SOX (Sarbanes-Oxley) Section 404 · Act of 2002 §404; COSO 2013 framework, 17 principles

SOX Section 404 is the obligation on a US issuer’s management to assess whether its internal control over financial reporting is effective, and to say so in the annual report. The Act publishes no control list, so that assessment is made against a recognized control framework — and the one issuers name is the COSO Internal Control—Integrated Framework (2013). That framework is Keel’s scope here, and the whole of it: the five components — control environment, risk assessment, control activities, information and communication, and monitoring activities — and all 17 principles beneath them, each written from the assessment angle of what an issuer has to be able to show. What is not modelled is said out loud rather than left to be discovered: the §302 and §906 officer certifications, the §404(b) auditor attestation, the process-level controls over revenue, procure-to-pay, payroll, the financial close and management estimates, and COSO’s points of focus. Scoring 100% here is an entity-level self-assessment against the principles, not a Section 404 conclusion — Keel is not an auditor and does not issue one.

17

requirements tracked

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Important

This is an entity-level self-assessment against the COSO 2013 principle set, not a Section 404 conclusion. Scoring 100% here means an implemented control is mapped to each of the seventeen principles; it is NOT a determination that internal control over financial reporting is effective, and it does not cover the process-level controls over revenue, procure-to-pay, payroll, the financial close and management estimates that a real 404 assessment scopes and tests, COSO’s points of focus, or the §302 and §906 officer certifications. Note who is subject to what: §404(a) — management’s own assessment — applies to every issuer, while the §404(b) auditor attestation is exempted for issuers that are neither large accelerated nor accelerated filers (15 U.S.C. 7262(c)) and for emerging growth companies. Keel’s summaries are paraphrase, not legal or accounting advice; if you are an SEC registrant, scope your assessment with your auditors.

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Scope

How much of the standard Keel models

Models its declared scope in full

Keel authors every leaf requirement in the scope declared below — all 17 of them, with nothing inside that scope left out. A test fails the build if the authored count and the declared count ever diverge, so this framework cannot quietly lose requirements after the fact.

Authored in Keel: 17 requirements
In Keel’s scored scope: 17 leaf requirements

Keel publishes this for every framework it ships, complete or not, so a readiness percentage can be read against a denominator you can see. Compare every framework

Who it is for

Who needs SOX (Sarbanes-Oxley) Section 404?

Newly public and pre-IPO companies facing management’s first assessment of internal control over financial reporting
Finance, IT and internal audit teams who own the entity-level half of a 404 program and currently run it out of spreadsheets
Private companies asked to demonstrate SOX-grade controls by an acquirer, a lender, or an issuer they supply

What Keel does

How Keel helps with SOX (Sarbanes-Oxley) Section 404

All 17 principles as scored requirements under the five COSO components, each stating what you need to be able to show and the evidence that shows it
32 pre-mapped starter controls you can apply in one click, with every one of the 17 principles carrying at least one
The technology general controls Principle 11 asks for — access and recertification, change management, operations, backup and restore — carried by the controls your security framework already needs, so that work is evidenced once instead of twice
An owner, a status and dated evidence against each principle, so the entity-level assessment is a live record rather than something reconstructed at year end

Collect once, comply everywhere

SOX (Sarbanes-Oxley) Section 404 shares canonical controls with SOC 2, ISO/IEC 27001 and NIST SP 800-53 and others in the catalog. Implement one of those controls and it counts toward every framework it satisfies, so adding SOX (Sarbanes-Oxley) Section 404 rarely means starting from scratch.

Shares canonical controls with

ISO/IEC 27001 shares canonical controls
CIS Critical Security Controls shares canonical controls
PCI DSS shares canonical controls
SOC 2 shares canonical controls
NIST Cybersecurity Framework shares canonical controls
NIST SP 800-53 shares canonical controls
NIST SP 800-171 shares canonical controls
HIPAA shares canonical controls
GDPR shares canonical controls
COPPA shares canonical controls
Google Play Families no shared canonical controls
Amazon Appstore Child-Directed Apps no shared canonical controls
Apple App Store Kids Category no shared canonical controls
PIPEDA shares canonical controls
ISO 9001 shares canonical controls
AI Governance Essentials shares canonical controls
ISO/IEC 42001 shares canonical controls
NIST AI Risk Management Framework no shared canonical controls
EU AI Act no shared canonical controls
ESG Essentials shares canonical controls
US Employment Law - Federal Baseline shares canonical controls

A framework is lit when at least one canonical control satisfies both SOX (Sarbanes-Oxley) Section 404 and that framework. Unlit means none of them do — an absence, not a judgment about that standard. 16 of 21 are lit here.

Other frameworks: ISO/IEC 27001 · CIS Critical Security Controls · PCI DSS · SOC 2 · NIST Cybersecurity Framework · NIST SP 800-53 · All frameworks