Service 06 — Controls

ICOFR Implementation & Testing

Riskweise implements Internal Controls Over Financial Reporting (ICOFR) frameworks aligned with COSO 2013 — covering risk-control matrix design, walkthroughs, operating effectiveness testing, deficiency remediation, and management attestation support — for GCC banks, NBFCs, fintechs, and listed entities.

ICOFR engagements range from first-time implementation to remediation of audit findings to ongoing testing programs. The framework supports management attestation, external auditor coordination, and audit committee reporting under the supervisory and listing-authority requirements of every GCC jurisdiction.

Methodology

How we approach it.

01 — Component

Framework design

Risk and control environment assessment, financial reporting process mapping, control identification and classification (entity-level, process-level, IT general), risk-control matrix development, and ICOFR policy and governance documentation.

02 — Component

Control testing

Design effectiveness testing through walkthroughs, operating effectiveness testing through sampling, deficiency identification with explicit severity classification, remediation action tracking and re-testing, and full testing documentation and evidence management.

03 — Component

Governance & reporting

Management assessment and attestation support, audit committee reporting frameworks, external auditor coordination and readiness, ongoing monitoring program design, and annual ICOFR cycle planning and execution.

What we deliver

Concrete outputs.

  • ICOFR policy and governance documentation
  • Risk-control matrix mapped to financial reporting processes
  • Control identification (entity-level, process-level, IT general)
  • Walkthrough documentation for design effectiveness
  • Operating effectiveness testing results with sampling
  • Deficiency tracker with severity classification
  • Remediation plans and re-testing evidence
  • Management attestation pack for audit committee
Who this is for

The fit.

  • Listed entities subject to external audit attestation
  • Banks and financial institutions under regulatory ICOFR requirements
  • NBFCs and fintechs preparing for first audit cycle
  • Banks responding to ICOFR deficiency findings
  • Institutions consolidating ICOFR across cross-border subsidiaries
  • Listed entities preparing for IPO or new market listing
Common questions

Questions we get asked.

Who needs ICOFR in the GCC?

Listed entities on GCC exchanges (DFM, ADX, Tadawul, BHB, QSE, Boursa Kuwait, MSX) generally have ICOFR attestation requirements. Banks and licensed financial institutions face ICOFR expectations from their central bank regardless of listing status. NBFCs and fintechs typically need ICOFR ahead of external audit and licensing milestones. The level of formality scales with size and listing status.

What does COSO 2013 alignment mean?

COSO 2013 is the global standard framework for internal control, structured around five components and seventeen principles. Alignment means the institution's ICOFR framework explicitly addresses each principle — control environment, risk assessment, control activities, information and communication, and monitoring activities. External auditors and regulators reference COSO 2013 directly when assessing framework adequacy.

How are deficiencies classified?

Three tiers: control deficiency (a control gap that does not rise to material weakness), significant deficiency (gap material enough to merit audit committee attention but not Board), and material weakness (gap creating reasonable possibility of material misstatement). Classification drives both remediation urgency and disclosure requirements — material weaknesses typically need formal disclosure under listing rules.

How long does an ICOFR implementation take?

First-time implementation for a mid-sized bank or listed entity: 16-24 weeks including framework design, control identification, walkthroughs, and first testing cycle. Smaller NBFCs or fintechs: 10-14 weeks. Remediation engagements following audit findings: 6-12 weeks depending on deficiency scope. Annual testing cycles thereafter: 8-12 weeks.

Do you coordinate with external auditors?

Yes. We work alongside (or directly with) your external auditors so the ICOFR framework, control testing, and documentation are organised to their expectations. This avoids the common failure mode where management ICOFR work and auditor ICOFR work duplicate or conflict — both teams end up working from the same risk-control matrix and testing evidence.

Is ICOFR separate from internal audit?

Yes — they overlap but serve different purposes. ICOFR is a management process for financial reporting integrity. Internal audit is an independent assurance function reviewing the institution as a whole. Internal audit may test ICOFR as part of its plan, but the ICOFR framework itself is owned by management and reports to the audit committee. Riskweise handles both, separately, with clear role distinction.

Get in touch

Tell us about your controls engagement.

We respond within one business day. No agency-style discovery process — straight to scope, fit, and what you actually need.

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