Governance, risk and compliance

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.

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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

compliance

Touches

contributes or approves

audit, issues-actions, reporting

Depends on

consumes its output

risk

How the GRC processes connect

Three lines of defense set the frame; the chain shows where each process hands off to the next. Colors follow the role: navy is owned, blue is touched, gray is depended on.

Reporting lines

Who this role reports to, who reports to them, and the peers they work with most.

Reports to

Head of Internal Controls

Head of Internal Controls

See the role

Direct reports

Works closely with

Internal Controls Manager

Internal Controls Manager

See the role
Control Owner

Control Owner

See the role
External Auditor

External Auditor

See the role
Internal Auditor

Internal Auditor

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Chief Audit Executive

Chief Audit Executive

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How SmartSuite supports this role

Lead

Compliance 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

SOX Compliance
Manage SOX compliance with structured control testing, evidence tracking, and real-time visibility into financial reporting controls and audit readiness.
Compliance Assessments & Testing
Manage assessment campaigns and testing schedules with a reusable question library, automated workflows, and one place for evidence collection.
Issues Management
Track and remediate issues across audits, risk, and compliance with structured workflows, clear ownership, and real-time visibility into resolution status.
Internal Audit Management
Plan, execute, and report on audits with complete assurance oversight — linking findings to risks, controls, and remediation actions in a single workspace.

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

Head of Internal Controls

See the role

Frequently asked questions

What is a SOX Program Manager accountable for?

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.

How does SmartSuite help a SOX Program Manager run the testing cycles?

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.

How do external auditors get access to testing results and evidence?

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.

How are deficiencies evaluated and remediated before year end?

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.

How does a SOX Program Manager report readiness to the Head of Internal Controls?

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.

How does an existing SOX program move into SmartSuite before the next cycle?

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.

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