Audit Fee Benchmarks by Industry [2025]

Why industry drives audit fees more than firm size

A €50 million revenue manufacturing company and a €50 million revenue financial services company sit in different audit universes. The financial services entity likely holds complex financial instruments requiring fair value measurement under IFRS 9, faces prudential regulatory requirements, and generates a higher volume of transactions per euro of revenue. ISA 540.13 requires the auditor to assess whether accounting estimates give rise to significant risks. In financial services, more of them do.

This means the audit of a €50 million bank costs more than the audit of a €50 million logistics company, even when the audit firm and jurisdiction are identical. Industry determines the risk profile. Risk profile determines the hours. Hours determine the fee.

Audit Analytics' 20-year fee review found the same pattern in US data: finance and manufacturing consistently rank as the two highest-fee sectors by total fee volume among S&P 500 companies, together comprising nearly 69% of total fees paid by the index. Agriculture, despite having the lowest total revenue of any sector, pays the highest audit fees as a proportion of revenue. Small revenue pools with high regulatory complexity create disproportionately expensive audits.

European audit fees by industry: the 2024 data

The FRC's 2025 report provides the most recent industry-level fee data for European listed companies, based on FTSE 350 constituents:

These averages are shaped by the specific companies within each ICB classification. Energy fees are inflated by the presence of Shell and BP, whose audit fees alone represent a substantial portion of the sector total. The FRC noted that the ten largest audit fees in the FTSE 350 represent 31% of total FTSE 350 audit fees in 2024.

At the European level, Mordor Intelligence's 2025 report found that BFSI generated 31.35% of total European audit demand. Financial audits delivered 35.63% of total 2024 revenues across all sectors. These proportions are driven by the regulatory density of financial services (Basel III, Solvency II, MiFID II) and the mandatory audit requirements those frameworks impose.

For the non-PIE mid-market, direct industry-level fee data is scarcer. The AFM collects data on over 31,000 non-PIE statutory audits in the Netherlands but does not publish granular industry breakdowns in the same format as the FRC. Practitioners benchmarking mid-market fees will need to combine multiple sources, which is what the worked example below demonstrates.

US comparison data and what it tells European firms

The IAA's 2025 Twenty-Year Fee Review (covering SEC registrants through FY2024) provides the deepest industry-level dataset available globally:

Average audit fees rose across all eight industry sectors the IAA tracks in 2024. The overall average reached $2.726 million (up 8% from $2.516 million in 2023). Total fees paid by the 6,656 SEC registrants in the analysis reached $21.675 billion, the highest annual total in the 20-year series despite a 7% decrease in the registrant population.

These are US-GAAP, SEC-regulated entities. European comparisons require adjustment for differences in regulatory framework (ISA vs PCAOB standards), market structure, and entity size distribution. But the relative ranking of industries is remarkably consistent across jurisdictions. Finance and manufacturing sit at the top in both markets. Real estate sits near the bottom in both.

The Manufacturers Alliance's 2024 Audit Fee Benchmark found that US manufacturers specifically paid between $1.17 million and $6.74 million in audit fees for 2023, with an average fee-to-revenue ratio of 0.07%. 60% of respondents reported that actual fees exceeded the initial quote, and 58% had fixed-fee contracts with adjustment provisions.

What makes certain industries more expensive to audit

Four factors explain why some sectors consistently carry higher fees. Understanding these helps you justify (or challenge) a fee level.

Accounting estimate density. ISA 540.13 requires auditors to identify significant risks arising from accounting estimates. Financial services entities carry more of these: expected credit loss models (IFRS 9), insurance contract liabilities (IFRS 17), fair value measurements on Level 2 and Level 3 instruments. Each estimate requires auditor assessment of the methodology, the inputs, and the range of reasonable outcomes. That work is specialist-intensive.

Regulatory overlay. Energy, healthcare, and financial services all face sector-specific regulatory regimes that expand audit scope beyond the financial statements. A bank audit includes regulatory capital adequacy. A pharmaceutical audit includes revenue recognition judgments on milestone payments and licensing arrangements (IFRS 15.B63). These regulatory layers don't exist for a logistics company.

Geographic dispersion. Energy and telecommunications companies typically operate across multiple jurisdictions, triggering component auditor considerations under ISA 600. Group audit coordination, component materiality calculations, and the review of component auditor work all add cost. The 2024 revisions to ISA 600 (effective for periods beginning on or after 15 December 2026) will increase the documentation burden for group audits further.

Transaction volume and complexity. A retail bank processes millions of transactions per year. A property holding company processes hundreds. Even with data analytics reducing the per-transaction audit cost, the absolute volume drives hours. This is why finance, despite often having lower revenue per entity than energy, still carries the highest average fees.

Fee-to-revenue ratios by sector

Fee-to-revenue ratios are the most useful benchmarking metric because they normalise for entity size. Here's what the available data shows for 2023-2024:

The ratio increases as entity size decreases. A €500 million revenue company's audit doesn't cost ten times more than a €50 million company's audit. It might cost two to four times more. This means the fee-to-revenue ratio for smaller entities is inherently higher, and comparing a mid-market entity's ratio against S&P 500 data is misleading.

For non-Big 4 firms serving the Dutch mid-market, a fee-to-revenue ratio between 0.08% and 0.20% is the realistic range, with the exact position determined by industry, complexity, and the number of jurisdictions. Financial services and healthcare sit at the high end. Wholesale, logistics, and simple holding structures sit at the low end.

Worked example: positioning a fee proposal using industry data

Client scenario: Jansen & Partners Farma B.V., a Dutch pharmaceutical distribution company with €72 million revenue, 210 employees, operations in three EU countries, and first-wave CSRD obligations from the 2025 financial year. Big Four incumbent auditor (KPMG) for the past eight years. Rotation required by 2026. The client has invited your firm (a regional SRA member firm) to tender.

Step 1: Establish the industry benchmark

Healthcare/pharmaceutical sits in the top tier of fee rankings. FRC data shows an average FTSE 350 health care audit fee of £8.1 million, but Jansen & Partners is not FTSE 350. Scale down to the mid-market. For a €72 million revenue pharmaceutical distribution company, apply the mid-market healthcare fee-to-revenue range of 0.12-0.18%.

€72,000,000 x 0.12% = €86,400
€72,000,000 x 0.18% = €129,600

The expected fee range is €86,000 to €130,000.

Documentation note: "Industry benchmark: healthcare/pharmaceutical distribution, €50-100M revenue band. Fee-to-revenue range of 0.12-0.18% applied. Source: FRC 2025 FTSE 350 health care industry data (directional), cross-referenced with comparable entity parameters."

Step 2: Adjust for CSRD assurance scope

Jansen & Partners falls within CSRD Wave 2 (large companies, 2025 financial year reporting in 2026). Limited assurance on the sustainability report adds 20-30% of the financial audit fee, based on Position Green's benchmark data. Using the midpoint of the financial audit fee range (€108,000):

€108,000 x 25% = €27,000 CSRD assurance fee.

Total proposed fee: €108,000 + €27,000 = €135,000.

Documentation note: "CSRD limited assurance priced at 25% of base audit fee. Benchmark: Position Green 2025 analysis (20-30% range). Separate line item in engagement letter per ISA 210.10."

Step 3: Price competitively against the Big Four incumbent

The Big Four premium on mid-market audits runs between 15% and 40% above mid-tier pricing in European studies (Gazilas, Belesis & Kampouris, 2025, found significantly higher fees at Big Four firms after controlling for entity characteristics). If the KPMG incumbent fee was €160,000, your total of €135,000 represents a 15.6% discount while still sitting comfortably within the industry benchmark range.

Documentation note: "Proposed fee of €135,000 (financial audit + CSRD limited assurance) represents a 15.6% reduction from incumbent fee of €160,000. Fee-to-revenue ratio of 0.19% (including CSRD) is within industry range. Documented in tender proposal appendix with benchmark sources."

Step 4: Present the benchmark to the audit committee

In the tender presentation, show the fee-to-revenue ratio against the industry range. Show it as a chart with two bars: their current ratio under the incumbent, and the proposed ratio under your firm. Both within the industry band. The audit committee sees that you're not competing on cheapness. You're competing on value within a defensible price range.

Documentation note: "Audit committee presentation slide includes fee-to-revenue benchmark chart. Sources cited: FRC 2025, Position Green 2025. Slide filed in permanent audit file, governance communications section."

Practical checklist for industry-based fee benchmarking

1. Before any fee proposal, identify your client's ICB industry classification (or the closest European equivalent). Pull the corresponding average fee from the FRC's latest Audit Market and Competition Update.
2. Calculate the client's fee-to-revenue ratio. Compare it against the sector-specific ranges in this post. If the ratio falls below the low end of the range, document why (simpler structure, single jurisdiction, clean control environment). If it falls above, document the complexity drivers.
3. For CSRD-obligated clients, price sustainability assurance as a separate line item. Use 20-30% of the financial audit fee as the starting benchmark and adjust based on the number of ESRS standards in scope.
4. When tendering against a Big Four incumbent, use the fee benchmark data to frame your proposal as "within industry range" rather than "cheaper." Audit committees respond better to evidence-based pricing than to discounts.
5. Track your firm's actual fee-to-revenue ratios by sector across your full client base. Identify sectors where you're consistently below the benchmark. Those are the practices where you have pricing power you're not using.
6. Update benchmarks annually. The FRC, AFM, and IAA all publish new data each year. Last year's benchmark is directional but not sufficient for a 2026 fee proposal.

Common mistakes

Using S&P 500 or FTSE 350 averages for mid-market fee proposals. The entity size distribution is completely different. A mid-market audit committee that sees a $2.7 million "industry average" next to their €45,000 fee will dismiss the benchmarking entirely.

Treating CSRD assurance as included in the base audit fee. Eumedion found a 19% cost increase among Dutch firms that bundled CSRD assurance. Firms that price it separately recover costs more reliably and set clearer scope expectations.

Ignoring the Big Four premium when setting tender prices. If you match the incumbent's fee exactly, you've left money on the table or the audit committee questions why you're as expensive as a Big Four firm. Position your fee 10-20% below the incumbent while remaining within the industry benchmark band. That's the sweet spot.

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Further reading and source references

• FRC 2025 Audit Market and Competition Update: FTSE 350 audit fees by ICB industry, market shares, and year-on-year trends.
• IAA 2025 Twenty-Year Fee Review: SEC registrant audit fees by industry sector, covering 6,656 registrants through FY2024.
• Manufacturers Alliance 2024 Audit Fee Benchmark: Manufacturing-specific fee data, fee-to-revenue ratios, and fixed-fee contract prevalence.
• Mordor Intelligence 2025 European Auditing Services Market Report: Sector-level demand proportions and growth projections.
• AFM 2025 State of the Auditing and Reporting Industry: Dutch non-PIE audit data covering 31,000+ statutory audits.
• Position Green 2025: CSRD assurance cost benchmarks (20-30% of financial audit fee under limited assurance).