The AICPA’s Professional Ethics Executive Committee (PEEC) on March 16, 2026, issued an exposure draft (ED) proposing revisions to the definition of “attest engagement team” in the Code of Professional Conduct to clarify its alignment with other AICPA professional standards.
This follows a decision made by the PEEC during a meeting on February 18 to release the proposal for public comment, according to the meeting agenda.
The ED would revise ET Section 0.400.05 in the code. If adopted, the revised definition would apply to CPAs in public practice.
The proposed new definition of attest engagement team is:
- Those individuals participating in the attest engagement, including those who perform concurring and engagement quality reviews.
- The attest engagement team includes all employees and contractors retained by the firm who participate in the attest engagement, regardless of their functional classification (for example, audit, tax, or management consulting services).
- The attest engagement team excludes internal auditors, auditor’s external specialists, practitioner’s external specialists, referred-to auditors, and referred-to practitioners. These roles are described in AICPA professional standards applicable to the attest engagement.
- The attest engagement team also excludes individuals who perform only routine clerical functions, such as word processing and photocopying.
Generic Term ‘Specialists’ Replaced
In particular, under the proposal, the term “specialists” would be replaced with more precise language. “PEEC is proposing that the phrase ‘auditor’s external specialists and practitioner’s external specialists’ replace ‘specialists’ in the definition” because the generic term “specialists” fails to make it clear that this reference in the code is for external specialists only.
According to the explanation section, the committee reviewed how “engagement team” is described in other AICPA standards, including AU-C Section 620, Using the Work of an Auditor’s Specialist; AU-C Section 610, Using the Work of Internal Auditors; AU-C Section 600, Special Considerations — Audits of Group Financial Statements (Including the Work of Component Auditors and Audits of Referred-to Auditors; and AT-C Section 105, Concepts Common to All Attestation Engagements. And the PEEC determined that the code’s existing definition of attest engagement team should be clarified to identify which individuals should be excluded from the attest engagement team.
“This clarity will reflect how the AICPA code’s definition of attest engagement team aligns with the term’s use in other AICPA professional standards,” the ED states. “The revisions in this exposure draft aim to achieve this clarity but do not change the intended application of the current definition.”
Other Proposed Revisions
The committee is also proposing to remove the reference AU-C Section 620 from the definition to make it clear that an external specialist used in any attest engagement is excluded from the code’s definition of attest engagement team.
The ED also says the proposal would explicitly exclude internal auditors from the definition of attest engagement team.
Further, the proposal says AU-C Section 600 and AT-C Section 105 distinguish between individuals who are part of the engagement team and those who are not.
“To clarify these points, PEEC is proposing to revise the definition of attest engagement team to explicitly exclude referred-to auditors and referred-to practitioners,” the document says.
At the same time, the committee said it does not plan to enumerate every possible role that may be included in an attest engagement team.
For example, the ED does not propose to include “component auditor” or “participating practitioner” in the definition of attest engagement team
“This is because such roles are considered to be ‘individuals participating in the attest engagement’ as stated in the existing definition of attest engagement team,” the ED says.
Comments are due by June 1.
The committee recommends that the revised definition, if approved, be effective for any attest engagements beginning on or after December 15, 2026. Early implementation would be permitted.
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