IIA Stakeholder Comment Period on the U.S. Sarbanes-Oxley (SOX) Law
The IIA recently formed a SOX Working Group to look at the relationship between internal audit and SOX. We also invite members of the profession and other stakeholders to share their views with us.
Stakeholder comment period: October 1 - November 14, 2025
Share your perspective on the U.S. Sarbanes-Oxley (SOX) Act.
Stakeholder consultation questions
Please find below a series of questions designed to guide the discussion concerning SOX and its impact on internal audit:
Why are we asking for your input now?
The U.S. Congress has signaled a growing interest in amending the Sarbanes-Oxley Act (SOX). This momentum accelerated over the past several months, highlighted by two recent developments:
- A proposal to eliminate the Public Company Accounting Oversight Board and consolidate its functions into the Securities and Exchange Commission (this provision was ultimately removed)
- The U.S. House Committee on Financial Services conducted an initial hearing to examine the rising costs of SOX compliance
Process for submitting comments
Stakeholders should submit their comments by:
- Emailing advocacy@theiia.org
- Please cc Michael Downing, Senior Director for North American Advocacy, at (Michael.Downing@theiia.org) when emailing.
SOX guided questions
- Internal audit is instrumental in providing organizations with the objective assurance needed to comply with Sections 302 and 404 of SOX. Given this important responsibility, should internal audit’s role be mentioned in the law?
- The cost of complying with SOX is of particular interest to Congress. With this context in mind, does internal audit have the potential to reduce compliance costs? If so, can you provide examples or evidence from your experience?
- Are there specific provisions of SOX that impede the work of internal auditors? If so, please list each section and describe how the law negatively impacts the profession. Do you have any recommendations on how the language can be improved?
- Are there any sections of SOX you have found that either directly or indirectly conflict with The IIA’s International Professional Practices Framework®? If so, please identify the section, describe the conflict, and suggest how alignment could be improved.
- Beyond the passage of SOX into law, are there issues or concerns related to the Public Company Accounting Oversight Board, its regulations, operations, or guidance which directly impact the internal audit profession and/or its ability to support compliance with SOX?
- What other policy opportunities exist – beyond those already mentioned – to promote the role of internal audit in SOX?
- Do you have any other thoughts concerning the intersection between SOX and internal audit?
- While SOX is a US-based law, it has had a global influence. At the same time, other countries have sought their own policy solutions to regulate external financial audits and protect investors. What insights from other countries' approaches could improve SOX and external audits and their relation to internal auditing?
Submit your comments by 5:00pm, Friday, November 14, 2025
Please contact Michael Downing at Michael.Downing@theiia.org with any questions regarding this solicitation request.