Crosswalk pair
ISO 9001 and SOX (Sarbanes-Oxley) Section 404, control by control
6 canonical controls in Keel’s library satisfy clauses of both ISO 9001 and SOX (Sarbanes-Oxley) Section 404. Implement each once, attach the evidence once, and it counts toward each standard. The overlap is the work you don’t repeat.
The overlap
What the two libraries have in common
Every figure here counts canonical controls in Keel’s library, not clauses of either standard. Each standard’s own authored count is on its framework page.
6
Controls that satisfy both
Canonical controls that crosswalk to at least one clause of each.
15
In Keel’s library for ISO 9001
40% of them also map to SOX (Sarbanes-Oxley) Section 404.
29
In Keel’s library for SOX (Sarbanes-Oxley) Section 404
21% of them also map to ISO 9001.
20
Evidence artifacts expected
Across the shared controls, from Keel’s evidence guidance. Gathered once.
-
ISO 9001 40%
6 controls of 15 in Keel’s library for ISO 9001 also map to SOX (Sarbanes-Oxley) Section 404.
-
SOX (Sarbanes-Oxley) Section 404 21%
6 controls of 29 in Keel’s library for SOX (Sarbanes-Oxley) Section 404 also map to ISO 9001.
The mapping
Controls that satisfy both
Each row is one control in Keel’s library and the clauses it answers on each side. Do the work once; both columns are then evidenced by the same artifacts.
| Canonical control | ISO 9001 clauses | SOX (Sarbanes-Oxley) Section 404 clauses |
|---|---|---|
| Governance & Risk | ||
| Document & records control Documented information is created, approved, versioned, and controlled; records are retained and protected for a defined minimum period - measured from the document’s creation OR from the date it last was in effect, whichever is later, so a policy that stayed in force for years does not start its clock on the day it was written - and are available to the people who have to act on the procedures they describe. Documentation is reviewed on a schedule and updated when an operational, environmental or legal change has made the current version wrong. A change forced by law is documented and put into effect promptly, and where that legal change materially affects what the organization has published to individuals about how it handles their data, THAT NOTICE IS REVISED TOO, as part of the same prompt action rather than as a separate task left to whoever owns the notice. Any other change may be made at any time provided the revised version still complies and IS DOCUMENTED BEFORE THE CHANGE TAKES EFFECT - the record precedes the effective date, so a routine that documents changes in arrears does not discharge this. | 7.5.2, 7.5.3.1, 7.5.3.2 | P12 |
| Internal audit program A risk-based internal audit program evaluates conformity and effectiveness at planned intervals, and again when an environmental or operational change could have undermined what was last evaluated; each evaluation covers both technical testing and non-technical review of whether the documented policies and procedures are actually being met. The programme itself is written down - how often audits run, what methods they use, who is responsible for them, what each one covers and how it reports - and nobody audits their own work, so a finding is an independent judgement rather than a self-assessment. The results of each audit go to the management responsible for the area audited, and the programme and its results are retained as evidence that it ran. | 9.2.1, 9.2.2 | P16 |
| Management review Leadership reviews how the management system is performing at planned intervals and decides what to do about it: what will be improved, and what about the system itself has to change. Each decision leaves the review with a named owner and a date rather than as a sentiment in the minutes, the previous review’s decisions are picked back up at the next one so nothing is decided twice and never done, and the record of the review and its outputs is retained. | 9.3.1, 9.3.3 | P16 |
| Nonconformity & corrective action (CAPA) When something fails to meet a requirement, the first response is to contain it: the nonconforming output is controlled so it goes no further, what has already gone wrong is corrected, and the consequences of it are dealt with. Then the question of cause is asked - why it happened, and whether the same failure exists somewhere else or could happen somewhere else - and where the answer warrants action, that action is taken and tracked to closure. Afterwards the action is reviewed for whether it actually removed the cause rather than only for whether it was completed, the management system is changed where the review shows it has to be, and the nonconformity, what was done about it and the result of doing it are all recorded. | 8.7.1, 8.7.2, 10.2.1, 10.2.2 | P17 |
| Third-party Risk | ||
| Third-party / vendor risk management Due diligence, contractual safeguards, and ongoing monitoring of vendors that handle your data: the agreement obliges the vendor to comply in its own right with the security requirements that apply to it - an absolute standard, not a promise to match whatever you happen to do - to pass those obligations down to any subcontractor it brings in BY ENTERING INTO a contract or equivalent written arrangement with that subcontractor rather than by merely requiring equivalent practice of it, and to report to you, within a stated time, security incidents it becomes aware of and confirmed breaches of your data. Where a contract is not the instrument available, an equivalent written arrangement carrying the same obligations discharges the duty. The same obligations, together with the separation that keeps a related organization out of data it is not entitled to, are written into the governing document of any other arrangement that puts your data in the hands of a sponsor, parent, affiliate or plan. Diligence is not confined to security where the relationship warrants more: for suppliers significant enough to matter, the organization states the standards of conduct it expects of them - how they behave commercially and how they treat the environment around their operations - and screens candidates and incumbents against those stated expectations as part of the same selection and monitoring cycle, rather than accepting a signature on a code as evidence of it. | 8.4.1, 8.4.3 | P11, P15 |
| People & Culture | ||
| Competence management The competence each role in the management system needs is determined and written down, and the people in those roles are established as having it - on the basis of their education, training or experience rather than on the basis of holding the job. Where the competence is not there, something is done about it - training, mentoring, supervision, reassignment or hiring - and the action is afterwards evaluated for whether it produced the competence, not merely for whether it was delivered. The records that show all of this are retained. | 7.2 | P4 |
Beyond the pair
Where else this work counts
A framework is lit when a shared control above also maps to it. Unlit means none of them do — an absence, not a judgment about that standard.
Also reached by these 6 controls
- AI Governance Essentials
- Amazon Appstore Child-Directed Apps
- Apple App Store Kids Category
- CIS Critical Security Controls
- COPPA
- ESG Essentials
- EU AI Act
- GDPR
- Google Play Families
- HIPAA
- ISO/IEC 27001
- ISO/IEC 42001
- NIST AI Risk Management Framework
- NIST Cybersecurity Framework
- NIST SP 800-171
- NIST SP 800-53
- PCI DSS
- SOC 2
- US Employment Law - Federal Baseline
Nearby pairs
- SOX (Sarbanes-Oxley) Section 404 and ISO/IEC 27001 24 shared controls
- SOX (Sarbanes-Oxley) Section 404 and SOC 2 23 shared controls
- SOX (Sarbanes-Oxley) Section 404 and NIST SP 800-53 20 shared controls
- SOX (Sarbanes-Oxley) Section 404 and HIPAA 16 shared controls
- SOX (Sarbanes-Oxley) Section 404 and PCI DSS 16 shared controls
- SOX (Sarbanes-Oxley) Section 404 and NIST Cybersecurity Framework 15 shared controls
The thesis
Why this is one project, not two
On a crosswalk-native model, SOX (Sarbanes-Oxley) Section 404 mostly lights up controls you already built for ISO 9001. You’re not re-uploading the same screenshot for a second audit. You apply the framework and see the genuine delta worth working. That’s the whole idea behind collect once, comply everywhere.
Next step
Add SOX (Sarbanes-Oxley) Section 404 to the work you already did
Apply both frameworks in one workspace and see the overlap measured against the controls you already hold.