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Internal Control: Guidance for directors on the Combined Code

The Turnbull Report was first published in 1999 and set out best practice on internal control for UK listed companies. In October 2005 the Financial Reporting Council (FRC) issued an updated version of the guidance with the title 'Internal Control: Guidance for Directors on the Combined Code'. In September 2014 this was superseded by the FRC's Risk Guidance.

The report

Internal Control: Guidance for Directors on the Combined Code 
Updated version of the Turnbull guidance published by the Financial Reporting Council on 13 October 2005. The updated version took effect for financial years beginning on or after 1 January 2006. In September 2014 it was replaced by the Risk Guidance.

Further information is available on the risk management and internal control page on the FRC website.


The FRC held a series of meetings with companies, investors and advisers in 2011 which were summarised in the report Boards and risk published in September 2011. One of the conclusions reached was that whilst the guidance was "still broadly fit for purpose, some change was needed to reflect the role of the Board as articulated in the new version of the [UK Corporate Governance] Code. The FRC intends to carry out a limited review during 2012."

In November 2013 the FRC launched a consultation on further updates to the guidance. On 17 September 2014 it published the resulting revised guidance, Risk management, internal control and related financial and business reporting (the Risk Guidance). This updates and replaces Internal Control: Guidance for Directors on the Combined Code (formerly known as the Turnbull Guidance).


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Introduction and background

Chapter 1 looks at the development of corporate governance and specifically the history of corporate governance in the UK.

Turnbull Report

A complete guide to the process and profession of internal auditing.

Turnbull: guidance on internal control

An introduction to governance for directors and executives. Chapter 5 looks at corporate governance in the UK and summarises the Turnbull report.

Online articles

The Library provides access to leading business, finance and management journals. These journals are available to logged-in ICAEW members, ACA students and other entitled users subject to suppliers' terms of use.

Regulation by disclosure: the case of internal control

The authors explore the use of disclosure as a regulatory tool, describing the background to the Turnbull guidance for directors on internal control reporting.

Work to do with Turnbull 2

The review of the Turnbull guidance on internal controls, led by HSBC FD Douglas Flint, has left a perception that there is virtually no change in the requirements. Martyn Jones points out three significant changes.

Sticking two fingers up at Sarbox

A short editorial piece by Andrew Sawers, commenting on Douglas Flint's updated Turnbull Report guidance. Sawers approves of the succinct revision, which he views as having rectified a few inconsistencies in the original report.

Useful links

Consultation Paper: Risk management, internal control and the going concern basis of accounting
Consultation paper published in November 2013 by the FRC on their updated draft guidance for directors of companies applying the UK Corporate Governance Code. The resulting Guidance on Risk management, internal control and related financial and business reporting (the Risk Guidance) has superseded Internal Control: Guidance for Directors on the Combined Code.

Guide on use of Turnbull for section 404
Guide 'on the use of the Turnbull guidance when complying with US requirements to report on internal controls over financial reporting'. Published on 16 December 2004.

Archived reports and guides

Consultation on draft revised Turnbull guidance
Consultation paper published by the FRC on 16 June 2005.

Review of the Turnbull Guidance on Internal Control: Evidence Paper
FRC paper published on 16 June 2005 analysing the responses to the evidence gathering public consultation paper issued on 2 December 2004.

Implementing Turnbull: A Boardroom Briefing
Briefing published by the Centre for Business Performance (ICAEW) in September 1999 aimed at providing directors with a number of straightforward steps in the implementation of the Turnbull guidance.

Internal Control: Guidance for Directors on the Combined Code
The first version of the guidance on the implementation of the internal control requirements of the Combined Code on Corporate Governance. The guidance is also known as 'The Turnbull Report'. Issued by the ICAEW in September 1999.

The KPMG Review Internal Control: A Practical Guide
Published by KPMG in November 1999 this guidance was prepared to assist in understanding the implications of the ICAEW publication Internal Control: Guidance for Directors on the Combined Code.

Articles and books in the Library collection

Selected article

What's your approach?
Governance and Compliance: the ICSA Magazine. August 2013. pp.16-17
The FRC is reviewing the way publicly listed companies report their risk activities as part of an update of the Turnbull guidance. ICSA and risk management association Airmic have issued a joint call for the rules to be tightened, and have published a report highlighting best practice. The author explains what the problem is, and how it can be overcome.

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