PEEC seeks input on proposed revisions to ‘public interest entity’ definition

The AICPA Professional Ethics Executive Committee (PEEC) released an exposure draft Monday proposing revisions to the definition of “public interest entity” in the AICPA Code of Professional Conduct (the code).

The proposal reflects PEEC’s efforts to better align the definition with regulatory thresholds established by the Federal Deposit Insurance Corporation (FDIC) and the National Association of Insurance Commissioners (NAIC).

The proposed revisions remove the fixed-dollar thresholds in the current definition and directly reference thresholds set by the FDIC and NAIC. The goal is to ensure that the code keeps pace with future regulatory updates without the need for additional standard-setting actions.

PEEC believes this change will continue to capture financial institutions and insurers considered higher risk by regulators, while improving the responsiveness and long-term sustainability of the definition.

The exposure draft also proposes removing certain redundant criteria and clarifying requirements related to internal control reporting and audit committee oversight.

In February, in connection with recent FDIC updates that took effect on Jan. 1, 2026, PEEC adopted a temporary enforcement policy. This policy allows AICPA members to apply the FDIC’s updated thresholds when determining public interest entity status under the current definition, helping ensure continued compliance during the exposure and transition period.

Public comment ends Sept. 15

The AICPA invites public comments on the exposure draft. The comment period began Monday and ends Sept. 15.

In response to requests from members and other stakeholders, PEEC is offering an online form for comments. Comments also can be submitted by email to ethics-exposuredraft@aicpa.org.

All responses received will be considered part of the public record.

After the comment period ends, PEEC will evaluate feedback and determine whether to issue a final revised definition.

— Kelly D. Mullins is the communications manager for the AICPA Professional Ethics Division. To comment on this article or to suggest an idea for another article, contact Neil Amato at Neil.Amato@aicpa-cima.com.