The Clean Opinion
Tools/SOX · Free · About 3 min

SOX 404 Deadline Calculator

Enter the date you became a public company and your fiscal year-end. The calculator works out which fiscal year management's Section 404(a) assessment plausibly applies to first, counts the planning milestones back from that date, and tells you which IT general controls the auditor will ask about first. Every assumption it makes is shown next to the result.

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IPO pricing, de-SPAC close, or the date your registration statement went effective. A planned date works too.
Determined by public float, revenue, EGC status, and reporting history. “Not sure” is a fine answer; the result will tell you what decides it.
Optional. Enter in millions, e.g. 85 for $85M. Numbers over 100,000 are read as whole dollars.
Optional. As of the last business day of your second fiscal quarter. Enter in millions, e.g. 85 for $85M. Numbers over 100,000 are read as whole dollars.
Optional. If you know when your first annual report was or will be filed, it pins down which fiscal year it covers.
Not the CFO by default. Someone who owns access, change, and deprovisioning evidence for every in-scope system.
Select everything a financial control depends on. Each one brings its application, database, infrastructure, and interfaces into scope.
A periodic review of who has access to each system, with the population, the reviewer's sign-off, and the removals retained.
Ticketed changes with test evidence and an approval by someone other than the developer, retained for each change.
Your planning timeline will appear here: the first fiscal year management's 404(a) assessment plausibly covers, milestones counted back from it, a caveated note on auditor attestation, and the four ITGC controls to get evidence for first.
Read nextYour first year as a public company: the SOX 404 timeline nobody hands youSOX 404 · 9 min readITGC scoping for SOX: the four controls your auditor tests firstSOX 404 · 8 min readThe SEC wants to move the 404(b) line. Here’s what changes for you — and what doesn’t.SOX 404 · 7 min read

This calculator provides planning guidance based on the dates and answers you enter, using general rules that apply to most newly public companies. It is not legal advice, not an audit opinion, and not a determination of your filer status or of whether Section 404(a) or 404(b) applies to you. Filer status, the availability of transition relief, and the applicability of the auditor attestation requirement are determined by SEC rules applied to your own facts and should be confirmed with your securities counsel and your auditor before you rely on any date shown here. Audits and attestations are performed by Alpha Secure LLP, a licensed CPA firm. Disclosure.

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