Identify the reporting role
Connect the recipient to the schedule and the review they must perform.
SOX · Financial-reporting access controls
SOX access controls for financial reporting files
During the close, a reviewer may need temporary access to a supporting schedule. Document who authorized the access, when it should end and how the control owner checks it.
Review temporary exceptions
Record the business reason, approver and expiry for additional access.
Verify the outcome
Check actual access against the approved list after the close.
Test a reporting access control
Choose a closed period and compare the authorization, applied settings and review evidence for one release.
| Define the control | Prepare the evidence |
|---|---|
| Which reporting information is in scope? | The population of users and recipients reviewed |
| Who approves and reviews access? | The decisions and supporting rationale |
| How are exceptions escalated? | Changes made following the review |
| When should the review take place? | Open exceptions and their accountable owners |
Follow an exception to closure
Identify the person responsible for reviewing extended access and record how the exception ended.
- 01
Connect access to a role.
Identify the reporting schedule and the task that requires access during this close.
- 02
Review changes in responsibility.
Reassess permissions when a preparer changes teams or a temporary reviewer completes the assignment.
- 03
Record the review outcome.
Keep the reviewer’s decision, date and supporting evidence with the control record.
Follow an access exception through the close.
A period-end review becomes more revealing when it includes a change in responsibility. Use the examples below to discuss how the control should operate and which evidence would let someone else understand the outcome.
| Change to review | Decision and evidence |
|---|---|
| A preparer moves to another team | Ask whether their continuing access still matches a reporting responsibility. Keep the reviewer’s decision, the reason for it and evidence of any resulting access change. |
| An external reviewer needs temporary access | Define the information required, the approving owner and the end of the assignment. Establish who checks the access again rather than relying on the initial invitation alone. |
| An exception remains open at sign-off | Identify the risk, accountable owner and next action. Make the unresolved item visible in the control record instead of treating the completed review date as evidence that every issue was closed. |
Leave evidence that can be followed.
A reviewer should be able to connect the access population, the decisions made and the changes completed. Keep enough context to distinguish a designed procedure from a review that actually took place.
- The population reviewed
- Record which users, recipients and reporting information were included, together with the date or period covered.
- The decision and rationale
- Show who performed the review, what they concluded and why exceptions were accepted or challenged.
- The follow-through
- Connect each required change to its completion or current status. Keep outstanding actions with a named owner and a clear next review point.
Prepare for the conversation
- A sample reporting pack
- Choose a close or audit handover with representative roles.
- Your control objective
- Explain the financial-reporting risk the review addresses.
- An exception to explore
- Use a role change or temporary reviewer to test the process.
Bring your close process. Map the handovers.
Use a sample reporting pack to discuss recipient management and available exchange records with MX. Your finance, control and IT teams can assess how the proposed workflow fits their responsibilities.
Review your financial-file workflowQuestions for
your review.
Is there a universal SOX-certified file-sharing product?
This page makes no such claim for MX. Evaluate the service against your defined controls and operating environment, within the wider internal-control assessment.
Does SOX prescribe this exact access-review checklist?
No. These are practical review questions. Your control design should follow the relevant financial-reporting risks, scope and assessment criteria.
Can access logs prove a control operated effectively?
They may contribute evidence, but need context. Confirm the completeness of the population, the review performed and the follow-up on exceptions.
Should preparers and reviewers have identical access?
Consider their responsibilities and the risks in the process. Define appropriate separation and approval arrangements rather than assuming one permission model fits everyone.