Segregation of duties in accounting: from theory to daily, audit‑ready control

Most finance leaders know the textbook definition of segregation of duties in accounting: no single person should control a critical transaction from initiation to completion without a compensating control. The real challenge is different, proving, every day, across complex ERP and cloud landscapes, that this principle is enforced in practice and will stand up to scrutiny from auditors, regulators, and boards.

In many organizations, policies look solid on paper while the real risk hides inside ERP roles, custom functions, and integrations that finance teams cannot easily see or explain. That gap between “we separate duties” and “we can prove it, continuously, across all systems” is exactly where exposure lives.

 

Why classic Segregation of Duties  breaks in modern finance

In a traditional accounting environment, duties are separated across activities like vendor setup, invoice processing, payment approval, journal posting, and reconciliation. The aim is simple: cash and data flows are never fully in the hands of one individual, so any attempt to manipulate results requires collusion and is more likely to be detected.

In the classic four‑part Segregation of Duties model, reconciliation sits alongside authorization, custody, and record‑keeping as a distinct function. The reconciler’s role is to compare what should have happened—per ledgers, subledgers, and policy—with what actually happened in bank accounts, clearing accounts, suspense balances, and key subledgers, and to raise questions when the two do not match. That only works if the person reconciling a bank, payroll, or vendor account is not the same person who initiates payments, changes master data, or posts journals; otherwise, the “check” becomes self‑review, and error or fraud can pass straight through.

On process maps, that structure often looks fine. In reality, modern finance operations rarely resemble the neat diagrams in internal control manuals. Lean teams, shared service centers, and offshore hubs concentrate multiple high‑risk capabilities into a small group of power users who carry several roles in ERP systems such as SAP, and Oracle. To hit deadlines, temporary workarounds creep in: a senior accountant both creates and approves journals during month‑end, or a payroll administrator is given access to change master data “to help HR.” Over time, these exceptions quietly erode the intended control design.

Another problem is scale and complexity. A single role can bundle dozens or hundreds of underlying entitlements, each of which may have implications for Segregation of Duties. What looks like a harmless “super user” role to a business approver can, in practice, combine vendor master changes, payment release, and bank reconciliation privileges in one place. Manual and spreadsheet‑based SoD testing simply cannot keep up with that complexity as organizations add new modules, new entities, and new applications around the core ERP.

This is also where reconciliations start to lose their value as a control. If reconciliations are rushed at month‑end, performed by the same people who have broad posting and approval authority, or signed off by managers who cannot see underlying access risks, they become a box‑ticking exercise rather than a genuine line of defense. You may still have a reconciliation, but you no longer have a meaningful separation between processing and independent review.

 

Turning Segregation of Duties principles into enforceable control

For SAP customers, this challenge usually arises from how roles and profiles are implemented. Roles combine menu paths, authorization objects, and field values in ways that are difficult for finance and audit teams to interpret in business language. A role that appears benign at a high level may, in a specific company code or organizational unit, allow a user to both maintain suppliers and release payments. That role may also include access to post or clear certain journal types, undermining both payables controls and the independence of key reconciliations. This is exactly why segregation of duties in SAP and other ERPs cannot be managed with static spreadsheets alone.

A similar pattern appears in Oracle ERP Cloud environments. Seeded roles, inherited privileges, configuration changes, and page‑level grants tend to accumulate over time. A Payables Manager’s responsibility, originally scoped just for approvals, can end up with rights to change supplier bank details, override workflow rules, and post manual journals. Mergers, reorganizations, and project‑driven access “exceptions” accelerate this role creep, making it difficult for finance and IT teams to say with confidence which users violate internal control principles. Effective segregation of duties in Oracle ERP Cloud has to operate at the privilege level, not just at the role‑name level.

One of the most effective ways to regain control is to use a clear, finance‑led segregation of duties matrix. The matrix defines incompatible activity pairs—such as “create or modify supplier master” versus “approve payments,” or “post journals” versus “approve journals”—in language business owners understand. It will usually treat reconciliation as a separate, incompatible activity in its own right, so that the person who reconciles a bank or clearing account cannot also initiate or approve the underlying transactions flowing through that account.

When a segregation of duties matrix is implemented, using an access governance platform, it stops being a static spreadsheet and becomes a live control asset. Every identity, role, and entitlement can be evaluated against these SoD rule sets across SAP, Oracle, and other critical applications. Rather than trying to interpret technical authorization strings, finance and audit teams see a business‑language view of risk: which users can both change vendor bank details and approve payments, which roles allow someone to post journals and then reconcile the same account, and where key reconciliations are in the hands of people who also control upstream processing.

For organizations running segregation of duties in SAP and segregation of duties Oracle projects, this approach creates a common language between policy and technology. Finance, risk, and IT can align on what “good” looks like, then test and refine roles until those expectations are reflected in the actual access model.

The final step is to close the loop with workflows and evidence. Identifying conflicts is not enough; someone has to decide what to change, who will change it, and by when. A governance platform can route SoD issues and reconciliation‑related conflicts to the right process owners, track remediation activities, and capture any approved compensating controls where removal of access is not immediately possible. Over time, this creates a defensible audit trail that shows not only where conflicts exist, but how they are being managed in line with risk appetite.

 

Putting Segregation of Duties into Practice with SafePaaS

Segregation of duties in accounting only delivers real value when organizations can demonstrate, with evidence, that the principle is enforced consistently across the systems where transactions and reconciliations actually happen. In a world of complex ERP environments such as SAP and Oracle, running a report, manually maintained spreadsheets, ad‑hoc reviews, and paper‑based narratives are no longer enough to prevent fraud, misstatements, or satisfy auditors.

SafePaaS gives finance, risk, audit, and IT teams a shared control fabric: a single platform where SoD rules are defined once, tested continuously, and backed by workflow, remediation tracking, and audit‑ready analytics across the application estate. By translating your segregation of duties matrix into preventive and detective controls that operate at the privilege level, SafePaaS helps you protect high‑risk processes like vendor management, payments, journal processing, and reconciliations without slowing the business down.

If you are ready to move beyond reactive approaches and want a clearer view of SoD risk across ERPs and your broader finance stack, talk to an expert and schedule a SafePaaS demo.

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