We design and implement ITGCs across all four domains — Access to Programs and Data, Change Management, Computer Operations, and Program Development — for every in-scope application and infrastructure component. Controls are designed to satisfy PCAOB AS 2201 requirements and your external auditor's specific expectations, which we coordinate with during the design phase to avoid surprises during testing.

Access controls include role-based access provisioning with manager approval workflows, quarterly access recertification reviews, privileged access management with monitoring, terminated-user deprovisioning within 24 hours, password complexity and rotation policies, and segregation of duties analysis. Change management controls include formal change request documentation, impact assessment and approval workflows, testing requirements and evidence, production deployment authorization with separation from development, and emergency change procedures with post-implementation review.

Computer operations controls include automated batch job monitoring with exception alerting, backup verification testing, disaster recovery planning and annual testing, and system monitoring with documented response procedures. Each control is designed with the evidence collection approach that external auditors expect.

Proper scoping is essential to an efficient SOX IT compliance program. We work with your finance and audit teams to identify financially significant applications, supporting databases and operating systems, network infrastructure components, and third-party service providers within SOX scope. Scoping considers materiality thresholds, transaction volume, financial statement assertions, and the risk of material misstatement.

The IT risk assessment evaluates each in-scope component for risks to financial reporting integrity — unauthorized access, unauthorized changes, processing failures, data loss, and system unavailability. Risk ratings drive control design, testing frequency, and evidence requirements. A well-scoped program focuses resources on the systems and controls that matter most to financial reporting accuracy, avoiding the over-scoping that wastes resources and the under-scoping that creates audit surprises.

We also assess IT dependencies for key financial controls, ensuring that automated controls within ERP and financial applications are supported by the ITGCs necessary for auditors to rely on them.

We design and execute ITGC testing programs that evaluate both the design and operating effectiveness of your controls. Design testing verifies that the control is properly designed to mitigate the identified risk. Operating effectiveness testing verifies that the control operated consistently throughout the testing period. Testing methodologies include inquiry, observation, inspection of documentation, and re-performance of control activities.

Sample sizes follow PCAOB guidance based on control frequency and population size. For continuous controls (like access provisioning), we test samples from throughout the year. For periodic controls (like quarterly access reviews), we test every instance. Evidence is organized, indexed, and documented in a format that external auditors can review efficiently, reducing the time and cost of their testing procedures.

When testing identifies exceptions, we evaluate their severity, determine root causes, implement corrective actions, and assess whether the exception constitutes a deficiency, significant deficiency, or material weakness. Prompt remediation of testing exceptions is critical to achieving a clean audit opinion.

When external auditors identify IT deficiencies — whether control deficiencies, significant deficiencies, or material weaknesses — the remediation must address root causes to prevent recurrence. We analyze each deficiency to understand why the control failed, design corrective actions that address the underlying issue, implement the remediated controls, and test them to verify effectiveness before the next audit cycle.

Common remediation areas include implementing formal access review processes where ad-hoc reviews existed, building change management workflows with proper authorization and testing gates, establishing backup verification testing where backups were assumed to work, deploying monitoring and alerting for batch processing exceptions, and creating segregation of duties matrices for financial applications.

We work directly with your external auditor to ensure our remediation approach meets their expectations and that remediated controls will be tested and accepted during the next audit cycle. Our goal is to close every deficiency in a single audit cycle rather than carrying findings forward year after year.

Companies preparing to go public must have SOX-compliant internal controls operational from their first day as a public company. Building these controls during the IPO process is significantly less disruptive and expensive than remediating deficiencies after going public under intense scrutiny from regulators, auditors, and investors.

Our pre-IPO readiness program assesses your current IT environment against SOX requirements, designs the ITGC framework you will need as a public company, implements controls and documentation during the pre-IPO period, trains your team on SOX compliance responsibilities, and conducts pre-audit testing to validate control effectiveness. We coordinate with your external auditor and legal counsel to ensure the IT control environment is ready for the first SOX assessment.

For emerging growth companies that qualify for the Section 404(b) exemption from auditor attestation, we still recommend building a robust ITGC framework — because the exemption is temporary, investor expectations exist regardless, and a material weakness in the first SOX assessment after the exemption expires is a devastating outcome for stock price and investor confidence.

SOX compliance is a year-round discipline. Controls must operate consistently throughout the fiscal year, and evidence must be collected continuously — not assembled in a rush before audit season. We implement continuous monitoring programs that track control operation in real time: access provisioning and deprovisioning workflows with automatic logging, change management systems with built-in approval tracking, automated backup verification with exception alerting, privileged access monitoring with session recording, and quarterly access review automation.

During the annual SOX audit, our team provides direct support to your external auditor — organizing evidence packages, answering technical questions, facilitating walkthroughs, and coordinating testing access. This reduces audit duration, minimizes disruption to your IT team, and helps ensure a smooth audit process.

Monthly SOX compliance reports keep management informed of control status, exceptions identified and remediated, upcoming control activities, and any risks to the annual assessment. Quarterly steering committee meetings ensure SOX compliance stays on track throughout the year.