Internal controls

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Internal controls

Also called internal control system, internal control framework

Definition

Internal controls are the policies, procedures, checks and systems a firm uses to make sure its operations run as intended, its reporting is reliable and it complies with laws and regulations. They include payment approvals, reconciliations, segregation of duties, access rights and automated system checks.

ENVIRONMENTRISK ASSESSMENTACTIVITIESINFORMATION
Fig. 1 · Internal controls
Basel internal control framework · Sarbanes-Oxley Act, section 404 · CRD, Article 74
Key rulesBasel internal control framework · Sarbanes-Oxley Act, section 404 · CRD, Article 74 · UK Corporate Governance Code 2024, Provision 29
Applies toCompanies with securities registered with the SEC and their auditors
RegionsGlobal · UK · EU · US
01

How it works

Controls are designed against specific risks. Preventive controls stop a problem happening, such as dual approval of payments or system limits. Detective controls find problems after the event, such as reconciliations and exception reports. Controls can be manual or automated, and most firms map them to risks in a risk and control matrix, often following the COSO framework of control environment, risk assessment, control activities, information and monitoring.

The first line runs the controls day to day, the second line sets standards and challenges them, and internal audit tests whether they work. Testing looks at design, whether the control would address the risk, and operating effectiveness, whether it worked in practice over a period. Failures are logged as issues with owners and deadlines, and boards report on control effectiveness to shareholders and regulators.

Step 1Assess risksIdentify what could go wrong in each process.
Step 2Design controlsSet preventive and detective checks against each risk.
Step 3OperateRun the controls and keep evidence that they were performed.
Step 4TestCheck design and operating effectiveness on a regular cycle.
Step 5Fix and reportRemediate failures and report effectiveness to the board.
02

The rules

Global · September 1998Basel internal control frameworkBasel Committee on Banking Supervision, Framework for Internal Control Systems in Banking Organisations

Sets principles for board and management oversight, control culture, risk assessment, control activities, segregation of duties, information and monitoring.

Banks and their supervisors
US · 30 July 2002Sarbanes-Oxley Act, section 404Sarbanes-Oxley Act of 2002, section 404, Management assessment of internal controls

Requires management to report annually on the effectiveness of internal control over financial reporting, with auditor attestation for larger filers.

Companies with securities registered with the SEC and their auditors
EU · 1 January 2014CRD, Article 74Directive 2013/36/EU (Capital Requirements Directive), Article 74, Internal governance

Requires robust governance arrangements, including effective processes to manage risks and adequate internal control mechanisms with sound administrative and accounting procedures.

Credit institutions and investment firms in scope of the CRD
UK · Financial years beginning on or after 1 January 2026UK Corporate Governance Code 2024, Provision 29Financial Reporting Council, UK Corporate Governance Code 2024, Provision 29

Requires boards to declare whether their material controls, financial, operational, reporting and compliance, were effective at the balance sheet date and to describe any that were not.

Companies with a premium or equity shares listing, on a comply or explain basis
03

Common questions

What are the main types of internal controls?

Preventive controls stop errors or fraud before they happen, detective controls find them afterwards, and corrective controls fix the cause. Each can be manual, automated or a mix of both.

Who is responsible for internal controls?

The board is accountable for the control framework. Business management runs the controls, risk and compliance functions set standards and challenge them, and internal audit gives independent assurance.

What is a control deficiency?

A control deficiency is a control that is missing, badly designed or not operating as intended. Serious deficiencies over financial reporting are called material weaknesses and must be disclosed under SOX.