ERP User Access Review Process Guide
User access reviews are a critical governance control ensuring that ERP system access remains appropriate as employees change roles, transfer departments, or leave the organization. Regulatory frameworks including SOX (PCAOB AS 2201), ISO 27001 (A.9.2.5), and NIST 800-53 (AC-2) mandate periodic review of user access rights. Without structured review processes, organizations accumulate excessive privileges that create security vulnerabilities and compliance findings. This guide establishes a repeatable access review framework.
Access Review Cycle Design and Scheduling
An effective access review program defines review frequency based on risk: privileged access (administrators, super users) reviewed quarterly, standard user access reviewed semi-annually, and service/system accounts reviewed annually. Each review cycle has defined phases: preparation (extract current access data), execution (manager certification), remediation (remove inappropriate access), and evidence collection (archive results for auditors). Review scheduling should align with the organization's audit calendar to ensure current evidence is available during audit fieldwork.
- Schedule quarterly reviews for privileged ERP accounts (administrators, security managers, financial approvers) per SOX requirements
- Conduct semi-annual reviews for standard ERP user access covering all active user accounts and their assigned roles
- Review service accounts and system integration accounts annually with business owner justification for continued access
- Align review cycles with external audit calendar: complete reviews 30 days before audit fieldwork begins for current evidence
- Maintain a rolling review schedule with automated notifications to reviewers 14 days before each review cycle opens
Review Execution and Certification Workflow
During the review execution phase, managers receive access reports listing each direct report's ERP roles, permissions, and last login dates. Managers must certify each user's access as appropriate or flag specific roles for removal. The certification workflow should enforce accountability: reviews not completed within the defined window trigger escalation to the manager's supervisor, and uncertified access is automatically flagged for suspension. Reviewers must have sufficient business context to evaluate access appropriateness, requiring clear role descriptions and last-activity indicators.
- Generate access reports per reviewer showing each user's assigned ERP roles, permission summary, and last activity timestamp
- Provide role descriptions and business context for each listed role enabling informed certification decisions by managers
- Require explicit certification (Approve or Revoke) for each user-role combination; bulk approval of all access is not permitted
- Implement escalation rules: incomplete reviews after 14 days escalate to next-level manager with notification to compliance team
- Auto-suspend uncertified access after 30 days with notification to the affected user and their manager for reinstatement request
Remediation and Audit Evidence Management
Remediation of flagged access must be completed within defined SLAs: revocations processed within 5 business days of review completion, with emergency revocation procedures for high-risk findings. All review activities, certifications, revocations, and exceptions must be archived as audit evidence with tamper-evident timestamps. The evidence package includes the access extract at review start, individual certification records, revocation confirmation, exception approvals, and review completion metrics (participation rate, on-time completion, revocation rate).
- Process access revocations within 5 business days of manager certification with confirmation notification to security team
- Document exceptions (access retained despite flag) with risk acceptance approval from information security officer and business owner
- Archive complete review evidence packages: access extracts, certification records, revocation logs, and exception approvals
- Track review KPIs: participation rate (target >95%), on-time completion (target >90%), revocation rate, and exception rate per cycle
- Retain review evidence for the full audit period (typically 3-7 years) in a tamper-evident document management system
Establish a robust access review program for your ERP system. Netray implements automated review workflows with audit-ready evidence management.
Related Resources
ERP Role-Based Access Control Setup Guide
Implement role-based access control in ERP systems with role design, permission matrices, least-privilege enforcement, and ongoing access governance processes.
ERPERP SOX Compliance Checklist
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ERPERP Segregation of Duties Setup Guide
Implement segregation of duties in ERP systems with SoD conflict matrices, rule configuration, violation detection, and compensating controls for SOX compliance.