- Regulator
- Public Company Accounting Oversight Board (PCAOB)
- Date filed
- Filed by
- Auditchain Labs AG
- Release number
- 2026-001
- Comment letter number
- 19
Summary
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.