The US has released its report into audit choice and the dominance of the Big Four firms. Reading through it, the UK’s mid-tier might well be looking on enviously.

The report was produced by the US Treasury and, although it draws on the ideas of the UK version, it goes much deeper and produces more tangible recommendations than its UK counterpart.

Regulators in the UK and the US are determined to tackle the dominance of the Big Four, but a blueprint drawn up by the UK’s FRC sidestepped radical intervention. Instead, a softly, softly approach has been adopted.

The principles of the UK approach are simple: create conditions within which the mid-tier might flourish, but don’t do anything to actively dismantle the market as it is. No-one is going to split PwC in two.

The US authorities have the same objectives as the UK’s, but this latest US Treasury committee report, steered by Hank Paulson, is subtly demanding much more reform of the accounting industry than UK officials have dared broach.

Published last week, it suggests that ‘Big Four-only clauses’ ­ forced on companies by lenders or otherwise ­ should be disclosed as a mandatory requirement by US companies.

By contrast, the UK report only recommended voluntary disclosure.

Where the UK has sought to recommend that companies consider the need to include the risk of withdrawal of their auditor from the market in their risk evaluation and planning approach, the US Treasury has taken this a step further. It recommended that a mechanism be established to assist in the preservation and rehabilitation of a troubled large firm.

The US wants to see that auditors have a back-up plan if things go wrong. If the first plan failed to stabilise the firm, a second phase would allow the SEC to appoint a trustee to intervene.

In Britain, the FRC chief executive Paul Boyle said he agreed a contingency plan would be sensible. ‘The primary responsibility needs to rest with the firms and clients,’ Boyle said. ‘It would be advisable to have this responsibility stretched across a variety of organisations and agencies.’

The FRC has itself launched a further consultation on improving choice in the market by proposing a change in the ownership rules governing the firms, as well as pursuing the idea of joint audits.

Both these ideas have been slammed by the major auditing firms ­ but the threat of failure could see partners warming to them.

Now that the US has launched its salvo in the ongoing challenge to tackle audit choice, the ball may now be back in the UK’s court.