COSO Seeks Comment for Internal Control Over External Financial Reporting

Sarah Woodman, Global events journalist
September 19, 2012 /

The Committee of Sponsoring Organizations of the Treadway Commission (COSO) – an organization providing thought leadership and guidance on internal control, enterprise risk management and fraud deterrence – has released for public comment an exposure draft of its Internal Control over External Financial Reporting (ICEFR): Compendium of Approaches and Examples.

This Compendium, part of COSO’s overall project to update its Internal Control–Integrated Framework (Framework), has been developed to assist users when applying the Framework to external financial reporting objectives.

“The addition of the Compendium and Illustrative Tools enhances the value of the Framework by providing additional context to how it is applied in various settings,” said COSO Chairman Dave Landsittel. “Because COSO publications carry weight with a wide range of stakeholders, public input is critical in assuring their relevance and usefulness.”

Authored by PwC under the direction of COSO, the Compendium illustrates how the principles set forth in the proposed updated Framework can be applied in designing, implementing and conducting internal control over external financial reporting.

COSO believes it is particularly relevant to those who publicly report on the effectiveness of their system of internal control over financial reporting based upon requirements set forth in the updated Framework. While the approaches set forth in the Compendium are likely to be relevant to many entities, COSO recognizes they may be applied differently depending on the entity’s circumstances.

In conjunction with the release of the Compendium for public comment, COSO is making available the revised version of its previously exposed updated Framework, which incorporates revisions arising from consideration of comments received during the comment period. More than 200 organizations and professionals provided comments on the exposure draft. COSO’s overall goal in updating the Framework is to ease use and application and to reflect changes in the increasingly complex business, operating and regulatory environments since 1992.

Furthermore, COSO is making available the proposed Illustrative Tools to assist users when assessing the effectiveness of a system of internal control based on requirements set forth in the updated Framework.

COSO welcomes comments on its proposed Compendium, as well as on the post public exposure version of the updated Framework and Illustrative Tools. To access these documents, answer our survey questions, and/or submit letters please visit

Following the public comment period, which ends on November 20, 2012, the proposed documents will be revised as necessary. Release of the final documents is expected during the first quarter of 2013. Drafts of these proposed documents and related public comments will remain available on COSO websites at and, respectively, for public viewing until the final Framework is issued.

For COSO’s responses to frequently asked questions (FAQs), including its perspective on transition from the present Framework to the updated version and other important topics of interest, please visit the COSO website at The FAQs are periodically updated on the “About This Project” page.

Finally, COSO wishes to thank PwC and the COSO Framework Advisory Council for their very effective contributions to the overall Framework update efforts.


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