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Oracle EBS SOX Audit-Preparation Checklist

Use this checklist to evaluate whether your Oracle EBS access reviews, user lifecycle controls, privileged-access governance, segregation-of-duties controls, and audit evidence are ready for the next SOX cycle. It is designed to help teams identify the practical gaps that often make quarterly Responsibility certifications take weeks, including manually assembled review populations, unclear Responsibility names, high-risk access buried in large review lists, disconnected remediation, and evidence spread across Oracle EBS extracts, spreadsheets, email, tickets, and shared folders. The goal is not to create more paperwork. It is to make sure your team can clearly show who has access to what, why that access is appropriate, who reviewed it, and what happened when access needed to change.

This checklist is designed for Internal Audit managers, Oracle EBS application and security managers, IT security leads, SOX and ITGC control owners, and business managers responsible for reviewing Oracle EBS access.

How to use this checklist

Work through each section and mark where your process is strong, partial, or missing. Focus on whether reviewers have enough context, whether evidence is easy to produce, and whether access changes and remediation are tracked through to completion. Then use the final sections to identify the most urgent gaps to fix before the next SOX cycle.

1. User lifecycle controls

Review whether Oracle EBS accounts and Responsibility assignments change on time when people join, move, leave, or receive temporary access.

  • Are terminated users disabled or end-dated in Oracle EBS within policy timelines?
  • Are contractor and temporary accounts reviewed regularly and removed when no longer needed?
  • Are obsolete Responsibilities removed when employees change roles, departments, or business processes?
  • Is there a defined process for comparing a transferred employee’s previous Responsibilities with the access required in the new role?
  • Are time-bound Responsibility assignments tracked and automatically reviewed or removed at the end of the approved period?
  • Can the team show approval, account-change evidence, Responsibility end-dating, and remediation history for joiner, mover, and leaver events?
  • Are shared, generic, integration, or concurrent-processing accounts identified and governed separately from normal end-user accounts?

2. Privileged and high-risk access

Review whether privileged Responsibilities and sensitive access are clearly identified, approved, monitored, and evidenced.

  • Is there a current inventory of privileged or sensitive Responsibilities?
  • Does the inventory include highly privileged Responsibilities such as System Administrator and Application Developer, as well as sensitive setup Functions, security-administration capabilities, and high-risk Concurrent Programs relevant to the environment?
  • Are privileged Responsibilities reviewed on a tighter cadence than standard business access?
  • Are custom Responsibilities analyzed for privileged Functions or Concurrent Programs rather than classified only by their names?
  • Is there documented business justification for each privileged assignment?
  • Are temporary elevated assignments approved, time-bound, and removed when the need ends?
  • Can the team show which users have privileged Responsibilities, why they have them, who approved them, and when they were last reviewed?
  • Are high-risk Concurrent Programs and Request Sets included in the access review scope, not just Responsibility names?
  • Are privileged accounts and sensitive Responsibilities monitored for overdue review or remediation?

3. Segregation-of-duties checks and mitigations

Review whether SoD analysis is based on real Oracle EBS access and supported by documented mitigation and follow-up.

  • Have high-risk Responsibility combinations been identified for key financial and operational processes?
  • Is SoD analysis performed at the Function and Concurrent Program level, not only at the Responsibility-name level?
  • Does the analysis consider Operating Unit, Inventory Organization, Ledger, or other organizational scope that affects whether a conflict is real?
  • Are known conflicts documented as remediated, approved with mitigation, or pending action?
  • Is there a named owner for each mitigating control?
  • Are mitigating controls reviewed periodically to confirm they still operate as intended?
  • Is there a process to identify new SoD conflicts after Responsibility changes, provisioning changes, or security configuration changes?
  • Can the team produce evidence showing the conflict, the related user or population, the owner, the mitigation, and the remediation history?

4. Access review process and evidence

Review whether Responsibility certification is structured, understandable to reviewers, and supported by complete evidence.

  • Is the access review population scoped intentionally, or is it assembled manually each cycle from multiple extracts?
  • Are reviewers given clear descriptions of what each Responsibility allows, including underlying Functions, Forms, Concurrent Programs, Request Sets, and relevant organizational scope?
  • Do managers have enough context to understand the business risk behind the Responsibility they are certifying?
  • Are privileged and high-risk Responsibilities separated or highlighted so they are not buried in large review populations?
  • Are review assignments, reminders, escalations, and completion tracking handled through a structured workflow rather than email alone?
  • Are reviewer decisions captured with comments or rationale where access is retained, revoked, or challenged?
  • Are revocations and remediation actions connected directly to the certification process rather than managed separately?
  • Is there centralized storage for review decisions, approval records, SoD results, mitigation decisions, and remediation evidence?
  • Can the team show a complete evidence trail for a single reviewed user from assignment through certification and remediation?

5. Reporting and documentation

Review whether Oracle EBS access evidence is consistent, reusable, and understandable during audit testing.

  • Are standardized reports available for active users, Responsibilities, privileged access, and SoD conflicts?
  • Can the organization produce a clear view of who has access to what and why for key financial processes?
  • Can control owners show Responsibility assignment history, approval history, certification decisions, and remediation status for the audit period?
  • Is evidence stored in a way that is complete, accurate, traceable, and retrievable?
  • Can the same evidence set be reused across quarterly reviews, annual SOX testing, and follow-up audit questions?
  • Are reports aligned to Oracle EBS concepts and terminology rather than generic role-based summaries that hide underlying risk?
  • Is there a documented owner and schedule for each recurring review and reporting requirement?
  • Can the team quickly assemble an audit-ready evidence package without rebuilding it from spreadsheets, email threads, and shared-drive files?

6. Quick self-assessment

Use the questions below to gauge whether your current Oracle EBS review process is audit-ready or still heavily manual.

Your process may still be too manual if:

  • Managers certify Responsibility names without seeing underlying Functions or Concurrent Programs.
  • Privileged Responsibilities are reviewed in the same undifferentiated list as low-risk access.
  • SoD conflicts are tracked in separate spreadsheets with limited mitigation detail.
  • Revocations are requested after the review but not tied back clearly to certification evidence.
  • Audit evidence is spread across EBS extracts, email approvals, tickets, spreadsheets, and shared folders.
  • The team has to rebuild the same control history every quarter or at year-end.
  • Review populations are not formally reconciled or validated before certification begins.
  • Managers regularly ask Oracle administrators to explain custom or unclear Responsibilities during the review.

Your process is moving toward audit readiness if:

  • Review populations are scoped based on risk and business context.
  • Reviewers can see the access beneath each Responsibility.
  • Sensitive and privileged access is clearly identified and reviewed separately.
  • SoD analysis includes organizational context and mitigation ownership.
  • Decisions, comments, remediation, and approvals are captured in one repeatable workflow.
  • The evidence package is ready before the auditor asks for it.

7. What to fix first

If your team can’t address everything at once, start here:

Validate the review population. Establish a repeatable method for identifying in-scope users, Responsibilities, effective dates, privileged access, organizational scope, and SoD exposure.

Identify privileged and high-risk access. Define privileged Responsibilities, sensitive Functions, high-risk Concurrent Programs, broad organizational access, and known SoD exposure so they can be prioritized and reviewed separately.

Improve reviewer context. Give managers plain-language Responsibility descriptions and visibility into the Functions, Concurrent Programs, sensitive activities, and organizational scope behind each assignment.

Connect decisions to remediation. Link rejected or modified access directly to an owner, due date, completion record, and verified Oracle EBS status.

Standardize the evidence package. Retain the review population, decisions, approvals, SoD results, mitigation records, remediation, and final status as one traceable control record.

Reduce manual routing and follow-up. Replace email- and spreadsheet-based assignments, reminders, escalations, and status tracking with a structured workflow.

For a more detailed explanation of how these controls, reviews, and evidence requirements fit together, use our practical guide to passing your next SOX audit in Oracle EBS.

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