New COSO ERM guidance | Norman Marks on Governance, Risk Management, and Internal Audit

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COSO has just released From Guidance to Action: Exploring Practical Enterprise Risk Management (2026) . The authors are with Crowe LLP: Ryan Luttenton (partner), Stefany Samp (Senior Manager), and Alexa Stone (Senior Manager). Ryan has many years’ experience in the risk consulting arena, primarily (based on his LI profile) in banking.

I love the title of the press release: “COSO Unveils New ERM Guidance to Help Organizations Improve Decision Confidence”.

Too much risk management practices and guidance are about ‘managing a list of risks’ instead of managing the business. There’s too little recognition that decisions are what drives an organization, and decisions are where risks are taken.

The press release goes on to say it’s “a new paper designed to help organizations strengthen the strategic relevance, decision making and real‑world impact of their enterprise risk management (ERM) programs”.

The press release sets a fine goal. Does it achieve it?

Well, the paper starts very well. It explains that “the catalyst for this paper [is] to move ERM from documenting risks to influencing choices. The goal is embedded risk decisioning – a repeatable way of working, built into planning, investment, delivery, and escalation – so leaders get decision-ready risk signals even when the risk team…

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