WorkflowInternal Audit & SOX Compliance

Risk and Control Matrix (RCM) Documentation

A risk and control matrix drafted the day of the walkthrough, every row cited to its source

Narratives and matrices drafted the day of the walkthrough, every row cited to its source.

See one case, screen by screen ↓
demo11minfor seven agents to draft the narrative, flow and matrix from a 45-minute walkthrough: 11 min 20 s
demo14controlsfor 11 risks, with 31 assertion links — every field pinned to the recording, an SOP or the system
demo$1.19Mof manual credit memos above $10,000 posted with no control since go-live, found and sized three weeks before Q4 interim testing
target100%of framework risks mapped to a control or flagged before the auditor's walkthrough
In short

What is Risk and Control Matrix (RCM) Documentation?

Software that drafts the SOX process narrative, the flowchart and the risk and control matrix from a walkthrough recording, your SOPs and the system configuration. Every field of every row cites the moment or paragraph it came from, a challenger agent tests each control description, and a gap agent flags any risk with no control. The process owner confirms each row, and the SOX program manager decides every gap and signs the version.

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Updated

The problem

Why every SOX process gets documented three times, by hand

Each process in scope needs a narrative, a flowchart and a risk and control matrix: every risk, the control that answers it, who runs it, how often, whether it is key and which assertions it covers. Today someone who already sat through the walkthrough writes it all up again from notes, SOPs and screenshots — then chases the process owner by e-mail for weeks, and does it over whenever a system, a deal or a reorganisation changes the process. In-scope systems have more than doubled in two years, and every new one means re-documenting the processes that run on it.

The risk sits in what nobody compared. The narrative describes the SOP, not what people actually do; control descriptions such as “reviews AR” cannot be tested; a key report is named with no completeness and accuracy procedure; and a risk with no control slips through until the external auditor finds it in interim work, as a design deficiency to evaluate. Lack of documentation, policies and procedures is a recurring theme in the material weaknesses companies disclose.

typical15,581hoursa year for the average SOX programme
typical17 → 40systemsin scope in two years, and every new one means re-documenting the processes on it
typical238reportsdisclosing material weaknesses in FY2025 filings
Where one process's first-draft hours goestimated
By hand60 days
With the solution18 days
  • Writing up the walkthrough notes8 → 1 d
  • Drafting the process narrative16 → 4 d
  • Drawing the flowchart8 → 1.5 d
  • Building the RCM: owners, frequency, type, assertions, key reports14 → 4 d
  • Comparing with the risk library and each account's assertions6 → 1.5 d
  • Process owner review rounds8 → 6 d

Estimated split of a 60-hour first-draft refresh for one process, by hand and with the solution — an assumption to measure in a pilot.

How it works

How a process is documented

Seven agents transcribe, draft, challenge and gap-check; the owner confirms and the SOX program manager decides and signs.

What comes in
Sources inWalkthrough, SOPs, ERP · recording, policies, configuration
Agents at work
Capture agenttranscript, quality floor
Then
Narrative agent
Flow agent
Then
Matrix agentevery field cited
Challenger agenttests, disagrees
Then
Gap agentsaid · written · configured
Watcher agent
A person decides
Process owner and SOX program managerconfirm, decide and sign
What comes out
Cited narrative and flow
Risk and control matrix
Gaps decided
One case, step by step

One process, from walkthrough to signed RCM

Kestrel & Vane Distribution US moved to a new ERP on 1 Sep 2026. Five of its SOX processes must be documented again before Q4 interim testing starts on 2 Nov, and the first is order-to-cash. The SOX program manager works with the agents the way she would with a team: they report what they drafted and found, she asks and instructs in plain words, and every answer shows its evidence. Here it is, screen by screen, in the working solution.

  1. 01Wednesday morning

    Four plain numbers, and the agents reporting in

    Claire Okafor · Group SOX Program Manager

    Claire opens Today: 3 gaps to decide, 2 rows waiting for the process owner, 4 changes proposed and 31 of 38 RCMs approved for FY2026. Below the numbers the agents post what they finished and what needs her, each message with its next step: the drafted order-to-cash matrix, a high gap over manual credit memos, Marcus Lindqvist's confirmations and four proposed changes. Beside the thread she asks the agents anything — “Why is O2C-02 low confidence?” — or tells them what to do.

    Watcher agent: “I drafted each redline; none is applied.”

  2. 0211 min 20 s after the walkthrough

    A full RCM draft, and every field cites its moment

    Matrix agent, with the narrative and flow agents

    Walkthrough WT-26-031 ran 45:12 with six people, consent read at 00:00, transcript quality 96%. From it, five documents and the ERP configuration, seven agents drafted a 6-page narrative, a 9-step flow and RCM v3.0: 11 risks, 14 controls, 9 of them key. Claire clicks the ▶ 12:41 chip on O2C-04 and the transcript jumps to Julia Meyer describing the credit check.

    Julia Meyer at 12:41: “When the order is entered, the system checks the customer’s credit limit and blocks the order if it would take them over.”

  3. 03Before anyone confirms

    A second agent disputes a description that can't be tested

    Challenger agent

    The matrix agent wrote O2C-10 as “Weekly, the Head of Order-to-Cash reviews unapplied cash.” The challenger agent disagrees: no report, no age, no evidence of the review. It proposes a precise wording from the walkthrough at 34:10 and the SOP. The matrix agent explains why it kept the SOP wording. Both reasonings are on screen, and a person chooses.

    The challenger agent never resolves its own disagreement and never edits a row.

  4. 04In the narrative

    Conflicts marked, rewrites shown as redlines

    Narrative agent

    The narrative has seven sections, every paragraph cited, and three conflicts marked where what people said differs from what is written: the change-log review, who can release credit holds, and manual credit memo approval. Asked to make §5 shorter, the narrative agent shows a redline that keeps every citation, for the reviewer to accept or reject.

    “Said ≠ written · Walkthrough and system: no approval enforced. SOP-O2C-03 §5.2: workflow approval above $10,000. Gap G1.”

  5. 05The flowchart

    Nine steps in six swimlanes, with the gap on the map

    Flow agent

    The flow agent draws the process from the narrative: credit, customer service, warehouse, billing, accounts receivable and the ERP, with risk and control markers at each step. Step 7, manual credit memos, carries the gap marker. Clicking it shows risk R-O2C-08, the narrative passage behind it and the plain note: no control at this step.

  6. 06Said, written, configured

    Three sources disagree about manual credit memos

    Gap agent

    Of the group risk library's 27 order-to-cash risks, 11 apply and 10 are covered. Gap G1 is high: nothing covers unauthorised or inaccurate manual credit memos. The SOP requires Credit Manager approval in the ERP workflow above $10,000; the workflow WF-CM-01 covers return credit memos only, and manual billing adjustments post with no workflow. The cause: the legacy control over all credit memos was retired at go-live.

    Tom Becker at 31:40: “Anything over ten thousand we e-mail Julia for an OK, but honestly the system doesn’t stop it. We can post it ourselves.”

  7. 07Claire decides

    A new control, an interim review and a reason code

    Claire Okafor · Group SOX Program Manager

    The gap agent sized the exposure from the ERP, read-only: 41 manual credit memos above $10,000 since go-live, $1,186,420, 12 with no approval e-mail found. The challenger re-ran the query blind and agrees. Claire decides with reason code GAP-NEW: new key control O2C-15, built by change CHG-26-0871 for 2 Nov, and interim O2C-15i, a weekly review by Julia Meyer from 19 Oct with a look-back over the 41. She refers it to SOX Control Testing as a potential design deficiency.

    “Decision recorded · O2C-15 and O2C-15i added to the draft as proposed rows.”

  8. 08Due Fri 16 Oct

    The owner answers in plain words, not in a matrix

    Marcus Lindqvist · Head of Order-to-Cash

    Marcus gets one question per row, with the clip of what was said. He has confirmed 11 and corrected one: the shipped-not-billed review covers items over $5,000. On O2C-13 he answers “No”: IT owns the quarterly access review. The matrix agent turns his words into a redline — owner Victor Hale, ERP Application Lead — citing his answer as the source, for him to confirm.

    Marcus: “IT owns it. Victor Hale’s team runs the review every quarter and removes access; I only confirm the billing users.”

  9. 09A policy changes

    The matrix keeps up, and nothing changes without her

    Watcher agent

    Credit Policy CP-07 v5, effective 1 Nov, moves Division Controller approval of credit limits from $250,000 to $500,000 and lets credit analysts release holds only up to $25,000. The watcher agent drafts the redline for O2C-01 and O2C-05 and the impact on Q4 testing. It also flags that Tom Becker moves to Logistics Planning on 1 Nov, leaving O2C-07 without an owner.

    “Accept into the draft · Reject · Ask about it.”

  10. 10Signed

    Approval only when everything is true

    Claire Okafor · Group SOX Program Manager

    Versions compares v3.0 with v2.4, approved 12 Jan 2026, field by field. Approve unlocks only when every row is confirmed by the owner, every gap is decided with a reason code, every challenger note is resolved, every row has a source and the preparer and approver differ. Claire picks the reason, ticks the attestation and signs with her name.

    “I have reviewed the narrative, the flow, the matrix and each gap decision, and I approve this version as management’s documentation of the process.”

Who it’s for

Built for everyone who owns a control.

The same order-to-cash RCM, seen by the five people who carry it — what documentation season looked like, and what it looks like now.

CO
Claire OkaforGroup SOX Program Manager · a programme of 38 process RCMs
SOX program manager
Before
Plans testing with the external auditor and answers to the CAE, while finding out late which risk has no control.
Now
Decides each gap with the evidence and its exposure in front of her, and signs a version only when every row is confirmed.
ML
Marcus LindqvistHead of Order-to-Cash, Kestrel & Vane Distribution US
Process owner
Before
Gets a matrix by e-mail and weeks of reminders to say whether it describes what his team does.
Now
Answers one plain question per row with the clip attached; when a row is wrong, his words become the cited correction.
AR
Aisha RahmanSenior Internal Auditor · facilitates walkthroughs
Internal auditor
Before
Spends days writing up a walkthrough she has already sat through, then redraws the flowchart to match.
Now
Edits a cited draft the same day, settles the challenger's disputes and asks the narrative agent for the rewrite she needs.
OP
Owen PritchardSenior Manager, Ashdown Pryce LLP
External auditor (read-only)
Before
Re-walks a process because he cannot trace the documentation back to where it came from.
Now
Clicks from a control to the moment the owner described it, and gets answers to his questions that management has approved.
HS
Helena StrandChief Audit Executive · reports to the Audit Committee
Chief Audit Executive
Before
Assembles documentation status for the Audit Committee from spreadsheets and status calls.
Now
Reads one drafted page — what's ready, what isn't and what was found — with every number cited.
Built on the engine

8 agents. Each with one job, and hard limits.

Seven agents transcribe, draft, challenge and gap-check; the owner confirms and the SOX program manager decides and signs.

Capture agent

Prepares walkthrough questions from the prior RCM, the SOPs and what changed; transcribes the recording with speakers and timestamps, scores its quality and splits it into passages.

  • Never records without the consent notice read at the start
  • Never drafts below the 85% transcript quality floor
  • Deletes the video after 90 days; the transcript stays with the documentation
Narrative agent

Writes the process narrative in the house template from the transcript, SOPs and system configuration, and rewrites a paragraph on instruction — shorter, for the auditor, or in plain words.

  • No sentence without a source
  • Marks said-versus-written conflicts, never resolves them
Flow agent

Draws the swimlane flowchart from the narrative, with risk, control and gap markers, and redraws it when the narrative changes.

  • No step that is not in the narrative
Matrix agent

Extracts risks and controls with owner, frequency, type, nature, key, assertions and key reports; cites each field and scores its confidence.

  • Never marks a control key without the key-control criteria
  • Rows under 0.85 confidence go to the owner
Challenger agent

Tests every control description against the standard — who, what, when, how much, evidence, precision — re-derives a sample of rows blind and disagrees with the matrix agent out loud.

  • Never resolves its own disagreement
  • Never edits a row
Gap agent

Compares the matrix with the group risk library and each significant account's assertions, sets what people said against what the SOP says and what the system enforces, and sizes the exposure from the ERP.

  • Never decides a gap
  • Never classifies a deficiency
  • Read-only in the ERP
Watcher agent

Watches SOP and policy versions, ERP change tickets, system settings and the directory, and proposes the RCM redline with its impact on testing.

  • Never applies a change
  • Never retires a control
Report writer

Drafts the Audit Committee status, the auditor pack, the gap register and answers to the external auditor's questions, every number cited.

  • Never sends to the external auditor
  • A person approves every answer
Process owner and SOX program manager

Owner confirms, manager signs. The agents propose; a named person decides.

Ask in plain words

Ask the agents about any row, in plain words

Ask about a row, a source, a gap or a change — or tell the agents what to do. The same conversation sits on Today, under the matrix and beside each gap. Every answer cites the walkthrough, the SOP or the configuration, and acts where you are.

Why is O2C-02 low confidence?

Two rows are below the 0.85 floor. O2C-02: Victor Hale said the change log is reviewed every week and Julia Meyer said “most weeks, Mondays”, but SOP-O2C-01 §4.1 says monthly. O2C-13: nobody said who decides on access. Both are with Marcus, due Fri 16 Oct. I’ve filtered the matrix to them.

What changed from v2.4?

Against v2.4 (approved 12 Jan 2026): 3 new (O2C-05, O2C-08, O2C-13), 5 changed (O2C-03, -04, -06, -07, -09) and 1 retired: O2C-L7, the legacy workflow over all credit memos, which is why G1 exists. 6 are unchanged.

How did you find the 41 memos?

I ran a read-only query on billing documents of type MCM posted from 1 Sep to 13 Oct 2026 with a value above $10,000: 41 memos, $1,186,420. Then I matched each memo to e-mails in Julia Meyer’s approval folder by memo number and amount: 29 matched, 12 did not ($318,750). The challenger agent re-ran the query blind and got the same result.

Draft the note to Marcus

Draft to Marcus: “Two questions left before Friday: is the customer change-log review weekly or monthly (O2C-02), and who owns the quarterly access review (O2C-13)? Each takes a minute; the clip is attached.” He has confirmed 11 rows and corrected 1. Send it from Owner confirmation.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

TodayFour plain numbers and the agents' thread — what they finished and what needs a person, each with its next step — beside a box to ask the agents.
Walkthrough to RCMThe process flow across the top, the transcript on the left, the matrix on the right grouped by risk; a source chip jumps the recording to its moment.
The challenger disagreesA control description the challenger agent calls untestable, its proposed wording, the matrix agent's reasoning and the row's history.
Cited narrativeSeven sections with a citation on every paragraph, the conflicts between what was said and what is written, and a rewrite shown as a redline.
Swimlane flowchartNine steps in six lanes with risk, control and gap markers; a step shows its risk, its controls and the narrative passage behind it.
Assertion coverageFour significant accounts by six assertions, with the controls behind each cell — and the one relevant assertion with no control.
Gap analysisWhat people said, what the SOP says and what the system enforces, side by side, with the root cause and the exposure sized from the ERP.
The gap decisionThe challenger's blind re-check, then the SOX program manager's decision with its reason code, the new control and the interim review.
Owner confirmationOne plain question per row with the clip; the owner's answer becomes a cited redline, with the service level and reminders below.
Change watchA policy change turned into a redline on two controls with its testing impact, the watched sources and a connection that needs renewing.
Versions and approvalThe field-level comparison with the last approved version, the prerequisites, and the attestation and signature.
Reports and auditor questionsAudit Committee status, the auditor pack, the gap register and owner service levels — and an auditor's question answered in a cited draft that waits for approval.
Your thresholdsConfidence and transcript quality floors, the owner service level, reminders, escalation, retention and performance materiality.
Governance

Built for ICFR: cited, challenged, confirmed, signed.

No row without a sourceEvery narrative sentence, flow step and matrix field cites the second of the recording, the SOP paragraph or the configuration line it came from. A version cannot be approved until every row has at least one source.
Floors that stop the agentsNothing is drafted from a transcript below the 85% quality floor — the inventory walkthrough at 71% waits for a person. Rows under 0.85 confidence go to the process owner with the reason.
Agents argue; a person settles itThe challenger agent tests every description and disputes the matrix agent in the open. Both reasonings are shown, and only a person chooses the wording.
People confirm, decide and signThe process owner confirms each row. The SOX program manager decides every gap with a reason code — GAP-NEW, GAP-COMP, GAP-RISK or GAP-NA — and approves a version with an attestation and her name. Preparer and approver must differ.
Nothing applied or sent unseenAgents never decide a gap, classify a deficiency, approve a version, apply a change or send anything to the external auditor. Business systems are read-only to them; only an approved version is written to the GRC system of record.
Every step on the audit trailEvery agent step and every person's confirmation, edit, decision and settings change is logged with who, what, when and the reason, and exports as an evidence pack. Recordings are kept 90 days; transcripts stay with the version.
Configuration

Your methodology, not ours

The floors, service levels and standards the agents work to are settings. A change needs a reason and goes on the audit trail.

SettingDefaultChoose from
Confidence floor0.85Rows below it go to the process owner
Transcript quality floor85%Below it, nothing is drafted
Owner service level5 business daysReminder on day 3 by e-mail and chat; open rows escalate to the SOX program manager on day 5
Recording retention90 daysTranscripts stay with the documentation
Performance materiality$18.0MSignificant account threshold, FY2026
Risk libraryGroup risk library v627 order-to-cash risks · 214 risks in all · owner Group Internal Audit
Control description standardWho · what · when · how much · evidence · precisionThe challenger agent tests every description against it
Key reportsCompleteness and accuracy procedure requiredA report used in a control needs one (AS 1105)
Connections

Works with the sources a walkthrough already touches

Walkthrough recordingsthe recordings the facilitator shares, read-only, with the consent notice
Document librarySOPs, policies and methodology memos, with their versions
ERPfinance, order management, workflow configuration and roles — read-only
Change ticketsERP change requests that create or change a control
Identity directorycontrol owners, moves and leavers
GRC system of recordthe prior approved RCMs in; approved versions written back only after approval
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
100%
of framework risks mapped to a control or flagged before the auditor's walkthrough
11 of 11
O2C risks covered or flagged
estimated
≈ $240K
of first-draft effort avoided on a 38-process refresh
By hand$342K
With agents≈ $102K
target
Sameday
narrative, flow and matrix drafted from the walkthrough
Todayweeks
With agents11 min

“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate (60 hours of first-draft effort per process, an assumption to measure in a pilot) · “typical” = published figures (KPMG, The 2025 SOX Survey — average programme 15,581 hours, in-scope systems 17 → 40; KPMG, Trends in material weaknesses — 238 adverse reports in FY2025 filings). PCAOB AS 2201 and AS 1105 are named as context. People, companies, systems and documents named on this page — Kestrel & Vane Group, Ashdown Pryce LLP, Brannock Controls and everyone in the story — are fictional: characters and sample data in the working solution.

Questions

What SOX teams ask us.

What is Risk and Control Matrix (RCM) Documentation?

Software that drafts the SOX process narrative, the flowchart and the risk and control matrix from a walkthrough recording, your SOPs and the system configuration. Every field of every row cites the moment or paragraph it came from, a challenger agent tests each control description, and a gap agent flags any risk with no control. The process owner confirms each row, and the SOX program manager decides every gap and signs the version.

How does it turn a SOX walkthrough into process narratives and flowcharts?

The capture agent transcribes the recording with speakers and timestamps and scores its quality. The narrative agent writes the narrative in your house template, the flow agent draws the swimlane flow from it, and the matrix agent extracts the risks and controls. In the working solution, a 45-minute order-to-cash walkthrough became a 6-page narrative, a 9-step flow and 14 controls in 11 minutes 20 seconds.

How does it find a risk with no control before the external auditor does?

The gap agent compares the matrix with your risk library and the assertions of each significant account. For each risk it sets what people said in the walkthrough against what the SOP says and what the system enforces, and sizes the exposure from the ERP, read-only. Every gap waits for the SOX program manager to decide it with a reason code.

Can our external auditor trace a control back to its source?

Yes. Every owner, frequency, threshold and assertion carries a source chip that opens the transcript at that second or the SOP paragraph or configuration line, highlighted. The external auditor has read-only access to approved versions, and answers to their questions are drafted with citations and sent only after a person approves them.

Does the RCM stay current when SOPs, policies, systems or owners change?

The watcher agent reads new SOP and policy versions, ERP change tickets, system settings and directory moves, and proposes the exact redline with its impact on testing. It never applies a change or retires a control: the SOX program manager accepts, rejects or dismisses each one with a reason.

Can we start SOX documentation for a business we just acquired?

Yes. In the working solution, Brannock Controls, acquired on 1 Jul 2026 with its first SOX year in FY2027, starts from the Processes screen: the agents find the target's SOPs and ERP role export, propose walkthrough dates and prepare the questions.

Do people stay in control of the documentation?

Yes. Agents never confirm a row, decide a gap, classify a deficiency, approve a version, apply a change or send anything to the auditor. The process owner confirms each row in plain words; the SOX program manager decides gaps with reason codes and approves with an attestation; preparer and approver must differ, and every step is on the audit trail.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents — your risk library, RCM template, control description standard and a sample walkthrough — and it goes live once every quality gate has passed. We will walk you through it on one of your own processes first.

See it on
your walkthroughs.

We'll run Risk and Control Matrix (RCM) Documentation on one of your own walkthrough recordings, its SOPs and your prior RCM.