Updating a previous thread: per a PCAOB spokeswoman, the last two paragraphs on page 4 of the staff guidance provide a bit more clarity to calculating auditor tenure after firms expressed some confusion.
If auditors cannot readily determine when an initial engagement letter was signed,they can determine tenure based on their own records, the company’s records, or publicly available information, such as company filings available on the SEC’s Electronic Data Gathering, Analysis and Retrieval (“EDGAR”) system.
In the absence of other evidence about when the auditor signed an initial engagement letter or began performing audit procedures, tenure can be determined based on the year in which the auditor first issued an audit report on the company’s financial statements or, if earlier, the auditor’s estimate of when work would have commenced to enable the issuance of such report.