Section 404 of the Sarbanes Oxley Act applies to all issuers required to file reports under the Securities and Exchange Act regardless of their size. Even small issuers need to evaluate their internal controls based on an internal control framwork such as COSO, CoCo etc. Due to an informal structure, such small issuers will have to tweak their evaluation of internal controls over financial reporting to their specific requirements.

For the purpose of the Sarbanes Oxley Act, Small business Issuers not covered under accelerated filer are those issuers -

- companies having public common stock capitalization of that is less that $ 75 million

- Or are eligible to file annual reports on Form 10 - KSB thus qualifying as "Small Business Issuers".

Small Business issuers are also not subject to the "Accelerated Filer" Rules.

COSO (Committee of Sponsoring Organizations) has recently issued an Internal Control: Integrated Framework guidance specifically for Small business issuers. The new Framework caters specifically to the requirements of small businesses. This framework draws heavily from the existing COSO framework with additional inputs for small businesses.