SOX Program Manager
Operations
SmartSuite for the SOX Program Manager
The SOX Program Manager manages SOX scope, testing cycles, timelines and coordination across entities and auditors. They launch quarterly and annual cycles, track completion, exceptions and evidence submission, and escalate readiness risks to the Head of Internal Controls before certification deadlines.
Reports to:
What you own
The SOX Program Manager manages SOX scope, testing cycles, timelines and coordination across entities and auditors.
- Define SOX scope, key controls and the annual program calendar
- Launch quarterly and annual testing cycles with assignments
- Track completion, exceptions and evidence submission across entities
- Coordinate control owners, testers and external auditors
- Manage deficiency evaluation and remediation timelines
- Report readiness status and escalate risks before deadlines
At a glance
The GRC processes this role owns, touches and depends on.
Owns
accountable for the process
Touches
contributes or approves
Depends on
consumes its output
How the GRC processes connect
Three lines of defence set the frame; the chain shows where each process hands off to the next. Colours follow the SOX Program Manager: navy is owned, blue is touched, grey is depended on.
- First lineThe business and its control ownersRun the processes, own the controls, fix the issues
- Second lineRisk, compliance and the domain programmesSet the frameworks, assess, monitor and advise
- Third lineInternal auditIndependent assurance to the board and audit committee
Reporting lines
Who this role reports to, who reports to them, and the peers they work with most.
Reports to
Head of Internal Controls
See the roleDirect reports
Works closely with
Internal Controls Manager
See the roleControl Owner
See the roleExternal Auditor
See the roleInternal Auditor
See the roleChief Audit Executive
See the roleHow SmartSuite supports the SOX Program Manager
The SOX Program Manager runs scope, testing cycles and evidence across entities and auditors, answering to the Head of Internal Controls for readiness before each certification deadline. SmartSuite connects processes, controls, tests, evidence and deficiencies in one workspace, so cycle status is live and the auditor's question is answered from the records the testers used.
Run scope and the testing cycles across entities
SOX scope, processes, risks, key controls and their frequency are held in one connected system, every control with a clear owner, so the annual program calendar is derived from the control population rather than a spreadsheet maintained beside it.
SOX Management suiteQuarterly and annual testing cycles launch with automated assignments to testers and evidence requests to Control Owners, reminders chasing the deadlines, and interim testing and year-end readiness tracked across quarters without manual status reporting.
SOX Management suiteIT general controls and business process controls are tested in the same connected workflow with consistent procedures, templates and scoring, so the entity that tests both reports completion on one scale and exceptions are compared like with like.
SOX Management suiteCoordinate control owners, testers and auditors
The External Auditor gets controlled, traceable access to testing results and supporting evidence, so the request list is answered from the workspace with every view logged. The Internal Auditor and Chief Audit Executive read the same population.
SOX Management suiteA control failure surfaced in testing is routed automatically to the Internal Controls Manager and the Control Owner for evaluation, with the deficiency, its severity and the remediation plan on the same record as the test that found it.
SOX Management suiteFinance, IT, Internal Audit and Compliance share visibility of SOX responsibilities, completion and open items by entity, so the coordination across subsidiaries and the auditor's firm is a dashboard everyone reads rather than a weekly reconciliation call.
SOX Management suiteReport readiness and escalate before the deadline
Real-time SOX dashboards show control coverage, testing status, deficiencies and remediation progress by entity and quarter, so the Head of Internal Controls and the Controller see readiness as it stands and you escalate from a number, not a feeling.
SOX Management suiteSignificant deficiencies, material weaknesses and corrective actions are tracked with due dates and escalation, and retesting decisions are captured with version control, so the aggregation decision at year end is made on complete remediation records.
SOX Management suiteThe AI Assistant in a SmartDoc field drafts testing summaries, deficiency narratives and responses to auditor queries from the records, and full histories of testing, evidence, approvals and changes stand behind each one for the 302 and 404 certifications.
SOX Management suiteCompliance management. Launches quarterly and annual testing cycles with automated assignments and tracks completion, exceptions and evidence across entities.
Internal audit. Gives external auditors controlled, traceable access to testing results and evidence.
Issues and actions. Tracks deficiencies and remediation with due dates and escalation.
Reporting. Monitors readiness with dashboards and escalates risks before certification deadlines.
Products this role uses most
Industry reference
SOX Section 302 requires quarterly executive certifications; Section 404(a) requires management's annual assessment of internal control over financial reporting and 404(b) the auditor's attestation for accelerated filers. PCAOB AS 2201 sets the top-down, risk-based approach the auditor follows, and COSO 2013 is the framework almost every registrant uses.
Equivalent programs exist elsewhere: FDICIA Part 363 for larger banks, Japan's J-SOX, and the UK's material controls declaration under the 2024 Corporate Governance Code. Subsidiaries of registrants in healthcare, technology and other sectors inherit the program regardless of their own listing status.
Related roles
Head of Internal Controls
See the roleExplore Further
Guides and definitions from the GRC Knowledge Center and the What-is glossary, chosen for this role.
Frequently asked questions
The SOX Program Manager is accountable for the program that gets the organization to certification: the SOX scope, key controls and the annual calendar, the quarterly and annual testing cycles and their assignments, completion, exceptions and evidence submission across entities, coordination of control owners, testers and external auditors, deficiency evaluation and remediation timelines, and the readiness reporting that escalates risks to the Head of Internal Controls before the Section 302 and 404 deadlines. Missed evidence is the failure mode the role exists to prevent.
SOX Compliance launches quarterly and annual testing cycles with automated assignments and tracks completion, exceptions and evidence across entities, so launching a cycle assigns every key control to its Control Owner and tester with a due date, and the SOX Program Manager watches completion, exceptions raised and evidence submitted entity by entity. Compliance Assessments & Testing holds the test steps and results. Chasing shifts from email to a view of what is outstanding and who owes it.
Internal Audit Management gives external auditors controlled, traceable access to testing results and evidence, so the External Auditor reviews the test results and the evidence behind them in the system rather than through evidence request lists and shared drives. Access is scoped and recorded, which means the SOX Program Manager can see what the auditor has looked at and what they have asked for. The Internal Auditor's own testing sits in the same place where management relies on it.
Issues Management tracks deficiencies and remediation with due dates and escalation, so each exception that becomes a deficiency carries its evaluation, its remediation owner and a date set with the certification deadline in mind, and an overdue remediation escalates to the Internal Controls Manager and upward. The SOX Program Manager can show the Head of Internal Controls which deficiencies will be remediated and retested in time and which will have to be reported.
SmartSuite monitors readiness with dashboards and escalates risks before certification deadlines, so the SOX Program Manager's report to the Head of Internal Controls and the Controller shows testing completion by entity, open exceptions and deficiencies and the remediation that will or will not land before the deadline, read from the cycle records. The Chief Audit Executive sees the same readiness picture. Risks to certification are raised when there is still time to act, not at the sign-off meeting.
By loading the scope, the key control list with owners and testers, the test steps and the calendar, which is the material every program already has in its risk and control matrix; the first cycle can then be launched from the system. Prior-year evidence is attached where auditors will want to compare. Programs under J-SOX, FDICIA Part 363 or the UK material controls declaration follow the same path, and subsidiaries that inherit a parent's program can be set up as entities within it.