Strengthening SOX Compliance: Lessons from the Field 

For more than two decades, the Sarbanes-Oxley (SOX) Act has shaped the way public companies approach internal controls and financial reporting. What began as a regulatory mandate has evolved into a practice that not only ensures compliance but also strengthens governance and drives business value. 

At Sikich, we’ve worked with companies at every stage of SOX maturity, from newly public corporations to large, well-established enterprises. We’ve observed that success depends less on “checking the boxes” and more on building a program that can adapt to changing risks, expectations, and business realities. Although each organization’s journey is unique, we have seen several themes consistently emerge. 

Emphasize Leadership and Tone at the Top 

SOX compliance is more than an operational exercise; it is a leadership responsibility. When executive management and boards are actively engaged, they set the tone for accountability, secure the resources needed, and ensure that compliance aligns with broader business objectives. Without backing from leadership, programs can end up underfunded or deprioritized. 

Take a Risk-Based Approach, Not a Checklist-Based Approach 

Sometimes, organizations approach SOX as a checklist, especially in their early years. Over time, this mindset can cause programs to stagnate. A risk-based approach is more effective, as an organization with a risk-based approach must continuously identify, reassess, and prioritize financial reporting risks and tailor control activities accordingly. This helps ensure that internal controls are meaningful, relevant, and responsive to change. 

Right-Size Documentation and Scope 

Documentation and scoping decisions can make or break a program. Too much detail can overwhelm teams, while too little can leave gaps that auditors will identify. Similarly, misclassifying operational activities as financial controls or failing to reassess scope following system changes can lead to inefficiencies. Clear, consistent documentation and regular scope reviews are critical for maintaining credibility. 

Collaborate with Auditors 

The relationship with external auditors plays a central role in the effectiveness of a SOX program. Transparent, proactive communication reduces duplication of effort, prevents last-minute surprises, and helps align expectations around evidence and the precision of internal controls. Organizations that foster this partnership find the audit process smoother and less resource-intensive. 

Stay Current with Expectations 

Although SOX has remained stable, the standards and interpretations that shape audit expectations continue to evolve. We frequently see organizations caught off guard by new audit requirements around evidence, management review controls, or third-party reliance. Staying current with audit expectations ensures that your internal controls are not just compliant but also effective under the latest guidance. 

Turn Compliance into Value 

Ultimately, the companies that benefit most from SOX are those that view compliance as more than a regulatory burden. When designed thoughtfully, SOX programs reinforce sound governance, improve process efficiency, and enhance investor confidence. By avoiding common pitfalls and approaching compliance with a proactive, risk-aware mindset, organizations can strengthen both their internal controls and their business resilience. 

At Sikich, we’ve seen firsthand how companies can transform their SOX programs from a cost center into a source of confidence and value. Whether you’re preparing for your first year of compliance or refining a mature program, our Internal Audit team can help you evaluate, build, and enhance internal controls so you can meet evolving expectations with confidence.