Reporting Governance · Record-to-Report
Controls
SOX 404 · ICFR · COSO 2013 control framework overlay
Framework Coverage
ICFRDeveloping
56%
0 covered2 partial1 gap
ICFR
KPI Definition Register AbsenthighDocumentation
No single authoritative register of KPI definitions; definitions vary across reporting channels creating silent inconsistency
ACTIONCreate and publish a KPI definition register with versioning; require sign-off before any definition change
Metric Lineage UndocumentedhighDocumentation
Calculation methodology for key metrics not documented; changes made without audit trail or approval workflow
ACTIONDocument metric lineage and calculation logic; implement change control for all metric definition updates
Board Pack Sign-off GaphighApproval Controls
Board pack distributed without formal CFO review and sign-off in multiple quarters; no evidence trail retained
ACTIONEnforce mandatory CFO sign-off before board pack distribution; retain sign-off evidence in system of record
Commentary Ownership FragmentedmediumOwnership
Narrative commentary assigned informally each period; no standing owner, review gate, or consistency standard
ACTIONAssign standing commentary owner per reporting channel; implement peer review gate before distribution
Reporting Single Point of FailuremediumSegregation of Duties
End-to-end reporting process owned by single FP&A Manager with no deputy, documented succession, or cross-training
ACTIONDesignate and train a deputy FP&A Manager; document full reporting process handover procedure