COSO 2013 Framework, Principle 9 — Identifies and analyzes significant change

Which editions this rests on

1. 1 January 2013

   Publication year of COSO’s Internal Control — Integrated Framework, held as the start of the year because the day is not asserted. An edition marker, not a commencement: nothing happens to anyone who departs from a voluntary framework.

2. 1 January 2026

   Publication year of COSO’s Achieving Effective Internal Control Over Generative AI (GenAI), again held as the start of the year. Commissioned thought leadership rather than an amendment to the Framework; it creates no principle and no duty.

The change you did not make

Which tools this reaches

Any AI tool a finance function does not itself control — a hosted service, an embedded feature in a finance system, a model consumed through an interface — where the supplier can change behaviour without the customer acting. Principle 9 binds nobody: COSO’s Framework is voluntary and no consequence follows from departing from it. It applies here through the control framework management has already adopted.

What the change file must hold

The artefacts an assessor asks to see, and what makes each one sufficient rather than merely present.

1. 01

   The vendor change-notification term, as signed

   The clause itself, not the account manager’s assurance. What counts as a material change, how much notice is owed, and whether the supplier must hand over its own evaluation results with it.

2. 02

   A log of notifications actually received

   Dates, what the supplier said had changed, and what the function did about each. An empty log after two years of service is evidence about the term rather than about the supplier.

3. 03

   The re-evaluation performed before a change reached production

   A test on the function’s own population against the prior configuration, dated before the change went live. Afterwards it is an investigation, not a re-evaluation.

4. 04

   A dated record of which model version produced which output

   Kept so that a variance found in April can be attributed to something that moved in February. Without it, a supplier release and an accounting error are indistinguishable months later.

Worked example — a release nobody mentioned

A vendor assessment with a date on it

A vendor assessment performed once, at selection. Security questionnaire returned, references taken, a pilot run on a sample of the function’s own data, sign-off filed. It was good work, and it describes a product that no longer exists in the form assessed. Nothing in the file establishes what the supplier has shipped since, whether the function would have been told, or what the current configuration is — and the assessment’s age is rarely noticed, because a tool that is working generates no reason to look at it.

Where the change lands

Where another instrument addresses the same obligation. These are correspondences, not comparisons — the Council does not rank one framework against another.

• MAS instruments

  MAS instruments reach the same event from a supervised institution’s side, where model change after deployment is treated as a matter of ongoing monitoring rather than of contract terms.

• Finance and accounting standards

  Whether a supplier’s change matters depends on whether a person re-performs the work behind the control. A non-reliance process absorbs a model change that a reliance process does not.

A correspondence indicates that two instruments address the same underlying obligation. It is not a mapping endorsed by either body, not a statement that one satisfies the other, and not a judgement about which is more demanding.

Where this is assessed

Examined in 2 credentials, in the domains named on each card.

The provision itself

This page sets out what the instrument requires and what discharges it. The official text is the authority — these go straight to it.

• COSO guidance index — Internal Control — Integrated Framework (2013), Principle 9, purchase required; and Achieving Effective Internal Control Over Generative AI (GenAI), 2026.
• The 2026 paper, whose Risk Assessment material treats model, prompt, connector and filter changes, including supplier-driven ones. Reproduction is expressly prohibited; it is described here, not quoted.
• COSO dates both documents by year on its guidance index, and neither states an effective date — consistent with documents that impose no obligation.

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