Working whatever angles it can to get information on overseas audit firms doing business in U.S. capital markets, the Public Company Accounting Oversight Board has published some new requirements it may impose on firms seeking new registrations.

The PCAOB added two additional questions and answers to its cumulative Q&A guidance on how non-U.S. firms can audit U.S.-listed companies. The Q&As give a heads up on what the PCAOB may require of new overseas firms seeking to do business in the United States as a way of working around the PCAOB’s growing problems inspecting non-U.S. firms in certain countries.

Sarbanes-Oxley requires all firms that audit public companies listed on U.S. exchanges to be registered with the PCAOB and to submit to periodic inspections. Firms are supposed to be inspected at least once every three years, and the largest firms are to be inspected annually, but the PCAOB has been unable to inspect overseas firms in the European Union, China, Hong Kong, and Switzerland.

Audit firms and officials in those countries have claimed the Sarbanes-Oxley requirement in the United States conflicts with their own national laws. While the PCAOB continues to try to navigate those obstacles, it’s also begun publishing names of firms and public companies whose work has not been inspected by the PCAOB as a result of the conflict.

The PCAOB began publishing the list to give U.S. investors a warning. “As long as those obstacles persist … investors in U.S. markets who rely on those firms' audit reports are deprived of the potential benefits of PCAOB inspections of those auditors,” the board wrote in publishing the information.

Now the FAQ guidance gives new firms considering registration with the PCAOB another sort of fair warning if they are located in a country denying inspection access. If such a firm intends to register with the PCAOB, it may be asked for some detailed information about any public company audit work it has done, or expects to do, or any currently registered firm it may be working with.

“The additional information will facilitate the Board’s understanding of the scope and nature of the applicant's activities related to SEC-reporting companies,” the PCAOB wrote in a statement regarding the guidance. The guidance says firms can saves themselves some delay and some hassle if they voluntarily provide the new information described in the FAQ when they initially apply for registration, rather than waiting for the board to request it formally.