Going Public
governance

Internal Controls Reality: HKEX A1 Governance Requirements

The internal controls review — typically conducted by an independent internal controls consultant engaged by the sponsors — is one of the most op.

· 11 min read

The internal controls review — typically conducted by an independent internal controls consultant engaged by the sponsors — is one of the most operationally disruptive parts of pre-IPO preparation. The review assesses: Financial Reporting Controls — does the company have documented procedures for financial close, consolidation, journal entry approval, and management review? IT General Controls — are there appropriate access controls, change management procedures, and backup systems for the company’s financial systems? Entity-Level Controls — does the board have adequate oversight, is there an appropriate code of conduct, and are whistleblowing mechanisms in place? The review produces a report identifying control deficiencies, categorised as significant deficiencies or material weaknesses. The company must remediate all material weaknesses before listing. Common findings in pre-IPO companies include: lack of segregation of duties (one person both initiates and approves payments), undocumented financial close procedures, and absence of a formal whistleblowing policy. The remediation process typically takes 3-6 months.