A fish can’t survive in dirty water, and your controls can’t thrive in the wrong environment. That’s where Entity Level Controls (ELCs) come in. COSO 2013 didn’t introduce new governance concepts, but it did give our profession a comprehensive set of principles to assess our organizations against. A decade later, many organizations still struggle to get real value from their ELC assessments.

In this short video, I share three priorities, drawn from years of practice (and some trial and error), to help you review the health of your ELCs:

1. Match and continually adapt your ELCs to your organization’s maturity

  • A small organization doesn’t need the same governance program as a large multinational.
  • Ask whether processes like budgeting, risk management and HR practices fit your current size and risk level.
  • It’s normal to raise the bar as you grow.

2. Group your questions into logical buckets and use a strong template

  • Early COSO 2013 templates often turned assessments into a laundry list or a game of whack-a-mole.
  • The model was never meant to be prescriptive, so professional judgment matters.
  • I share how our 13-point approach helps focus on the bigger questions.

3. Focus on continuous improvement, not pass/fail

  • Unlike transactional testing, ELCs are about getting better year over year.
  • The most value comes when Management reflects on where the organization is heading and the tangible steps it wants to take.

I also touch on how transformation, AI, outsourcing and gig work are reshaping governance today, and why the fundamentals of COSO 2013 still hold.

Watch the video below to see how it works. 👇