# Comment on the 2026–2030 Strategic Plan

- Regulator: Public Company Accounting Oversight Board (PCAOB)
- Date filed: 2026-05-12
- Filed by: Auditchain Labs AG
- Release number: 2026-001
- Comment letter number: 19
- Filed submission: https://assets.pcaobus.org/pcaob-dev/docs/default-source/about/administration/strategic-plan-comments-2026/19_auditchain.pdf?sfvrsn=aeb35a16_2
- Article and analysis: https://auditchain.com/https-auditchain-com-pcaob-strategic-plan-comment-submission/
- Web page: https://auditchain.com/about/policy/pcaob-comment-2026-2030-strategic-plan/

Responding to the PCAOB's 2026–2030 strategic priorities, this letter advances the thesis that audit transformation enables oversight transformation, with machine-readable disclosure as the foundation. It proposes three strategic actions: harmonize with European standards by amending PCAOB AS 4101 to align auditor responsibilities for Inline XBRL / machine-readable filings with the CEAOB's ESEF guidelines, so auditors opine on the machine-readable layer rather than leaving quality issues to post-filing SEC staff review; commit to updating standards to support cryptographically enforced, straight-through audit trails from internal controls to public disclosures; and prepare for the new digital asset audit engagements created by the GENIUS Act — which already mandates PCAOB-registered firm examination of stablecoin reserve disclosures — and the pending CLARITY Act, including on-chain attestations, smart contracts, and tokenized assets.

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Part of [Auditchain Labs AG: regulatory policy submissions](https://auditchain.com/about/policy/)