How should a CFO judge investment in security, risk and compliance? 8 requirements explained one by one

A CFO in Taiwan signs the financial reports and carries civil liability, and also owns the financial cycles of internal control, annual report disclosure and the compliance budget. This page goes through ERM, ISO 27001, ISO 37001, trade secrets and ISO 56001, ISO 22301, DORA, GDPR, the EU CRA and the EU AI Act from the CFO's seat: their effect on financial reports, disclosure, the TWSE ESG evaluation and the budget.

Updated 2026-11-03

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

RuleKey wordingWhat 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 omissionsThe signers answer for the accuracy of the financial reports
Securities and Exchange Act, Article 20-1Officers 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 6A 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 governanceA statutory continuing education duty
Internal control regulations for public companies, Articles 7 and 8Sales 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 informationThe finance cycles are where compliance systems must connect
Internal control regulations, Articles 22 and 24The 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 yearAudit and self-assessment results of new systems must feed the statement
Annual report regulations, Article 18, item 6Disclose the cybersecurity risk management framework, policy, concrete programmes and resources invested, and the losses, possible effects and responses for major cybersecurity incidentsSecurity spending and incident losses must be explainable in financial terms
Annual report regulations, Article 20, item 6Analyse 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 responsesEU 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.

IndicatorContent (summary)BonusService
S-12Cybersecurity risk management framework, policy, concrete programmes and resourcesOne extra point overall for ISO 27001, CNS 27001 or similar third-party certificationISO 27001
S-10An intellectual property management plan linked to business goals, reported to the board at least once a yearOne extra point overall for TIPS, ISO 56001 or similar third-party certificationTrade secret protection, ISO 56001
G-18Board-level committee oversight of risk management, reported to the board at least once a yearAA item, one extra point overallERM

Requirement by requirement: what the CFO looks at, how to budget, how long it takes

ERM enterprise risk management

ISO 27001 information security management system

ISO 37001 anti-bribery management system

Trade secret protection and ISO 56001

ISO 22301 business continuity management

DORA Digital Operational Resilience Act

GDPR and ISO 27701

EU CRA and the EU AI Act

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.

RuleWhat you already haveHow the new requirements fold in
Internal control regulations, Articles 7 and 8: finance cycles and controlsControl points in the sales and collection, purchasing and payment, financing and investment cyclesMap 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 statementThe annual self-assessment and the board-approved statementInclude the internal audit results of each management system in the basis for the annual self-assessment
Annual report regulations, Article 18, item 6: cybersecurity managementThe annual report's cybersecurity sectionDisclose resources, programmes and certification results with one set of numbers
Annual report regulations, Article 20, item 6: risk itemsThe annual report's risk analysisAdd 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.

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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.

DimensionThe question it answersTypical gap when only this part is done
Process (management system)Who is responsible, what is done, when, where the evidence is, how it improvesTools are in place but nobody runs them on schedule, so there are no records at audit time
Security technologyHow controls are designed and how their effectiveness is verifiedDocuments are complete but the systems do not actually do what they describe
Legal complianceWhich regulation applies, which role you hold, the deadlines and penaltiesControls 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.

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