Internal Control: Guidance for directors on the Combined Code (2025)

In October 2005 the Financial Reporting Council (FRC) issued an updated version of the guidance with the title 'Internal Control: Guidance for Directors on the Combined Code'. In September 2014 this was superseded by the FRC's Risk Guidance.

The report

Internal Control: Guidance for Directors on the Combined Code
Updated version of the Turnbull guidance published by the Financial Reporting Council on 13 October 2005. The updated version took effect for financial years beginning on or after 1 January 2006. In September 2014 it was replaced by theRisk Guidance.

Further information is available on therisk management and internal control page on the FRC website.

Background

The FRC held a series of meetings with companies, investors and advisers in 2011 which were summarised in the reportBoards and riskpublished in September 2011. One of the conclusions reached was that whilst the guidance was "still broadly fit for purpose, some change was needed to reflect the role of the Board as articulated in the new version of the [UK Corporate Governance] Code. The FRC intends to carry out a limited review during 2012."

In November 2013 the FRC launched a consultation on further updates to the guidance. On 17 September 2014 it published the resulting revised guidance,Risk management, internal control and related financial and business reporting(the Risk Guidance). This updates and replaces Internal Control: Guidance for Directors on the Combined Code (formerly known as the Turnbull Guidance).

eBooks

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Exclusive Introduction and background

  • Jul 2017
  • ICSA Publishing
  • ICSA Publishing
  • The ICSA Corporate Governance Handbook

Chapter 1 looks at the development of corporate governance and specifically the history of corporate governance in the UK.

Exclusive Turnbull Report

  • Jan 2005
  • Robert R. Moeller
  • Wiley
  • Brinks Modern Internal Auditing

A complete guide to the process and profession of internal auditing.

Exclusive Turnbull: guidance on internal control

  • Mar 2008
  • Alan Calder
  • Kogan Page
  • Corporate Governance - A Practical Guide to Legal Frameworks

An introduction to governance for directors and executives. Chapter 5 looks at corporate governance in the UK and summarises the Turnbull report.

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More eBooks

  • eBooks on Corporate Governance
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  • A-Z of eBooks

Online articles

The library provides access to a range of articles in full text from leading business, finance and management journals. Access to articles is provided to logged-in ICAEW members, ACA students and other entitled users subject to suppliers' terms of use.

Exclusive Regulation by disclosure: the case of internal control

  • Nov 2010
  • Michael Page | Laura F.Spira

The authors explore the use of disclosure as a regulatory tool, describing the background to the Turnbull guidance for directors on internal control reporting.

Exclusive Work to do with Turnbull 2

  • Feb 2006

The review of the Turnbull guidance on internal controls, led by HSBC FD Douglas Flint, has left a perception that there is virtually no change in the requirements. Martyn Jones points out three significant changes.

Exclusive Sticking two fingers up at Sarbox

  • Jul 2005
  • Andrew Sawers

A short editorial piece by Andrew Sawers, commenting on Douglas Flint's updated Turnbull Report guidance. Sawers approves of the succinct revision, which he views as having rectified a few inconsistencies in the original report.

terms of use

You are permitted to access articles subject to the terms of use set by our suppliers and any restrictions imposed by individual publishers. Please see for full terms of use.

Useful links

Consultation Paper: Risk management, internal control and the going concern basis of accounting
Consultation paper published in November 2013 by the FRC on their updated draft guidance for directors of companies applying the UK Corporate Governance Code. The resultingGuidance on Risk management, internal control and related financial and business reporting(the Risk Guidance) has superseded Internal Control: Guidance for Directors on the Combined Code.

Guide on use of Turnbull for section 404
Guide 'on the use of the Turnbull guidance when complying with US requirements to report on internal controls over financial reporting'. Published on 16 December 2004.

Archived reports and guides

Consultation on draft revised Turnbull guidance
Consultation paper published by the FRC on 16 June 2005.

Review of the Turnbull Guidance on Internal Control: Evidence PaperFRC paper published on 16 June 2005 analysing the responses to the evidence gathering public consultation paper issued on 2 December 2004.

Implementing Turnbull: A Boardroom Briefing
Briefing published by the Centre for Business Performance (ICAEW) in September 1999 aimed at providing directors with a number of straightforward steps in the implementation of the Turnbull guidance.

Internal Control: Guidance for Directors on the Combined Code
The first version of the guidance on the implementation of the internal control requirements of the Combined Code on Corporate Governance. The guidance is also known as 'The Turnbull Report'. Issued by the ICAEW in September 1999.

The KPMG Review Internal Control: A Practical Guide
Published by KPMG in November 1999this guidance was prepared to assist in understanding the implications of the ICAEW publication Internal Control: Guidance for Directors on the Combined Code.

Articles and books in the ICAEW Library collection

Selected article

What's your approach?
Governance and Compliance: the ICSA Magazine. August 2013. pp.16-17
The FRC is reviewing the way publicly listed companies report their risk activities as part of an update of the Turnbull guidance. ICSA and risk management association Airmic have issued a joint call for the rules to be tightened, and have published a report highlighting best practice. The author explains what the problem is, and how it can be overcome.

Find more articles and books

  • View a list of articles and books in our collection on the Turnbull Report

See also

  • FRC Risk guidance
  • Sarbanes-Oxley
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Internal Control: Guidance for directors on the Combined Code (2025)

FAQs

What is the internal control guidance for directors? ›

Internal Controls – The Code asks boards to monitor and review all material controls and make a declaration on their effectiveness. This guidance does not set out a framework that companies should follow or define a material control; this will be dependent on the nature of the principal risks.

Which one of the following published the internal control guidance for directors on combined code? ›

1 Turnbull, N. (1999) Internal Control: Guidance for Directors on the Combined Code. London: Institute of Chartered Accountants.

What is the internal control of the board of directors? ›

The Board of Directors is responsible for the internal control and monitoring of the company's management. This is done through both internal and external control activities, and through examination and monitoring of the company's steering documents related to risk management.

What are the 5 components of internal control? ›

The COSO internal control framework identified five interrelated components:
  • Control Environment. The control environment sets the tone of an organization, influencing the control consciousness of its people. ...
  • Risk Assessment. ...
  • Control Activities. ...
  • Information and Communication. ...
  • Monitoring.

What is internal control guidelines? ›

Internal controls consists of all the measures taken by the organization for the purpose of; (1) protecting its resources against waste, fraud, and inefficiency; (2) ensuring accuracy and reliability in accounting and operating data; (3) securing compliance with the policies of the organization; and (4) evaluating the ...

What type of internal control guidance does COSO offer? ›

This COSO Internal Control – Integrated Framework (ICIF) — also somewhat confusingly known simply as COSO or the COSO framework — provided guidance for how organizations can implement controls to prevent, detect, and manage fraud risk related to external financial reporting.

Who is responsible for implementing internal controls? ›

Management is responsible for establishing internal controls. In order to maintain effective internal controls, management should: Maintain adequate policies and procedures; Communicate these policies and procedures; and.

What is the combined code of Corporate Governance? ›

The Code provides for the accountability of the Company's Board of Directors to all the other shareholders in accordance with applicable law and also provides guidance to the Board of Directors in monitoring the activities of the executive bodies and in making decisions.

What is the purpose of the internal control review? ›

It helps an organization accomplish its objectives by bringing a systematic, disciplined approach to evaluate and improve the effectiveness of risk management, control, and governance processes".

Who controls the board of directors? ›

A board of directors (BofD) is the governing body of a company, whose members are elected by shareholders (in the case of public companies) to set strategy, oversee management, and protect the interests of shareholders and stakeholders.

What 4 major responsibilities does the board of directors have? ›

Recruiting, supervising, retaining, evaluating and compensating the CEO or general manager are probably the most important functions of the board of directors. Value-added business boards need to aggressively search for the best possible candidate for this position.

What control do directors have? ›

Directors are the creative leads of the film. They hold the creative vision throughout the whole process, from pre-production through to the final edit. They are employed by the executive producer or producer, who is ultimately in charge of a production.

What are the 7 principles of internal control? ›

The seven broad principles are: Establish responsibilities; Maintain adequate records; Insure assets and bond key employees; Separate recordkeeping from custody of assets; Divide responsibilities for related transactions; Apply technology controls; Perform regular and independent reviews.

What are key controls in internal controls? ›

Key controls are those that must operate effectively to reduce the risk to an acceptable level. Secondary controls are those that help the process run smoothly but are not essential.

What are the four basic purposes of internal controls? ›

Internal controls function to minimize risks and protect assets, ensure accuracy of records, promote operational efficiency, and encourage adherence to policies, rules, regulations, and laws.

What is the importance of internal controls for a company directed at? ›

Internal controls ensure all activities are conducted per applicable laws, regulations, and standards. This involves controls that identify relevant laws and regulations, monitor compliance, and correct any instances of non-compliance.

Who provides guidance and oversight in the process of internal control? ›

Management is responsible for establishing internal controls. In order to maintain effective internal controls, management should: Maintain adequate policies and procedures; Communicate these policies and procedures; and.

What are the administrative internal controls? ›

Internal control is the integration of activities, plans, attitudes, policies and efforts of an organization working together to provide reasonable assurance that the organization will achieve its objectives and mission. As such, internal control is people-dependent.

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