Segregation of Duties Policy Template

Build your SoD matrix offline with a live conflict checker. Pre-labeled fields for finance processes including AP, AR, GL, payroll, and treasury. Download in Excel, Word, or PDF.

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ARSP
50K+ downloads by Finance & Internal Audit teams
SoD Policy Matrix
ProcessAuthorizeCustodyRecord
AP InvoiceManagerAP ClerkGL Team
Vendor creationControllerN/AAP Clerk
Payment releaseCFOTreasuryGL Team
AR Credit memoManagerAR ClerkAR Clerk
3 OK 1 Conflict

Build your segregation of duties matrix

Add each financial process and assign the three core duties. The tool flags conflicts where one role holds more than one incompatible function.

1

Policy details

2

SoD matrix (Process / Authorize / Custody / Record)

Live preview

Set up your SoD policy in four steps

1

Download

Pick Excel, Word, or PDF. Each has a pre-built SoD matrix covering AP, AR, GL, payroll, and treasury functions.

2

Define processes

List each financial process in scope. For each, identify who authorizes, who has custody, and who records the transaction.

3

Flag conflicts

Review the matrix for rows where the same role appears in more than one column. These are SoD conflicts that need mitigating controls.

4

Sign off and review

Get management approval, document mitigating controls for any accepted conflicts, and schedule the next review cycle.

Download a ready-to-use template

Grab a blank template in the format that fits your workflow. Every version includes the SoD matrix with conflict flagging.

Excel (.xlsx)

Spreadsheet with conflict formulas. Best for ongoing SoD tracking and audit preparation.

Word (.docx)

Policy document with tables. Best for board presentations and compliance documentation.

PDF

Print-ready layout. Best for physical sign-off and audit binders.

Automate SoD monitoring across your ERP

Stop checking access conflicts manually. Let Bluecopa continuously monitor role assignments and flag SoD violations in real time.

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How segregation of duties works

SoD splits critical financial tasks among multiple people so that no single individual controls all stages of a transaction. The three core functions are authorization, custody, and recording.

1

Identify critical processes

Map every financial process that involves money, assets, or reporting. AP, AR, payroll, treasury, and journal entries are the most common starting points.

2

Define the three duties

For each process, identify who authorizes (approves), who has custody (handles the asset or payment), and who records (posts to the ledger).

3

Build the SoD matrix

Create a matrix mapping processes to roles. Flag any cell where the same person or role appears in more than one duty column.

4

Resolve conflicts

For each conflict, either reassign the duty to a different role or document a compensating control (supervisory review, dual approval, system restriction).

5

Monitor continuously

Review the matrix whenever roles change. Access creep (gradual accumulation of permissions) is the most common source of new SoD conflicts.

Do this, avoid that

✓ Do
Document compensating controlsIf a conflict cannot be eliminated (small team, single-person department), document the mitigating control: who reviews, how often, and what they check.
Include system access in your matrixERP roles and permissions create SoD conflicts just like manual processes. Map system access to your matrix alongside manual duties.
Review after every org changeNew hires, promotions, and departures all shift the SoD landscape. Trigger a review with every HR change in finance.
Get internal audit sign-offInternal audit validates that the matrix is complete and that compensating controls actually work. Their sign-off strengthens the policy.
✗ Avoid
Treating SoD as a one-time exerciseA matrix that was accurate a year ago is likely outdated. Annual review is the minimum, quarterly is better for fast-growing teams.
Ignoring system-level conflictsA person with both "create vendor" and "approve payment" access in your ERP has an SoD conflict even if the process says otherwise.
Accepting all conflicts without controlsAcknowledging a conflict is not the same as mitigating it. Every accepted conflict needs a documented compensating control with evidence of execution.
Limiting scope to AP onlySoD applies to every financial process: AR, payroll, treasury, GL, fixed assets. Limiting scope to AP leaves other areas exposed.

Segregation of duties terms, explained

Segregation of duties (SoD)
An internal control principle that divides critical financial tasks among multiple people to prevent fraud, errors, and unauthorized transactions.
Authorization
The duty of approving a transaction or action. The person who authorizes should not also execute or record the same transaction.
Custody
The duty of handling physical or digital assets, processing payments, or executing transactions. Separate from the authorization and recording functions.
Recording
The duty of posting transactions to the general ledger or financial records. The recorder should not also authorize or handle the underlying assets.
SoD conflict
A situation where one person holds two or more incompatible duties for the same process. Conflicts must be resolved or mitigated with compensating controls.
Compensating control
An alternative control that mitigates the risk of an SoD conflict that cannot be eliminated. Examples include supervisory review, dual signatures, and system alerts.
Access creep
The gradual accumulation of system permissions over time as users change roles or take on temporary duties without their old access being removed.
SOX compliance
Sarbanes-Oxley Act requirements for internal controls over financial reporting. SoD is a core control that SOX auditors evaluate during compliance reviews.
SoD matrix
A grid mapping financial processes to roles across the three core duties (authorize, custody, record). Used to identify and document conflicts and their mitigating controls.

Frequently asked questions

Segregation of duties (SoD) is an internal control that divides critical tasks among multiple people to prevent fraud and errors. No single person should be able to initiate, approve, and record a financial transaction.

SoD prevents unauthorized transactions, reduces fraud risk, and satisfies audit requirements. Regulators and auditors expect documented SoD policies for SOX compliance, internal audits, and financial reporting.

The three core functions are authorization (approving transactions), custody (handling assets or payments), and recording (posting entries to the ledger). No one person should perform all three for any transaction.

Yes. No cost, no account, no watermark. The interactive tool runs in your browser and the downloadable files are yours to keep.

Review your SoD policy at least annually, or whenever there are organizational changes like new hires, role changes, or system migrations. Regular reviews catch access creep and role conflicts.

An SoD conflict occurs when one person has access to two or more incompatible duties. For example, if the same person can create vendors and approve payments, they could create a fake vendor and pay themselves.

Templates work for small teams with stable roles. When you have 50+ users, frequent role changes, or audit findings around access conflicts, automation tools like Bluecopa can continuously monitor SoD conflicts across your ERP.