Compliance · SOX ITGC

Does AI code review satisfy SOX program change management?

No. SOX IT general controls for program change management require that developers cannot approve or promote their own changes to financially relevant systems. An AI reviewer’s approval does not make the change independently approved. PSCO puts an independent approver on every change and the Evidence Pack maps to change-population testing.

The mapping row

FrameworkControlWhat it asksHow PSCO satisfies it
SOX ITGCProgram change managementDevelopers cannot approve or promote their own changesIndependent approver on every change; Evidence Pack maps to change-population testing

Suggested control wording

Name the approver. Name the standard.

Paste this into your control description. The first sentence is the control; the second names the reviewer and the standard they review against, which is what an auditor needs to accept an outside approver.

All changes to production code require approval from a qualified reviewer who is not the author. Reviewers are PSCO Officers, background-checked US-based engineers contracted by the company, who review each change against the company’s Security & Compliance Model before approval.

For financially relevant repositories, list the paths in the Security & Compliance Model so the attestation records the tier and the Evidence Pack can be filtered to the in-scope population.

What a SOX auditor samples

Build the record so it is already there.

Auditors test change management by sampling. These are the facts they look for on each sampled change, and where PSCO puts them.

  1. 01The complete population of changes to in-scope systems for the period.
  2. 02For each sampled change, evidence of approval by someone other than the developer before promotion.
  3. 03Segregation between development and production promotion, which branch protection enforces.

Auditor Guide

Hand your auditor the design once. Then they recommend it.

Before public launch PSCO briefed audit firms that together cover most startup and mid-market SOC 2 reports on the control design, the Officer Dossier and the Evidence Pack. The Auditor Guide is their questions, answered, for your auditor to read before the first sample.

Auditor Guide · SOX

The control design, the Officer Dossier and the Evidence Pack, written for your auditor.

A short PDF that answers the questions audit firms asked when we briefed them: who the approver is, how they are qualified, what the attestation records, and how to sample it. Enter a work email and we send the guide.

One email with the PDF. No sequence unless you ask for one.

Other frameworks

SOC 2 · ISO 27001 · PCI DSS · HIPAA · CMMC · The full mapping

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