COSO Principle 5: The entity holds individuals accountable for their internal control responsibilities

COSO Principle 5 requires you to assign internal control responsibilities to specific people, set clear expectations, and enforce accountability when controls are missed or performed poorly. To operationalize it fast for SOC 2, build an ownership map (RACI), connect controls to job roles and performance processes, and retain repeatable evidence that accountability is applied consistently ¹.

Key takeaways:

• Assign named owners to each in-scope control and document what “good performance” looks like ¹.
• Tie internal control responsibilities to HR processes (onboarding, role changes, performance management) and show consequences for nonperformance ¹.
• Keep auditable proof: ownership records, training/acknowledgments, exception handling, and follow-through documentation ¹.

Compliance teams often document controls well but fail audits on a simpler point: nobody can prove who is accountable, how expectations are communicated, or what happens when control tasks do not occur. The “coso principle 5: the entity holds individuals accountable for their internal control responsibilities requirement” closes that gap. For SOC 2, auditors want more than a control list. They want to see that responsibility is assigned to real roles, that performance is monitored, and that the organization responds when control execution slips.

This is an operational requirement. It touches Governance, Risk, and Compliance (GRC), but also HR, IT, Security, Engineering, Finance, and any business unit that performs controls. The fastest path is to treat accountability as a control system of its own: define ownership, communicate expectations, verify execution, and document corrective action when outcomes fall short.

This page translates COSO Principle 5 into a practical playbook you can implement quickly, with step-by-step actions, evidence to retain, and the exam questions that tend to derail teams ¹.

Regulatory text

Requirement excerpt (TSC-CC1.5): “COSO Principle 5: The entity holds individuals accountable for their internal control responsibilities” ¹.

What the operator must do:
You must be able to demonstrate all of the following in a way that is consistent and repeatable:

1. Clear assignment of responsibility for internal control activities to specific roles and individuals ¹.
2. Defined expectations for how those responsibilities are performed (quality, timing, approvals, documentation) ¹.
3. Ongoing oversight and follow-through when responsibilities are not met, including remediation and, when appropriate, consequences ¹.

Auditors generally assess this through interviews plus artifacts that show responsibility is formalized and enforced, not informal and assumed ¹.

Plain-English interpretation

Accountability means two things you can prove:

• Someone owns each control activity. Ownership is named, current, and unambiguous.
• Ownership has teeth. When a control is late, skipped, or done poorly, you track it, fix it, and prevent recurrence.

If your SOC 2 evidence shows controls “happen,” but you cannot show who is accountable for outcomes, you risk a report observation because the control environment is weak even if the technical safeguards look solid ¹.

Who it applies to (entity and operational context)

Applies to: Service organizations seeking or maintaining a SOC 2 report under the AICPA Trust Services Criteria ¹.

Operational scope: Any function that designs, executes, reviews, or approves controls, including:

• Security and IT operations (access reviews, logging, incident response)
• Engineering (SDLC controls, change management, code review standards)
• People/HR (background checks, onboarding/offboarding, training tracking)
• Finance/Procurement (third party onboarding, approvals, contract controls)
• Compliance/GRC (risk assessment cadence, policy management, exceptions)

Where teams get tripped up: shared controls across departments. A control that spans Security and Engineering needs a primary owner plus defined contributors. “Everyone owns it” fails in practice.

What you actually need to do (step-by-step)

Step 1: Build a control accountability map (ownership and RACI)

Create an inventory of in-scope SOC 2 controls and add:

• Control owner (single throat to choke): accountable for performance and evidence quality.
• Performer(s): who executes the task.
• Reviewer/approver: who checks the work.
• Backup: coverage for PTO and turnover.

Operational tip: Put the RACI directly into your control description so it cannot drift from the control narrative.

Step 2: Define “done” for each control (quality + timing + evidence)

For each control, define:

• Frequency/trigger (e.g., on hire, on termination, on change, monthly)
• Completion criteria (what must be true when complete)
• Evidence required (screenshots, tickets, reports, approvals)
• Exception path (what to do if you cannot complete on time)

This is where accountability becomes testable: the owner is responsible for meeting these criteria and producing evidence that stands on its own.

Step 3: Tie responsibilities to HR and role management

Accountability is easier to prove when internal control duties appear in:

• Job descriptions for control owners and key performers
• Onboarding checklists for privileged roles (admins, approvers, reviewers)
• Role-change workflows (promotions, transfers) that re-check control duties
• Policy acknowledgments (Code of Conduct, security policies) where relevant

Minimum bar: you can show that people who perform controls were informed of responsibilities and were assigned those responsibilities intentionally ¹.

Step 4: Implement routine oversight (performance monitoring)

Set a mechanism that tells you when accountability is breaking down:

• A control calendar with due dates and owners
• Ticket queues with required fields for evidence attachments
• Periodic check-ins run by GRC (status, blockers, overdue items)

Oversight should produce artifacts that an auditor can reperform: a list of controls, due dates, completion status, and follow-up notes.

Step 5: Create an exception and escalation process

Accountability requires consequences, but “consequences” does not have to mean punishment. It must mean documented follow-through:

• Record the missed/defective control
• Assess impact (scope, affected systems, customer impact if any)
• Assign corrective actions with owners and due dates
• Escalate repeated misses to management
• Track closure with evidence

This becomes your strongest proof that accountability exists beyond policy statements.

Step 6: Prove it works during the audit period (operating effectiveness)

For SOC 2, design alone is not enough. During the period:

• Sample completed control executions with attached evidence
• Sample overdue/exception items and show resolution
• Show role changes and how ownership was updated
• Show how you handled coverage during absences or turnover

Practical shortcut: For each control, maintain a single “evidence packet” per period that includes the output plus review sign-off and any exception notes.

Required evidence and artifacts to retain

Maintain these artifacts in a system of record (GRC tool, ticketing system, or well-controlled repository):

1. Control matrix/control register with named owners, performers, reviewers, and backups ¹.
2. RACI or responsibility mapping tied to in-scope controls ¹.
3. Job descriptions / role expectations for key control roles (as applicable).
4. Training and policy acknowledgment records for personnel with control duties.
5. Control execution evidence (tickets, screenshots, system reports, approvals) with dates and reviewer sign-off.
6. Exception log (missed controls, deviations, compensating actions) plus remediation tracking to closure.
7. Meeting notes or dashboards showing oversight and follow-up.

Retention should cover your audit period and support re-performance. Keep evidence readable without relying on tribal knowledge (“Ask Sam what this means”).

Common exam/audit questions and hangups

Expect auditors to ask:

• “Who is accountable for this control, and how do they know they own it?” ¹
• “Show me evidence that the reviewer actually reviewed, not just received.” ¹
• “What happens when this control is missed? Show an example from the period.” ¹
• “How do you handle turnover or PTO for control owners?” ¹
• “How do you ensure responsibilities stay current when systems or org structure changes?” ¹

Hangup pattern: teams produce a policy that says “employees are accountable,” but cannot show assignment, monitoring, or follow-through.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
Control ownership listed as a department (“IT”)	No single accountable person; audit interviews become inconsistent	Assign a named role/person and maintain a backup
No definition of “done”	Evidence is messy; reviewers cannot verify	Add completion criteria + required evidence fields
Reviewer is the same person as performer without rationale	Weak segregation of duties; auditors may question independence	Assign independent review where feasible; document rationale and compensating checks
Exceptions handled in chat/email	No durable audit trail	Use an exception log or ticketing workflow with approvals
Ownership not updated after org changes	Controls lapse silently	Add ownership review to role-change and quarterly control governance

Enforcement context and risk implications

No public enforcement cases were provided for this requirement in the source catalog, so this page does not list specific cases.

Operationally, weak accountability increases the chance that controls become “paper controls”: documented but inconsistently executed. For SOC 2, that commonly shows up as operating effectiveness exceptions, management letter comments, or scope limitations if evidence cannot support testing ¹.

Practical 30/60/90-day execution plan

Days 0–30: Establish ownership and minimum evidence standards

• Identify in-scope systems and controls for SOC 2.
• Assign control owners, performers, reviewers, and backups in a control register.
• Define completion criteria and evidence requirements for the controls most frequently sampled (access, change management, incident response, onboarding/offboarding).
• Stand up a simple exception log and escalation path (who gets notified, who approves compensating actions).

Deliverables: control ownership map, updated control narratives with RACI, evidence checklist templates, exception log.

Days 31–60: Operationalize oversight and connect to people processes

• Add control tasks to a calendar or ticketing workflow with due dates and required evidence fields.
• Train control owners and reviewers on what auditors will request and what “complete evidence” looks like.
• Connect accountability to HR mechanics: role expectations, onboarding checklists for control roles, and a role-change trigger to update ownership.
• Run a monthly control governance check: overdue controls, recurring issues, remediation status.

Deliverables: recurring oversight cadence, training completion records, updated onboarding/role-change workflows, first month of operating evidence packets.

Days 61–90: Prove operating effectiveness and harden against drift

• Perform an internal “mini-audit”: sample controls, verify evidence quality, and test that reviewers can explain and defend outputs.
• Stress-test turnover scenarios: confirm backups, update responsibilities, and show continuity.
• Review exception trends; implement corrective actions that reduce repeats (process changes, automation, clearer criteria).
• Package evidence for the audit period in a consistent structure that auditors can navigate quickly.

Deliverables: internal test results, remediations to closure, readiness package (control-by-control evidence indexing).

How Daydream fits (without changing your operating model)

If your bottleneck is evidence quality and consistency, Daydream can act as the system of record for control ownership, recurring tasks, and evidence collection. The goal is simple: one place to show who owns each control, what they must produce, and what happened when work slipped, mapped directly to SOC 2 expectations ¹.

Frequently Asked Questions

Do I need a formal RACI for every SOC 2 control?

You need a clear assignment of responsibility you can prove. A lightweight RACI (owner/performer/reviewer/backup) per control is usually the fastest way to make accountability auditable ¹.

Can one person own and perform a control?

Sometimes, yes, especially in smaller teams. Document the rationale and add a reviewer or compensating oversight where feasible, because auditors often scrutinize independence for high-impact controls ¹.

What evidence best proves “accountability” to an auditor?

Named ownership in your control documentation plus operating evidence that shows execution, review sign-off, and documented follow-up when something goes wrong. Exception logs with remediation to closure are often the clearest proof ¹.

How do we handle accountability when controls are shared across teams?

Assign one primary control owner who is accountable for end-to-end performance, then list contributors as performers with clearly defined handoffs. Put the handoffs into the control “done” criteria so gaps are visible ¹.

What if we missed a control during the audit period?

Record it as an exception, assess impact, document a compensating action if applicable, and track corrective action to closure. Auditors generally react better to a well-documented miss than to a hidden one ¹.

How often should we review control ownership?

Review ownership whenever there is a role change that affects control execution, and also on a recurring governance cadence so drift does not accumulate. Keep proof of the review (meeting notes, approvals, or a control register change log) ¹.

Related compliance topics

• 2025 SEC Marketing Rule Examination Focus Areas
• Access and identity controls
• Access Control (AC)
• Access control and identity discipline
• Access control management

Footnotes

1. AICPA TSC 2017