5) Internal Control Over Financial Reporting
5) Internal Control Over Financial Reporting
5) Internal Control Over Financial Reporting
IJEM
International Journal of Economics and Management
Journal homepage: http://www.ijem.upm.edu.my
D
Internal Control Over Financial Reporting, Organizational Complexity,
and Financial Reporting Quality
a
Faculty of Economics and Business, Universitas Katolik Indonesia, Indonesia.
bFaculty of Economics and Business, Universitas Indonesia, Indonesia
ABSTRACT
Article history:
Received: 8 April 2019
Accepted: 21 October 2019
*
Corresponding author: Email: [email protected]
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International Journal of Economics and Management
INTRODUCTION
According to Conceptual Framework of Financial Accounting Standards (IFRS), there are some important
qualitative characteristics of financial reporting such as predictive and feedback value, timeliness, neutrality and
representational faithfulness. The extent to which the four values are well represented in the financial reporting
depends on various factors. These factors, at the company level, include Internal Control Over Financial
Reporting (ICOFR) and organizational complexity.
ICOFR is a series of activities undertaken by all members of the company and designed to provide
reasonable assurance that its financial reports are reliable (COSO, 2006; Nalukenge et al., 2017), and the
Committee of Sponsoring Organizations of the Treadway Commission (COSO) argues that ICOFR can ensure
the reliability of the financial reports because they are free from material misstatements. In this case, an effective
control can in fact identify fraud, inaccurate accounting records and inconsistent application of accounting
standards (Ashbaugh-Skaife et al., 2008; Donelson et al., 2016). ICOFR can also mitigate any risks inhibiting
the objectives of the financial reporting, such as the absence of solutions to the identified fraud and the lack of
management awareness of the quality of the financial reports. This implies that an ineffective ICOFR is likely
to result in poor quality financial reports.
In order to maintain the financial report quality, it is likewise vital that business strategies that relate to
company environment are employed, one of which is the idea of diversification. This strategy can create various
business lines, allowing the firm to develop into several divisions. Consequently, getting difficult in
coordinating and increase internal bureaucracies (Hashai, 2015), resulting in information asymmetry which then
might increase the risk of impaired quality of financial reporting.
Important though it seems, studies of ICOFR have rarely been conducted in countries that do not require
the disclosure of the weaknesses of ICOFR, such as Indonesia. Most of studies of ICOFR were performed in
countries that already regulate ICOFR like SOX 302 and 404 in the United States (Doyle et al., 2007; Lai et al.,
2017). Concerning the lack of research on ICOFR, Kinney (2000) and Chalmers et al. (2019) pinpoint that the
underlying problem is the difficulty for researchers to directly assess the effectiveness of ICOFR. This study
therefore offers solutions to these problems by developing a scoring list to assess the effectiveness of ICOFR.
It is true that some researchers (Van de Poel and Vanstraelen, 2011; Ying, 2016) have developed some
scoring schemes for IC assessment, but their studies are laden with inconsistent results, presumably because the
scorings are not specially developed for ICOFR and they are less comprehensive. In contrast, the present study
attempts to develop a scoring system that specifically measures ICOFR and assesses broader aspects. These
scoring instruments are developed based on evaluation tools by COSO (2006) and modified using relevant
literature (Deumes and Knechel, 2008).
Another salient difference is that the present study utilizes four measurements of financial reporting
quality, much more robust than most previous studies on ICOFR and organizational complexity which only use
one or two. Given the multiple measurements applied, it is expected that this research will provide more
comprehensive insight on how ICOFR and organizational complexity can influence the quality of financial
reporting in various dimensions. In particular, this study will analyze the impact of ICOFR and organizational
complexity on four dimensional measurements of the financial reporting quality, which are predictive and
feedback value, timeliness, neutrality and representational faithfulness.
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Internal Control Over Financial Reporting, Organizational Complexity, and Financial Reporting Quality
The basic concept of the relationship between the effectiveness of internal control and the quality of
financial information is based on Study D’Mello et al. (2017) which explains the statement of the former US
Securities and Exchange Commission (SEC) chairman that the quality of information to shareholders is
determined by internal controls. Their statement concluded that ineffective ICOFR would cause misstatements
in financial reporting. The failure to prevent or detect fraud or misstatements in the financial reporting process
will worsen its quality. Control activities should be able to warn management in case of irregularities that could
potentially lead to misstatements or fraud in financial reporting (Ashbaugh-Skaife et al., 2008; Donelson et al.,
2016). Some studies add that ICOFR’s ineffectiveness will as well cause low quality of financial reporting
(Donelson et al., 2016). At this point, based on the agency-theory perspective, ICOFR can be an oversight
component and is expected to align the interest between the principal and the agent, and this oversight function
of ICOFR, according to the COSO framework, encompasses five components such as control environment, risk
assessment, control activities, information and communication and monitoring.
Nonetheless, although many realize that ICOFR is essential, researchers find it difficult to directly
observe and assess the quality of ICOFR since ICOFR activities are normally integrated into the company's
operational activities (Deumes and Krechel, 2008; D’Mello et al., 2017). External parties often rely on voluntary
disclosure by the management to obtain any information regarding the design and implementation of ICOFR,
which can serve as a detailed description of its effectiveness (Chalmers et al., 2019). Following the practice in
previous disclosure studies (Ji et al., 2017), this study also uses annual reports as a source of information to
assess the effectiveness of ICOFR.
In Indonesia, the practice of disclosure of IC for public companies, particularly ICOFR, is voluntary. The
general rule concerning IC for public companies per se was put into effect in 2006 when the Bapepam-Lembaga
Keuangan1 issued the Regulation No.KEP-134/BL/2006 concerning Obligation to Submit Annual Reports and
it was then updated by Financial Services Authority in 2016 2. In the context of IC, this rule has not changed
significantly because it still does not set the standard format and does not apply specifically to ICOFR. This
regulation requires management to elaborate the implementation of its IC system.
In relation to ICOFR, Indonesia has adopted the IC framework formulated by the COSO for its disclosure
practice, and assessment towards the ICOFR practices is undeniably relevant. It is in fact urgent considering
that there have been several serious cases of fraudulent financial statements in some Indonesian companies such
as Lippo Bank, Kimia Farma and Indofarma (Siregar and Tenoyo, 2015). These cases can serve as grounds why
policies regarding the ICOFR practices have become rather crucial in Indonesia.
Strongly associated with ICOFR, IC is especially conducted to ensure the protection of the firm’s assets
and to give assurance regarding the reliability of financial reports. In evaluating these reports, ones would use
earnings as an important source of information because either investors or analysts normally take into account
earnings when making investment decisions (Dichev et al., 2013; Hosseini et al., 2016). Following this
argument, the current study will hence use the construct of earnings to measure the financial reporting quality.
Earnings is a summary of performance that is prepared using accrual basis (Han, 2010; Zhang, 2016),
which in turn allows manager to estimate and justify the accounting treatment of transactions. Nonetheless,
there are two explanations why the accrual can lead to low quality of financial reporting (Doyle et al., 2007;
D’Mello et al., 2017). First, management usually behaves opportunistically, resulting in biased accrual
estimation, and secondly, unintentional mistakes are likely to occur as the management finds it difficult to
predict the transactions accurately. These factors may impair the quality of the financial reporting if they are
not detected and rectified earlier.
Some research enumerate some characteristics of quality reporting based on the FASB, such as predictive
and feedback value, timeliness, neutrality, and representational faithfulness (Velury and Jenkins, 2006; Jaggi et
al., 2015; Ying, 2016; Lourenço et al., 2018). The first component is an indicator of how financial information
should be able to predict the condition of the company and to confirm these predictions, particularly with respect
to the ability to generate cash flow. The notion of timeliness refers to how the information will lose its relevance
to decision-making process if it is not available in time. Next, neutrality implies that the information is not
1
As of 1 January 2013, OJK (Financial Services Authority) is established to regulate and supervise the activity of financial services in the
Banking Sector, financial services in the Capital Market sector, and financial services in Insurance, Retirement Fund, Financial institutions,
and other Financial Services Institutions sector (in accordance with the Law of the Republik Indonesia Number 21 of 2011 concerning
Financial Services)
2
(Financial Services Authority Circular Letter number 30 /SEOJK.04/2016 concerning Forms and Content of Annual Reports of Issuers or
Public Companies).
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International Journal of Economics and Management
biased and does not tend to benefit only one party (Ji et al., 2017). Lastly, the information is said to be faithfully
represented if management reports all transactions and events to investors accurately. These company’s values
mirror how investors will assess the accuracy of earnings (Hosseini et al., 2016; Lennox et al., 2016).
Ineffective ICOFR is more likely to lead to poor quality of financial reporting. To illustrate, when ICOFR
is indeed ineffective, it is incapable of both preventing and detecting any errors or misstatements or it fails to
mitigate any opportunistic attempts to manipulate the financial reports (Doyle et al., 2007; Han, 2010; Ji et al.,
2017). On the other hand, effective ICOFR can be reflected in the company’s commitment to disclose any
essential information concerning the implementation of ICOFR. Effective ICOFR is expected to help mitigate
the agency problem because it increases the reliability of the financial reporting. Accordingly, it can
immediately detect any material misstatements due to fraud in the financial reports so that corrective actions
can be taken. This will finally make financial reporting more relevant and reliable.
Conceptually, ICOFR has the potential to enhance the quality of financial reports. Many researchers have
proven that ICOFR have an impact on the improvements of financial reports quality (Doyle et al., 2007a;
Ashbaugh-Skaife et al., 2008; Ying, 2016; Ji et al., 2017). This empirical evidence substantiates the
effectiveness of ICOFR in ensuring that the financial reports are free of material misstatements.
The present study argues that the implementation of effective ICOFR will improve the quality of
financial reports, pinpointing the positive effects of ICOFR on four dimensions of financial reporting quality,
which are predictive and feedback value, timeliness, neutrality and representational faithfulness. Effective
ICOFR should therefore be able to detect errors and suggest corrective measures for such errors, which might
stem from either unintentional error in estimated accruals or even to manage earnings (Doyle et al., 2007; Jaggi
et al., 2015). It is likewise inferred that ICOFR can reduce earning management or can boost the predictive
value and neutrality of financial reporting.
ICOFR gives a reasonable assurance that financial report has no material misstatements. In addition, the
quality of preparatory process of financial reporting is related to its qualitative indicators like timeliness
(Abernathy et al., 2015) and for this reason, ICOFR can contribute to better timeliness of reporting. Effective
ICOFR also enables investor to assess firms’ actual condition so they can estimate the investment risks, meaning
that the increased accuracy of earnings will have a positive impact on representational faithfulness. Based on
these arguments and some previous studies, the hypothesis tested in this study is:
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Internal Control Over Financial Reporting, Organizational Complexity, and Financial Reporting Quality
organizational structure will as well pose more challenges to the coordination and distribution of information,
and this could potentially impede the timeliness of reporting. Investors would find it difficult to predict company
performance and estimate the ability to generate future cash flows (Lennox et al., 2016). Based on this argument
and some previous studies, the second hypothesis to be tested is:
METHODOLOGY
Sample Selection
The sample for this study is comprised of all firms registered in Indonesia Stock Exchange from 2007 to 2012,
with the exception of financial firms. The selection of the commencement year is based on the issuance of
COSO’s ICOFR framework in June 2006 and therefore, it is assumed that the framework was initially
implemented in 2007. Disclosure of ICOFR in Indonesia is voluntary and the format is not standardized unlike
that of some other countries especially the US, which regulates the practice of ICOFR disclosure, Indonesia
listed companies on the New York Stock Exchange (NYSE) that are excluded, making the obtained scores
comparable. With these criteria and with the outliers checked, this study covers a sample of 1056 firms per year
and the data are in the form of a balanced panel data set. Based on Chow, Breusch Pagan Lagrange Multiplier
and Hausman test, the hypothesis is to be analyzed using the panel data and the fixed effect regression model.
The equation used to test the hypotheses can be seen in table 2.
Definition of Variables
This study assesses financial report quality constituted by four dimensions, which are predictive and feedback
values, timeliness, neutrality and representational faithfulness. The testing of hypotheses H1 and H2 will be run
based on the four measures of the financial report quality. The four dimensions are scrutinized using the
following criteria. Dechow (1994) stated that the reported earnings at the end of the fiscal year period should
predict cash flow in the next period. Based on this argument, following Ebirien et al. (2019) the predictive and
feedback value is measured by linking earnings to future cash flows. Concerning timeliness, the sooner a
company reports their financial reports to the authorities since the end of its fiscal year, the timelier it is
(Abernathy et al., 2015). In respect to the idea of neutrality, when management conducts earnings management,
the reported earning is biased because it brings advantage only to a particular party. Earnings management is
measured with absolute accruals as modified Jones (Dechow et al., 1995; Ji et al., 2017). Lastly, representational
faithfulness is measured by linking profits to stock returns utilizing the earnings coefficient response (Velury
and Jenkins, 2006; Hosseini et al., 2016).
This study bases its analysis on ICOFR framework developed by COSO (2006). The assessment of
effective ICOFR is done with a 24-item scoring scheme which is specifically concerned with ICOFR practice
(Appendix 1). This study subsequently measures the effectiveness of ICOFR based on the disclosure of the
annual reports. Following Schommer et al. (2019), complexity of organization is measured using the entropy
index developed by Jacquemin and Berry (1979).
Based on the previous relevant studies, (Jaggi et al., 2015; Masud et al., 2017), some other variables such
as size, leverage, loss and growth are regarded as control variables. Large companies are subject to greater
attention from the public and analysts and therefore tend to report high-quality financial reports (Hosseini et al.,
2016), whereas losing companies will try to obscure theirs by delaying the report (Lourenço et al., 2018) and
performing earnings management. Companies with higher debt will normally perform earnings management in
order to reduce the possibility of violating the debt covenant and having low earnings informativeness. Growing
companies tend to report high-quality financial reports (Abbadi et al., 2016).
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Descriptive statistics are presented in Table 1. The present study determines whether the data is normally
distributed by observing the skewness, and the outliers of the variables are examined and winsorized. Overall,
the companies being scrutinized have a positive operating cash flow (CFO). The average number of days (LAG)
of submission to the stock exchange authority is 94 days after the fiscal year ends. The observed companies also
have relatively small discretionary accruals (ABDAC). In addition, the samples also demonstrate a positive stock
return (RET). Many of the companies report their profits before extraordinary events and discontinuation of
operations (INCOM). This condition is reflected in the small number (16.3%) of companies reporting losses
(LOSS). Changes in income before extraordinary events and discontinuation of operations (DNIBE) are as well
positive on an average.
The average level of organizational complexity (CMPLX) is 0.45. ICOFR variable has a mean of 0.512
with not so many variations (standard deviation is 0.102). The total score of the effectiveness of ICOFR for each
company refers to the sum of all items and then weighted using the multiplication of the highest value and the
number of items used. The list of questions used to score the ICOFR effectiveness in this research is relatively
new and consequently, validity and reliability testing is necessary. Tests show that the 24 score items have
Cronbach's alpha of 0.831, indicating that the scores of the ICOFR effectiveness can be used for the following
analysis.
Consequently, the time needed to prepare a precise financial report that is in compliance with GAAP will be
shorter.
Lennox et al. (2016) provides empirical evidence that investors typically pay attention to earnings quality
before making any decisions to invest. As an effective ICOFR results in more accurate information, investors
will ultimately react positively to the company’s earnings information and such reaction is reflected in the stock
price. This means that the earnings has a value of informational and representational faithfulness.
In summary, ICOFR has a vital role in increasing the quality of financial reports. Studies have found that
effective ICOFR will ensure the accuracy of a financial report with no material misstatements (Doyle et al.,
2007; Skaife et al., 2013; Ji et al., 2017). The result suggests that the scoring developed in this study has an
explanatory power to elucidate financial report quality. Empirical evidence shows that ICOFR can prevent and
detect fraud, irregularities or material misstatements, thereby increasing the relevance and reliability of financial
statements.
Moreover, sensitivity analysis shows that the scoring scheme is capable of providing a better statistical
explanation than the one developed in earlier studies (Van de Poel and Vanstraelen, 2011). Finally, the findings
support the hypothesis H1 in all dimensions of financial reporting quality.
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Sensitivity analysis
The ICOFR variables and organizational complexity are examined by means of sensitivity analysis. The
sensitivity analysis for ICOFR is based on the scoring system of IC in general that is developed by Van de Poel
and Vanstraelen (2011). Overall, the sensitivity analysis is consistent with respect to all dimensions except
predictive and feedback values. This is presumably because IC in general is incapable of increasing the accuracy
of the estimation of accruals performed by management, which is a task that is plausible to accomplish with
ICOFR. The results show that ICOFR is constantly capable of ensuring the quality of financial report compared
with the IC in general. This study also makes a comparison between ICOFR and IC in order to determine which
is better as a determinant of the quality of financial reports based on the magnitude of the coefficients,
significance, R2 (Frank et al., 2009; Jaggi et al., 2015) and the F-statistic. The result is that ICOFR variables
are still relatively better when used to determine the quality of financial reports than the IC in general.
Concerning the second variable, sensitivity analysis uses Herfindahl index to measure organizational
complexity. The analysis is consistent with hypothesis H2 in most dimensions. The more complex the
organization is, the lower the predictive and feedback values are and the lengthier it becomes to disseminate
financial statements after the end of the fiscal year. In agreement with the H2 for neutrality dimension,
Herfindahl index shows that complexity has no significant influence on the neutrality of financial reports.
CONCLUSION
It is empirically evident that ICOFR has a significant influence on the four dimensions of the quality of earnings.
While ICOFR leads to an increase in predictive and feedback values, timeliness, neutrality and representational
faithfulness. Organizational complexity negatively affects the three dimensions except neutrality, on which
complexity has no significant impact.
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The study of ICOFR has been prevalent in countries that require companies to disclose ICOFR
weaknesses, but in countries where ICOFR disclosure has yet to be regulated, research on the topic is rather
scarce. This is not without reason as, according to Kinney (2000) and Chalmers et al. (2019), the implementation
of ICOFR is hard to observe. Therefore, this study has formulated a scoring system that can be applied in ICOFR
observation in countries that have not issued any policies on ICOFR weaknesses. Future research should also
take a firm’s business strategy into account when studying the quality of financial report and monitoring
mechanism.
Despite its potential, Indonesia Stock Exchange authority has yet to apply any ICOFR regulations to
improve the quality of financial reporting. The presents study provides insights of ICOFR’s integral roles in
enhancing the quality of financial report. Scoring results reveal that public companies which have already
implemented ICOFR are likely to maintain the effectiveness of its financial reporting process. This implies the
authority should consider expanding the existing rules so that public companies are not only required to describe
the IC, but they are also obliged should describe in more detail the IC and ICOFR practices.
Management accountants can use an accounting report as information to protect company’s assets and
capital allocation so that the business can run efficiently and effectively. To achieve this goal, the company can
design ICOFR in a fashion suiting their own needs. Since management accountants have a special interest in
financial report preparation and operational control (Chenhall, 2003; Brands and Holtzblatt, 2015). They can
contribute by taking initiative to design and implement effective ICOFR. Their contributions are needed to
identify risks that may impede the objectives of financial reports.
Nonetheless, there is a caveat regarding the ICOFR scoring which is based on information regarding the
implementation of ICOFR—both specific and nonspecific. The total scores are obtained through one evaluator’s
justification, and the approach may entail different results if performed by a different evaluator. Hence, future
research should consider a peer review to minimize the subjective justification.
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