Insights from the 2023 COSO ICIF report

Takeaways and ways to build an effective ESG reporting architecture

With the impending finalization of the SEC Climate-Related Disclosures rule, the pressure is on to address the biggest challenge in voluntary ESG reporting: consistency and comparability of data. As companies are reevaluating their current ESG data controls and revising their reporting processes to work toward compliance, the demand for effective tools and guidance keeps growing.

Companies have used the COSO Internal Control—Integrated Framework (ICIF) to successfully create controls for their financial information for 30 years, and nonfinancial information for the past decade. Their 130-page, 2023 interpretive publication reinterprets the framework specifically for sustainability information. It can be used by companies that are just beginning as well as companies that are years into ESG reporting—there is no need to start over. We believe it is the best tool for creating and implementing a strong control structure to support ESG reporting requirements.

In this paper, we walk through each principle and discuss how it can be applied to ESG data, and at the end of each component, list some key considerations.

COSO ICIF for ESG Reporting
The Committee of Sponsoring Organizations of the Treadway Commission (COSO) developed the Internal Control—Integrated Framework (ICIF) as an infinitely adjustable control infrastructure, applicable across sectors and industries, that companies can adapt to their individual needs.

Contact us

Steve Estes

Steve Estes

ESG Governance Leader, KPMG US

+1 214-840-2448
Aila Pallera

Aila Pallera

Principal | Internal Audit & Enterprise Risk, KPMG US

+1 213-955-8918
Sue King

Sue King

Partner and SOX Solutions Lead, KPMG LLP

+1 213-955-8399
Michael A. Smith

Michael A. Smith

Partner, Advisory, and U.S. Internal Audit Solution Leader, KPMG US

+1 214-840-6019
Debbie Biddle-Castillo

Debbie Biddle-Castillo

Advisory Managing Director, Internal Audit & Enterprise Risk, KPMG US

+1 213-533-3375
Ivor O’Neill

Ivor O’Neill

Advisory Managing Director, Internal Audit & Enterprise Risk, KPMG US

+1 614-241-4636