Auditor liability to third parties after Sarbanes-Oxley: An international comparison of regulatory and legal reforms

This study compares the status of auditors’ legal liability to third parties in seven countries. It analyzes recent legislation, regulation, and case law as well as pronouncements from national accounting and auditing bodies. With the increasing internationalization of capital markets and audit firms, an understanding of auditor liability on a global basis is important. Our findings show that common law countries (the United States, Canada, the United Kingdom, Australia, and New Zealand) have enacted legislative reforms that directly or indirectly increased auditors’ liability. In contrast, civil law countries (Germany and France) did not mandate legislative or regulatory reforms.