues to fulfill its responsibilities under SMO 3 through the Auditing Standards Board (ASB), which issues auditing, attestation, and quality management standards for nonissuer engagements and maintains an ongoing process to consider and incorporate new and revised International Standards on Auditing (ISA) into U.S. standards. The ASB continues to publish its strategy, work plan, and current projects, demonstrating an active and continuing standard-setting role.

Since the previous assessment, the AICPA has continued to support implementation through audit and assurance resources, practice guidance, continuing professional education, and regular technical updates for practitioners, including ongoing audit and accounting update webcasts and implementation materials related to new auditing and quality management standards. The AICPA also maintains dedicated resource pages for audit, assurance, and quality management to support firms and practitioners in applying revised requirements.

Recent jurisdiction-level developments affecting fulfillment include the Public Company Accounting Oversight Board (PCAOB)’s adoption of QC 1000, A Firm’s System of Quality Control, which was subsequently postponed and is now effective on December 15, 2026. While this development applies to the public company audit segment rather than the AICPA’s direct standard-setting remit, it underscores the continuing evolution of the U.S. audit framework and the importance of coordination across regulatory segments.

Overall, the AICPA has demonstrated an ongoing process to maintain fulfillment of SMO 3 through active standard-setting, participation in convergence-related activities, and sustained implementation support for members and firms.

Current Status: Sustain

The American Institute of Certified Public Accountants (AICPA) continues to maintain and update the AICPA Code of Professional Conduct for its members through the Professional Ethics Executive Committee (PEEC) and related ethics standard-setting processes. Since the previous assessment, the AICPA has continued its convergence work by finalizing new and revised definitions related to public interest entities, issuing conforming ethics changes related to quality management in 2025, and progressing additional projects through exposure drafts and discussion papers, including tax services, simultaneous employment or association with an attest client, and alternative practice structures. These developments demonstrate ongoing implementation and review activity, but also confirm that convergence with the latest International Ethics Standards Board for Accountants (IESBA) Code remains in progress rather than complete.

The AICPA continues to support members through its ethics hotline, online ethics library, practice aids, toolkits, and regular PEEC meeting materials and updates. It also continues to participate in international ethics developments and to consider IESBA revisions as part of its standard-setting agenda. These activities reflect sustained support for implementation and ongoing monitoring of emerging ethics and independence issues.

Jurisdiction-level developments continue to affect fulfillment. Ethical requirements in the United States remain fragmented across state boards of accountancy, the AICPA, the Public Company Accounting Oversight Board, and the Securities and Exchange Commission. As a result, although the AICPA continues to make substantive progress in updating its code and supporting members, the jurisdiction has not yet achieved full alignment with the latest IESBA Code across the profession. Accordingly, the AICPA has demonstrated continued implementation and improvement, but the remaining convergence and jurisdiction-level consistency gaps support retaining the assessment at Review & Improve.

The AICPA is encouraged to continue its timely convergence work and outreach to state boards of accountancy so that remaining differences from the latest IESBA Code are reduced and broader jurisdiction-level alignment with SMO 4 can be achieved.

Current Status: Review & Improve

As the American Institute of Certified Public Accountants (AICPA) has no legal responsibility for adopting public sector accounting standards in the United States, its role remains focused on supporting high-quality public sector reporting and practice. The AICPA continues to provide technical resources, certificates, continuing professional education, conferences, and audit and accounting guidance for professionals working in federal, state, and local government environments. This includes dedicated government resource hubs and current training for state and local government audits and accounting issues.

Since the previous assessment, the AICPA has also continued broader public sector support activities, including work highlighting public sector workforce and audit capacity challenges and promoting tools and thought leadership relevant to government finance professionals. These activities demonstrate ongoing engagement with public sector financial reporting and auditing issues, even though the jurisdiction continues to apply domestic standards issued by the Federal Accounting Standards Advisory Board and the Governmental Accounting Standards Board rather than International Public Sector Accounting Standards (IPSAS).

Given the AICPA’s limited mandate in this area and its continued efforts to support members, raise awareness, and contribute to public sector capacity and reporting quality, it has demonstrated an ongoing process to maintain fulfillment of SMO 5.

Current Status: Sustain

The American Institute of Certified Public Accountants (AICPA) continues to maintain an established investigative and disciplinary framework for its members and to operate the Joint Ethics Enforcement Program (JEEP) in coordination with participating state societies and state boards of accountancy. The AICPA continues to publish disciplinary actions and maintain enforcement resources, including the JEEP Manual of Procedures, which it reports is aligned with SMO 6 requirements.

Since the previous assessment, the AICPA has continued to apply JEEP procedures in practice and coordinate enforcement actions with participating state bodies, as reflected in recent published disciplinary outcomes. It also continues to support members through ethics guidance, professional resources, and ongoing benchmarking of its investigative and disciplinary procedures against SMO 6 best practices.

While investigative and disciplinary authority at the jurisdiction level remains distributed across state boards of accountancy and other regulatory bodies, the AICPA has demonstrated well-established ongoing processes to fulfill its responsibilities under SMO 6 and continues to maintain and improve its enforcement framework.

The AICPA is encouraged to continue working with the remaining non-participating jurisdictions to strengthen nationwide alignment with SMO 6 best practices.

Current Status: Sustain

The American Institute of Certified Public Accountants (AICPA) continues to support implementation and awareness of IFRS Accounting Standards despite having no legal responsibility for their adoption in the United States. The AICPA continues to provide IFRS-focused training, learning materials, and the IFRS Certificate Program, which remains available through its professional education platform. It also maintains broader accounting and financial reporting resources and continuing education offerings that support practitioners working in multinational and cross-border reporting environments.

Since the previous assessment, the AICPA has continued to support members through current learning offerings and broader technical programming relevant to international reporting developments. It also continues to engage in financial reporting advocacy and comment-letter activity on accounting matters through its accounting and financial reporting function.

Jurisdiction-level developments remain unchanged in substance. The IFRS Foundation’s jurisdictional profile, last updated on April 4, 2025, confirms that domestic issuers in the United States continue to apply U.S. Generally Accepted Accounting Principles, while foreign private issuers may use IFRS Accounting Standards as issued by the International Accounting Standards Board without reconciliation to U.S. GAAP. There remain no plans to require or permit IFRS for domestic listed companies.

Given the AICPA’s limited mandate in this area and its continued efforts to provide training, resources, and implementation support related to IFRS, it has demonstrated an ongoing process to maintain fulfillment of SMO 7.

Current Status: Sustain