Deloitte, PwC, and EY Dutch units fined $8.5M for Exam Misconduct

“Test Anxiety” Hits the Big Leagues! You'd think the most stressful part of being a Big Four auditor would be signing off on a billion-dollar balance sheet—but it turns out, it might just be passing an internal training quiz. In a revelation that reads more like a college exam scandal than a regulatory filing, the Dutch arms of Deloitte, PwC, and EY have found themselves on the receiving end of a collective $8.5 million penalty from the Public Company Accounting Oversight Board (PCAOB). The reason? Widespread answer sharing on mandatory internal exams between 2018 and 2022. That’s right—some of the most respected global firms were found to have gaps not in their balance sheets, but in their internal ethics checks. And while nobody's calling it intentional malpractice, the PCAOB’s findings certainly turned heads in audit and regulatory circles.

The Cheat Sheet Chronicles

Between 2018 and 2022, “hundreds” of professionals, yes, including partners and even members of senior leadership, at the Dutch affiliates of Deloitte, PwC, and EY, engaged in improper answer sharing. The training tests in question weren’t just pop quizzes—they covered critical topics like professional integrity, independence, and PCAOB audit requirements. So, how did this happen? According to the PCAOB, answer sharing took many forms: some staff sent or received answers electronically, others took the exams together, and in a few cases, senior personnel were found to have gained access to test materials in advance.

In one particularly eyebrow-raising instance, a Deloitte Netherlands executive board member resigned after it came to light that he received answers shortly before taking a required test. PwC Netherlands also had a senior leader step down after it was discovered they had taken a test in tandem with a colleague. These weren’t isolated incidents—they reflected systemic gaps in oversight.

Regulators Do Their Homework

The PCAOB didn’t go alone. Working alongside the Dutch Authority for the Financial Markets (AFM), the U.S. watchdog conducted a deep dive investigation into the Dutch member firms’ internal training controls. Both agencies found that the firms’ quality control systems didn’t just miss a red flag—they missed a whole parade. Despite earlier exam-related enforcement actions against KPMG Netherlands in 2024 (which resulted in a record $25 million fine), the other Big Four firms had not yet tightened their internal exam processes. The PCAOB noted that firms had failed to properly evaluate the risk of answer sharing, even after learning about similar issues in the industry.

Each firm consented to the PCAOB’s orders without admitting or denying the findings. Deloitte and PwC Netherlands will each pay $3 million in civil penalties, while EY Netherlands will pay $2.5 million. All three firms were formally censured.

Turning the Page

To their credit, all three firms acted swiftly following the PCAOB's findings. They’ve committed to reviewing and strengthening their quality control systems, implementing changes that go beyond the usual HR reminders. The goal: ensure internal training reflects not just knowledge retention but professional integrity. The Dutch AFM, for its part, isn’t letting this slide quietly into the past. It has placed the firms under what’s described as “intensive supervision,” a structured oversight mechanism designed to prevent similar issues from popping up in the future. The firms are also required to report back to the PCAOB on their internal training reforms and ethical compliance efforts.

On the internal side, disciplinary actions varied, ranging from formal warnings and demotions to financial penalties and, in some cases, terminations. Chris Buijink, chair of PwC Netherlands' supervisory board, summed up the moment candidly: “This undermines public trust in the organization. We must learn from this.”

Lessons for Accounting and Audit Professionals

Let’s keep it real—training modules and ethics quizzes don’t exactly get your heart racing. But they’re more than just a checkbox. They're a reflection of a firm’s culture and an individual’s commitment to the profession.

Here’s what professionals should take away from this:

• Ethics starts small: Integrity isn’t just about signing clean audit opinions—it’s about everyday choices, including how you complete internal training.
• Shortcuts can have long consequences: Even informal answer sharing on quizzes can trigger real regulatory penalties and internal disciplinary action.
• Leadership sets the tone: When senior leaders get involved in misconduct, it erodes trust across the firm. Ethical tone from the top matters.
• Quality control is everyone’s job: Don’t wait for compliance teams to catch red flags. Speak up if something feels off—even during training season.
• Compliance is a culture, not a checkbox: Regulators now expect firms to show that integrity is embedded across operations, not just policy documents.

The profession has high standards, and living up to them doesn’t stop at the audit file. It starts with how you learn.

Future-Proofing Integrity

This wasn’t a billion-dollar fraud or headline-grabbing accounting gimmick—but it matters. Because trust in audit starts long before a report gets filed. It begins in the classroom, in the training portal, in how firms build and enforce a culture of doing the right thing—even when no one’s watching. The PCAOB’s actions—and the firms’ responses—show a push for higher standards and more transparency. As global firms take steps to clean house, it’s clear the future of audit isn’t just technical; it’s ethical. And for everyone in the profession, that’s a test worth taking seriously.  Erica Williams, Chair of the PCAOB, wrapped it up best: “The PCAOB will not allow impaired ethics to threaten the integrity of our capital markets.” Her words may not be poetic, but for finance professionals. They hit home like a GAAP adjustment. Sign up for weekly accounting insights, regulatory updates, and expert guidance from MYCPE ONE Insights.