SOX deadline requirement for placing documents into mgmt sys 2182

  • I hope that someone on this forum can answer a very specific question. We have a document management system in place, but we are still trying to migrate all the documents to the new system. I’ve been asked by management if SOX compliance requires that a new document be placed into the system within a specific timeframe. For example, if a new document is finished on October 10, does it need to be put into the document management system 1) within 10 business days, 2) within 6 weeks, 3) before the auditors arrive, or 4) same day?
    I have looked through 10 articles about SOX requirements for document management, and I cannot find an answer to what should be a fairly basic question.
    Could someone on this forum provide some guidance?
    Thank you.

  • This depends on company policies. There is no official requirement as to where and how you maintain your evidence, as long as you can produce of what is asked for when external and/or internal auditors come knocking on the door.

  • Thanks. I’d appreciate hearing from others, too.

  • Not sure what type of documentsd you’re referring to but there is no specific document retention requirement in SOX.
    However, you would expect the timeliness of transaction entry into the financial systems to be a risk that is addressed within your assessment. Provided that the DMS isn’t impacting this I do not believe that you have much of an issue.
    It is good practice to have a corporate standard around this sort of stuff even if not required for SOX compliance

  • I agree with the above responses. No SOX requirements around this. You are free to set your own internal guidelines.

  • THANK YOU so much. This is very helpful and much appreciated. We are all trying to comply with requirements, stated and implied, and we are trying to establish preventive practices so that we don’t find ourselves in trouble down the road.

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