Given the critical role that IT-based systems play in the success of many companies and due to increased regulatory requirements, senior management is becoming more accountable for IT control effectiveness. However, given the paucity of quality data on IT control, to our knowledge, no empirical studies examine the influence of internal and external governance that could potentially affect IT control. This study examines the influence of senior management, the board of directors, and audit committee regarding IT control governance, by using companies' SOX 404 report data.