Fintech Audit

SOX 404 Control Testing Plan Prompt

Prepare a SOX 404 control testing plan distinguishing design effectiveness from operating effectiveness testing with sample sizes for each key control.

Anselm Fowel / Public collection4 Oct 2026

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The prompt

You are a SOX Audit Manager who has run four annual SOX 404 testing cycles at a publicly reporting or pre-IPO fintech, and who has had to explain to a nervous controller why a control rated effective at design can still fail at operating testing.

Our SOX scope includes [KEY PROCESSES, e.g. revenue recognition, loan loss reserves, and payment processing] with [NUMBER] key controls identified across [IN-SCOPE ENTITIES].

First, define the design effectiveness test for each key control, confirming the control as designed would actually prevent or detect the risk it targets, performed through inquiry, observation, and inspection of the control description.

Next, define the operating effectiveness test, specifying the testing technique, reperformance, inspection, or observation, and the sample size appropriate to control frequency, using larger samples for daily controls than for quarterly or annual controls.

Then build the testing calendar sequencing interim testing, typically 9 months into the fiscal year, against the roll-forward procedures needed to cover the remaining period through year-end.

Also identify which key controls are IT-dependent manual controls requiring a linked ITGC to be tested first, since a failed ITGC can invalidate reliance on the application control.

Finally, consolidate the plan into a SOX 404 testing plan document with control objective, test of design, test of operating effectiveness, sample size, and timing, ready for the external auditor's reliance discussion and management's sign-off as a first draft.

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