COSO’s Call for Compliance Leadership with the Corporate Governance Framework

According to Tom Fox in an article on the Compliance Podcast Network, the Public Exposure Draft of the Committee of Sponsoring Organizations of the Treadway Commission’s (COSO) new Corporate Governance Framework marks a pivotal shift in how strategy is understood within governance. 

Fox highlights component 2 of the Corporate Governance Framework, Strategy, which positions compliance not as an after-the-fact control, but as a proactive, guiding force in strategic development and execution. This reflects a growing recognition that in an era of regulatory scrutiny, ESG pressures, and geopolitical volatility, governance without compliance integration is incomplete.

COSO outlines four key principles under the Strategy component: defining purpose and values, developing and communicating the strategy, executing it, and measuring performance. For compliance professionals, this is a strategic inflection point. Rather than simply policing rules, compliance is invited to shape strategy through risk foresight, ethical alignment, and stakeholder accountability.

To operationalize this role, Fox says compliance teams are encouraged to review corporate strategies through COSO’s lens, engage in early planning discussions, develop forward-looking compliance metrics, pilot compliance-integrated strategic initiatives, and educate boards on the governance implications of strategy. The Corporate Governance Framework offers concrete ways for compliance to influence incentives, performance indicators, and change management processes, ensuring integrity is embedded throughout the process.

Ultimately, COSO makes a compelling case: compliance is not just a check on strategy but a core driver of sustainable governance. By claiming a seat at the strategy table, compliance can shape more resilient, ethical, and accountable organizations.