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SOX 404 Costs: A Case Study

Two Dutch economists present: Sarbanes Oxley Section 404 Costs of Compliance: A Case Study:

The European division of a US listed company is used as a case study. The divisional project approach is described, and costs of compliance for this division are presented in two categories: assessment costs, mainly hours spent by internal staff; and attestation costs, mainly audit fees.

The case study shows that the internal hours spent on assessment are approximately 12 times higher than the initial estimate made by the SEC in 2002, and that the realised other expenses are approximately 1.4 times higher than this estimate. Furthermore, a year on year increase of 50 per cent of the company’s audit fee in the first year of Section 404 compliance is found.

Companies can reduce the costs of compliance by implementing programmed controls, using auditors from countries with lower rates, remediating material weaknesses only, focusing on the internal control system rather than on individual controls, and by encouraging the auditor to rely on the company’s assessment.

For additional guidance on lowering Section 404 compliance costs, see my The Complete Guide to Sarbanes-Oxley.