New Year, New COSO

If you haven't already transitioned to the new COSO 2013 Framework, now is the time!  Previously, guidance was somewhat vague, stating that the transition date was December 15, 2014, but that the SEC would defer to the COSO board in regards to the transition timing.  This led to many companies choosing to delay the transition to the new Framework until 2015.

According to a Compliance Week article titled “More Hints on Putting New COSO to Work,” at the most recent annual national conference for the American Institute of Certified Public Accountants, the SEC Deputy Chief Accountant, Nili Shah, addressed the topic.  He stated that “At least for the 2014 reporting season, we will not object to companies that continue to use the 1992 Framework, but as we move further from the end of COSO’s transition period, both investors and we may continue to question continued use of the 1992 Framework.” 

Auditors are cautioned to look for strong business reasons for not adopting the new framework, going forward.   Being too busy with other projects or not being able to comply with the new Framework are not acceptable reasons. It is of utmost importance that during the transition period, companies must disclose in the financial statements which Framework they are using.

Does your company still need to make the leap to the 2013 Framework?  If so, Schneider Downs has professionals that have significant experience with the new Framework and can help guide you through the transition.  We can help you map your current controls to the new COSO principles with our detailed mapping tools that we have developed.  For more information on how Schneider Downs can assist you or your company with implementing the COSO 2013 Framework, contact Jim Yard at 412-697-5345 or

This advice is not intended or written to be used for, and it cannot be used for, the purpose of avoiding any federal tax penalties that may be imposed, or for promoting, marketing or recommending to another person, any tax related matter.

You’ve heard our thoughts… We’d like to hear yours

The Schneider Downs Our Thoughts On blog exists to create a dialogue on issues that are important to organizations and individuals. While we enjoy sharing our ideas and insights, we’re especially interested in what you may have to say. If you have a question or a comment about this article – or any article from the Our Thoughts On blog – we hope you’ll share it with us. After all, a dialogue is an exchange of ideas, and we’d like to hear from you. Email us at

Material discussed is meant for informational purposes only, and it is not to be construed as investment, tax, or legal advice. Please note that individual situations can vary. Therefore, this information should be relied upon when coordinated with individual professional advice.

© 2019 Schneider Downs. All rights-reserved. All content on this site is property of Schneider Downs unless otherwise noted and should not be used without written permission.

our thoughts on

The Privacy of Consumer Banking Data and the Financial Data Exchange
National Flood Insurance Program Extension
Continued Compliance with CAISO SQMD Requirements in Non-Reporting Years
Bill S. 1564 Calls for Delay of CECL Implementation Until a Quantitative Economic Impact Study is Completed
Artificial Intelligence in Higher Education
Why Higher Education Institutions Must Comply with GDPR

Register to receive our weekly newsletter with our most recent columns and insights.

Have a question? Ask us!

We’d love to hear from you. Drop us a note, and we’ll respond to you as quickly as possible.

Ask us

contact us

Map of Pittsburgh Office

One PPG Place, Suite 1700
Pittsburgh, PA 15222
p:412.261.3644     f:412.261.4876

Map of Columbus Office

65 East State Street, Suite 2000
Columbus, OH 43215
p:614.621.4060     f:614.621.4062

Map of Washington Office
Washington, D.C.

1660 International Drive, Suite 600
McLean, VA 22102