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SAP SoD Mitigating Control Register Worksheet

Not every segregation of duties conflict can be removed. Small teams and Basis roles often need a compensating control, and auditors want to see it written down with an owner and a review date.

Download:

User or role	Risk description	Process	Impact (1-5)	Likelihood (1-5)	Inherent score	Mitigating control	Control frequency	Control owner	Next review	Status
					15
					12
					10
					8

Total inherent score

Highest single score

Average inherent score

11.25

Use impact and likelihood on a 1 to 5 scale agreed with your risk team. A mitigating control must be performed by someone independent of the conflicting duties and must leave evidence. Set the status to Remove access if no workable control exists.

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How to use the register

Add a row for each accepted conflict. Describe the risk in plain language, score impact and likelihood, then record the control that reduces the risk, who performs it and how often. The score column multiplies impact by likelihood so you can sort the worst items to the top. Review the whole register at least annually and re-approve overdue items.

One row per conflict per user or role
Name the control precisely, including the report or check used
Assign a person as owner, not a department
Set a next review date and track overdue rows

What makes a control valid

A mitigating control has to detect or prevent the misuse the conflict allows. A manager who reviews vendor master changes each month detects a fake vendor, while a general policy statement does not. The control owner should be independent of the user holding the conflict, the work must be evidenced (a signed report, a ticket, a log), and it must run at a frequency that fits the risk. SAP GRC Access Control lets you assign mitigating controls to users and roles, and this sheet works as an offline register or for systems outside GRC.

Reading the scores

The inherent score shows the risk before the control. A score of 15 or more usually deserves senior attention, but the thresholds belong to your risk policy. Rows with high scores and a weak control, or a control that is overdue, are the first to challenge. If a conflict has a high score and no practical control, remove access.

Common mistakes

Frequent mistakes are accepting a risk with no named owner, using a control the conflicted user performs themselves, and leaving expired approvals in place. Another is treating the register as a one-time clean-up instead of a living control.

Frequently Asked Questions

Is a mitigating control the same as a compensating control?

In practice the terms are used interchangeably. Both describe an additional control that reduces the risk of a conflict that cannot be removed. Use the term your auditors use.

Can the user's manager be the control owner?

Often yes, if the manager is independent of the conflicting duties and has the information needed to detect misuse. Avoid a manager who also approves the user's transactions.

How often should mitigating controls be reviewed?

At least annually, and when the user, role or process changes. High-risk items may need a shorter cycle. Your risk policy sets the rule.

Does this replace SAP GRC risk analysis?

No. GRC finds the conflicts. This register records the decision about each one that remains, and can be used where GRC is not available.

If you want conflict reports and control evidence pulled from SAP automatically, Netray can build read-only reporting on-prem for your GRC team.

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