Is your Oracle EBS segregation of duties actually governance-ready?

Use this checklist to assess whether your Oracle E-Business Suite segregation of duties and privileged access process is governance-ready at the entitlement level — not just at the Responsibility label.

Complete it with Oracle EBS application, security, IT risk, Internal Audit and business control owners where possible. Record the evidence behind each answer rather than scoring the process from memory.

How to score

• Yes — 2. The requirement is documented, consistently performed, and supported by evidence.
• Partial — 1. The activity happens in some cases, depends on manual judgment, or isn’t supported by consistent evidence.
• No — 0. The requirement isn’t defined, isn’t performed, or can’t be evidenced.

Critical items represent gaps that leave privileged access or a segregation-of-duties conflict invisible, unowned, or unprovable. Any zero on a critical item is a priority even if the total score looks acceptable. This checklist has 41 checks, 18 of them critical, and a maximum score of 82.

1. User lifecycle and privileged accounts

#	Governance check	Critical?	Score: 0, 1, or 2	Evidence or action
1	We maintain a current inventory of privileged Responsibilities, including SYSADMIN, System Administrator, Application Developer, and other elevated admin or sensitive setup Responsibilities.	Yes
2	We separately identify users with high-risk Concurrent Programs or sensitive Functions, even when those capabilities are buried inside broader Responsibilities.	Yes
3	Privileged Responsibilities and sensitive capabilities are reviewed on a defined cadence that is distinct from routine business access reviews.	No
4	Joiner processes assign only the Responsibilities and organizational scope required for the user's job.	No
5	Mover processes remove or end-date Responsibilities and organizational access that are no longer appropriate when roles change.	No
6	Leaver processes disable Oracle EBS accounts and remove or end-date Responsibilities within defined policy timelines.	Yes
7	We can show evidence, not just ticket records, that joiner, mover and leaver changes were completed in Oracle EBS.	Yes
8	We periodically review obsolete, custom or rarely used Responsibilities for hidden sensitive Functions and high-risk Concurrent Programs.	No
9	We check for lingering privileged or sensitive access on users who have changed roles or left the organization.	Yes
10	We review whether broad Operating Unit, Inventory Organization or Ledger access is still appropriate for each user population.	No

Section maximum: 20

Warning signs for this section

• Privileged capability is only visible where someone thought to look — sensitive Functions and high-risk Concurrent Programs inside broader Responsibilities go uncounted.
• Evidence is reassembled from emails, spreadsheets and ticket notes when an auditor asks for it.

2. Segregation of duties rules and conflicts

#	Governance check	Critical?	Score: 0, 1, or 2	Evidence or action
11	We have documented the high-risk conflict scenarios that matter in our Oracle EBS environment.	No
12	Our rules cover common patterns such as supplier maintenance and payment processing, journal entry and journal posting, bank maintenance and payment execution, user administration and Responsibility assignment, customer maintenance and receipts or refunds, and asset creation and disposal.	No
13	Conflict definitions are reviewed periodically with business, audit and control owners.	No
14	We run segregation of duties analysis at the Responsibility level and at the Function and Concurrent Program level.	Yes
15	We resolve what sits beneath each Responsibility so that conflict analysis is based on effective access, not labels alone.	Yes
16	Our segregation of duties analysis considers organizational context such as Operating Units, Inventory Organizations, Ledgers or equivalent scope when determining whether a conflict is real.	Yes
17	We have reduced dependence on Responsibility-name-only reviews that create false positives and false negatives.	No
18	We maintain a current conflict list showing which issues are open, mitigated, remediated, accepted or under review.	Yes
19	Each conflict record is tied to specific users, the Responsibilities involved, the Functions or Concurrent Programs that create the conflict, and the organizational scope where the conflict exists.	Yes
20	We can separate high-risk open conflicts from lower-risk or already mitigated items quickly.	No

Section maximum: 20

Warning signs for this section

• Segregation of duties analysis is run on Responsibility names alone, so conflicts are both invented and missed.
• A conflict list exists but cannot say which users, which Functions, or which Operating Unit it applies to.

3. Mitigation and remediation

#	Governance check	Critical?	Score: 0, 1, or 2	Evidence or action
21	We document mitigating controls for retained segregation of duties conflicts and privileged access exceptions.	No
22	Each mitigation has a named owner responsible for its operation.	Yes
23	Mitigating controls are described clearly enough that reviewers and auditors can understand how residual risk is reduced.	No
24	We review mitigating controls on a defined cadence to confirm they are still in place and still appropriate.	No
25	We record approval evidence for why a conflict or privileged access assignment was accepted instead of removed.	Yes
26	We create formal remediation plans for conflicts that should be removed.	No
27	Remediation plans include timelines, responsible parties and specific actions, such as Responsibility removal, narrowing of organizational scope, or removal of sensitive Functions or Concurrent Programs.	No
28	We track remediation progress and can see which actions are completed, in progress or overdue.	No
29	We can prove that flagged access was actually revoked, end-dated or changed in Oracle EBS.	Yes
30	The rationale for retain, remove, modify, escalate or mitigate decisions is captured consistently.	No
31	Evidence of mitigation and remediation decisions can be retrieved without reconstructing the story from emails, spreadsheets and ticket notes.	Yes
32	Privileged access exceptions follow the same discipline as segregation of duties conflicts: documented, owned and evidenced.	No

Section maximum: 24

Warning signs for this section

• A mitigating control is recorded with no named owner, so nobody is accountable for it operating.
• Access is flagged for removal and nobody confirms it was actually removed or end-dated in Oracle EBS.
• Evidence is reassembled from emails, spreadsheets and ticket notes when an auditor asks for it.

4. Evidence and reporting

#	Governance check	Critical?	Score: 0, 1, or 2	Evidence or action
33	Responsibility assignments, review populations, segregation of duties results, approvals, mitigation decisions and remediation outcomes are stored in a consistent way.	No
34	We can connect the full chain for a sample user or conflict: access requested, access approved, Responsibility assigned with organizational scope, conflicts identified, mitigation or remediation decisions made, and final access status after changes.	Yes
35	Evidence is retained in a centralized model rather than scattered across extracts, spreadsheets, emails, ticket histories and shared folders.	Yes
36	We can produce Oracle EBS segregation of duties and privileged access reports that do not require extensive manual cleanup.	No
37	Reports show Responsibility names, underlying Functions and Concurrent Programs where relevant, organizational scope such as Operating Units, Inventory Organizations and Ledgers, and conflict status including open, mitigated, remediated and accepted.	No
38	We can easily separate privileged Responsibilities and sensitive Functions, high-risk open conflicts, and conflicts that are already mitigated or remediated.	No
39	Our team can clearly explain how segregation of duties rules are defined, how conflicts are evaluated in business and organizational context, how exceptions are approved and mitigated, and how remediation is tracked to completion.	No
40	We can respond to auditor requests using our existing evidence and reports, without having to rebuild the story from scratch.	Yes
41	Reviewers looking at our reports can understand the real access risk behind each Responsibility, not just the label.	Yes

Section maximum: 18

Warning signs for this section

• Evidence is reassembled from emails, spreadsheets and ticket notes when an auditor asks for it.
• Segregation of duties analysis is run on Responsibility names alone, so conflicts are both invented and missed.

Score your Oracle EBS SoD and privileged access maturity

Section	Maximum score	Your score
1. User lifecycle and privileged accounts	20
2. Segregation of duties rules and conflicts	20
3. Mitigation and remediation	24
4. Evidence and reporting	18
Total	82

Governance-ready: 66–82

Your Oracle EBS segregation of duties and privileged access controls are likely operating at a governance-ready level, with entitlement-level insight and reusable evidence.

What to do next: Keep the cadence. Confirm that privileged Responsibility reviews stay distinct from routine business access reviews, and that new custom Responsibilities enter the inventory when they are created rather than at the next audit.

Control depth, inconsistent evidence: 41–65

You probably have control depth but need better consistency, documentation or evidence. The controls are being performed; what is missing is the ability to show that they were.

What to do next: Pick the chain that breaks first. For one real user and one real conflict, try to assemble request, approval, assignment with organizational scope, conflict identification, decision, and final access status. Whichever link you cannot retrieve is the one to fix.

Busy but blind: 0–40

Several No answers around privileged access inventories, Function or Concurrent Program analysis, organizational context, mitigation ownership or centralized evidence mean the controls are at risk of being busy but blind — producing activity and reports without visibility into effective access.

What to do next: Start with what you cannot see. Build the privileged Responsibility inventory and resolve what sits beneath each Responsibility before investing further in reporting, because a report built on Responsibility labels will keep producing both false positives and missed conflicts.

What to fix first

1. Tighten privileged access oversight. Establish the inventory of privileged Responsibilities and the sensitive Functions and high-risk Concurrent Programs inside broader Responsibilities, then review them on a cadence separate from routine business access reviews.
2. Deepen analysis below the Responsibility label. Run segregation of duties analysis at Function and Concurrent Program level, resolving effective access and organizational scope, so conflicts reflect what a user can actually do rather than what a Responsibility is called.
3. Strengthen mitigation and remediation discipline. Give every retained conflict and privileged exception a named owner, recorded approval rationale, and a remediation plan whose completion can be proven in Oracle EBS rather than in a ticket.
4. Consolidate the evidence model. Retain assignments, review populations, results, approvals, decisions and outcomes in one place, so the chain for any user or conflict can be retrieved without rebuilding it from emails, spreadsheets and ticket histories.

What this checklist reviews

• The inventory of privileged Responsibilities, and the sensitive Functions and high-risk Concurrent Programs held inside broader Responsibilities
• Joiner, mover and leaver controls, and whether their completion can be evidenced in Oracle EBS rather than in a ticket system
• Segregation of duties rule definitions, and whether analysis runs below the Responsibility label
• Organizational scope — Operating Units, Inventory Organizations and Ledgers — as a factor in whether a conflict is real
• Mitigating controls, their named owners, and the cadence on which they are re-confirmed
• Remediation plans, progress tracking, and proof that flagged access was actually revoked or end-dated
• Whether the full evidence chain for a user or a conflict can be retrieved without reconstructing it

Read next

• Oracle EBS segregation of duties and privileged access governance
• Oracle EBS SoD audit-readiness criteria
• How a telecommunications company replaced manual Oracle EBS SoD reviews