An Excerpt from

A Comparison of Internal Controls:
COBIT®, SAC, COSO and SAS 55/78

By: Janet L. Colbert, Ph.D., CPA, CIA
and Paul L. Bowen, Ph.D., CPA

In recent years, increased attention has been devoted to internal control by auditors, managers, accountants, and legislators. Five recently issued documents are the result of continuing efforts to define, assess, report on, and improve internal control. They are: the Information Systems Audit and Control Foundation's COBIT (Control Objectives for Information and related Technology), the Institute of Internal Auditors Research Foundation's Systems Auditability and Control (SAC), the Committee of Sponsoring Organizations of the Treadway Commission's Internal Control - Integrated Framework (COSO), and the American Institute of Certified Public Accountants' Consideration of the Internal Control Structure in a Financial Statement Audit (SAS 55), as amended by Consideration of Internal Control in a Financial Statement Audit: An Amendment to SAS 55 (SAS 78).

COBIT (1996) is a framework providing a tool for business process owners to efficiently and effectively discharge their IS control responsibilities. SAC (1991, revised 1994) offers assistance to internal auditors on the control and audit of information systems and technology. COSO (1992) makes recommendations to management on how to evaluate, report, and improve control systems. SASs 55 (1988b) and 78 (1995) provide guidance to external auditors regarding the impact of internal control on planning and performing an audit of an organization's financial statements.

Because different bodies developed the documents to address the specific needs of their own audiences, some disparities may exist. Nevertheless, each document focuses on internal control and each audience, i.e., internal auditors, management, and external auditors, devotes much time and effort toward establishing or evaluating internal controls. Therefore, comparing the internal control concepts presented in these documents is of interest to members of all three audiences.

A comparison of the five documents reveals that each builds on the contributions of the previous documents. COBIT incorporates as part of its source documents booth COSO and SAC. It takes its definition of control from COSO and its definition of IT Control Objectives from SAC. SAC embodies the internal control concepts developed in SAS 55, COSO uses the internal control concepts in both SAS 55 and SAC, and SAS 78 amends SAS 55 to reflect the contributions to internal control concepts made by COSO. In particular, SAS 78 responds to the Winters and Guy (1992) call for a reconciliation of the internal control concepts presented in the COSO report and SAS 55.

This article summarizes the four documents (SAC 55/78 are combined.) and compares the internal control concepts presented in each. The following Table notes the major issues presented.

Comparison of Control Concepts
COBIT SAC COSO SASs 55/78
Primary Audience Management, users, information system auditors Internal Auditors Management External Auditors
IC viewed as a Set of processes including policies, procedures, practices, and organizational structures Set of processes, subsystems, and people Process Process
IC Objectives organizational Effective & efficient operations
Confidentiality, Integrity and availability of information
Reliable financial reporting
Compliance with laws & regs
Effective & efficient operations
Reliable financial reporting
Compliance with laws & regs
Effective & efficient operations
Reliable financial reporting
Compliance with laws & regs
Reliable financial reporting
Effective & efficient operations
Compliance with laws & regs
Components or Domains Domains:
Planning and organization
Acquisition and implementation
Delivery and support
Monitoring
Components:
Control Environment
Manual & Automated
Systems Control Procedures
Components:
Control Environment
Risk Management Control
Activities Information & Communication Monitoring
Components:
Control Environment Risk
Assessment Control
Activities Information & Communication Monitoring
Focus Information Technology Information Technology Overall Entity Financial Statement
IC Effectiveness Evaluated For a period of time For a period of time At a point in time For a period of time
Responsibility for IC System Management Management Management Management
Size 187 pages in four documents 1193 pages in 12 modules 353 pages in four volumes 63 pages in two documents