SOX IT General Controls Checklist Template

Your vendor processes financial transactions. Their system goes down during quarter-end close. Your SOX auditor asks for their ITGC assessment. You have nothing.

This scenario keeps TPRM managers awake at night. The SOX IT General Controls Checklist Template prevents it by systematically evaluating whether third parties maintain the technical controls required for accurate financial reporting.

IT General Controls (ITGCs) form the foundation of SOX compliance. They ensure the technology supporting financial processes operates correctly, consistently, and securely. When vendors touch your financial systems—whether through ERP integration, payment processing, or data hosting—their ITGCs become your risk.

This checklist transforms ITGC assessment from a scramble into a repeatable process. Instead of starting from scratch for each vendor, you deploy a comprehensive control framework that captures evidence, maps to regulatory requirements, and generates audit-ready documentation.

Core Components of the SOX ITGC Checklist

The template organizes controls into five interconnected domains that mirror how auditors evaluate IT environments:

1. Access Controls

The largest section, typically containing 25-35 control points focused on authentication, authorization, and access review processes.

Key control areas:

• User provisioning and deprovisioning procedures
• Password complexity and rotation requirements
• Privileged access management
• Access review frequency and documentation
• Multi-factor authentication implementation

Evidence requirements:

• Screenshots of access control configurations
• User access listings with last login dates
• Termination checklists showing disabled accounts
• Quarterly access review sign-offs

2. Change Management

15-20 controls ensuring modifications to financial systems follow documented procedures with appropriate approvals.

Critical checkpoints:

• Change request documentation standards
• Testing requirements before production deployment
• Segregation between development and production
• Emergency change procedures
• Post-implementation review processes

Common evidence gaps:

• Missing CAB (Change Advisory Board) meeting minutes
• Incomplete testing documentation
• Lack of rollback procedures

3. Computer Operations

10-15 controls covering the day-to-day management of IT infrastructure supporting financial processes.

Assessment focus areas:

• Backup procedures and restoration testing
• Job scheduling and monitoring
• Incident response procedures
• Capacity planning documentation
• System availability metrics

4. Program Development

Controls ensuring new systems or significant modifications follow secure development practices.

Key verification points:

• SDLC (Software Development Lifecycle) documentation
• Code review procedures
• Security testing requirements
• Data migration controls
• User acceptance testing sign-offs

5. Segregation of Duties

Cross-functional controls preventing single individuals from controlling entire financial processes.

Risk indicators:

• Developers with production access
• Single approval for critical changes
• Shared administrative accounts
• Lack of compensating controls

Industry-Specific Applications

Financial Services

Banks and investment firms extend the basic ITGC framework with additional controls for:

• Trading system access restrictions
• Real-time transaction monitoring
• Regulatory reporting accuracy
• Customer data protection under GLBA

Implementation tip: Financial services vendors often maintain SOC 1 Type 2 reports. Cross-reference their control descriptions with your checklist to avoid redundant testing.

Healthcare

Healthcare organizations adapting the SOX ITGC template must overlay HIPAA requirements:

• PHI access logging beyond financial data
• Encryption controls for data at rest and in transit
• Business Associate Agreement compliance
• Breach notification procedures

Evidence overlap: Many ITGC controls satisfy both SOX and HIPAA. Document once, reference twice.

Technology Companies

SaaS providers and technology vendors typically require expanded sections on:

• API security controls
• Multi-tenant data isolation
• Continuous deployment safeguards
• Source code management

Framework Alignment Opportunities

The SOX ITGC checklist creates efficiencies across multiple compliance requirements:

SOC 2 Mapping

• CC6.1 (Logical Access Controls) → SOX Access Controls section
• CC8.1 (Change Management) → SOX Change Management section
• CC7.2 (System Monitoring) → SOX Computer Operations section

ISO 27001 Crosswalk

• A.9 (Access Control) maps directly to ITGC access requirements
• A.12.1 (Operational Procedures) aligns with computer operations controls
• A.14.2 (Security in Development) parallels program development section

NIST Cybersecurity Framework

• PR.AC (Identity Management and Access Control) = Access Controls
• PR.IP (Information Protection Processes) = Change Management
• DE.CM (Security Continuous Monitoring) = Computer Operations

Implementation Best Practices

1. Risk-Based Scoping

Not all vendors require full ITGC assessment. Apply tiered approach:

Tier 1 (Critical): Full checklist for vendors touching GL, financial reporting, or SOX-relevant systems Tier 2 (High): Focus on access controls and change management Tier 3 (Medium): Abbreviated questionnaire covering authentication and backup procedures

2. Evidence Collection Strategy

Structure evidence requests to minimize vendor fatigue:

• Request screenshots during live demos
• Accept existing audit reports where controls align
• Use sampling for high-volume evidence (3 months of change tickets vs. full year)
• Leverage automated evidence collection where possible

3. Assessment Cadence

Align ITGC reviews with broader vendor management cycles:

• Initial assessment during onboarding
• Annual refresh for critical vendors
• Triggered reassessment after incidents or significant changes
• Abbreviated quarterly check-ins for highest-risk vendors

4. Control Mapping Documentation

Maintain traceability between checklist items and regulatory requirements:

Checklist Item	SOX Requirement	SOC 2 Criteria	ISO 27001 Control
User Access Reviews	Section 404	CC6.2	A.9.2.5
Change Approval Process	AS5	CC8.1	A.12.1.2
Backup Testing	Section 404	A1.2	A.12.3.1

Common Implementation Mistakes

1. Over-Testing Low-Risk Vendors

Running full ITGC assessments on vendors that don't touch financial systems wastes resources. If they can't impact financial reporting, basic security controls suffice.

2. Accepting Vague Responses

"We follow industry best practices" isn't evidence. Demand specific procedures, screenshots, and approval records.

3. Ignoring Compensating Controls

Small vendors may lack sophisticated controls. Document compensating measures like increased monitoring or transaction limits.

4. Point-in-Time Thinking

ITGCs require ongoing operation. Don't just verify controls exist—confirm they operated effectively throughout the period.

5. Siloed Assessment Approach

ITGC reviews shouldn't happen in isolation. Integrate findings with broader vendor risk assessments, contract reviews, and performance monitoring.

Frequently Asked Questions

How often should we update our SOX ITGC checklist template?

Review annually at minimum, with updates triggered by regulatory changes, audit findings, or significant control failures. Most organizations refresh before their SOX audit planning cycle.

Can we use SOC reports instead of the ITGC checklist?

SOC reports provide valuable evidence but rarely cover all ITGC requirements. Use them to pre-populate responses, then supplement with vendor-specific questions for gaps.

What's the minimum vendor size that needs full ITGC assessment?

Size matters less than system access. A two-person vendor with financial system admin rights needs full assessment. A thousand-person vendor providing office supplies needs none.

How do we handle vendors who refuse to complete the full checklist?

Document the refusal, escalate through procurement, and consider compensating controls. For critical vendors, refusal to provide ITGC evidence should trigger contract renegotiation or replacement.

Should we customize the checklist for each vendor?

Maintain a core template but allow section-level customization. Cloud vendors need different controls than on-premise software providers. Build modular sections you can mix and match.

How long should vendors have to complete the ITGC assessment?

Provide 15-20 business days for initial assessments, 10 days for annual updates. Critical findings may require faster response. Build timelines into your vendor contracts.

What if a vendor's controls don't align with our checklist structure?

Focus on control objectives, not format. If they achieve the same risk reduction through different means, document the alternative approach and its effectiveness.