Robotic Process Automation (RPA) is transforming the way organizations perform routine business activities. It promises faster execution, improved accuracy, and substantial cost savings. However, as automation becomes more widespread, it also introduces new challenges in governance and internal control. The white paper titled „Achieving Effective Internal Control Over Robotic Process Automation Aligning with the COSO Internal Control Integrated Framework“, authored by Marc Eulerich, Jan Gruene, and David A. Wood, provides a structured response to these challenges. Commissioned by the Committee of Sponsoring Organizations of the Treadway Commission (COSO), the paper delivers a comprehensive guide to integrating RPA within the widely accepted COSO internal control framework.
The core contribution of the publication is the development of a dedicated RPA Bot Governance Framework. This framework identifies four central governance areas: deciding when and how bots should be used, managing access and authorizations, controlling changes in bot processes, and ensuring secure and efficient IT operations. Each governance area includes specific control requirements and is directly aligned with COSO’s five internal control components: Control Environment, Risk Assessment, Control Activities, Information and Communication, and Monitoring Activities. This structured mapping allows organizations to embed RPA into existing control systems in a consistent and traceable way.
One of the most important insights of the paper is the unique nature of RPA compared to traditional IT systems. Because RPA is accessible, low-cost, and often developed outside of IT departments by non-specialists known as citizen developers, it can easily bypass traditional control structures. As a result, organizations are exposed to new risks such as bot proliferation, poor documentation, data security issues, and a loss of control over key processes. The authors argue that these risks can only be mitigated if RPA is governed with the same discipline as other critical IT resources.
In terms of the control environment, the authors recommend formal training programs for bot developers, detailed policies for bot backup and recovery, and alignment of RPA goals with broader digital transformation efforts. Organizations should also consider creating centralized units such as Centers of Excellence to ensure consistency, competence, and accountability across all RPA initiatives. These measures form the cultural and operational foundation of strong RPA governance.
The section on risk assessment emphasizes the need to evaluate whether processes are suitable for automation and to identify which bots play a role in financial reporting and other critical control areas. Maintaining an inventory of bots, anticipating failure scenarios, and building in backup procedures are seen as essential components of a risk-aware automation strategy. The paper highlights the importance of not becoming overly dependent on bots without contingency plans in place.
Control activities, as described in the COSO model, are also adapted to the specific needs of RPA. These include role-based access controls, password policies, formal change management procedures, and strict rules for deploying bots into production environments. Each bot and its updates should be documented and subject to approval, just like any other part of the IT infrastructure. These controls help ensure that automation enhances rather than weakens internal oversight.
For the area of information and communication, the authors emphasize maintaining up-to-date records of all bots, implementing incident reporting systems, and enabling clear communication between stakeholders such as IT, audit, and business units. Transparency is key to ensuring that RPA decisions and operations are understood and traceable across the organization. Cybersecurity also plays a vital role, particularly in protecting bot credentials and enforcing secure authentication methods.
Monitoring activities complete the COSO control cycle. Organizations are encouraged to implement automated monitoring tools that track bot performance and detect deviations from expected behavior. Logs should be kept of all bot activities, including failures and anomalies, and regular testing should be performed to confirm that bots are functioning properly. Feedback loops and lessons learned from incidents help strengthen governance over time.
To help with practical implementation, the paper provides a step-by-step roadmap for aligning RPA governance with COSO. This includes conducting an initial gap assessment, creating detailed policies, forming cross-functional oversight teams, and implementing training programs. An extensive appendix offers ready-to-use checklists for each COSO component, allowing practitioners to track their progress and identify areas for improvement.
This COSO white paper is more than a conceptual discussion. It is a hands-on guide for organizations seeking to integrate automation into their internal control environments without compromising governance. It demonstrates that with the right approach, RPA can enhance efficiency and accuracy while preserving control integrity and regulatory compliance.
The full paper by Prof. Dr. Marc Eulerich, Jan Gruene, and Dr. David A. Wood, titled „Achieving Effective Internal Control Over Robotic Process Automation Aligning with the COSO Internal Control Integrated Framework“, was published in December 2024 and is available online here.