财政部牵头、五部委联合于2008年发布《企业内部控制基本规范》(简称《基本规范》),2010年发布20项《配套指引》,在国内外内控发展史上是具有里程碑意义的举措,有力地推动了国内上市公司和国有企业内部控制制度建设,其贡献有目共睹。但从笔者主持设计40家左右的企业单位内部控制体系的经验来看,笔者认为,《基本规范》和《配套指引》仍有一些不足,还需要进一步修改完善。首先是《基本规范》的修改完善。笔者认为,《基本规范》至少需要在如下方面进行调整:(1)整体 Under the lead of the Ministry of Finance, the five ministries and commissions jointly released the “Basic Norms for Enterprise Internal Control” (the “Basic Specifications”) in 2008 and released 20 “Supporting Guidelines” in 2010, which are milestones in the development of internal control at home and abroad To promote the domestic listed companies and state-owned enterprise internal control system, its contribution for all to see. However, from the author’s experience in designing the internal control system of about 40 enterprises and units, the author believes there are still some shortcomings in the “basic norms” and “supporting guidelines”, and further improvements and improvements are needed. The first is the revision of the “basic norms”. The author believes that “basic norms” at least need to be adjusted in the following areas: (1) the overall