How many US companies need to comply? 1364

  • Does someone know, how many US companies need to comply with SOX? I know that the approx. 3,000 US listed companies on the New York Stock Exchange need to comply with SOX.
    But, I heard that also companies need to comply with SOX that are not listed on the NYSE, but that have business relations with those listed companies. How many US companies approx. have a business relation with NYSE listed companies.

  • Solu:
    SOx applies to all companies that either have stocks listed on the exchanges in the U.S. (not just the NYSE) AND all entities that issue public debt that is traded.
    There is approximately 14,000 companies lsited on the U.S. stock exchanges. Of that number there are probably 2,000 foreign (non-U.S.) companies.
    I have not seen an estimate of the aggregated total (public companies entities with public/traded debt in the U.S.) but it’s probably around 20,000 total. There was an interesting thread on the required compliance by foreign countries/governments
    (Sarbanes Oxley for foreign governments? Yes.:
    The SEC lists the types of entities required to file, based on SEC forms.
    Doing busuiness with a company whose stock trades on the NYSE has no effect on the company’s SOx requirement, unless it provides services to that company including accounting and IT functions (that affect the listed companies financial control environment).
    Hope that this helps.

  • The following is slightly dated, but should give an approximate number of the companies required to comply with SOX:
    The SEC ordered the executives of nearly 1,000 companies to personally certify all of the financial statements their companies filed in 2001. S.E.C. File No. 4-460: Order Requiring the Filing of Sworn Statements Pursuant to Section 21(a)(1) of the Securities Exchange Act of 1934, available at (last visited Dec. 15, 2002) (list includes 945 publicly registered companies). The certifications were to be submitted to the SEC by August 15, 2002. SEC Order at E6.
    Hope this helps,

  • Thanks, Milan…do you know if the SEC has a similar list re SOx?
    I haven’t been able to find a good list, although Karl Nagel has done a pretty good job of compiling data (

  • Re Milan’s list of companies…
    I think that it would be interesting to compare/contrast the certifications required pre-SOx to any restatements that resulted in complying with SOx.
    For the schadenfreude, if nothing else…

  • Hi John,
    I’m sorry, but I have not come across a list of companies compiled by the SEC or other regulatory body that identifies cmpanies that must comply with SOX.
    Off hand, I think that if such a list were published, it might be used improperly or misinterpreted…for example, if a company is not included on the list, does it mean that the SEC does not require it to comply with SOX?
    Also. because other entities such as transaction processing companies, indirectly fall under SOX requirements per se via the Type II SAS 70 requested from companies using their services, it is difficult to compile a comprehensive list of companies that are directly/indirectly impacted by SOX.
    Other persons who have posted on this Forum state that existing international financial reporting compliance requirements are also in place. Again, a comprehensive list of companies seems problematic when considering the different means by which a company might be required to comply with some or all aspect of SOX through its business and investment relationships with other companies.
    As for companies that have de-listed or have not gone public due to the SOX burden, that seems to be another issue. I agree that it would be nice to see a compare/contrast of statistics related to companies impacted by SOX and a before/after snapshot. A listing of restatements driven by SOX
    would also be interesting.

  • I agree, Milan. A list of companies covered would be difficult to compile, since some entities are directly affected, while others are indirectly affected. But, it seems odd that the SEC, with all available data since they have to monitor compliance, cannot produce such a list of even the companies directly required to comply. If not for SOx than for all of the other corprate filings.
    Especially since the SEC’s Advisory Committee on Smaller Companies is shortly going to be deciding on its recommendations to the Commission on the fate of SOx for smaller companies.
    I think that other data (like actual compliance costs) would be useful, too.
    On the cost issue, the best information avalable for non-accelerated filers is based on a handful of companies that responded to an questionnaire by the American Electronics Association (which aside from being a trade association, is really a lobbying shop).
    Maybe it’s just me, but it seems that the SEC is making a lot of judgment calls without having a good database of companies/cost affected, and then must rely on non-statistical surveys (no validity, no accuracy, no completeness).
    Solu: Aren’t you glad that you asked a simple SOx question? Let this be a lesson: there are no easy SOx issues.

  • Maybe the SEC HAS compiled a List of Companies that must comply with SOX based on data reported to them under SEC reporting requirements…seems entirely possible and a list that would be quite useful to perform a risk analysis to identify and monitor companies that do not comply with SOX for whatever reason.
    Not to digress, but there are several indirect references in the message thread and others related to the high cost of compliance in connection with SOX.
    An excerpt from a Q-and-A conducted with Lynn Turner is below. Mr. Turner was Chief Accountant for the U.S. Securities and Exchange Commission (SEC) from July 1998 through August 2001. I think the following question and his reply captures the essence of the SOX value proposition:
    Q: So despite all of the complaints, is Sarbanes-Oxley just the price of doing business today if you’re going to do it the right way?
    A: I think so. In November, BusinessWeek ran an article saying that companies are spending an average of USD3 million and 30,000 hours to comply with Sarbanes-Oxley. It would be wrong to refute that. But there was also a much higher price to the corporate greed and the impact it had not only on investors, but on the economy and people in general.
    So if it costs the U.S. USD10-20 billion to implement SOX, that’s a drop in the bucket compared to the USD7 trillion decline in the market cap that we had after Enron, WorldCom, and others. That is a phenomenal cost that is directly attributable to investors’ trust in those corporate executives. And it’s an unfortunate painting of the many corporate executives and employees who are honest, straightforward, and frank.
    For anyone interested, the entire Q-and-A may be found at:

  • BTW guys
    any link which gives a list of companies who have already complied with SOX???

  • NC:
    The best list that I’ve found is at
    There’s a subsription charge, but much of the information is available for free. I don’t think that even this site has a list, per se, but you can see get pieces of lists.

  • The Sox Compliance World would change if the proposal mentioned in the article below goes through
    A U.S. Securities and Exchange Commission panel’s proposal to exempt 80 percent of public companies from having auditors certify their internal controls ‘simply goes too far,’ former Federal Reserve Chairman Paul Volcker and former SEC Chairman Arthur Levitt told the agency.
    In a Feb. 13 letter to the SEC, a group including Volcker and Levitt said such a change would undercut the 2002 Sarbanes-Oxley Act by failing to safeguard against future accounting and company fraud. The letter was sent to SEC Chairman Christopher Cox and William Gradison, acting chairman of the Public Company Accounting Oversight Board (PCAOB).
    ‘In passing the Sarbanes-Oxley legislation, the Congress adopted a reasonable approach to achieve real reform, not just the appearance of reform,’ the letter said. ‘It would be unfortunate now if the SEC and PCAOB undercut the effectiveness of congressional legislation through misguided regulatory action.’
    The law currently requires all U.S. public companies to have their internal controls validated by an auditor. Internal controls refer to the system of checks that companies put in place to safeguard assets, provide reliable financial reports and comply with regulations.
    The SEC’s Advisory Committee on Smaller Public Companies intends to recommend in April that only the largest 20 percent of U.S. public companies obtain annual approval of their internal controls by auditors, as required by Sarbanes-Oxley.
    ‘People will ask who was responsible for a policy decision resulting in such sweeping exemptions,’ the letter said.
    The letter challenging the SEC’s proposal was also signed by John Biggs, former chairman and chief executive officer of TIAA-CREF, the biggest U.S. pension manager; John Bogle, founder and former chairman of mutual-fund company Vanguard Group Inc., and former U.S. Comptroller General Charles Bowsher. The Wall Street Journal reported the letter earlier Tuesday.
    The proposed exemption would free companies with less than USD700 million in stock-market value from the auditing requirement. Critics including the U.S. Chamber of Commerce say smaller companies cannot afford to comply with the requirement.
    The SEC in 2003 estimated that complying with internal- control requirements would cost companies an average of USD91,000 a year each.
    A survey last March by Financial Executives International, which represents chief financial officers and treasurers, said companies with less than USD100 million in market value expected to pay an average of USD824,000 annually to comply.

    The letter endorsed an alternative proposed last month by Levitt. He said the SEC and the accounting oversight board should step up enforcement while easing regulation on companies that have kept a clean record. Levitt also urged development of software to help small companies document and test controls.
    Levitt, 74, is a board member of Bloomberg, parent of Bloomberg News. Volcker was Fed chairman from 1979 to 1987. Most recently, he oversaw the investigation of the United Nations oil-for-food program.
    Roel Campos, one of the five SEC commissioners, has also questioned the rationale for a Sarbanes-Oxley exemption.
    ‘Smaller companies often present the greatest risks to investors,’ Campos said last week in videotaped remarks to an Australian Securities and Investments Commission conference.

  • The PCAOB posts a list of those companies who are current on their support fees. These fees are paid by all public companies and are assessed pro-rata based on market capitalization. My rough guess without counting them all is 10,000 companies 90 pages with about 120 companies listed on each page). How many of these have the requisite market cap that requires them to comply with the rules is not indicated.

Log in to reply