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How User Access Reviews Help Organizations Achieve SOX Compliance
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Tuesday, September 30, 2025
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In 2025, SOX compliance has evolved beyond basic financial reporting requirements into a comprehensive mandate for robust internal controls that safeguards investor confidence and prevents fraud - it’s about proving that all systems influencing financial reporting are secure, governed, and auditable. ****That includes not only ERP platforms like SAP, NetSuite, and Oracle, but also the infrastructure, identity providers, and cloud services hosting or securing those systems.
User Access Reviews (UARs) have become a cornerstone of SOX compliance. They provide the visibility and control needed to demonstrate that only the right people have the right level of access to financial systems, infrastructure, and supporting applications. With financial data now distributed across SaaS apps, cloud platforms like AWS, and identity providers like Okta or Entra, the ability to demonstrate continuous access governance becomes paramount for audit success and fraud prevention.
SOX Section 404 establishes a dual mandate to internal control oversight.
Section 404(a) requires management to annually assess and report on the effectiveness of their internal controls over financial reporting (ICFR). Meanwhile, Section 404(b) mandates independent external auditor attestation of these internal controls, creating a dual-layer validation system that ensures both accountability and transparency.
The legislation targets a fundamental vulnerability: no single individual should have unchecked control over financial processes or the systems that support them.
This principle directly translates into access control requirements that govern who can view, modify, or authorize actions across scoped enterprise systems.
That scope includes:
Modern SOX compliance encompasses several key access domains that auditors scrutinize during assessments:
Financial Application Access: Direct access to core financial systems including NetSuite, SAP, Oracle ERP, and specialized accounting platforms requires strict governance. These systems process the transactional data that ultimately flows into financial statements, making access control a material concern for audit teams.
Administrative and Privileged Access: Users with administrative rights can bypass standard controls, modify system configurations, or access sensitive financial data across multiple applications. Research indicates that 30% of data breaches involve insider events, with 63% resulting from intentional errors or careless mistakes, highlighting the critical need for privileged access oversight.
Service and Shared Account Management: Generic accounts often fall outside traditional review processes but pose significant risks due to their broad access and lack of individual accountability. These accounts require specialized treatment including periodic password changes and enhanced monitoring protocols.
Organizations must demonstrate compliance across several key areas:
Despite the critical importance of access governance, many organizations still rely on manual, spreadsheet-based review processes that are fundamentally incompatible with modern compliance requirements. These legacy approaches create multiple points of failure that auditors consistently flag during SOX assessments.
Manual processes suffer from inherent visibility gaps and human error, making it nearly impossible to maintain real-time awareness of who has access to what across complex, interconnected financial systems. When employees change roles, receive temporary access for critical business needs, or leave the organization, spreadsheet-based tracking often fails to capture these changes promptly.
Privilege creep represents one of the most pervasive security risks in modern enterprises, occurring when employees accumulate access permissions over time without corresponding removal of previous access rights. This progressive accumulation creates security vulnerabilities that remain undetected without systematic oversight.
The phenomenon accelerates in dynamic business environments where employees frequently change roles, take on temporary assignments, or receive emergency access for critical business needs. Research shows that most organizations have employees who retain inappropriate access beyond their role requirements, while many former employees continue to maintain access to systems after termination.
Modern enterprises typically operate with disconnected identity systems spanning HR platforms, identity providers, ERP suites, and individual financial applications. This fragmentation makes it extremely difficult to maintain a unified view of user access across the organization, particularly for financial systems that often operate with separate access controls.
The complexity multiplies when organizations use multiple ERP systems or have grown through acquisitions, creating access governance blind spots that auditors consistently identify during SOX assessments.
As financial applications migrate to the cloud, infrastructure and platform access has become part of the SOX control environment. Yet many organizations fail to apply the same rigor here as they do with ERP or accounting systems.
Examples include:
Auditors increasingly scrutinize these infrastructure layers because weaknesses here can compromise the integrity of financial reporting just as easily as gaps in the applications themselves.
User Access Reviews provide the systematic mechanism needed to enforce least privilege principles across financial systems. By conducting regular reviews, organizations can identify and revoke excessive permissions that accumulate over time, ensuring that users maintain only the access necessary to perform their current job functions.
Automated UAR platforms can flag users with excessive permissions and provide risk-based recommendations for access optimization. This proactive approach prevents the accumulation of unnecessary privileges that could be exploited for fraudulent activities or create compliance violations during audits.
Segregation of Duties forms the foundation of effective internal controls by ensuring that no single individual can complete critical financial processes end-to-end. SOX requires organizations to prevent toxic combinations such as users who can both approve and release payments, or individuals who can both create and authorize purchase orders.
Modern UAR systems can enforce policy-based SoD restrictions across multiple ERP and finance systems, automatically detecting violations and preventing inappropriate access combinations. This automated enforcement provides continuous monitoring rather than periodic point-in-time assessments.
User Access Reviews serve both detective and preventive control functions within the SOX framework. As detective controls, they identify inappropriate access after it has been granted. As preventive controls, they enable organizations to terminate potentially harmful access before it causes damage.
Documented reviews provide tangible evidence to external auditors that organizations maintain systematic oversight of financial systems. This documentation demonstrates ongoing compliance with SOX requirements and shows management's commitment to maintaining effective controls throughout the year.
Comprehensive audit trails represent a critical component of SOX compliance, providing auditors with the evidence needed to assess control effectiveness. Automated UAR platforms generate timestamped logs of every access decision, reviewer action, and remediation step, creating an immutable record of access governance activities.
This audit-ready documentation significantly reduces the time and effort required during SOX assessments, allowing organizations to quickly produce the evidence auditors need to validate control effectiveness.
As financial systems increasingly move to cloud environments, SOX auditors expect controls to extend beyond applications to the infrastructure and identity platforms that secure them. AWS, Azure, and GCP IAM roles, S3 buckets storing financial exports, or privileged admin access to cloud-hosted SAP environments all fall within scope.
Automated UAR platforms make it possible to review and certify cloud and infrastructure entitlements alongside ERP and SaaS access, ensuring that the entire stack supporting financial reporting is covered under SOX controls.
SOX auditors typically expect quarterly reviews for systems that have material impact on financial reporting. This includes not only direct financial applications but also systems that feed data into financial processes or contain sensitive financial information.
Review coverage must encompass multiple user categories including regular employees with financial system access, privileged users with administrative rights, and service accounts that process automated transactions. Each category requires different review approaches and documentation standards.
Auditors evaluate UAR programs across several dimensions:
Every access decision must be tied to a specific reviewer and timestamp, with clear justification for access grants and documented remediation for inappropriate access. This level of detail demonstrates that reviews are conducted thoughtfully rather than as perfunctory exercises.
BalkanID's platform enables organizations to conduct risk-based User Access Review campaigns specifically aligned with SOX control requirements. The system automatically identifies high-risk access scenarios, such as users with administrative privileges to financial systems or individuals with SoD violations, allowing reviewers to focus attention on the most critical access decisions.
The platform provides native integration with leading financial systems (NetSuite, Workday, SAP, and Oracle) and identity/cloud platforms (Okta, Entra, AWS, Azure, GCP), automatically discovering user access across these critical applications. This integration eliminates the manual data collection that typically consumes weeks of preparation time during SOX audits.
BalkanID offers a graph-based view of detailed access relationships across ERP, IdPs, SaaS, and cloud infrastructure that helps reviewers understand complex access patterns and identify potential risks. This visualization capability makes it easier to spot SoD violations, excessive access accumulation, and other compliance concerns that might be missed in traditional list-based reviews.
The platform includes Joiner-Mover-Leaver lifecycle automation that ensures access changes are processed promptly and documented appropriately. It ensures access is provisioned, updated, or revoked promptly in line with HR events. This automation reduces the risk of former employees retaining access to financial systems and provides auditors with clear evidence of effective access management.
BalkanID's system can enforce Segregation of Duties policies in real-time, preventing toxic access combinations before they occur rather than detecting them during periodic reviews. This proactive approach strengthens SOX controls and reduces the compliance burden during audit seasons.
The platform generates comprehensive audit reports that provide external auditors with the documentation they need to assess control effectiveness. These reports include detailed access histories, review decisions, and remediation activities, presented in formats that align with SOX documentation requirements.
User Access Reviews represent far more than a compliance checkbox—it’s about proving trust at every layer of the stack. User Access Reviews they form the foundation of secure, well-governed organizations that can demonstrate financial integrity to investors, regulators, and stakeholders. In an era where financial fraud can destroy decades of corporate value within months, systematic access governance provides essential protection against both intentional misconduct and accidental errors.
Automating UAR processes through platforms like BalkanID positions organizations ahead of audit timelines rather than scrambling to collect evidence during assessment periods. This proactive approach reduces human error, ensures consistent documentation, and provides the real-time visibility that modern SOX compliance demands.
Organizations that invest in automated UAR capabilities don't just meet compliance requirements—they build competitive advantages through stronger operational controls, reduced fraud risk, and enhanced audit efficiency. As SOX enforcement continues to evolve in 2025 and beyond, these capabilities will become increasingly essential for maintaining market confidence and regulatory standing.
Ready to transform your SOX compliance approach? Explore how BalkanID's automated User Access Review platform can strengthen your internal controls and streamline your audit readiness.
BalkanID UAR Lite - https://www.balkan.id/solutions/uar-lite
BalkanID Lifecycle mangement Lite - https://www.balkan.id/solutions/lifecycle-management-lite
BalkanID UAR- https://www.balkan.id/solutions/uar
BalkanID Lifecycle Management- https://www.balkan.id/solutions/lifecycle-management
Note: The information and product comparisons provided in this document are based on publicly available data and vendor documentation as of September 2025. Sources include official product websites, user documentation, and industry reports. Features and pricing are subject to change. Organizations should verify details directly with vendors before making purchasing decisions.
