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With the end of Q3 approaching our guide can help you streamline meeting prep, prioritize agenda items, and plan for the future.
On July 4, President Trump signed the One Big Beautiful Bill Act (“Act”). The new tax law includes a broad range of provisions affecting businesses, including extending and modifying certain key Tax Cuts & Jobs Act (TCJA) provisions (both domestic and international), expanding certain Inflation Reduction Act incentives while accelerating the phase-out of others, and modifying the endowment excise tax for higher education institutions.
The Act is likely to have financial reporting implications for most companies with US operations. However, given the timing of enactment (after the June 30 period-end date) and the variety of effective dates for key provisions, only certain of those financial reporting implications will affect current-year financial statements.
Under US GAAP, changes in tax law are accounted for in the period of enactment. For US federal purposes, the enactment date for US GAAP is the date the president signs the bill into law. All tax effects of a change in tax law on existing current or deferred tax balances, including changes in valuation allowances, are recorded discretely as a component of the income tax provision related to continuing operations in the period of enactment.
US federal tax reform may also have state and local tax effects. Companies will need to evaluate how a state conforms to the US tax code to determine the state tax effect and relevant tax accounting.
This document is not intended to be a comprehensive summary of all corporate tax provisions included in the new tax legislation. Refer to this Tax insight from PwC’s tax specialists on the final legislation. Also, monitor our US Tax services page to stay up to date on the latest developments and PwC’s insights.
The compliance and strategic implications of the new tax law cannot be underestimated. Audit committee members should understand how new tax laws translate into financial accounting and reporting requirements. Certain provisions were extended or modified, and several of the provisions being modified are retroactive to an earlier date in 2025. Significant provisions of the new tax law include:
Given the significance and complexity of the new tax law, audit committees should consider how best to engage with management to assess the company’s preparedness. Companies may have increased compliance obligations, and the audit committee will want to confirm management is prepared to account for the impacts of changes appropriately.
California sustainability regulations
While California’s climate disclosure laws (referred to as Senate Bills 253 and 261) remain in litigation, the deadlines for reporting are approaching. SB 253 reporting on scope 1 and scope 2 greenhouse gas (GHG) emissions begins in 2026 on 2025 information and on scope 3 emissions in 2027 on 2026 information. SB 261 requires posting a climate-related financial risk report to the company’s website by January 1, 2026. As a reminder, SB 253 applies to US entities with annual revenue over $1 billion that do business in California. SB 261 applies to US entities with annual revenue over $500 million that do business in California.
The California Air Resources Board (CARB) is the state agency tasked with implementing and enforcing SB 253 and enforcing SB 261. Currently, CARB is focused on public outreach and held a public workshop on August 21 to advance rulemaking. Draft regulations addressing both SB 253 and SB 261 are expected to be released October 17 for a 45-day comment period, with the final proposed regulations to be presented to the Board in mid-December. CARB has also proposed that the initial GHG report on prior year scope 1 and scope 2 GHG emissions be due by June 30, 2026.
European Commission provides new relief to entities currently reporting under the EU requirements
On July 11, the European Commission adopted the “quick fix” delegated act which provides transition relief to entities currently reporting under the Corporate Sustainability Reporting Directive (CSRD). The delegated act extends the year 1 transition relief in European Sustainability Reporting Standards (ESRS) to 2026 and 2027 to these “wave 1” reporters.
Revised European Sustainability Reporting Standards (ESRS) published
On July 31, EFRAG published exposure drafts requesting comments on revised ESRS. The revised ESRS is one component of the European Commission’s February 2025 “Omnibus” package intended to simplify EU reporting rules related to the European Green Deal. The proposed revisions are intended to reduce the burden of sustainability reporting by reducing the number of mandatory datapoints, clarifying unclear provisions, simplifying the structure and presentation of the standards, and enhancing interoperability with global reporting standards. The exposure drafts are open for public comment until September 29.
While there remain significant domestic and international developments for sustainability-related reporting requirements, impacted companies (particularly multinationals) should continue monitoring developments and gearing up for potential disclosures. California climate laws may trigger the first mandatory sustainability reporting requirements for many — if not most — of the entities in their scope. Entities potentially in scope of the California laws should start to prepare for their reporting obligations now. More broadly, companies subject to sustainability reporting requirements should be developing processes and controls and having technology in place to produce quality reporting. Understanding management’s processes and controls relating to the scope and quality of disclosures is an important aspect of the audit committee’s oversight role.
Today, the risk landscape is anything but static. Companies are navigating a VUCA world — characterized by Volatility, Uncertainty, Complexity and Ambiguity. From disruptive technologies like generative AI to shifting geopolitical alliances, cybersecurity threats, supply chain instability and regulatory overhauls, the nature and velocity of risks are changing rapidly. Companies must be nimble and responsive to constant change. Key challenges and negative outcomes of operating in a VUCA world can include:
The audit committee plays a vital role in overseeing risks that affect financial reporting, internal control, compliance and operational integrity. In a VUCA world, understanding the company’s risk management process, including enterprise risk management (ERM), is among the audit committee’s most important responsibilities. In the current environment, the audit committee will want to gain a deep understanding of the company’s risk landscape to be prepared to oversee risks that may be right around the corner.
The audit committee must engage deeply with management on how its ERM anticipates, prepares for and responds to a broad set of risks. This means asking whether the company’s ERM framework is dynamic, forward-looking and decision-useful; confirming alignment with strategic risks; and verifying that financial implications are accurately reported and disclosed.
Cybersecurity and data privacy remain top-of-mind risks for many companies. Cybersecurity is no longer just an IT issue — it’s a business resilience and financial reporting issue. A cyber incident can have immediate and material implications for financial results, internal controls and investor confidence. Moreover, the SEC’s 2023 rulemaking on cybersecurity governance underscores the expectation that companies be prepared to disclose a material cybersecurity incident.
Regulatory scrutiny is also intensifying globally, with new privacy laws being enacted and existing frameworks, such as the EU’s General Data Protection Regulation (GDPR) and state-level regulations in the US, being enforced. Further, given the increasing use of artificial intelligence and third-party technology providers, companies must confirm they are assessing risks associated with emerging technology, vendor ecosystems and supply chain vulnerabilities. These developments make now the right time for audit committees to step back and evaluate how well the company’s strategy, controls and disclosures position it to address rapidly evolving cyber and privacy risks.
From an oversight standpoint, audit committees with cybersecurity oversight responsibility should be sure their fall agendas include an update from management on the company’s overall cybersecurity strategy, recent threat intelligence, the status of key controls and testing, and any refinements to incident response plans. Equally important is understanding how lessons from recent high-profile breaches across industries may be learning points.
For audit committees, there are three dimensions of relevance:
Audit committees that treat cybersecurity as a standing agenda item — and go beyond technical updates to probe governance, accountability, evolving threats and culture — are better positioned to fulfill their oversight responsibilities and support enterprise resilience.
The regulatory compliance landscape continues to shift rapidly — both in scope and complexity. Companies are facing heightened expectations from US regulators, new international mandates (e.g., EU Corporate Sustainability Reporting Directive) and a growing push for corporate accountability on topics ranging from climate disclosures to anti-corruption to cybersecurity. The ability to monitor changes and comply with rules represents the minimum threshold for companies to build trust and operate in a global market that increasingly expects transparency and the highest standards from its leaders and employees.
Importantly, enforcement trends show that regulators are not just interested in whether companies have compliance programs; they want to know whether those programs are effective, risk-based and responsive to changing expectations. Compliance programs are increasingly tied to financial reporting, operational risk and reputational impact and are being scrutinized more closely by external auditors, investors and other stakeholders.
Source: PwC, Global Compliance Survey 2025.
While regulatory compliance oversight may be shared with other committees (e.g., risk), the audit committee plays a vital role in confirming that the compliance function supports reliable reporting, internal control effectiveness and ERM. Areas of potential renewed scrutiny for the audit committee include:
As regulatory requirements become more interconnected with financial and nonfinancial disclosures, audit committees should ask probing questions and maintain a clear line of sight into the compliance infrastructure. As Q3 ends, audit committees should confirm they are receiving meaningful updates on regulatory changes, understanding how compliance obligations may affect the financial statements and assessing the governance of the compliance function.
As companies enter the final stretch of 2025, audit committees should be sharpening their focus on the year-end audit. This is the time to confirm the status of the external auditor’s plan; that the committee understands any significant risks identified to date; and that management, internal audit, and the external audit team are aligned on timing and deliverables.
But effective oversight goes beyond reviewing plans and progress. An important, and sometimes overlooked, responsibility is confirming the audit committee assesses the quality of the external audit team — not just the lead engagement partner and director. Year-end audits often rely on managers and other staff who are closest to the work, and their skills, judgment and integrity are critical to audit quality. Audit committees that create opportunities to meet and evaluate these team members are better positioned to confirm the “right team” is in place.
Practical steps might include asking the audit partner to introduce key team members during meetings, requesting updates directly from managers, or inviting audit staff to share their perspectives on audit risks or challenges. These interactions provide valuable insight into whether the team has the right mix of experience, depth of industry knowledge, and commitment to independence and quality.
Audit committees play a vital role in audit quality, and that role extends beyond reviewing the audit plan or discussing issues with the partner. Audit quality depends heavily on the engagement team assigned. While the engagement partner sets the tone, the day-to-day execution often rests with other members of the team. Creating intentional opportunities to engage with the broader external audit team provides the committee with richer insight, helps validate that the “right team” is in place, and ultimately enhances the integrity and effectiveness of the audit process.
In today’s environment, skills and experience matter more than ever, and building a strong working relationship with the external audit team is imperative. Among other things, the audit committee will want to confirm the audit team understands the industry, leverages technology effectively, has the capacity to meet the engagement timeline, and importantly, exhibits the behavior and professionalism that reinforces trust in their independence and integrity. Regular interaction with team members beyond the partner and director becomes imperative.
As companies navigate continued geopolitical volatility, cyber threats, climate-driven disruptions and increasing regulatory scrutiny, among others, crisis preparedness and business continuity have moved to the forefront of management priorities and boardroom agendas. The events of the past year — including ransomware attacks, geopolitical events, extreme weather and supply chain interruptions — underscore the reality that crises are no longer rare “black swan” events. They are an expected part of doing business.
Business continuity planning is no longer just about IT recovery or emergency evacuation procedures. It now encompasses sustaining operations across all critical business processes — finance, operations, supply chain, data infrastructure and third- party services — during and after disruptive events.
When it comes to crisis management and business continuity, several areas under the audit committee’s responsibility are directly or indirectly impacted. Audit committees play a vital role in overseeing risk management, financial reporting integrity and internal control systems — all of which can be put under pressure during a crisis.
Potential implications of a crisis on areas under the audit committee’s responsibility could include:
Now may be a good time for audit committees to refamiliarize themselves with management’s crisis response plan, especially as it relates to implications for the areas under its oversight responsibility.
Strong processes and controls are the foundation of reliable operations, accurate financial reporting and regulatory compliance. They may not only safeguard assets but also drive efficiency and consistency across an organization. When well designed, processes help systems work together seamlessly, minimize errors and manage risks proactively.
Recently, several developments have made the spotlight on processes and controls even sharper:
In this environment, companies that regularly refresh their understanding of how processes operate — and whether controls are still effective — are better positioned to avoid surprises, reduce inefficiencies and maintain stakeholder trust.
For audit committees, processes and controls directly underpin the committee’s ability to oversee the integrity of financial reporting and compliance. Confirming that the control environment is robust and effective is at the core of the committee’s mandate.
Heading toward year end, this becomes particularly relevant. Weaknesses in processes — such as excessive manual journal entries, delayed reconciliations or reliance on nonintegrated systems — may escalate into control deficiencies, reporting errors or audit challenges. Audit committees benefit from understanding how management evaluates and reports on processes, rather than relying solely on end results.
By updating your understanding now, the audit committee can identify where systems may not be keeping pace with the business, assess the quality of management’s reporting on processes and controls, and determine whether the committee is comfortable with the way different systems interact to produce reliable information. Probing these areas signals to management that the committee expects rigor not only in compliance but also in operational efficiency and transparency.
As Q3 2025 draws to a close, companies should be preparing for new guidance coming from two significant accounting standards: (1) income tax disclosures and (2) crypto asset accounting and disclosures. Both represent a shift toward greater transparency, and both require careful coordination across tax, finance, technology and governance functions to support readiness.
Income tax disclosures
Effective for fiscal years beginning after December 15, 2024 (and interim periods within those years), companies need to provide clearer insight into the geographic distribution of taxes and drivers of their effective tax rate.
For year-end reporting, additional annual disclosures will be required, including:
For interim reporting periods, companies must present enhanced effective tax rate reconciliations and some interim jurisdictional data.
Crypto assets
Effective for fiscal years beginning after December 15, 2024 (including interim periods), the standard requires companies to measure certain crypto assets at fair value with changes reflected in net income.
For year-end reporting, annual disclosures expand to include:
For interim reporting periods, companies disclose fair value measurements and changes in net income plus certain qualitative information about holdings and restrictions.
As part of its financial reporting oversight, the audit committee will want to understand how management is considering the potential impacts of the new standards and disclosures. This would include understanding whether there are underlying systems and processes in place to report disaggregated information completely and accurately. Additionally, the audit committee will want to understand management’s overall crypto strategy, the business and financial reporting risks, and management’s plan for monitoring, measuring and mitigating those risks.
Every audit committee meeting agenda should include these important items or, at least, they should be discussed at scheduled intervals:
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