Assess and Envision—Through literature reviews, global surveys, and public forums, this phase identified current challenges for organizations in implementing the Framework. During this phase, PwC analyzed information, reviewed various sources of input, and identified critical issues and concerns. COSO launched a global survey, available to the general public for providing input on the original framework, soliciting over 700 responses.

Build and Design—PwC, with COSO Board oversight, developed the updated Framework. Multiple drafts of the documents were reviewed by the Advisory Council, and various user and stakeholder groups provided additional insight about proposed updates via participation in conferences, webinars, and seminars sponsored by COSO organizations.

Preparation for Public Exposure—With assistance provided by the Advisory Council and oversight of the COSO Board, PwC prepared exposure drafts and an on-line questionnaire to facilitate a review by the general public. The COSO Board and PwC asked for comments from the general public on many relevant topics, including whether the:

Requirements of effective internal control are clearly set forth in the Framework

Roles of components, relevant principles, and points of focus are clearly set forth in the Framework

The Framework is sound, logical, and useful to management of entities of all sizes.

Public Exposure—In this phase, PwC refined the update through reviews with the general public. The Framework was issued for public exposure for a 104-day comment period. During this phase, PwC, COSO Board members, and Advisory Council members presented the updated Framework at numerous professional conferences, seminars, round tables, and meetings with users and stakeholders. The updated Framework was also made available for comment during the public exposure of the companion documents: Internal Control over External Financial Reporting: Compendium of Approaches and Examples, and Illustrative Tools for Assessing Effectiveness of a System of Internal Control. PwC reviewed and analyzed all comments received during these public exposure periods, and reviewed resolutions and modifications related to more significant issues raised during public exposure with the COSO Board and Advisory Council.

Finalization—PwC finalized the Framework and related publications and provided final documents to the COSO Board for review and acceptance.