The Public Company Accounting Oversight Board has updated its staff guidance for auditing firms filing the new Form AP, in which firms are now required to disclose the names of engagement partners and other accounting firms that participated in audits.

The updated staff guidance explains how firms should treat professional staff involved in “secondment arrangements,” that is, when an employee is assigned on a temporary basis to work for another firm.

For purposes of reporting on Form AP, a secondment arrangement is one in which an employee of an accounting firm in one country is physically located in another country, in the offices of another firm, for at least three consecutive months, performing audit procedures for entities in the other country (and not performing more than a minimal amount of audit procedures during the term of the arrangement with entities in the country of his or her employer).

For purposes of determining participation in the audit and calculating audit hours, the PCAOB said employees in a secondment arrangement should be treated as if they were employed by the accounting firm to which they are seconded.

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Photo: PCAOB

The latest version of the staff guidance replaces a document that was issued in late January. The PCAOB noted that its staff may update the guidance further as needed.

Michael Cohn

Michael Cohn, editor-in-chief of, has been covering business and technology for a variety of publications since 1985.