Illustrative Tools
Illustrative Tools
Illustrative Tools
The Committee of Sponsoring Organizations of the Treadway Commission (COSO) has issued the updated Internal Control–Integrated Framework (Framework) and a
companion document: Internal Control over Financial Reporting – Illustrative Tools for Assessing Effectiveness of a System of Internal Control (Illustrative Tools). It is
expected that organizations will customize the templates presented in the Illustrative Tools to match the facts and circumstances in their particular organizations. To help
organizations customize the templates for their assessment process and organization, this file is an extract of only the blank templates from the Illustrative Tools.
The form and use of the templates are explained in the Introduction to the Illustrative Tools; they should not be used without reading and understanding that chapter. Also,
please refer t0 the Framework when using these templates, particularly, Chapter 2, Objectives, Components, and Principles, and Chapter 3, Effective Internal Control.
The templates are designed to present only a summary of assessment results. They are not an integral part of the Framework, and they may not address all matters that
need to be considered when assessing a system of internal control. Further, they do not represent a preferred method of conducting and documenting an assessment.
Their purpose is limited to illustrating one possible assessment process based on the requirements for effective internal control set forth in the Framework.
• Components—Summarizes management’s determination of whether each component and relevant principles are present and functioning. A template for each of the
five components is included.
• Principles—Summarizes the controls to effect principles and management’s determination of whether each relevant principle is present and functioning. A template
for each of the seventeen principles is included.
• Deficiencies—A log of all identified internal control deficiencies that can be leveraged in the evaluation of components and principles, and can enable the internal
control deficiencies to be aggregated.
Operations
Reporting
Compliance
Risk Assessment
Control Activities
Identification No. Internal control deficiency description Evaluate internal control deficiency severity:
(Consider whether controls to effect other
principles within and across components
compensate for the internal control deficiency.)
Identification No. Internal control deficiency description Evaluate internal control deficiency severity:
(Consider whether controls to effect other
principles within and across components
compensate for the internal control deficiency.)
Explanation/Conclusion
Evaluate deficiencies across the component:*
Evaluate if any internal control deficiencies or combination of internal control deficiencies,
when considered across the component, represent a major deficiency**
Evaluate the component using judgment and based on the principles and the deficiencies** Yes/No
Identification No. Internal control deficiency description Evaluate internal control deficiency severity:
(Consider whether controls to effect other
principles within and across components
compensate for the internal control deficiency.)
8. Assesses Fraud Risk—The organization considers the potential for fraud in assessing
risks to the achievement of objectives.
Identification No. Internal control deficiency description Evaluate internal control deficiency severity:
(Consider whether controls to effect other
principles within and across components
compensate for the internal control deficiency.)
Evaluate the component using judgment and based on the principles and the Yes/No
deficiencies**
Is the component present?
Identification No. Internal control deficiency description Evaluate internal control deficiency severity:
(Consider whether controls to effect other
principles within and across components
compensate for the internal control deficiency.)
Identification No. Internal control deficiency description Evaluate internal control deficiency severity:
(Consider whether controls to effect other
principles within and across components
compensate for the internal control deficiency.)
Identification No. Internal control deficiency description Evaluate internal control deficiency severity:
(Consider whether controls to effect other
principles within and across components
compensate for the internal control deficiency.)
Explanation/Conclusion
Evaluate the component using judgment and based on the principles and the deficiencies** Yes/No Explanation/Conclusion
Identification No. Internal control deficiency description Evaluate internal control deficiency severity:
(Consider whether controls to effect other
principles within and across components
compensate for the internal control deficiency.)
Identification No. Internal control deficiency description Evaluate internal control deficiency severity:
(Consider whether controls to effect other
principles within and across components
compensate for the internal control deficiency.)
Explanation/Conclusion
Evaluate the component using judgment and based on the principles and the deficiencies** Yes/No Explanation/Conclusion
Identification No. Internal control deficiency description Evaluate internal control deficiency severity:
(Consider whether controls to effect other
principles within and across components
compensate for the internal control deficiency.)
Identification No. Internal control deficiency description Evaluate internal control deficiency severity:
(Consider whether controls to effect other
principles within and across components
compensate for the internal control deficiency.)
Evaluate the component using judgment and based on the principles and the deficiencies** Yes/No Explanation/Conclusion
Explanation/Conclusion
Explanation/Conclusion
Explanation/Conclusion
ol is not effective.
Explanation/Conclusion
Explanation/Conclusion
ol is not effective.
Explanation/Conclusion
on/Conclusion
ol is not effective.
Explanation/Conclusion
on/Conclusion
ol is not effective.
Explanation/Conclusion
ol is not effective.
Points of Focus
• Sets the Tone at the Top – The board of directors and management at all levels of the entity demonstrate through their directives, actions, and behavior the
importance of integrity and ethical values to support the functioning of the system of internal control.
• Establishes Standards of Conduct – The expectations of the board of directors and senior management concerning integrity and ethical values are defined in
the entity’s standards of conduct and understood at all levels of the organization and by outsourced service providers and business partners.
• Evaluates Adherence to Standards of Conduct – Processes are in place to evaluate the performance of individuals and teams against the entity’s expected
standards of conduct.
• Addresses Deviations in a Timely Manner – Deviations of the entity’s expected standards of conduct are identified and remedied in a timely and consistent
manner.
Identification No. Internal control deficiency description Evaluate internal control deficiency severity:
(Consider whether controls to effect other
principles within and across components
compensate for the internal control deficiency.)
—The board of directors demonstrates independence from management and exercises oversight of the development and performance
of internal control.
Points of Focus
• Establishes Oversight Responsibilities—The board of directors identifies and accepts its oversight responsibilities in relation to established requirements and
expectations.
• Applies Relevant Expertise—The board of directors defines, maintains, and periodically evaluates the skills and expertise needed among its members to
enable them to ask probing questions of senior management and take commensurate actions.
• Operates Independently—The board of directors has sufficient members who are independent from management and objective in evaluations and decision
making.
• Provides Oversight for the System of Internal Control—The board of directors retains oversight responsibility for management’s design, implementation, and
conduct of internal control:
– Control Environment—Establishing integrity and ethical values, oversight structures, authority and responsibility, expectations of competence, and
accountability to the board.
– Risk Assessment—Overseeing management’s assessment of risks to the achievement of objectives, including the potential impact of significant changes,
fraud, and management override of internal control.
– Control Activities—Providing oversight to senior management in the development and performance of control activities.
– Information and Communication—Analyzing and discussing information relating to the entity’s achievement of objectives.
– Monitoring Activities—Assessing and overseeing the nature and scope of monitoring activities and management’s evaluation and remediation of
deficiencies.
—Management establishes, with board oversight, structures, reporting lines, and appropriate authorities and responsibilities in the
pursuit of objectives.
Points of Focus
• Considers All Structures of the Entity—Management and the board of directors consider the multiple structures used (including operating units, legal entities,
geographic distribution, and outsourced service providers) to support the achievement of objectives.
• Establishes Reporting Lines—Management designs and evaluates lines of reporting for each entity structure to enable execution of authorities and
responsibilities and flow of information to manage the activities of the entity.
• Defines, Assigns, and Limits Authorities and Responsibilities —Management and the board of directors delegate authority, define responsibilities, and use
appropriate processes and technology to assign responsibility and segregate duties as necessary at the various levels of the organization:
– Board of Directors — Retains authority over significant decisions and reviews management’s assignments and limitations of authorities and
responsibilities
– Senior Management—Establishes directives, guidance, and control to enable management and other personnel to understand and carry out their internal
control responsibilities
– Management—Guides and facilitates the execution of senior management directives within the entity and its subunits
– Personnel—Understands the entity’s standard of conduct, assessed risks to objectives, and the related control activities at their respective levels of the
entity, the expected information and communication flow, and monitoring activities relevant to their achievement of the objectives
– Outsourced Service Providers—Adheres to management’s definition of the scope of authority and responsibility for all non-employees engaged
Identification No. Internal control deficiency description Evaluate preliminary deficiency severity:
(Consider whether other controls to effect this
principle compensate for the internal control
deficiency.)
—The organization demonstrates a commitment to attract, develop, and retain competent individuals in alignment with objectives.
Points of Focus
• Establishes Policies and Practices—Policies and practices reflect expectations of competence necessary to support the achievement of objectives.
• Evaluates Competence and Addresses Shortcomings—The board of directors and management evaluate competence across the organization and in
outsourced service providers in relation to established policies and practices, and act as necessary to address shortcomings.
• Attracts, Develops, and Retains Individuals—The organization provides the mentoring and training needed to attract, develop, and retain sufficient and
competent personnel and outsourced service providers to support the achievement of objectives.
• Plans and Prepares for Succession—Senior management and the board of directors develop contingency plans for assignments of responsibility important for
internal control.
Identification No. Internal control deficiency description Evaluate preliminary deficiency severity:
(Consider whether other controls to effect this
principle compensate for the internal control
deficiency.)
—The organization holds individuals accountable for their internal control responsibilities in the pursuit of objectives.
Points of Focus
• Enforces Accountability through Structures, Authorities, and Responsibilities—Management and the board of directors establish the mechanisms to
communicate and hold individuals accountable for performance of internal control responsibilities across the organization and implement corrective action as
necessary.
• Establishes Performance Measures, Incentives, and Rewards—Management and the board of directors establish performance measures, incentives, and
other rewards appropriate for responsibilities at all levels of the entity, reflecting appropriate dimensions of performance and expected standards of conduct,
and considering the achievement of both short-term and longer-term objectives.
• Evaluates Performance Measures, Incentives, and Rewards for Ongoing Relevance—Management and the board of directors align incentives and rewards
with the fulfillment of internal control responsibilities in the achievement of objectives.
• Considers Excessive Pressures—Management and the board of directors evaluate and adjust pressures associated with the achievement of objectives as
they assign responsibilities, develop performance measures, and evaluate performance.
• Evaluates Performance and Rewards or Disciplines Individuals—Management and the board of directors evaluate performance of internal control
responsibilities, including adherence to standards of conduct and expected levels of competence and provide rewards or exercise disciplinary action as
appropriate.
Identification No. Internal control deficiency description Evaluate preliminary deficiency severity:
(Consider whether other controls to effect this
principle compensate for the internal control
deficiency.)
—The organization specifies objectives with sufficient clarity to enable the identification and assessment of risks relating to objectives.
Points of Focus
Operations Objectives
• Reflects Management’s Choices—Operations objectives reflect management’s choices about structure, industry considerations, and performance of the entity.
• Considers Tolerances for Risk—Management considers the acceptable levels of variation relative to the achievement of operations objectives.
• Includes Operations and Financial Performance Goals—The organization reflects the desired level of operations and financial performance for the entity within
operations objectives.
• Forms a Basis for Committing of Resources—Management uses operations objectives as a basis for allocating resources needed to attain desired operations
and financial performance.
• Reflects Entity Activities—External reporting reflects the underlying transactions and events to show qualitative characteristics and assertions.
Compliance Objectives
• Reflects External Laws and Regulations—Laws and regulations establish minimum standards of conduct which the entity integrates into compliance
objectives.
• Considers Tolerances for Risk—Management considers the acceptable levels of variation relative to the achievement of compliance objectives.
—The organization identifies risks to the achievement of its objectives across the entity and analyzes risks as a basis for determining
how the risks should be managed.
Points of Focus
• Includes Entity, Subsidiary, Division, Operating Unit, and Functional Levels—The organization identifies and assesses risks at the entity, subsidiary, division,
operating unit, and functional levels relevant to the achievement of objectives.
• Analyzes Internal and External Factors—Risk identification considers both internal and external factors and their impact on the achievement of objectives.
• Involves Appropriate Levels of Management—The organization puts into place effective risk assessment mechanisms that involve appropriate levels of
management.
• Estimates Significance of Risks Identified—Identified risks are analyzed through a process that includes estimating the potential significance of the risk.
• Determines How to Respond to Risks—Risk assessment includes considering how the risk should be managed and whether to accept, avoid, reduce, or share
the risk.
• (Other entity specific points of focus, if any)
Identification No. Internal control deficiency description Evaluate preliminary deficiency severity:
(Consider whether other controls to effect this
principle compensate for the internal control
deficiency.)
—The organization considers the potential for fraud in assessing risks to the achievement of objectives.
Points of Focus
• Considers Various Types of Fraud—The assessment of fraud considers fraudulent reporting, possible loss of assets, and corruption resulting from the various
ways that fraud and misconduct can occur.
• Assesses Incentive and Pressures—The assessment of fraud risk considers incentives and pressures.
• Assesses Opportunities—The assessment of fraud risk considers opportunities for unauthorized acquisition, use, or disposal of assets, altering of the entity’s
reporting records, or committing other inappropriate acts.
• Assesses Attitudes and Rationalizations—The assessment of fraud risk considers how management and other personnel might engage in or justify
inappropriate actions.
• (Other entity specific points of focus, if any)
—The organization identifies and assesses changes that could significantly impact the system of internal control.
Points of Focus
• Assesses Changes in the External Environment—The risk identification process considers changes to the regulatory, economic, and physical environment in
which the entity operates.
• Assesses Changes in the Business Model—The organization considers the potential impacts of new business lines, dramatically altered compositions of
existing business lines, acquired or divested business operations on the system of internal control, rapid growth, changing reliance on foreign geographies,
and new technologies.
• Assesses Changes in Leadership—The organization considers changes in management and respective attitudes and philosophies on the system of internal
control.
• (Other entity specific points of focus, if any)
Identification No. Internal control deficiency description Evaluate preliminary deficiency severity:
(Consider whether other controls to effect this
principle compensate for the internal control
deficiency.)
—The organization selects and develops control activities that contribute to the mitigation of risks to the achievement of objectives to
acceptable levels.
Points of Focus
• Integrates with Risk Assessment—Control activities help ensure that risk responses that address and mitigate risks are carried out.
• Considers Entity-Specific Factors—Management considers how the environment, complexity, nature, and scope of its operations, as well as the specific
characteristics of its organization, affect the selection and development of control activities.
• Determines Relevant Business Processes—Management determines which relevant business processes require control activities.
• Evaluates a Mix of Control Activity Types—Control activities include a range and variety of controls and may include a balance of approaches to mitigate risks,
considering both manual and automated controls, and preventive and detective controls.
• Considers at What Level Activities Are Applied—Management considers control activities at various levels in the entity.
• Addresses Segregation of Duties—Management segregates incompatible duties, and where such segregation is not practical management selects and
develops alternative control activities.
• (Other entity specific points of focus, if any)
Identification No. Internal control deficiency description Evaluate preliminary deficiency severity:
(Consider whether other controls to effect this
principle compensate for the internal control
deficiency.)
—The organization selects and develops general control activities over technology to support the achievement of objectives.
Points of Focus
• Determines Dependency between the Use of Technology in Business Processes and Technology General Controls—Management understands and
determines the dependency and linkage between business processes, automated control activities, and technology general controls.
• Establishes Relevant Technology Infrastructure Control Activities—Management selects and develops control activities over the technology infrastructure,
which are designed and implemented to help ensure the completeness, accuracy, and availability of technology processing.
• Establishes Relevant Security Management Process Control Activities—Management selects and develops control activities that are designed and
implemented to restrict technology access rights to authorized users commensurate with their job responsibilities and to protect the entity’s assets from
external threats.
• Establishes Relevant Technology Acquisition, Development, and Maintenance Process Control Activities—Management selects and develops control activities
over the acquisition, development, and maintenance of technology and its infrastructure to achieve management’s objectives.
Identification No. Internal control deficiency description Evaluate preliminary deficiency severity:
(Consider whether other controls to effect this
principle compensate for the internal control
deficiency.)
—The organization deploys control activities through policies that establish what is expected and procedures that put policies into action.
Points of Focus
• Establishes Policies and Procedures to Support Deployment of Management’s Directives—Management establishes control activities that are built into
business processes and employees’ day-to-day activities through policies establishing what is expected and relevant procedures specifying actions.
• Establishes Responsibility and Accountability for Executing Policies and Procedures—Management establishes responsibility and accountability for control
activities with management (or other designated personnel) of the business unit or function in which the relevant risks reside.
• Performs in a Timely Manner—Responsible personnel perform control activities in a timely manner as defined by the policies and procedures.
• Takes Corrective Action—Responsible personnel investigate and act on matters identified as a result of executing control activities.
• Performs Using Competent Personnel—Competent personnel with sufficient authority perform control activities with diligence and continuing focus.
• Reassesses Policies and Procedures—Management periodically reviews control activities to determine their continued relevance, and refreshes them when
necessary.
• (Other entity specific points of focus, if any)
Summary of Controls to Effect Principle 12
Identification No. Internal control deficiency description Evaluate preliminary deficiency severity:
(Consider whether other controls to effect this
principle compensate for the internal control
deficiency.)
—The organization obtains or generates and uses relevant, quality information to support the functioning of internal control.
Points of Focus
• Identifies Information Requirements—A process is in place to identify the information required and expected to support the functioning of the other
components of internal control and the achievement of the entity’s objectives.
• Captures Internal and External Sources of Data—Information systems capture internal and external sources of data.
• Processes Relevant Data into Information—Information systems process and transform relevant data into information.
• Maintains Quality throughout Processing—Information systems produce information that is timely, current, accurate, complete, accessible, protected, and
verifiable and retained. Information is reviewed to assess its relevance in supporting the internal control components.
• Considers Costs and Benefits—The nature, quantity, and precision of information communicated are commensurate with and support the achievement of
objectives.
• (Other entity specific points of focus, if any)
Identification No. Internal control deficiency description Evaluate preliminary deficiency severity:
(Consider whether other controls to effect this
principle compensate for the internal control
deficiency.)
—The organization internally communicates information, including objectives and responsibilities for internal control, necessary to
support the functioning of internal control.
Points of Focus
• Communicates Internal Control Information—A process is in place to communicate required information to enable all personnel to understand and carry out
their internal control responsibilities.
• Communicates with the Board of Directors—Communication exists between management and the board of directors so that both have information needed to
fulfill their roles with respect to the entity’s objectives.
• Provides Separate Communication Lines—Separate communication channels, such as whistle-blower hotlines, are in place and serve as fail-safe mechanisms
to enable anonymous or confidential communication when normal channels are inoperative or ineffective.
• Selects Relevant Method of Communication—The method of communication considers the timing, audience, and nature of the information.
Identification No. Internal control deficiency description Evaluate preliminary deficiency severity:
(Consider whether other controls to effect this
principle compensate for the internal control
deficiency.)
—The organization communicates with external parties regarding matters affecting the functioning of internal control.
Points of Focus
• Communicates to External Parties—Processes are in place to communicate relevant and timely information to external parties including shareholders,
partners, owners, regulators, customers, and financial analysts and other external parties.
• Enables Inbound Communications—Open communication channels allow input from customers, consumers, suppliers, external auditors, regulators, financial
analysts, and others, providing management and the board of directors with relevant information.
• Communicates with the Board of Directors—Relevant information resulting from assessments conducted by external parties is communicated to the board of
directors.
• Provides Separate Communication Lines—Separate communication channels, such as whistle-blower hotlines, are in place and serve as fail-safe mechanisms
to enable anonymous or confidential communication when normal channels are inoperative or ineffective.
• Selects Relevant Method of Communication—The method of communication considers the timing, audience, and nature of the communication and legal,
regulatory, and fiduciary requirements and expectations.
Identification No. Internal control deficiency description Evaluate preliminary deficiency severity:
(Consider whether other controls to effect this
principle compensate for the internal control
deficiency.)
—The organization selects, develops, and performs ongoing and/or separate evaluations to ascertain whether the components of
internal control are present and functioning.
Points of Focus
• Considers a Mix of Ongoing and Separate Evaluations—Management includes a balance of ongoing and separate evaluations.
• Considers Rate of Change—Management considers the rate of change in business and business processes when selecting and developing ongoing and
separate evaluations.
• Establishes Baseline Understanding—The design and current state of an internal control system are used to establish a baseline for ongoing and separate
evaluations.
• Uses Knowledgeable Personnel—Evaluators performing ongoing and separate evaluations have sufficient knowledge to understand what is being evaluated.
• Integrates with Business Processes—Ongoing evaluations are built into the business processes and adjust to changing conditions.
• Adjusts Scope and Frequency—Management varies the scope and frequency of separate evaluations depending on risk.
—The organization evaluates and communicates internal control deficiencies in a timely manner to those parties responsible for taking
corrective action, including senior management and the board of directors, as appropriate.
Points of Focus
• Assesses Results—Management and the board of directors, as appropriate, assess results of ongoing and separate evaluations.
• Communicates Deficiencies—Deficiencies are communicated to parties responsible for taking corrective action and to senior management and the board of
directors, as appropriate.
• Monitors Corrective Actions—Management tracks whether deficiencies are remediated on a timely basis.
Identification No. Internal control deficiency description Evaluate preliminary deficiency severity:
(Consider whether other controls to effect this
principle compensate for the internal control
deficiency.)
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This template is an example of a summary of deficiencies. Management may tailor this template to include additional columns to capture other relevant information, as n