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Fast growth fixes revenue, then exposes controls. Close runs longer, access piles up, and approvals drift from Slack threads to memory. You do not need a full SOX program yet. You do need a “Sox-Lite for Scale-ups: Practical Internal Controls Before Your First Audit” set that keeps risk low and documentation clean.

What this section covers

A pragmatic control framework for pre-audit scale-ups in the US and UK, including teams that work with offshore accountants. It covers entity-level controls, ITGCs, and key process controls across revenue, purchasing, and payroll. You also get simple templates to plug in today.

1) Entity-level controls that set the tone

Board and oversight

  • Quarterly financial pack to the board with KPI trends and variance notes
  • Written delegation of authority with spend limits by role
  • Related-party register updated each quarter

Policies and training

  • Accounting policy manual with revenue, capitalization, and expense recognition rules
  • Document retention policy for finance and tax
  • Annual fraud and ethics acknowledgement for finance and IT

Template: Delegation of Authority (one page)

Role            Threshold     Requires Second Approval?
Finance Lead    Up to $25k    Yes, above $10k by Controller
Controller      Up to $75k    Yes, above $50k by CFO
CFO             Up to $250k   Yes, above $150k by CEO

2) IT General Controls (ITGCs) that keep data reliable

Access and change

  • User provisioning with ticket evidence and manager approval
  • Quarterly access review for ERP, billing, payroll, and data warehouse
  • Change management tickets for code and configuration with peer review

Operations and backups

  • Daily automated backups for ERP and billing, restore tested each quarter
  • Audit logging enabled on finance apps and SSO
  • Offboarding checklist that removes access within one business day

Template: Access Review Log

System  Period  Reviewer   Exceptions Found  Fix Date  Evidence Link
ERP     Q1      Controller None              n/a       /ITGC/Q1/ERP_Access.pdf

3) Revenue controls that prevent reclass and restatements

Order to cash

  • Signed order, price, and term in CRM before billing
  • Billing generated from approved order only; no manual price edits without a ticket
  • Credit memos require approver different from biller

Revenue recognition

  • Contract review checklist that flags multi-element bundles and setup fees
  • Revenue schedule auto-generated by billing or RevRec tool and reviewed monthly
  • Cutoff test each month: sample the first 10 next-month invoices for prior-period services

Receivables

  • Cash application performed by a person who does not raise invoices
  • AR aging reviewed monthly with write-off policy and approver

Template: Contract Review Checklist (extract)

[ ] Is there variable consideration (usage, overage, rebates)?
[ ] Are services distinct? If not, bundle documented.
[ ] Term start date aligns to service delivery start.
[ ] Revenue schedule attached to ticket and reviewed.

4) Purchasing controls that stop leakage

Procure to pay

  • Vendor onboarding with bank verification and tax forms
  • Three-way match for POs over the threshold
  • No vendor master edits without a ticket and second reviewer

Expense and card controls

  • Corporate card policy with per-user limits and MCC blocks
  • Monthly expense review by someone other than the cardholder’s manager
  • AP cutoff test: sample receipts received but not invoiced and accrue

Template: Vendor Change Ticket

Vendor: ______  Change: Bank details update
Requestor: ____ Approver: ____  Verification: Call-back completed (Y/N)
Evidence: Screenshot + bank letter, stored at /AP/Vendors/<Vendor>/YYYYMMDD.pdf

5) Payroll controls that keep totals tight

Hires and changes

  • HRIS to payroll sync with maker-checker review
  • Pay rate changes require manager approval and HR verification
  • Access to payroll limited to named roles; quarterly payroll access review

Pay run

  • Gross-to-net report reviewed and signed by Controller
  • Bank file release by a second person
  • Post-payroll reconciliation of payroll expense, taxes, and liabilities

Template: Payroll Sign-off

Prepared by: Payroll Lead  Date: ___
Reviewed by: Controller   Date: ___
Bank file released by: CFO  Date: ___
Tie-out to GL completed: Yes/No   Evidence link: /Payroll/TieOut_YYYYMM.xlsx

6) Maker-checker when using offshore teams

  • Separate preparer and approver for journals, bank recs, and revenue schedules
  • Handoffs documented with ticket IDs and links to source evidence
  • Restricted access to bank portals, payroll, and vendor banking
  • Weekly close cadence with a 30-minute pre-close review

Template: Close Handoff Note

Task: Bank Rec May
Preparer: Offshore Sr. Accountant
Approver: Controller
Evidence: /Close/2025-05/Bank/XYZ_BankRec.pdf
Exceptions: None

7) Minimum monthly close pack

  • Trial balance with flux analysis vs last month and same month last year
  • Bank, AR, AP, and payroll reconciliations with sign-offs
  • Revenue recognition rollforward and deferred revenue schedule
  • Fixed asset rollforward and capex additions
  • JE log with purpose, support link, and approver

Template: JE Log (columns)

Date | JE # | Purpose | Amount | Accounts | Support Link | Prepared by | Approved by

8) Control testing plan for pre-audit readiness

  • Pick 10 high-value controls across entity-level, ITGCs, revenue, purchasing, and payroll
  • For each, test one sample per month for three months
  • Store results in a single workbook with pass or fail and remediation owner
  • Present summary to leadership each quarter

Template: Control Test Matrix

Control ID  Process   Assertion   Frequency  Samples  Result  Remediation Owner  Due Date
R-02        Revenue   Accuracy    Monthly    3        Pass    n/a                n/a

9) Document retention and evidence rules

  • Use searchable PDFs. Add page numbers to multi-page exhibits
  • Save evidence where the control lives, not in email threads
  • Keep a cross-reference index so auditors can trace from control to support in one click
  • Retention: finance seven years unless law requires longer

10) Rollout sequence that works in a quarter

  1. Publish the delegation of authority and card policy
  2. Turn on SSO and audit logs for finance apps, then run an access review
  3. Lock the close calendar and maker-checker for journals and reconciliations
  4. Implement contract review and revenue schedule sign-off
  5. Add vendor change tickets and bank verification
  6. Pilot control testing on five controls, then expand to ten

Summary

Keep controls small, visible, and testable. With clear approvals, clean access, and maker-checker on the big money flows, you arrive at your first audit with evidence that reads like a story and a close that does not stall. This is enough structure to protect the numbers and light enough to run fast.