Change Report: Disclosure and Internal Controls Over Financial Reporting (ICFR)
This report details the material changes observed in Oracle Corp's compliance disclosures across successive filing periods, focusing on strategic pivots, scope adjustments, and control effectiveness.
2021-05-31 to 2022-05-31:
The controls environment remained stable during this period. Management concluded that both Disclosure Controls and Procedures (DCP) and ICFR were effective with no material weaknesses or significant deficiencies identified. In the 2022 filing, the conclusion of effectiveness was noted as having been audited by Ernst & Young LLP.
2023-05-31:
This period saw a significant strategic and operational pivot:
- Strategy Pivot/Restructuring: The company completed the acquisition of Cerner on June 8, 2022.
- Control Scope Expansion (Material Change): As a direct result of this acquisition, the scope of ICFR was expanded to include certain additional internal controls relating specifically to Cerner subsequent to the date of acquisition.
2024-05-31 and 2025-05-31:
Following the integration phase initiated by the Cerner acquisition in 2023, the control environment returned to a state of stability. Both filing periods reported that:
- ICFR remained effective (and was audited by Ernst & Young LLP in 2024).
- There were no material changes or noteworthy new controls identified during the last fiscal quarter in either period.
Summary: The most meaningful change across the reporting history was the expansion of the ICFR scope in the 2023 filing, necessitated by the strategic acquisition and integration of Cerner. All other periods demonstrated consistent effectiveness and stability in the existing control framework.