SOX 302 and access reviews: where governance still breaks down

TL;DR: SOX Section 302 requires senior executives to certify disclosure controls, review internal controls, and confirm the accuracy of financial reporting, while the article notes disclosure committees must also examine access, breaches, and other material developments according to Zluri. The governance challenge is that manual certification can still miss who actually had access, when it changed, and whether the control was operational.

NHIMG editorial — based on content published by Zluri: What Is Sarbanes-Oxley (SOX) 302?

Questions worth separating out

Q: How should organisations evidence access control for SOX 302 certification?

A: They should map each certification assertion to identity evidence, including access reviews, privileged access logs, and revocation records.

Q: Why do access reviews matter for SOX 302 compliance?

A: Access reviews matter because SOX 302 depends on executives certifying that disclosure controls are accurate and complete.

Q: What breaks when disclosure committees do not have identity data?

A: What breaks is the ability to verify who had access, who approved exceptions, and whether the controls were active before certification.

Practitioner guidance

• Map certification evidence to identity controls Link each SOX 302 sign-off requirement to a specific IAM, IGA, or PAM evidence source so reviewers can prove who had access, who approved changes, and when revocations were completed.
• Operationalise quarterly access reviews before filing windows Schedule access certification early enough to resolve exceptions before 10-Q or 10-K disclosure decisions, and preserve the approval trail for audit retrieval.
• Track privileged access separately from standard entitlements Keep privileged financial-system access under a distinct review path so elevated rights are not hidden inside broad user recertification cycles.

What's in the full article

Zluri's full blog post covers the operational detail this post intentionally leaves for the source:

• Step-by-step SOX 302 certification workflow and committee responsibilities
• Specific differences between SOX 302 and SOX 404 in disclosure and internal control testing
• How Zluri positions access review automation for Microsoft 365 in the compliance process
• The article's checklist-style FAQs on disclosure committees and de-SPAC obligations

👉 Read Zluri's SOX 302 guide on disclosure controls and executive certification →

SOX 302 and access reviews: where governance still breaks down?

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