How to Map Internal Controls: A Step-by-Step Guide to Creating a Risk and Control Matrix

• What controls are in place?
• What risk does each control address?
• Who is responsible?
• How often is the check performed?
• What evidence proves that it was carried out?
• Has the control been tested?
• Is the control really effective?
• What happens when control fails?

When this information is scattered across spreadsheets, documents, and emails, the organization loses visibility, and the effort required for audits and compliance assessments increases.

That's why the Mapping of Internal Controls It should go beyond a simple checklist.

The goal is to build a structure that connects:

Process → Risk → Control → Person Responsible → Evidence → Test → Result → Action Plan

In this guide, you'll learn How to Map Internal Controls Step by Step and how to turn this mapping into a management tool.

What is Internal Control Mapping?

O Mapping of Internal Controls It is the process used to identify, document, and map existing controls to the organization's risks and processes.

The goal is to develop a structured overview of how the company manages its key risks.

A mapping can answer:

“What controls are in place to mitigate a particular risk, and how do we know they’re working?”

This question is essential for auditing, compliance, risk management, and governance.

Why Map Internal Controls?

Without structured mapping, the company may have duplicate controls, insufficient controls, or risks for which there are no adequate mitigation mechanisms.

Mapping helps to:

• Identify risks without controls;
• Find duplicate controls;
• Define responsibilities;
• Identify critical controls;
• Organize evidence;
• Prepare audits;
• Improve processes;
• Strengthen Compliance;
• Monitor the effectiveness of controls;
• Prioritize action plans.

More than just documenting controls, mapping allows us to identify where the organization is protected and where there are still gaps.

What is a Risk and Control Matrix?

A Risk and Control Matrix It is a tool used to link identified risks to the controls in place to address them.

A basic matrix can contain:

This structure makes it possible to visualize the relationship between the different elements of the process.

How to Map Internal Controls Step by Step?

1. List the organization's key processes

The first step is to understand which processes need to be evaluated.

Depending on the organization, there may be processes such as:

• Finance;
• Shopping;
• Sales;
• Human Resources;
• Technology;
• Information security;
• Supplier management;
• Compliance;
• Legal;
• Operations;
• Data protection.

Ideally, you should start with the processes that are most relevant to your strategic objectives and those that are most exposed to risk.

2. Understand how the process works

Before identifying controls, it is necessary to understand the process.

Here are a few questions that might help:

• How does the process begin?
• What are the main steps involved?
• Who participates?
• What systems are used?
• What information is generated?
• Where are decisions made?
• Where can errors occur?
• Which activities are critical?

This step may involve interviews with managers, analysis of procedures and documents, and observation of activities.

3. Identify the risks associated with the process

Once you understand the process, identify what could go wrong.

A risk must be an event that could affect the organization's objectives.

For example:

Process: accounts payable.

Risk: payment made to an unauthorized supplier.

Another example:

Process: access management.

Risk: An employee retains access to systems after leaving the company.

The identification must take into account the actual characteristics of the operation.

4. Assess the risks

After identifying the risks, it is necessary to assess their significance.

A common methodology takes the following into account:

• Probability;
• Impact;
• Risk level.

The result can be classified, for example, as:

The methodology should be defined by the organization itself, based on its context and risk appetite.

5. Identify existing controls

Now comes one of the most important steps.

For each identified risk, ask:

“What is the company already doing to prevent or detect this problem?”

Controls can be:

• Policies;
• Procedures;
• Approvals;
• Validations;
• Segregation of duties;
• Reconciliations;
• Revisions;
• Monitoring;
• Systemic blockages;
• Audits.

The goal is to map out what actually happens in the process, not just what is described in a policy.

6. Define the purpose of each control

Every control must have a clear purpose.

For example:

Control: independent approval of payments.

Objective: reduce the risk of improper or unauthorized payments.

This relationship helps verify whether the control actually addresses the identified risk.

7. Classify the type of control

Controls can be classified in various ways.

A simple classification is:

It may also be helpful to determine whether the control is:

• Manual;
• Automated;
• Hybrid.

8. Designate the person responsible for oversight

A control must have a clearly defined person in charge.

This prevents situations where everyone believes that someone else should be the one to perform a certain task.

Mapping can identify:

• Responsible for implementation;
• Responsible for supervision;
• Department in charge;
• Responsible for monitoring.

A control without a defined responsibility is a vulnerable control.

9. Set the frequency

It is also necessary to record how often the check is performed.

Examples:

• Per transaction;
• Every day;
• Weekly;
• Monthly;
• Quarterly;
• Annually;
• When necessary.

The frequency should be appropriate for the risk being addressed.

10. Define the evidence

A key question is:

“How can the company prove that this audit was conducted?”

This evidence is the proof.

Examples:

• Reports;
• Logs;
• Approval records;
• Checklists;
• Documents;
• Tickets;
• System reports;
• Minutes;
• Supporting documents.

The existence of evidence enhances the company's ability to demonstrate that the control was actually implemented.

11. Evaluate the effectiveness of the control

After mapping the control, you need to check whether it works.

A control can be:

• Effective;
• Partially effective;
• Ineffective;
• Not executed;
• Not tested.

This assessment can be conducted through tests.

12. Test the controls

The test verifies that the control was executed as defined.

A basic structure might include:

1. Define the control;
2. Set the period;
3. Select a sample;
4. Gather evidence;
5. Check the execution;
6. Log exceptions;
7. Draw conclusions about its effectiveness.

Test criteria and methods must be defined based on the nature of the control and the associated risk.

13. Identify control gaps

During the mapping process, situations such as the following may arise:

• Uncontrolled risk;
• Control without evidence;
• Duplicate control;
• Controls were implemented inconsistently;
• Controls that are inadequate for the risk;
• Control without a person in charge;
• Control without monitoring.

These gaps represent opportunities for improvement.

14. Create action plans

When a deficiency is identified, the organization can develop an action plan.

An action plan must establish:

• What will be done;
• Who will be responsible;
• When will it be completed?;
• What is the priority;
• What evidence will support the conclusion?

Thus, the process is no longer merely a diagnosis.

Mapping is now leading to tangible improvements.

15. Reevaluate the controls periodically

Controls must keep pace with changes in the organization.

A process can change due to:

• New systems;
• New regulations;
• Organizational changes;
• New suppliers;
• New products;
• International expansion;
• Incidents;
• Audit results.

When the process changes, the risk may change.

And when the risk changes, the controls may also need to be reviewed.

Internal Controls Matrix Template

A matrix can be structured as follows:

Checklist for Mapping Internal Controls

How can I tell if the mapping of internal controls is complete?

A good mapping isn't necessarily the one with the most controls.

The goal is to ensure that the organization's key risks are adequately addressed.

Here are some questions that can help you assess the quality of the mapping:

• Do all significant risks have controls in place?
• Are the controls related to the correct risks?
• Have specific people been assigned to be in charge?
• Is there evidence of enforcement?
• Are the controls tested?
• Do disabilities lead to action plans?
• Are the action plans being monitored?
• Are the controls reevaluated?

If several of these questions remain unanswered, there is likely room to refine the structure.

How do you map internal controls in a company that uses spreadsheets?

Spreadsheets can be useful as a starting point for organizing an inventory of controls.

However, as the number of cases increases, challenges arise related to:

• Version control;
• Updating information;
• Responsibilities;
• Deadlines;
• Evidence;
• Tests;
• History;
• Metrics.

A spreadsheet can indicate that a control exists.

But she isn't always able to present it in a cohesive way:

What is the risk, who conducted the test, what evidence was presented, when was the test performed, what was the result, and what action is being taken?

It is precisely at this stage that technology can significantly enhance the maturity of the process.

How does technology help with mapping internal controls?

A GRC platform allows you to centralize the control lifecycle.

Instead of working with disconnected information, the organization can structure:

Process → Risk → Control → Person Responsible → Evidence → Test → Result → Action Plan

This structure makes it easier to:

• Traceability;
• Monitoring;
• Audits;
• Evidence management;
• Monitoring of action plans;
• Metrics;
• Decision-making.

How does Triskle help with mapping internal controls?

A Triskle GRC It allows you to centralize risks, controls, records, audits, nonconformities, and action plans in a single environment.

In practice, your organization can use the platform to:

• Map risks and controls;
• Link controls to risks;
• Assign responsibilities;
• Organize evidence;
• Monitor controls;
• Record tests;
• Identify nonconformities;
• Create action plans;
• Track deadlines;
• Generate indicators;
• Present information on an Executive Dashboard.

This allows the mapping to go beyond just a spreadsheet and become a ongoing management and monitoring process.

Frequently Asked Questions About Internal Controls Mapping

What is Internal Control Mapping?

It is the process of identifying, documenting, and mapping existing controls to the organization's processes and risks.

How do you create an internal controls matrix?

Start by identifying the processes, then map out the risks, controls, responsible parties, frequency, evidence, and testing criteria. Finally, evaluate effectiveness and document any action plans.

What is the difference between a risk matrix and a control matrix?

The risk matrix focuses on identifying and assessing risks, while the control matrix lists the mechanisms used to address those risks. In practice, the two frameworks can be integrated into a single matrix.

Who should map the internal controls?

The process typically involves the departments responsible for the processes, with the participation or support of functions such as Risk, Compliance, Internal Controls, and Audit, depending on the organization’s governance model.

Does every risk need to be controlled?

Significant risks must be assessed and addressed in accordance with the organization’s risk appetite. This does not necessarily mean that every risk will have a specific control, but the decision to accept, mitigate, transfer, or avoid the risk must be informed and documented.

How to Test Internal Controls?

The test should verify whether the control was implemented as defined and whether there is sufficient evidence to substantiate its implementation. The method depends on the nature of the control and the associated risk.

How Can You Identify Weaknesses in Internal Controls?

Deficiencies can be identified through testing, audits, incidents, nonconformities, indicators, and monitoring.

Are spreadsheets sufficient for managing internal controls?

Spreadsheets may work for small-scale operations, but they can have limitations when the number of risks, controls, evidence, responsible parties, and action plans increases. A GRC platform can centralize and automate the monitoring process.

Mapping internal controls is much more than just creating a table of procedures.

The goal is to develop a clear understanding of how the organization identifies, manages, and monitors its risks.

Good mapping connects:

Process → Risk → Control → Person Responsible → Evidence → Test → Result → Action

This connection enhances the company's ability to identify gaps, prepare for audits, demonstrate compliance, and continuously improve its processes.

The greatest benefit is realized when the mapping is no longer a static document but is instead continuously updated and monitored.

Internal controls should not exist only on paper. They must be implemented, documented, tested, and improved.

For organizations that still manage this structure using spreadsheets, centralizing it on a GRC platform can represent a significant step forward in maturity.

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