Your controls Are Only As Good As Your ERP Configuration#
If you're a CFO, Internal Audit Director, or Compliance Officer, you know that ERP systems are where internal controls live or die. The best-documented policies mean nothing if the ERP configuration allows someone to both create vendors and approve payments.
The uncomfortable truth: Most ERP implementations prioritise functionality over control. Go-live pressure pushes security and segregation of duties to "phase two"—which often never arrives. The result? ERPs that enable rather than prevent fraud, that create audit trail gaps rather than audit trails, that generate compliance risk rather than compliance assurance.
What's at stake: A single segregation of duties breach can enable six-figure fraud. A missing audit trail can turn a routine audit into a forensic investigation. A control failure in your ERP can mean regulatory penalties, restated financials, and personal liability for directors.
This article provides a practical framework for ERP governance—covering segregation of duties, approval workflows, audit trails, and compliance monitoring—designed for people who are responsible for control effectiveness, not just system functionality.
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Governance as Foundation#
The Governance Framework#
1. Segregation of Duties (SoD)#
Segregation of duties ensures that no single individual can complete a transaction cycle without independent verification.
Key principles: - Custody of assets separate from recording - Authorisation separate from execution - Reconciliation performed by someone independent of processing
ERP implementation: - Role-based access control - SoD conflict matrices - Automated conflict detection - Compensating control documentation
2. Approval Workflows#
ERP systems enforce approval hierarchies that ensure appropriate authorisation.
Workflow design principles: - Approval thresholds aligned with authority levels - Escalation paths for exceptions - Delegation mechanisms for absences - Audit trail of all approvals
3. Audit Trails#
Comprehensive audit trails enable investigation and compliance verification.
Audit trail requirements: - User identification - Timestamp - Before and after values - Transaction context
Retention considerations: - Regulatory requirements (typically 7 years) - Legal hold capability - Tamper-proof storage
4. Data Integrity Controls#
ERP systems must maintain data accuracy and completeness.
Control types: - Input validation - Referential integrity - Calculated field verification - Reconciliation processes
Compliance Monitoring#
Continuous Controls Monitoring#
Automated monitoring of control effectiveness:
SoD monitoring: Real-time detection of conflicts.
Threshold monitoring: Alerts when transactions exceed limits.
Pattern monitoring: Detection of unusual patterns that may indicate fraud.
Periodic Control Testing#
Regular testing of control effectiveness:
Design testing: Are controls appropriately designed?
Operating effectiveness: Are controls operating as designed?
Remediation tracking: Management of identified issues.
NZ/AU Regulatory Context#
New Zealand#
Financial Markets Conduct Act: Requirements for NZX-listed entities.
Companies Act: Director responsibilities for internal controls.
Privacy Act 2020: Data protection requirements.
Australia#
Corporations Act: Director duties and financial reporting requirements.
ASX Corporate Governance Principles: Governance standards for listed entities.
Privacy Act 1988: Australian privacy requirements.
Governance Roles and Responsibilities#
Management#
- Design and implement controls
- Monitor control effectiveness
- Remediate identified issues
Internal Audit#
- Independent assessment of controls
- Recommendations for improvement
- Follow-up on remediation
External Audit#
- Audit of financial statements
- Assessment of internal controls over financial reporting
- Management letter findings
Audit Committee/Board#
- Oversight of control environment
- Review of audit findings
- Approval of significant control changes
ERP Configuration Best Practices#
Role Design#
- Roles based on job functions
- Minimal necessary access
- Regular access reviews
- Documented role definitions
Workflow Configuration#
- Approval thresholds aligned with delegation of authority
- Exception handling procedures
- Timeout and escalation rules
- Mobile approval capability
Change Management#
- Controlled transport process
- Testing in non-production environments
- Documentation of changes
- Approval before promotion
Monday Morning Action Plan#
This week:
- Run the SoD Quick Scan: List all users with "super user" or "administrator" access. Each one is a control gap waiting to happen.
- Check Your Audit Trail: Can you answer: "Who changed customer X's credit limit last month, what was it before, and who approved it?" If not, your audit trail is inadequate.
- Review Critical Workflows: For your top 3 highest-risk processes (typically: procurement, payments, journal entries), document what controls exist in the ERP vs. manual workarounds.
- Schedule the "Phase Two" Conversation: If security was deferred during implementation, schedule the meeting to define what "phase two" means and when it happens.
- Test Your Compliance Reporting: Run your standard compliance reports. Do they actually work? Are they accurate? Fix before auditors ask.
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Conclusion: Governance Enables Trust#
ERP governance is not bureaucratic overhead. It is the foundation of trust in organisational data and processes. Effective governance protects the organisation, enables compliance, and supports decision-making with reliable information.