Direct answer: for a CFO, security, risk and compliance are more than a cost. Under Article 14 of Taiwan's Securities and Exchange Act, a public company's financial reports must be signed or sealed by the chairman, managers and the accounting head, with a statement that they contain no false statements or omissions; under Article 20-1, the signers are liable for damages unless they can show they exercised due care. The CFO also owns the finance-related cycles of internal control, the cybersecurity and integrity disclosures in the annual report, cybersecurity risk among the annual report's risk items, and the budget for compliance investment. Winners Consulting's services give a CFO three kinds of value: a system and evidence behind the annual report and ESG evaluation disclosures; EU penalties and market access risk translated into impact; and every compliance investment tied to a customer, a market or an evaluation bonus.
The CFO's responsibilities in the rules
| Rule | Key wording | What it means for the CFO |
|---|---|---|
| Securities and Exchange Act, Article 14(3) | Financial reports must be signed or sealed by the chairman, managers and the accounting head, with a statement that they contain no false statements or omissions | The signers answer for the accuracy of the financial reports |
| Securities and Exchange Act, Article 20-1 | Officers who signed or sealed the financial reports are liable for damages, unless they can show they exercised due care and had reasonable grounds to believe the content contained no false statements or omissions | "Due care" has to be provable with a system and records |
| Regulations on qualifications and continuing education of accounting heads, Article 6 | A newly appointed accounting head completes 30 hours or more of training within one year (including at least 3 hours of ethics and legal liability), then 12 hours or more every year, with subjects including corporate governance | A statutory continuing education duty |
| Internal control regulations for public companies, Articles 7 and 8 | Sales and collection, purchasing and payment, financing and investment cycles; controls over lending of funds, related-party transactions and financial statement preparation; listed companies also cover sustainability information | The finance cycles are where compliance systems must connect |
| Internal control regulations, Articles 22 and 24 | The self-assessment is the main basis for the board and the president to issue the internal control statement; the statement is approved by the board and filed within three months after the end of the financial year | Audit and self-assessment results of new systems must feed the statement |
| Annual report regulations, Article 18, item 6 | Disclose the cybersecurity risk management framework, policy, concrete programmes and resources invested, and the losses, possible effects and responses for major cybersecurity incidents | Security spending and incident losses must be explainable in financial terms |
| Annual report regulations, Article 20, item 6 | Analyse the effect of major domestic and foreign policy and legal changes, and of technology change (including cybersecurity risk), on the company's finances and business, and the responses | EU law and cybersecurity risk belong among the annual report's risk items |
TWSE ESG evaluation: indicators where third-party certification earns a bonus
The ESG evaluation replaced the corporate governance evaluation from 2026 and covers listed companies. The indicators below have the same wording in the 2026 and 2027 editions; the bonus points are the part of the return a CFO can quantify.
| Indicator | Content (summary) | Bonus | Service |
|---|---|---|---|
| S-12 | Cybersecurity risk management framework, policy, concrete programmes and resources | One extra point overall for ISO 27001, CNS 27001 or similar third-party certification | ISO 27001 |
| S-10 | An intellectual property management plan linked to business goals, reported to the board at least once a year | One extra point overall for TIPS, ISO 56001 or similar third-party certification | Trade secret protection, ISO 56001 |
| G-18 | Board-level committee oversight of risk management, reported to the board at least once a year | AA item, one extra point overall | ERM |
Requirement by requirement: what the CFO looks at, how to budget, how long it takes
ERM enterprise risk management
- What it means for the CFO: the risk items under Article 20, item 6 of the annual report regulations and ESG indicator G-18 both need a working risk management system. Neither COSO ERM nor ISO 31000 has a certificate; the result is shown through board-approved policies, operating records and disclosure.
- Timeline (as listed on the service page): four phases, usually 4–6 months; the first board report usually comes at the end of month 3.
- Go deeper: ERM consulting, ERM budget and timeline, CRO role page
ISO 27001 information security management system
- What it means for the CFO: the annual report must disclose the resources invested in cybersecurity; Article 9 of the internal control regulations requires controls over cybersecurity inspection; ESG indicator S-12 adds one point for third-party certification.
- Timeline (as listed on the service page): typically 4–8 months; implemented against ISO/IEC 27001:2022.
- Go deeper: ISO 27001 consulting, CISO role page
ISO 37001 anti-bribery management system
- What it means for the CFO: a typical implementation includes financial controls and approval design and third-party due diligence; the annual report must disclose how integrity management is carried out; ESG indicators S-7 and S-9 look at the integrity policy, the responsible unit and the whistleblowing system.
- Limits of the certificate: ISO 37001 itself states that conformity cannot guarantee that no bribery occurs; the current version is ISO 37001:2025, and certified organisations must transition by 28 February 2027 (as announced by UKAS in the UK and SCC in Canada).
- Timeline (as listed on the service page): typically one to two quarters to build the system and run the internal audit, then certification.
- Go deeper: ISO 37001, Choosing an ISO 37001 consultant
Trade secret protection and ISO 56001
- What it means for the CFO: R&D output is a source of company value; to be protected as a trade secret, information must have secrecy, economic value and reasonable confidentiality measures at the same time (Trade Secrets Act, Article 2). ESG indicator S-10 adds one point for TIPS or ISO 56001 third-party certification.
- Timeline (as listed on the service pages): a trade secret protection programme usually takes 3–6 months; ISO 56001 usually 6–9 months.
- Go deeper: Trade secret protection programme, ISO 56001, ISO 56001 budget and timeline
ISO 22301 business continuity management
- What it means for the CFO: the business impact analysis (BIA) assesses disruption losses and the maximum tolerable period of disruption, which is the basis for estimating the financial impact of an outage.
- Timeline (as listed on the service page): usually 4–7 months; about 3–5 months with 27001 in place.
- Go deeper: ISO 22301, ISO 22301 budget and timeline
DORA Digital Operational Resilience Act
- What it means for the CFO: DORA has applied since 17 January 2025, directly to the EU financial entities listed in Article 2(1); Taiwanese ICT providers serving them take on contract clauses on audit rights, data portability, business continuity and exit strategy.
- Timeline (as listed on the service page): preparing an ICT provider's contractual obligations usually takes 2–3 months; a full framework for a financial institution usually 6–9 months.
- Go deeper: DORA
GDPR and ISO 27701
- What it means for the CFO: a Taiwanese company that offers goods or services to people in the EU, or monitors their behaviour, is covered; fines reach 4% of worldwide annual turnover or EUR 20 million.
- Timeline (as listed on the service page): baseline GDPR compliance usually 2–3 months; with ISO 27701 certification 5–8 months.
- Go deeper: GDPR, ISO 27701 budget
EU CRA and the EU AI Act
- What it means for the CFO: breaching the EU CRA essential requirements can cost up to EUR 15 million or 2.5% of worldwide annual turnover; from 11 December 2027, digital products without conformity assessment and CE marking may not be placed on the EU market. Under the EU AI Act, prohibited practices can cost up to EUR 35 million or 7%, other obligations up to EUR 15 million or 3%.
- Go deeper: EU CRA compliance, CRA budget, AI governance budget
How it fits the systems you already have
Public companies already have an internal control system, an annual self-assessment and an annual report disclosure process; new compliance requirements should connect to them rather than form a second system. The internal control regulations and the annual report regulations apply to public companies; companies that are not public companies are not covered by them and can use them voluntarily.
| Rule | What you already have | How the new requirements fold in |
|---|---|---|
| Internal control regulations, Articles 7 and 8: finance cycles and controls | Control points in the sales and collection, purchasing and payment, financing and investment cycles | Map ISO 37001 financial controls, approvals and supplier due diligence to existing control points in the purchasing and payment cycle |
| Internal control regulations, Articles 22 and 24: self-assessment and the internal control statement | The annual self-assessment and the board-approved statement | Include the internal audit results of each management system in the basis for the annual self-assessment |
| Annual report regulations, Article 18, item 6: cybersecurity management | The annual report's cybersecurity section | Disclose resources, programmes and certification results with one set of numbers |
| Annual report regulations, Article 20, item 6: risk items | The annual report's risk analysis | Add the financial effect of EU legal change and cybersecurity risk, and the responses, to the existing analysis |
How Winners Consulting works
This is Winners Consulting's own description; hold us to the questions above, just as you would any other consultant.
- Who leads: vice-president and director-level consultants personally lead the work end to end, never outsourced
- One body of evidence: ERM risk language links the management systems, and audit results and KRIs go into the same board report
- Fees: depend on scope and the maturity of existing systems; an estimate follows the free diagnosis, and the budget guides show the cost structure of each service
- First step: the first mechanism diagnosis is free
Related questions
- Who signs a Taiwanese public company's financial reports, and what liability do they carry? Under Article 14(3) of the Securities and Exchange Act, the chairman, managers and the accounting head sign or seal the financial reports and state that they contain no false statements or omissions. Under Article 20-1, officers who signed are liable for damages unless they can show due care and reasonable grounds to believe the content contained no false statements or omissions. ERM consulting
- How many hours of continuing education must an accounting head complete? Under Article 6 of the regulations on qualifications and continuing education of accounting heads, 30 hours or more within the first year (including at least 3 hours of ethics and legal liability), then 12 hours or more every year, covering accounting, auditing, finance, financial regulation, corporate governance, ethics and legal liability. ERM consulting
- What cybersecurity information must the annual report disclose? Article 18, item 6 of the annual report regulations requires the cybersecurity risk management framework, policy, concrete programmes and resources invested, and the losses, possible effects and responses for major cybersecurity incidents in the latest year and up to the printing date. ISO 27001 consulting
- Which certifications earn a bonus in the TWSE ESG evaluation? In the 2026 and 2027 indicators, S-12 adds one point overall for ISO 27001, CNS 27001 or similar third-party certification; S-10 adds one point for TIPS, ISO 56001 or similar third-party certification; G-18 on risk management is an AA item worth one extra point. ERM consulting
- What are the maximum fines under EU law? GDPR: 4% of worldwide annual turnover or EUR 20 million; EU CRA essential requirements: EUR 15 million or 2.5%; EU AI Act: EUR 35 million or 7% for prohibited practices and EUR 15 million or 3% for other obligations; whichever is higher in each case. EU compliance integration
- How are consulting fees estimated? They depend on scope, products and the maturity of existing systems; Winners provides a case-specific estimate after the free diagnosis. The budget guides for CRA, TISAX, ISO 27701, AI governance, ERM, ISO 22301 and ISO 56001 show the cost structure. CRA budget
Request a free mechanism diagnosis
Compliance needs all three; a consultant's value is integration
CRA, TISAX, ISO 27701 and the AI Act are not single technical problems. They are only complete when process, security technology and legal compliance all hold at the same time. Fix only one and the gaps in the other two surface during audits, incident reporting or customer due diligence, and the work has to be redone.
| Dimension | The question it answers | Typical gap when only this part is done |
|---|---|---|
| Process (management system) | Who is responsible, what is done, when, where the evidence is, how it improves | Tools are in place but nobody runs them on schedule, so there are no records at audit time |
| Security technology | How controls are designed and how their effectiveness is verified | Documents are complete but the systems do not actually do what they describe |
| Legal compliance | Which regulation applies, which role you hold, the deadlines and penalties | Controls are built against the wrong regulation or role, so obligations are not covered |
Winners' consulting team covers all three dimensions and plans regulatory scoping, process design and technical controls together, so a single body of evidence serves multiple regulations and customer requirements.
Official sources
- 證券交易法第 14 條(全國法規資料庫)
- 證券交易法(全國法規資料庫)
- 發行人證券商證券交易所會計主管資格條件及專業進修辦法(全國法規資料庫)
- 公開發行公司建立內部控制制度處理準則(全國法規資料庫)
- 公開發行公司建立內部控制制度處理準則(金管會主管法規查詢系統)
- 公開發行公司年報應行記載事項準則(全國法規資料庫)
- 臺灣證券交易所公司治理中心:ESG 評鑑(115、116 年度指標)
- Regulation (EU) 2016/679 GDPR(EUR-Lex)
- Regulation (EU) 2024/2847 Cyber Resilience Act(EUR-Lex)
- Regulation (EU) 2024/1689 AI Act(EUR-Lex)