How sub-certification can strengthen disclosure governance

Sub-certifications have increasingly become a foundational element of SOX execution and broader disclosure governance for public companies, helping reinforce consistency, accountability and reporting readiness at scale today. This report, Corporate governance in focus, is based on findings from the EY/Society for Corporate Governance survey of 102 public companies across six broad industry groups. It provides insights into how organizations are designing, governing and evolving their sub-certification processes.

While sub-certifications are widely seen as important, companies differ in how they operationalize them. Nearly all surveyed companies use them quarterly, often across large groups of employees, and many are moving toward automated or hybrid processes. Questionnaire design varies, with most organizations relying on a standardized core and a smaller group tailoring questions by function, role or risk area. Integration with disclosure committee reporting also varies, with some companies providing formal summaries and others treating sub-certifications as a separate process.

The survey results make it clear that sub-certifications are now a core governance mechanism, but their effectiveness can depend on how deliberately they are designed and embedded. Differences in scope, ownership, timing and committee integration may materially influence how well organizations surface disclosure issues, manage late-cycle risk and support executive confidence in the reporting process.