Evaluating Blockchain and Internal Control Through a COSO Lens

: on 07 August 2020

While blockchain is still a mystery to many people, Big 4 surveys indicate that blockchain is critical and amongst the top-five strategic priorities for the majority of larger businesses surveyed, and that more than three-quarters of those responding to such executive surveys are actively involved in blockchain themselves. Individually, professional bodies associated with the business reporting supply chain are delivering their own guidance and thought-leadership materials (1).

At such a crucial time, the pandemic has led to limited opportunities to meet together within and across these organizations to discuss the relevant issues – not within the islands of individual professional organizations, let alone in collaborative forums that can bring together the needs, motivations and potential contributions of financial executives, internal auditors, external auditors, management accountants and academics.

On what has evolved as a timely basis, the Committee of Sponsoring Organizations of the Treadway Commission (COSO) released on Tuesday (August 4, 2020) a new thought leadership paper, Blockchain and Internal Control: The COSO Perspective (2020) (2). The paper sought to provide insight on how to leverage the COSO Internal Control – Integrated Framework (2013) when considering implementing blockchain within an organization.

Like blockchain, COSO is a mystery to some people. We all know about the topic of internal controls; many of us are familiar with the so-called “COSO Cube”; most larger companies’ annual filings with the US SEC have an auditor’s report on internal controls that refers specifically to how the audited company “maintained, in all material respects, effective internal control over financial reporting as of ##/##/####, based on the criteria established in Internal Control – Integrated Framework (2013) issued by COSO.

COSO brings together representatives to the focus groups mentioned above:

Financial executives (FEI)
Internal auditors (IIA)
External auditors (AICPA)
Management accountants (IMA), and
Academics (AAA)

As noted in the COSO press release, I am one of the co-authors. My goals included helping counter the fallacies, providing an objective view to both potential benefits and risks, and bringing together stakeholder communities to come together for the greatest possible WIN-WIN-WIN situation.

It was a terrific exercise. The Cube was a great place to start in thinking through the potential impacts of blockchain. One side of the cube speaks to the subdivision of the Entity itself; blockchain has the potential to transform the nature of what we consider an entity, blurring the lines of where internal controls must operate (see discussions within on consortium blockchains, for example). Another side speaks to “Operations, Reporting and Compliance” – all of these areas may be impacted by blockchain, in conjunction with other emerging technologies. Finally, there are the five components and seventeen principles; I’ll probably write more about them soon, but you can read up in the meanwhile.

Footnotes:

(1) For example, CPA Canada’s resources can be found at https://www.cpacanada.ca/en/business-and-accounting-resources/other-general-business-topics/information-management-and-technology/publications/cpa-perspectives-on-blockchain

(2) https://www.coso.org/Documents/Blockchain-and-Internal-Control-The-COSO-Perspective-Guidance.pdf

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Data Driven Sustainability Decisions

Tuesday, 03 May 2022

Gerald Trites, FCA, CISA

While companies have traditionally viewed sustainability decisions as separate from monetary decisions, this is changing. It’s partly because of generational changes, with millennials now being the largest component of the workplace and partly considerations driven by customer demand, investor demand regulatory requirement and common-sense observation of the destruction caused by climate change. Compelling reasons.

Companies have been moving more clearly to data driven decision making for several years. So it makes sense they would turn to data to drive their decisions in the sustainability area.

To accomplish this, they need to first define their sustainability goals. This usually begins with industry trends and information from stakeholders about their sustainability concerns and the development of a sustainability strategic plan. Second, begins the process of data modelling and analysis drawn from internal and external sources. Many organizations have well defined data gathering processes already in place, but these need to be modified to take into account sustainability goals. Finally, the adoption of data driven sustainability decision making requires the adoption of AI techniques to automate data gathering, modelling and reporting functions.

Established enterprise systems are moving in this direction, the availability of which, as well as their compatibility with existing systems, is an important consideration.

Overall, a creative combination of data management, analytics, AI and integration of sustainability processes with established corporate processes are crucial to a successful outcome – the creation of a truly sustainable enterprise.

How All Accounting Reports Will be Digitized

Thursday, 31 March 2022

Gerald Trites, FCA

The SEC was the major regulatory body that got the ball rolling in 2009, when it mandated rules for the use of the interactive data format (XBRL) for public company financial statements. Then several other countries and organizations got on the band wagon. There was a relatively quiet period for a few years, when the new electronic form of reporting seemed stalled. But then the EU stepped in and began requiring their ESEF filings in 2021. That meant most of the major companies in the world were using digitized reporting.

For regulators and governments, digital filing of reports has been an opportunity to streamline the processing and analysis of the reports. Users such as investors, on the other hand, have often been unsure about what to do with these reports.

The fact is, much attention has been given in recent years to the production of digital reports, but very little given to their consumption. True, there are utilities that can be purchased to enable people to read reports in digitized form, the SEC provides such a one, and the recent moves to inline XBRL mean the reports can be read in the conventional way, (ESEF is a variation on inline XBRL). But most of these attempts to render digital reports readable cater to the idea of sequential reading in the conventional sense. Most people do not read this way, unless perhaps they are reading a novel. When they want information, they tend to go to that information as fast as they can. This is the standard approach most people follow in using the internet. People don’t read the internet. Nor generally do they read a corporate website from beginning to end. That would be bizarre!

But yet, we provide annual reports in paper or PDF form, which extend to around 150 pages and often more, of difficult, often technical, material and expect people to read them. It doesn’t happen. Professional analysts might, but they are more likely to employ analytical tools to get the information they need.

There is an excellent article on the website of the International Federation of Accountants (IFAC) by Amir Ghandar, titled “The Accounting Revolution Will Be Digitized”.^[1] In that article, Mr Ghandar points out that “A 2D, static annual report format in paper or pdf is not that different to the papyrus on which Egyptian scribes reported on the royal inventories more than 7,000 years ago.”

Much more than this is needed in the modern world. Technology and complexity have advanced tremendously and the style of reporting needs to keep pace.

Two areas need further work. One involves the steps necessary to encourage legislators and regulators in countries to adopt digital reporting. While a majority of countries have adopted it, there is still a number who haven’t. Then there is the need to take the steps to change digital reporting to make it more understandable and usable to the users. This means providing the resources for them to actually draw out the data they want. These resources need to be made available along with the reports themselves. Some companies in their websites have started doing this, through the provision of data banks and some analytical tools, however it needs to become commonplace and much more powerful and sweeping.

Developing this approach to corporate reporting requires interaction and discussion between corporate reporters and users, regulators and standards-setters to address the issues.

Those issues involve more than figuring out how to present digital information and how to use it. It involves determining what information to present, how to present it and when. It involves looking back at the basic tenets that have ruled accounting since its beginnings. The need for annual and other periodic reports. Can they be continuous? Can we eliminate the need for those pesky annual accounting judgements that cause so much trouble? Can we include the tools for analysis within the disclosures rather than relying on the software industry to deliver them? This cannot be accomplished within paper or pdf reports, but rather on the corporate websites. Most companies have moved their reporting to their websites. But they generally have ported over the old paper paradigm, rather than seriously adopting new and innovative ways to report in the information age. It’s well past time we did that.

https://www.ifac.org/knowledge-gateway/contributing-global-economy/discussion/accounting-revolution-will-be-digitized

^[1] https://www.ifac.org/knowledge-gateway/contributing-global-economy/discussion/accounting-revolution-will-be-digitized

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