Global Recession Didn't Hamper Sarbanes-Oxley Compliance Efforts, According to Survey from Protiviti

New study reveals state of SOX through candid insights from U.S. executives; June 14 Protiviti webinar will explore survey results

Jun 13, 2011, 14:00 ET from Protiviti

MENLO PARK, Calif., June 13, 2011 /PRNewswire/ -- An overwhelming majority of finance and audit executives say that the global recession didn't impact their Sarbanes-Oxley (SOX) compliance efforts, according to new research from Protiviti (, a global business consulting and internal audit firm. In fact, 45 percent of respondents to Protiviti's 2011 Sarbanes-Oxley Compliance Survey ( said that internal control over financial reporting in their organizations is better now than it was one year ago.


Protiviti's 2011 Sarbanes-Oxley Compliance Survey – which includes feedback from a combination of more than 400 executives, corporate SOX leaders and audit professionals across a variety of industries – assesses the current state of SOX compliance, related costs, associated benefits and value, as well as how to achieve a desired state of verifiable compliance and sustainability. This is the second year the survey has been conducted, and this year it includes two new sections focusing on the impact of the economic events of 2009 on ongoing compliance with SOX requirements and the exemption of non-accelerated filers from Section 404(b) compliance as stipulated in the Dodd-Frank Act.

"Our survey results demonstrate that nine years after the passage of Sarbanes-Oxley, companies remain committed to continuously improving their compliance efforts – despite ongoing economic challenges and global instabilities," said Bob Hirth, Protiviti executive vice president and leader of the firm's global internal audit and financial controls practice. "Organizations' systems of internal control over financial reporting need to be dynamic and constantly improved in order to effectively react to and address changes in operations and the external environment, such as new regulations, technology, accounting principles, industry issues and business models."

The vast majority, 89 percent, of respondents said the global recession did not have an adverse effect on their SOX compliance efforts. "In reality, it may take a number of years to gain a clear picture of the effects the global economic crisis may have created," Hirth said. "If an organization reduced its workforce or streamlined its processes with a resulting effect on its internal control structure, mistakes may increase over time. Given this, it will be interesting to monitor these survey results over the next few years to see what patterns develop."

Other key findings from Protiviti's 2011 SOX survey include:

  • By year four of SOX compliance, most organizations spend in the range of $100,000 to $1 million annually on SOX compliance-related activities. More than 80 percent of small companies spend less than $100,000 annually, and nearly 70 percent of mid-sized companies spend less than $500,000 on SOX compliance.  
  • Companies, regardless of size or year of compliance, plan to reduce SOX compliance costs in the coming year, but that reduction is expected to be nominal – less than 10 percent on average.
  • Compared to 2010 survey results, more organizations are applying COSO's guidance on monitoring internal control systems, and one in three reports this is having a positive impact on their SOX compliance activities.
  • About 50 percent of organizations handle their SOX compliance efforts internally; this statistic is relatively consistent regardless of company size.
  • Fifty-six percent of non-accelerated filers – who became exempt from having to comply with Section 404(b) of SOX (the auditor attestation of internal control over financial reporting) with the passage of the Dodd-Frank Act in July 2010 – reported their organizations were "very prepared" to comply with Section 404(b) when Dodd-Frank pulled the plug on the requirement, while 29 percent said they were "somewhat prepared." These filers, however, also noted that areas related to IT and automation – including IT general controls, spreadsheet controls, and segregation of duties – would have required the most attention if they were required to comply with Section 404(b).

"While non-accelerated filers currently are exempt under law from the need to comply with Section 404(b), the question is whether this exemption is permanent," said Jim DeLoach, Protiviti managing director and the firm's senior SOX practice leader as well as a key survey architect. "If restatements by these filers were to trend upwards and restatements by companies complying with Section 404(b) were to continue trending downward, Congress could decide to revisit whether a new law should be enacted to mandate compliance. In addition, an organization cannot rule out the possibility that it could grow beyond non-accelerated filer status and, as a result, be compelled to comply with Section 404(b)."

The survey also finds that organizations are increasingly looking to IT solutions to improve the effectiveness and efficiency of their compliance efforts. Among the top three strategies respondents plan to employ in 2011 and beyond:

  • Increasing the number of automated controls
  • Using continuous monitoring techniques
  • Decreasing the number of manual controls

Webinar and Podcast Explore Survey's Results

Protiviti will host a complimentary 90-minute webinar titled "Where U.S.-listed Companies Stand: Reviewing Cost, Time, Effort and Processes" to review the results of its SOX compliance survey on June 14 at 11:00 am PDT. Moderated by Hirth, the speakers will include DeLoach along with Protiviti Managing Directors Paresh Raghani and Tony Samer. To register for the webinar, please click here or visit

Additionally, Hirth and DeLoach have recorded a podcast delving into the survey's findings, "Perspectives on Sarbanes-Oxley Compliance – Where Companies are Saving Costs and Achieving Greater Efficiencies," that is available at

Protiviti's 2011 Sarbanes-Oxley Compliance Survey gathered insights from professionals at companies with gross annual revenues ranging from less than $100 million to more than $20 billion. Seventy-nine percent of respondents work for companies in or beyond their fourth year of SOX compliance and 83 percent are from large or accelerated filers.

The 2011 Sarbanes-Oxley Compliance Survey was completed in the first quarter of 2011 to assess the strategies and tactics companies have employed to derive value from the SOX compliance process. A complimentary copy of the survey is available at

About Protiviti

Protiviti is a global business consulting and internal audit firm composed of experts specializing in risk, advisory and transaction services. The firm helps solve problems in finance and transactions, operations, technology, litigation, governance, risk, and compliance. Protiviti's highly trained, results-oriented professionals provide a unique perspective on a wide range of critical business issues for clients in the Americas, Asia-Pacific, Europe and the Middle East.

Protiviti has more than 60 locations worldwide and is a wholly owned subsidiary of Robert Half International Inc. (NYSE: RHI). Founded in 1948, Robert Half International is a member of the S&P 500 index.

Protiviti is not licensed or registered as a public accounting firm and does not issue opinions on financial statements or offer attestation services.

SOURCE Protiviti