COSO Releases Updated Internal Control Framework

The Committee of Sponsoring Organizations of the Treadway Commission issued its long-awaited update to its Internal Control–Integrated Framework and related illustrative documents on Tuesday.

COSO published its original framework in 1992 and it is recognized as the leading guidance for designing, implementing and conducting internal control and assessing its effectiveness.  The organization provides thought leadership and guidance on internal control, enterprise risk management, and fraud deterrence.

The updated framework was authored by PricewaterhouseCoopers under the direction of the COSO Board and is expected to help organizations design and implement internal control in light of many changes in business and operating environments since the issuance of COSO’s original internal control framework.  The new framework also broadens the application of internal control in addressing operations and reporting objectives, and clarifies the requirements for determining what constitutes effective internal control.

COSO also issued on Tuesday its Illustrative Tools for Assessing Effectiveness of a System of Internal Control and the Internal Control over External Financial Reporting (ICEFR): A Compendium of Approaches and Examples. The Illustrative Tools are expected to assist users when assessing whether a system of internal control meets the requirements set forth in the updated Framework. The ICEFR Compendium is particularly relevant to those who prepare financial statements for external purposes based upon requirements set forth in the updated Framework.

“COSO and PwC are very appreciative of the extensive and thoughtful input received from stakeholders through participation in an initial survey of potential updates, the public exposures of draft documents during 2011 and 2012, and other forums during the 2 ½ year development process,” said COSO chairman David Landsittel in a statement. “While our original framework remains fundamentally sound and broadly accepted in the market place, we are confident that the 2013 framework will bring added benefits to users.”

COSO believes that users should transition their applications and related documentation to the updated framework as soon as is feasible under their particular circumstances. As previously announced, COSO will continue to make available its original framework during the transition period extending to Dec. 15, 2014, after which time COSO will consider it as superseded by the 2013 framework (see COSO Issues ED on Internal Control over Financial Reporting and COSO Chair Previews New Internal Control Framework).

The COSO board said it believes that continued use of the original framework during the transition period from May 14, 2013 to Dec. 15, 2014 is appropriate. During this period, the COSO board believes that organizations reporting externally should clearly disclose whether the original framework or the 2013 framework was used. COSO will also continue to make available its publication, Internal Control over Financial Reporting–Guidance for Smaller Public Companies until Dec. 15, 2014, after which time it will no longer be available.

COSO publications, including the Framework, Illustrative Tools, and ICEFR Compendium, are available for purchase at www.coso.org in both print and electronic formats. An Executive Summary can be downloaded by the public free of charge from www.coso.org. In addition, the public exposure drafts of these publications, the related public comment letters, and other background information about the project will remain available on COSO’s Web site through Dec. 31, 2013.

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