SOX 404
SOX ITGC Cost Estimator
Estimate first-year and ongoing IT general controls readiness + audit cost by auditor tier and system scope.
How this is calculated
- Readiness = systems in scope x US$15,000-40,000 per system, scaled by a gap factor of 0.5 + (missing control areas / 5): 0.5 when all five ITGC areas exist, 1.5 when none do.
- External audit = a yearly fee band for the auditor tier you pick: Big 4 US$150,000-500,000, mid-tier US$75,000-250,000, boutique US$40,000-150,000.
- First year = readiness + audit. Ongoing = 60% of the first-year low end to 70% of the high end.
- Colour: for a public company, red with 3 or more control areas missing, otherwise amber; green if you are not public.
Constants the tool uses
Unless a value names a study, it is VITI Security's working estimate for budgeting - not taken from a statute or a dated study - so treat it as an adjustable assumption.
- Readiness per in-scope system
- US$15,000-40,000
- Gap factor
- 0.5 + missing areas / 5
- Audit fee: Big 4 / mid-tier / boutique
- US$150k-500k / 75k-250k / 40k-150k a year
- Ongoing cost
- 60%-70% of year one
Worked example
The calculator run on its default inputs:
- Public company (or pre-IPO)?
- Yes
- IT systems in SOX scope
- 5 systems
- ITGC already in place
- Change management (tickets + approvals); Audit logging & retention
- External auditor tier
- Mid-tier / national firm
Estimated SOX ITGC cost
$157.5K-$470K yr 1
- Applicability
- SOX 404(a) management assessment applies; 404(b) auditor attestation only if you are an accelerated or large accelerated filer
- First year: readiness (5 systems, 3/5 control areas missing) + audit
- $157,500-$470,000
- Ongoing annual (audit + evidence + maintenance)
- $94,500-$329,000
- Auditor tier fee assumption
- Mid-tier: $75,000-$250,000/yr
Five systems with two of five control areas in place give a gap factor of 0.5 + 3/5 = 1.1, so readiness is 5 x US$15,000-40,000 x 1.1 = US$82,500-220,000. Adding the mid-tier audit band (US$75,000-250,000) gives US$157,500-470,000 in year one and US$94,500-329,000 a year after that.
Sources
- Sarbanes-Oxley Act s.404, 15 U.S.C. 7262 (govinfo) - management assessment (404(a)) and auditor attestation (404(b)), with the exemption for non-accelerated filers
- Regulation S-K Item 308 (eCFR) - management’s ICFR report and the transition period for newly public companies
- PCAOB AS 2201 - the auditor’s integrated audit of internal control over financial reporting
- SEC proposed rule, File S7-2026-18 (May 2026) - the pending proposal to narrow 404(b) auditor attestation
Sources last checked September 2026.
Limitations
There is no public fee schedule: audit fees depend on the company, the auditor and its history of findings. The model treats every system alike and does not price SOC 1 reports from service providers or remediation of audit findings. This is an indicative estimate for education and planning, not legal advice. Laws and published figures change, and regulators and courts apply discretion no calculator can model - confirm with a qualified legal or compliance professional before acting on a result.