2013 COSO Framework Implementation: First Glance

In May 2013, the Committee of Sponsoring Organizations of the Treadway Commission (COSO) released an updated Framework for companies to use in evaluating their Internal Controls over Financial Reporting (ICFR). The 1992 Framework entered a transitional period that ended on December 15, 2014, at which time it was considered superseded by the 2013 COSO Framework.

In this blog, we will examine the initial implementation of the new guidance by accelerated and large accelerated filers.

COSO 2013 Framework

2,132 accelerated filers, or more than 82%, were able to meet the COSO implementation deadline. 448 companies, or about 17% of the accelerated filers, were still using the 1992 Framework, and 15 filers either did not disclosure the Framework used or the disclosure was not clear.

An additional 33 companies with fiscal years ending between June 30, 2014 and December 15, 2014 also used 2013 Framework in their ICFR evaluation. The early adopters comprised a very small percentage of all filers.

It is yet to be seen whether smaller reporting companies will follow the lead of larger filers in the strong implementation of the 2013 COSO guidance.

Note: This analysis is based on a download of Audit Analytics data as of 4/15/15 and includes the population of accelerated and large accelerated filers.