2024 Enforcement Activity Involving Auditors

A recent report from The Brattle Group analyzes enforcement activity against auditors by the Public Company Accounting Oversight Board and the US Securities Exchange Commission in 2024. Data from 2024 is compared to 2022 and 2023 – the first two years of PCAOB Chair Erica Williams and SEC Chair Gary Gensler’s administrations – and to 2018–2021 activity, a proxy for the regulators’ prior administrations.

“2024 Enforcement Activity Involving Auditors: SEC & PCAOB Enforcement Actions Brought Against Public Accounting Firms and Individuals” was authored by Principal Alison Forman and Associate Adam Karageorge and is a follow-up to their “2023 Enforcement Involving Auditors” and “Enforcement Activity Involving Auditors – 2024 Mid-Year Update” reports.

Notable findings from the report include:

• Together, the PCAOB and SEC brought 58 enforcement actions against auditors in 2024, in line with 2023 (60) and 2022 (59) levels but more than 50% higher than the average number of initiated actions during the regulators’ prior administrations (2018–2021).
• Though aggregate enforcement activity remained elevated in 2024, the SEC only initiated seven actions against auditors in 2024, down 50% from 2023, undoubtedly due to the Supreme Court’s June SEC vs. Jarkesy ruling that the SEC’s use of administrative proceedings to seek financial civil penalties in a securities fraud suit was unconstitutional.
• Together, the PCAOB and SEC imposed $52.2 million in monetary sanctions against auditors in 2024, an increase of 66% from 2023 and 2.5 times higher than the 2018–2021 average.
• 2024 enforcement was driven primarily by the PCAOB, which brought 88% of total actions and imposed 68% of total penalties.

The report also includes predictions about changes to the auditor enforcement landscape in and after 2025 due to constitutional challenges faced by both regulators and the impact of Trump’s second presidency.

View Report

View Press Release