An efficient and organized testing strategy is an important part of complying with Sarbanes-Oxley (SOX) Section 404. This guide can be used by Sarbanes-Oxley project teams to test Section 404 key controls and document the testing results. It incorporates the importance of independent testing by internal audit to lessen the work required by the external auditor.

At year-end, management must assess whether there have been changes in internal controls or factors that affect the performance of internal controls that would invalidate, or otherwise impact, the test results of controls performed at an earlier point in time during the year.