ERP SOX Compliance Checklist for IT General Controls
Sarbanes-Oxley Act compliance for ERP systems requires IT General Controls (ITGCs) that ensure the integrity, confidentiality, and availability of financial data processed through the ERP platform. SOX Sections 302 and 404 mandate that management assess and report on the effectiveness of internal controls over financial reporting, with ERP systems typically in scope as they process the majority of financial transactions. This checklist provides the complete ITGC control framework mapped to SOX requirements.
Access Control and User Management (ITGC-01)
SOX access controls ensure that only authorized personnel can initiate, process, and approve financial transactions within the ERP system. The audit will examine user provisioning procedures, access review processes, privileged account management, and segregation of duties enforcement. Evidence must demonstrate that access is granted based on documented business need, reviewed periodically, and revoked promptly upon termination or role change. PCAOB AS 2201 specifically evaluates the design and operating effectiveness of these controls.
- Document user provisioning procedures with approval workflows: request, business owner approval, security team implementation
- Maintain evidence of quarterly access reviews showing manager certification of each user's role assignments and access rights
- Implement privileged account inventory with justification documentation for every admin-level ERP account (PCAOB AS 2201)
- Configure automated account deactivation within 24 hours of employee termination notification from HR systems
- Generate monthly user access reports showing all active accounts, assigned roles, and last login dates for audit evidence files
Change Management and Program Development (ITGC-02)
SOX change management controls ensure that modifications to the ERP system (configuration changes, customizations, patches, upgrades) follow a documented process with proper authorization, testing, and approval before production deployment. Auditors examine the change management policy, change request documentation, test evidence, approval records, and separation between development and production environments. Emergency change procedures must also be documented with compensating controls.
- Maintain change management policy defining the complete lifecycle: request, impact assessment, approval, development, testing, deployment
- Document all ERP changes in a ticketing system (ServiceNow, Jira) with linked approval records and test evidence artifacts
- Enforce separation of environments: development, testing/QA, and production with access controls preventing developer access to production
- Require formal sign-off from business process owner and IT security before any change is migrated to the production ERP environment
- Document emergency change procedures with compensating controls: post-implementation review and retroactive approval within 48 hours
Computer Operations and Data Integrity (ITGC-03/04)
SOX computer operations controls cover backup and recovery procedures, batch job monitoring, system availability management, and data integrity validation. Data integrity controls ensure that financial data is processed completely and accurately through the ERP system, with reconciliation procedures detecting and correcting errors. Auditors will request evidence of backup testing, disaster recovery plan testing, batch processing monitoring, and data reconciliation procedures performed during the audit period.
- Test ERP backup restoration quarterly with documented results confirming successful recovery of database and application tiers
- Conduct annual disaster recovery plan testing simulating complete site failure with recovery time and data loss measurements
- Monitor batch processing jobs (MRP, financial close, report generation) with automated alerting for failures and delayed completions
- Implement data integrity reconciliation procedures: subledger-to-GL balance reconciliation performed monthly with variance investigation
- Maintain system availability metrics demonstrating ERP uptime meets SLA requirements (typically 99.5%+) for financial processing periods
Preparing for a SOX audit? Netray delivers ITGC assessment and remediation services that ensure your ERP system passes SOX compliance requirements.
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