TL;DR: SOX programmes often fail where manual access reviews, segregation of duties checks, and audit readiness depend on scarce internal expertise, leaving organisations exposed to errors and remediation delays, according to Zluri. The governance lesson is broader than SOX: identity controls break when review cycles cannot keep pace with operational change.
Editorial analysis by NHI Mgmt Group, based on content published by Zluri: “SOX Compliance Consultants: Critical Skills Required”.
Key questions
Q: What breaks when access reviews are too manual for SOX programmes?
A: Manual access reviews break when the organisation cannot keep pace with entitlement changes, exception handling, and evidence capture.
Q: Why do SOX programmes struggle when internal expertise is limited?
A: Limited internal expertise slows control design, makes remediation harder to track, and increases the chance of review errors.
Q: How do organisations know if access certification is actually working?
A: Look for shrinking numbers of standing privileges, faster revocation after review decisions, and fewer orphaned or overprivileged accounts over time.
Practitioner guidance
- Formalise access certification ownership Assign clear business and control owners for each access review cycle, including approvers, reviewers, evidence custodians, and remediation follow-up.
- Define and maintain SoD rules centrally Create a single SoD rule set for critical finance and IT systems, then map exceptions to named business owners and documented approvals.
- Standardise audit evidence collection Keep walkthrough notes, certification outputs, exception records, and remediation proof in one consistent evidence package for each control period.
Bottom line: The article frames SOX compliance as an identity governance workload problem, where access review and SoD controls fail when they depend too heavily on manual effort.
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SOX access review is really an identity governance problem. The article shows that the hardest part of SOX compliance is not policy language but the ability to verify access, exceptions, and remediation at scale. When organisations rely on manual reviews, they turn identity governance into a recurring labour problem instead of a control system. The practitioner lesson is that SOX effectiveness depends on whether identity data can be reviewed, not merely whether a policy exists.
A few things that frame the scale:
- Nearly 60% of IT leaders cite restrictive cost and complexity as a weakness of legacy identity governance, according to the 2025 State of Identity Governance Report.
A question worth separating out:
A: Access certification verifies whether people still need the access they have. Segregation of duties analysis checks whether those entitlements create toxic combinations that could enable fraud, errors, or misuse. Certification answers whether access should exist at all, while SoD analysis answers whether the remaining access creates an unacceptable control conflict.
👉 Read our full editorial: SOX compliance consultants expose access review gaps in controls