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2026 Q1 audit committee update

Complex global shifts demand stronger board and audit committee oversight.


In brief
  • Global conflict, trade policy shifts and economic volatility are forcing audit committees to reassess risk, capital allocation and financial judgments.
  • As AI scales across core operations, boards are sharpening oversight of governance, controls, cyber exposure and workforce impacts.
  • Rapid regulatory and policy change is increasing complexity in disclosures, tax planning and financial reporting assumptions.

Global conflicts, macroeconomic volatility, shifting trade and industrial policy, evolving regulation, and accelerating AI adoption are placing new pressure on capital allocation, operating models, internal controls and financial reporting judgments. While the Supreme Court’s recent decision on the Trump-era tariffs provided some legal clarity, uncertainty remains about the durability of the tariff changes, the potential for tariffs to return under other statutory authorities and how to treat tariffs that have already been collected.

Additionally, the war in Iran has elevated geopolitical risks, prompting companies to evaluate various business impacts such as supply chains, lead times, shipping routes, supply availability, possible revenue impacts and adjusting hedging strategies to prepare for multiple oil price scenarios. Companies are actively scrutinizing operations and evaluating possible tariff exposures, contingency planning and pricing discipline. Key areas of focus for audit committees include the governance and control impacts of scaling AI, increased cyber and data risks, workforce disruption tied to automation and policy change, and the financial reporting impacts of rapid regulatory and policy shifts in the US and globally.

 

This quarterly update provides key considerations for audit committees as they navigate these and other ongoing developments.

 

Risk management

 

Geopolitical uncertainty and uneven economic momentum are intensifying pressure on companies to adapt their business models more rapidly, with many accelerating adoption of AI to boost agility and competitiveness. As these forces increasingly converge, companies must strengthen integrated oversight of risk, strategy and financial planning to respond effectively. Below are the key risks, trends and considerations that boards and audit committees should prioritize for the upcoming quarter:

Macroeconomic volatility

Slowing growth, tariff driven inflation divergence, elevated global debt and shifting monetary policy paths are increasing pressure on liquidity, treasury management, forecasting accuracy and internal controls. According to the latest EY survey of CEOs, while approximately 90% of CEOs expect revenue, profitability and productivity growth in 2026, rising energy, labor and compliance costs — combined with reduced ability to pass through price increases — are putting pressure on margins. In response, CEOs are prioritizing operational optimization and productivity, with 43% citing digitalization as a top objective, alongside a renewed focus on customer engagement and retention to stabilize demand. Looking ahead, we anticipate organizations will continue to sharpen cost discipline through productivity enhancing investments such as AI and adopt more targeted, customer informed pricing strategies.

Supply chain shifts

As trade alliances and supply chains shift, companies are deciding where to pursue growth — and where to optimize flexibility and manage risk, often pulling back from some markets while doubling down on others. The recent conflicts in Iran have further caused disruptions and continue to fuel uncertainty around the macroeconomic impacts as well as impacts to the business (e.g., supply chain, shipping routes, energy and fuel costs). We anticipate organizations will be stress-testing both short- and long-term impacts stemming from the war in Iran. Additionally, aggressive use of reciprocal and sector-specific tariffs is accelerating supply chain redesign, localization and “friendshoring,” causing companies to carefully evaluate capital deployment, third party risk and margin resilience.

Artificial intelligence

AI is emerging as both a growth catalyst and a governance challenge. The vast majority of CEOs report that their AI initiatives have met or exceeded expectations. Many report that AI deployments have demonstrated solid economic fundamentals: automation of routine work, faster and more accurate forecasting, improved risk detection, and accelerated product development. Among leading companies, the focus is shifting from proliferating pilots to scaling proven use cases, prioritizing depth over breadth by embedding AI across critical value chains. Boards are increasingly focused on understanding how AI governance is evolving as well as oversight of AI related risks, including data governance, cyber resilience, regulatory compliance and talent disruption.

Cybersecurity

Cyber risk continues to escalate in scale and consequence. Heightened geopolitical tensions, expanding digitalization and broader AI adoption are increasing exposure to cyber incidents, operational disruption and intellectual property loss, elevating cyber resilience as a sustained audit committee priority.

Talent

Talent dynamics are evolving rapidly – boards are grappling with how automation, augmentation and new operating models will reshape jobs, skills and communities. In particular, we anticipate boards and audit committees will seek to understand how automation and AI adoption affect talent risks, cost structures and internal controls. As a result, boards and audit committees are increasingly embedding talent considerations into broader transformation and risk discussions. Leading companies will also be prioritizing workforce planning, reskilling and productivity enhancing investments as well as building in AI-related workforce scenarios directly into enterprise risk planning.

These rapid changes and risks continue to challenge and expand audit committee agendas. To be effective in this environment, strong audit committees are making continuous learning a key part of how the committee operates. Leading audit committees are building regular deep dives and training sessions into their rhythm, covering topics like cyber, AI, sustainability, regulatory and geopolitical change, and core business operations.

Accounting and disclosures

This quarter, audit committees are prioritizing how they navigate macroeconomic conditions and adapt to the shifting legislative and regulatory landscape. They are actively evaluating how ongoing economic uncertainty and changes in the business environment will impact financial reporting processes. Key financial reporting developments are outlined below:

Customs and Border Protection provides initial plan for tariff refunds

Customs and Border Protection (CBP) on 6 March 2026 outlined its plans to establish a system for tariff refunds in 45 days following an order by the Court of International Trade (CIT) on 4 March 2026 for CBP to progress with the tariff refund process. CBP said it would work on a streamlined system to process the refunds after noting it was operationally infeasible for the agency to manually process millions of individual refund requests. The CIT noted in its order that “all importers of record whose entries were subject to IEEPA duties are entitled to the benefit of” the Supreme Court’s 20 February 2026 ruling that tariffs imposed by President Donald Trump in April 2025 under the International Emergency Economic Powers Act (IEEPA) are unlawful.

While the CIT order and CBP’s response provide additional information on eligibility and potential refund processes, uncertainty continues to exist. Companies will need to closely monitor developments and evaluate any impact of these developments on their financial statements.

OECD releases side-by-side package on Pillar Two global minimum tax

The Organisation for Economic Co-operation and Development (OECD) released a side-by-side arrangement that includes a new side-by-side safe harbor (safe harbor) under the Pillar Two Global Anti-Base Erosion (GloBE) rules. The safe harbor, once enacted into local jurisdictional law, exempts a multinational entity (MNE) from certain Pillar Two taxes, mainly the income inclusion rule and the undertaxed profits rule top-up tax charging provisions, when the ultimate parent entity is located in a jurisdiction that maintains a qualified side-by-side tax regime. However, the MNE would remain subject to the qualified domestic minimum top-up tax charging provision in the jurisdictions in which they maintain constituent entities.

The OECD determines whether a jurisdiction has a qualified side-by-side tax regime based on whether the regime contains minimum tax elements such that it will qualify as a side-by-side comparison to the Pillar Two taxes. Once enacted into local jurisdictional law, the safe harbor is applicable for fiscal years beginning on or after 1 January 2026. The safe harbor does not impact any Pillar Two taxes related to periods before 2026 (e.g., 2025 for calendar-year-end companies).

The OECD has determined the US maintains a qualified side-by-side tax regime, and accordingly, once the safe harbor is enacted into local jurisdictional law, it is expected to reduce the amount of Pillar Two taxes that US parent MNEs would otherwise be subject to if the safe harbor was not in place.

For the safe harbor to be recognized within a jurisdiction there generally must be enacted tax legislation that recognizes the safe harbor within that particular jurisdiction. Entities should continue to update their estimated annual effective tax rate in each interim reporting period to consider developments in the period.

SEC rulemaking and other regulatory considerations

SEC Chairman Paul Atkins continues to position capital formation, innovation and crypto assets as SEC top priorities. One change in the SEC’s crypto plans came with Atkins’ January announcement that Project Crypto, an internal initiative to modernize crypto regulations, is now a joint initiative with the Commodity Futures Trading Commission (CFTC). Among the goals of this work is to create a unified approach to the federal oversight of crypto asset markets, remove duplicative compliance requirements and reduce regulatory fragmentation.

The SEC approved an interpretive release outlining a token taxonomy defining various categories of crypto assets to create certainty for market participants and safeguard investors. Chairman Atkins has said that tokenization and blockchain have the potential to streamline both trading and the entire issuer-investor relationship.

The SEC also continues to consider updates to current corporate reporting requirements to center disclosures on materiality and to reduce regulatory compliance burdens. Chairman Atkins has signaled that a proposal is expected early this year to shift SEC registrants to semi-annual reporting, with the option to continue filing quarterly. He also has invited the public to submit input on potential revisions to Regulation S-K’s non-financial statement disclosure requirements to avoid the disclosure of immaterial information.

Corporate governance may also be an area of SEC activity in the coming months, having come under heightened scrutiny recently by both the White House and the SEC. President Trump issued an executive order (EO) in December directing the SEC to consider rescinding all rules and guidance relating to shareholder proposals. This includes Rule 14a-8, which governs the proxy process. The EO also directs the SEC to review and possibly revise or rescind rules and guidance on proxy advisors (especially to the extent they implicate DEI- and ESG-related policies). Separately, Chairman Atkins has expressed the view that both shareholder proposals and proxy advisory firms contribute to a less attractive environment for companies to go public and indicated plans to consider related rule changes.

The start of 2026 has brought changes to both the Commission’s leadership and senior staff. Former Commissioner Caroline Crenshaw’s departure from the SEC in early January as her term expired left two vacant seats on the Commission, both previously held by Democrats. The Trump Administration has not indicated plans to put forward nominees to fill those slots. The Commission continues to fill out its senior leadership team, including a new chief economist, deputy directors in the Divisions of Corporation Finance and Enforcement and deputy chief accountants in the Office of the Chief Accountant (OCA).

Download the PDF for in-depth coverage of Q1 issues and access questions for the audit committee to consider.


Reports from previous quarters

2026 audit committee priorities

2025 Q3 audit committee update

2025 Q2 audit committee update


Summary

Global conflict, economic volatility, regulatory change and rapid AI adoption are intensifying demands on audit committee oversight. Boards are focusing on integrated risk management, resilient operating models and sound financial judgment amid uncertainty. Heightened attention to AI governance, cybersecurity, talent impacts and evolving disclosure requirements reflects the need for continuous learning and adaptability as external pressures reshape audit committee priorities.

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