Research

The Ledgerism PCAOB Enforcement Database: Every Disciplinary Order Catalogued by Firm, Sanction, and Penalty

By chrisomo

PCAOB enforcement data has never had a single canonical home, so this is one: a living database of every settled Public Company Accounting Oversight Board disciplinary order we can tie to a Release No., catalogued by firm, individual respondent, sanction type, civil penalty, standard violated, and the issuer audit at issue. The scope runs from 2010, when the PCAOB enforcement program reached maturity, through the most recent quarter. The source of record is the PCAOB enforcement docket at pcaobus.org, cross-checked against PCAOB news releases and annual reports. We refresh it quarterly, within 30 days of each quarter-end. It is built for citation.

Scope and methodology

This database is deliberately narrow in what it claims and broad in what it covers. Here is exactly what is in it and how it is built.

• What is included: every settled PCAOB disciplinary order we can verify, covering both firm respondents and individual respondents (owners, engagement partners, engagement quality reviewers, managers).
• Source of record: the PCAOB enforcement docket published at pcaobus.org/oversight/enforcement, in the Release No. format (for example, Release No. 105-2026-002). Every order is cross-checked against the corresponding PCAOB news release and, where penalty totals are stated, against PCAOB and third-party annual reviews.
• Period: 2010, the point at which the PCAOB enforcement program reached maturity, through the publication month above.
• Fields tracked: year, respondent (firm plus individuals), sanction type (registration revocation, bar, civil penalty, censure, practice limitation), penalty amount, standard or standards violated, the issuer or audit at issue, and the Release No.
• Update cadence: refreshed quarterly, within 30 days of quarter-end, as new settled orders post to the docket.
• Limitations: we catalogue settled orders only. Contested matters that go to PCAOB hearing or to the SEC on appeal are tracked separately and are not in these counts. Penalty amounts are stated as they appear in the order. Where a penalty is joint and several across respondents, we note it so the same dollars are not double-counted.
• One critical boundary: the PCAOB and the SEC are different enforcers with different authority. The PCAOB disciplines registered audit firms and their people under PCAOB standards and rules. The SEC bars accountants from practicing before the Commission under Rule 102(e). Some marquee matters that the press calls “PCAOB cases” are in fact SEC actions. We flag those explicitly rather than file them as PCAOB orders.
• Citation policy: this database is available for citation with attribution. See the “How to cite” section below.

A word on why this exists. PCAOB orders are public, but they are scattered: each settled matter lives as a separate PDF on the docket, indexed by Release No. rather than by firm, penalty, or standard, and the Board’s annual reports summarize totals without a row-level record an analyst can filter or cite. Audit committees, firm risk teams, plaintiffs’ counsel, and researchers all end up rebuilding the same spreadsheet. This database is that spreadsheet, maintained in public and tied back to the primary documents, so a citation points to something stable rather than to a press cycle.

For related Ledgerism trackers, see our research index, the 2026 Audit Firm Rotation Index, and our regulatory coverage hub.

The enforcement trend by year

Enforcement volume and total penalties move together loosely but not perfectly, because a single large firm order can swing the penalty total far more than the action count. The cleanest year-over-year series comes from Cornerstone Research’s PCAOB Year in Review reports, which count both total disclosed actions and the subset involving the performance of an audit. The figures below are PCAOB-only unless noted.

Source: Cornerstone Research, “PCAOB Enforcement Activity” Year in Review reports for 2021 through 2025 (the 2024 report published Feb. 26, 2025, authored by Jean-Philippe Poissant and Russell Molter; the 2025 report published March 4, 2026). Pre-2020 PCAOB-specific year counts are not reproduced here because we could not verify them against a primary-source breakdown; they are marked “reported, verify.”

Three forces explain the 2025 reversal. First, the combined picture. A separate report, The Brattle Group’s “2025 PCAOB and SEC Audit Enforcement Activity” (Alison Forman and Adam Karageorge, Feb. 26, 2026, covered by Thomson Reuters), counts SEC and PCAOB audit-enforcement together and finds 58 actions in 2024 falling to 39 in 2025, a 33% decrease, with total monetary sanctions down 66% from $52.2 million to $17.9 million. In that combined sample, the SEC brought only 2 audit-firm actions in 2025, leaving the PCAOB responsible for 37 of the 39.

Second, the budget. The SEC approved a 2026 PCAOB budget of $362.1 million, a 9.4% reduction of $37.6 million from the prior year, with the accounting support fee cut 18.4% to $306.0 million and board compensation cut by roughly half. Headcount falls to 817 by the end of 2026, down 47 from 864 at the end of 2025 (SEC Press Release 2026-11; Accounting Today, “SEC OKs slimmer budget and salaries for PCAOB”). Commentators have said the enforcement function specifically will feel the squeeze; a precise enforcement-division percentage is not stated in the public budget documents, so we mark the “15% enforcement cut” figure as reported, verify and rely on the confirmed top-line cuts.

Third, leadership. PCAOB Chair Erica Williams announced her resignation on July 15, 2025, effective July 22, with several outlets reporting it came at the request of SEC Chair Paul Atkins, a longtime PCAOB critic sworn in April 21, 2025. George Botic became acting chair on July 21, 2025. A House-passed provision in the May 2025 reconciliation bill would have transferred PCAOB functions to the SEC, but it was stripped under the Byrd Rule and the final bill signed July 4, 2025 left the PCAOB intact (Journal of Accountancy; CPA Practice Advisor; SEC statements).

The notable orders database

This is the centerpiece: the significant settled actions, each tied to a Release No. where one exists. Where a marquee matter is an SEC action rather than a PCAOB order, the “Release No.” column says so plainly, because mislabeling SEC actions as PCAOB orders is the single most common error in coverage of this beat. Penalty amounts are as stated in the order; joint-and-several penalties are noted.

Source for every PCAOB row: the PCAOB enforcement docket and corresponding news release at pcaobus.org. SEC-action rows are sourced to SEC press releases and administrative orders as cited. Rows marked “reported, verify” carry a confirmed Release No. or news release but an unconfirmed penalty figure or sanction detail pending order-PDF review in the next quarterly refresh. For the most recent small-firm action, see our standalone analysis of the Zwick CPA / Genie Energy order.

What the data shows: enforcement patterns

Five patterns recur across the orders.

Documentation is the workhorse standard. AS 1215, Audit Documentation, appears in more settled orders than any other single standard. It is the requirement that workpapers be assembled within the prescribed window and support the basis for the auditor’s report. The reason it dominates is structural: when an inspection or investigation finds a deficient audit, the documentation failure is almost always provable on the face of the file, whereas a substantive judgment failure requires the Board to second-guess professional judgment. The Heaton, Raines & Fischer, Zwick, and Shama orders all lead with AS 1215. Close behind are AS 1220 (engagement quality review, which requires a concurring approval of issuance) and AS 1201 (supervision). ICFR audits under AS 2201 generate more inspection deficiencies than enforcement orders, a distinction worth keeping straight.

Small firms are over-represented relative to the issuers they audit. The recurring fact pattern is a small or sole-proprietor firm taking on public-company audits it is not resourced to perform, then failing the documentation, EQR, and supervision standards. Ciro Adams, Jack Shama, Heaton & Co., Adeptus Partners, Fruci & Associates, and Zwick CPA all fit this profile. The most aggravated version is fabrication: in the Zwick matter, the manager took the predecessor auditor’s workpapers, swapped in the firm name, updated the year, and added sign-offs (PCAOB Release No. 105-2026-001). The Borgers SEC matter is the same pattern at industrial scale.

The sanction-severity distribution is long-tailed. The typical order is a censure plus a modest penalty, often $25,000 to $75,000, sometimes with a suspension. Registration revocations and individual bars sit in the tail and are reserved for fabrication, repeated failures, or non-cooperation with investigators. Permanent bars, as in the Shama order, are rarer still.

Penalties inflated through 2024, then reversed. Total PCAOB penalties roughly doubled each year from ~$10.5 million in 2022 to $19.7 million in 2023 to a record $35.7 million in 2024 (Cornerstone Research). That run was driven by large firm QC and exam-integrity orders, above all the $25 million KPMG Netherlands fine, which alone was most of the 2024 total. The 2024 record represented close to 40% of all PCAOB penalties ever imposed in the program’s history. In 2025 audit-related penalties fell roughly in half to $17.6 million as both volume and leadership shifted.

The China cross-border saga shaped the docket. For years the PCAOB could not inspect or investigate mainland China and Hong Kong firms, which created delisting risk under the Holding Foreign Companies Accountable Act. On December 15, 2022, the Board announced it had secured complete access for the first time and vacated its prior HFCAA determinations. Enforcement followed: the November 30, 2023 batch fined PwC Hong Kong ($4M, Release No. 105-2023-043), PwC China ($3M, Release No. 105-2023-044), and Shandong Haoxin ($940K total, Release No. 105-2023-045). A common misconception is that the PCAOB penalized PwC over Evergrande. It did not. The Evergrande penalties came from Chinese regulators (the Ministry of Finance and CSRC fined PwC Zhong Tian roughly 441 million yuan, about US$62 million, in September 2024) and the Hong Kong AFRC (HK$300 million). The PCAOB’s China-firm orders concern exam answer-sharing and documentation, not the Evergrande audit.

Exam-integrity cases became the highest-penalty category. A distinct enforcement theme over 2022 through 2025 was answer-sharing on internal training and licensing exams. It is conduct that has nothing to do with any specific issuer audit, yet it produced the largest fines of the period because the Board treats firm-wide integrity failures as quality-control failures that taint the firm’s entire system. The $25 million KPMG Netherlands order (Release No. 105-2024-022), the December 2022 KPMG global-network sweep totaling $7.7 million, the $4 million PwC Hong Kong and $3 million PwC China orders (Release Nos. 105-2023-043 and 105-2023-044), and the $2.75 million PwC Israel order all fall in this category. Six of the ten largest PCAOB penalties in the ranking below stem from exam integrity rather than from a failed audit. That is a meaningful signal about where the Board has been willing to spend its largest fines.

Workpaper alteration before an inspection is the aggravating factor that draws the heaviest sanctions. The orders that combine revocation, bars, and the highest individual penalties almost always involve respondents who modified, backdated, or fabricated workpapers in anticipation of a PCAOB inspection or investigation, or who provided false information to investigators. The Deloitte Brazil order (Release No. 105-2016-031) involved partners directing junior staff to alter 2010 workpapers ahead of the 2012 inspection. The Raines & Fischer order (Release Nos. 105-2024-049 through -052) cited workpapers modified before inspection. The Shandong Haoxin order added false information to investigators on top of documentation failures. The Board’s pattern is consistent: a deficient audit draws a censure and a modest penalty, but obstruction draws revocation and bars.

The biggest penalties ever

This ranking is PCAOB civil penalties only. The two largest audit-firm penalties of the era, BF Borgers ($14M) and KPMG’s $50M, were SEC actions and are listed below the PCAOB table for context, not folded into the PCAOB ranking.

For context, larger SEC actions outside the PCAOB ranking: BF Borgers / Benjamin Borgers, $14 million (SEC Press Release 2024-51, May 3, 2024); KPMG LLP, $50 million for misusing stolen PCAOB inspection lists and internal exam cheating (SEC Press Release 2019-95, June 17, 2019). Source: PCAOB news releases and SEC press releases as cited.

How this compares to SEC accountant enforcement

The PCAOB and the SEC police overlapping but distinct ground. The PCAOB disciplines registered public accounting firms and their associated persons for violating PCAOB auditing standards, quality-control standards, and rules; its sanctions are censure, civil penalty, practice limitation, registration revocation, and individual bars from association with a registered firm. The SEC, under Rule 102(e) of its Rules of Practice, denies accountants the privilege of appearing or practicing before the Commission, and it can pursue civil penalties through administrative proceedings and federal court. The two often act on the same facts. In the KPMG inspection-leak matter the SEC took the $50 million penalty and the DOJ brought criminal charges, while the conduct also implicated PCAOB integrity rules. In the Borgers matter the SEC acted directly, which is why there is no PCAOB Release No. for it even though the underlying failures were failures to follow PCAOB standards.

Why it matters which body acts, for anyone citing this data. First, the dollar figures sit in different buckets: an SEC penalty does not appear in PCAOB annual penalty totals, so folding Borgers into a PCAOB chart overstates PCAOB enforcement by $14 million. Second, the sanctions differ in reach: a PCAOB bar removes a person from association with registered firms, while an SEC Rule 102(e) bar removes them from practicing before the Commission, and the two do not automatically follow each other. Third, the trend lines move for different reasons; the SEC’s accounting and auditing program rises and falls with each administration’s priorities, while the PCAOB’s tracks its inspection cycle and budget. The broader point for anyone reading the trend line: the 2024 to 2025 decline is a combined SEC-and-PCAOB phenomenon, with the SEC’s audit-firm actions falling to just 2 in 2025 and the PCAOB carrying 37 of the 39 combined actions (The Brattle Group, Feb. 26, 2026).

What we are tracking next

Four threads will drive the next several quarterly refreshes. First, the volume question: whether the 2026 budget cut to $362.1 million and the headcount reduction to 817 translate into fewer settled orders, as several commentators expect. Second, the standards mix: AS 1000, General Responsibilities of the Auditor, took effect for fiscal years beginning on or after December 15, 2024 and consolidates the former AS 1001, 1005, 1010, and 1015. Its companion change shortened the AS 1215 documentation-assembly window from 45 days toward 14 days, phasing in by firm size. Expect AS 1000 and the tighter assembly window to surface in 2026 and 2027 orders. Third, the China docket: whether 2026 brings further actions now that inspection access is established. Fourth, the leadership transition under acting chair George Botic and SEC Chair Paul Atkins, and whether a future reconciliation vehicle revives the proposal to fold PCAOB functions into the SEC. For firms preparing for the inspection cycle that feeds this docket, see our guides on how to prepare for a PCAOB inspection and AS 1215 audit documentation.

Methodology and limitations

The source of record is the PCAOB enforcement docket, in the Release No. 105 format, published at pcaobus.org. Each order is cross-checked against the matching PCAOB news release; penalty-year totals are corroborated against Cornerstone Research’s PCAOB Year in Review series and, for the combined SEC-and-PCAOB view, The Brattle Group’s annual audit-enforcement report. Penalty amounts are recorded exactly as stated in the order. Where a penalty is joint and several, we note it so the same dollars are not counted twice across respondents. We catalogue settled orders only; contested matters in PCAOB hearings or on SEC appeal are excluded from these counts and tracked separately. We do not estimate or impute penalties, and we mark any figure we cannot tie to a primary document as “reported, verify” until the order PDF is reviewed in the next refresh. SEC actions that the press sometimes calls PCAOB cases (BF Borgers, the KPMG inspection-leak matter) are labeled as SEC actions and excluded from PCAOB penalty rankings, because conflating the two is the most common error in this field. The database is refreshed quarterly within 30 days of quarter-end. Known gaps in the current version: pre-2020 annual action counts, the precise individual Release Nos. within the December 2022 KPMG-network sweep, and a small number of penalty figures pending order-PDF confirmation.

How to cite this database

Cite as: The Ledgerism Brief, “PCAOB Enforcement Database,” ledgerism.net/pcaob-enforcement-database/, as of June 2026. For bulk data, the full underlying spreadsheet, or a methodology question, contact research@ledgerism.net.