A small church may have one volunteer who understands the accounting software, knows how to pay the bills, prepares the financial reports, and reconciles the bank account. Another person may count offerings, while the pastor or board approves larger expenditures. Everyone involved may be trustworthy and conscientious. There simply are not enough financially capable people to assign every task to someone different.
Advice to “segregate duties” can feel disconnected from that reality. Full segregation remains the stronger arrangement where a church has enough people to achieve it, but limited staffing does not leave a congregation with only two choices: build a large finance team or accept having no meaningful controls.
Church Training Center recommends a more practical approach for small churches. Identify where financial responsibilities overlap, determine what one person can do without someone else seeing or verifying it, and place another workable control at the points where the risk is greatest.
The Goal Is Not Four Different People
Segregation of duties is intended to keep one person from controlling too much of a financial process from beginning to end. Professional internal-control frameworks recognize that complete separation may be impractical when personnel are limited and that other controls can be designed around the remaining risk. Those frameworks support the principle, but they do not impose one staffing model on every church.
There is no general GAAP rule requiring a congregation to have four different people performing four financial functions. A church may have specific requirements arising from its denomination, bylaws, state law, grant agreements, lender requirements, insurance arrangements, or other governing documents. Those requirements need to be honored when they apply. The guidance here is Church Training Center’s recommendation for designing a workable system when no more specific requirement governs the situation.
Weak controls should not be dismissed simply because the church is small. The World Christian Database’s 2026 research estimates that approximately $70 billion in Christian monies is embezzled worldwide each year. That figure is a global estimate rather than a count of reported U.S. church cases, so it should not be treated as a precise measurement of fraud in American congregations. It does, however, reinforce a broader concern already familiar to church financial leaders: access to money without meaningful oversight creates opportunity for misuse as well as ordinary error.
Follow the Money Through Four Functions
When I teach segregation of duties, I ask churches to follow a financial process through four basic functions.
Who authorizes it? Who approves the expenditure, payroll change, transfer, reimbursement, or other financial action?
Who has access to or can move the money? This includes possession of cash or checks as well as the ability to initiate payments or transfers through a bank.
Who records what happened? Who enters, changes, classifies, or maintains the transaction in the accounting records?
Who reconciles or verifies it afterward? Who compares the records with independent information and investigates differences?
Those questions are more useful than starting with titles. A person called “treasurer” may have very different responsibilities from one church to another. The same is true of a financial secretary, bookkeeper, pastor, administrator, or finance committee member.
Write down what each person can actually do. Follow an offering from collection to deposit and accounting entry. Follow an invoice from receipt to approval, payment, and recording. Follow payroll from an employee change through the bank withdrawal. Once those processes are visible, the church can see where one person controls several stages.
Find the Open Window
Some overlapping duties create more exposure than others. A bookkeeper who records transactions and also prepares the bank reconciliation presents a different situation from someone who can approve a payment, release the money, record the expense, prepare the reconciliation, and be the only person who reviews the result.
The concern increases when one person can both cause something to happen and control the records that would reveal whether it happened properly.
Suppose a treasurer receives invoices, enters them into the accounting system, and initiates payments. If someone else has already authorized the expenditures and another authorized leader can review the resulting bank activity, the treasurer’s work takes place within a larger control structure. If the treasurer can also create vendors, decide what should be paid, release the funds, change the accounting record, and provide the only financial review, far more of the process rests with one person.
Church Training Center refers to this as finding the open window. The task is to identify what a person could do incorrectly or improperly and then ask what evidence or review would expose it.
Close the Window With Another Control
A small church does not have to solve every overlap in the same way. The additional control should fit the risk created by the duties that have to remain together.
If the bookkeeper also prepares the bank reconciliation, another financially knowledgeable leader can independently review the completed reconciliation and obtain bank information without depending entirely on what the bookkeeper chooses to provide. The detailed reconciliation process deserves its own treatment, but the principle is straightforward: someone other than the preparer should be able to see whether the account was properly reconciled and whether unexplained items were resolved.
If one person performs most accounts-payable work, another authorized person might approve expenditures before payment, review unusual or significant payments, or retain control over payment release. Where one person processes payroll, someone else can review employee and pay-rate changes, unusual adjustments, the payroll register, or the resulting bank withdrawal.
Electronic banking creates similar opportunities for a second control without requiring another employee. Depending on the bank and the church’s needs, another leader might have read-only access, receive transaction alerts, or participate in authorization of selected transfers. Detailed online-banking controls belong in a separate discussion, but small churches should know that technology can create additional visibility without giving more people unrestricted access to the money.
Cash and check offerings deserve particular care because money can disappear before it ever reaches the accounting records. Church Training Center recommends more than one person be involved in handling and documenting those receipts so that an independent record exists before one individual controls the deposit or accounting entry.
None of these arrangements eliminates risk. They create another point where a mistake, unauthorized transaction, or inconsistency has a better chance of being prevented or discovered.
Two Sets of Eyes Must Mean Real Review
I frequently use the phrase two sets of eyes when discussing church financial controls. That does not mean two people must perform every task together. It means significant financial activity should not disappear inside the work of one person without meaningful independent visibility somewhere in the process.
A second signature is useful only if the signer understands what is being approved. Initialing a bank reconciliation does little if the reviewer never examines it. A finance committee receiving a packet each month has not necessarily reviewed the underlying financial activity merely because the packet appears on the agenda.
Useful review requires enough information and understanding to recognize when something needs an explanation. The reviewer should also be able to follow an exception through to resolution. A questionable payment, unexplained reconciliation item, unfamiliar bank transfer, unexpected payroll change, or other unusual activity should not be considered resolved because someone asked about it once.
Independent source information strengthens the review. When practical, a reviewer should be able to obtain a bank statement, transaction report, payroll register, count sheet, or other evidence without relying exclusively on information selected by the person whose work is under review.
Policies Have to Live in the Church
Financial policies can create the appearance of control while having little effect on what actually happens. I have encountered churches with written financial policies that the treasurer, financial secretary, staff, and even outside accounting support did not know existed. Some policies had been written years earlier and no longer reflected online banking, electronic giving, current staffing, or the church’s actual workflow.
A small church usually benefits more from a short set of understandable procedures that people follow than from an extensive policy manual that sits on a shelf. The people handling money should know who can approve expenditures, who can access accounts, what documentation must be retained, who reviews the work, and what happens when something unusual appears.
Leadership should also review the financial system regularly. Church Training Center recommends recurring financial oversight, ordinarily at least monthly, rather than leaving all financial activity with the person who processes it. The exact reports and procedures will vary, but the review needs to occur often enough that questions can still be investigated and corrected.
Documentation and cross-training serve another purpose. They reduce the church’s dependence on one person’s memory, password, files, or knowledge. If the treasurer becomes ill, resigns, moves away, or simply needs a break, the church should still be able to locate its records and understand how routine financial work is performed. Cross-training supports continuity, although it does not replace independent financial review.
Controls Protect the People Doing the Work
Churches sometimes hesitate to establish controls because they do not want a faithful volunteer to feel distrusted. Leaving one person alone with nearly every financial responsibility is not a particularly generous form of trust. It concentrates both authority and burden.
Clear approvals, independent review, reliable records, and shared access to appropriate information mean that a treasurer or bookkeeper does not have to be the sole source of evidence that everything was handled correctly. Errors can be discovered while they are still correctable. Questions can be answered from records rather than memory. Responsibility is shared rather than quietly accumulating around the person who happens to know the system best.
Return to the small church with one experienced financial volunteer. That person may still enter transactions and prepare the reconciliation because there is nobody else available to do those jobs well. The church can arrange for another leader to review the reconciliation using bank-originated information. It can require separate authorization for significant payments, provide another person with visibility into banking activity, review payroll changes, and document offerings before they reach the accounting system.
The church has not solved its staffing limitation. It has designed its financial system around that limitation instead of allowing one person’s responsibilities to become unchecked.
Sources
World Christian Database. Gina A. Zurlo, ed. Status of Global Christianity, 2026, in the Context of 1900–2075. Accessed October 5, 2026.
https://www.worldchristiandatabase.org/static/downloads/Status-of-Global-Christianity-2026.2b54be19fc0c.pdf
Committee of Sponsoring Organizations of the Treadway Commission. Internal Control—Integrated Framework. Accessed October 5, 2026.
https://www.coso.org/guidance-on-ic/pages/internal-control—integrated-framework.aspx
U.S. Government Accountability Office. Standards for Internal Control in the Federal Government. 2025 revision. Accessed October 5, 2026.
https://www.gao.gov/greenbook
Washington State Auditor’s Office. Segregation of Duties Guide, second edition, March 2026. Accessed October 5, 2026.
https://sao.wa.gov/the-audit-connection-blog/2026/download-your-copy-new-and-improved-segregation-duties-guide-today
Washington State Auditor’s Office. Best Practices for ACH Electronic Payments, updated June 2026. Accessed October 5, 2026.
https://sao.wa.gov/the-audit-connection-blog/2026/are-your-ach-internal-controls-strong-enough-protect-you-fraudsters-sao-has-new-resource-help-you
Financial Accounting Standards Board. Standards. FASB identifies the Accounting Standards Codification as the authoritative source of nongovernmental U.S. GAAP. Accessed October 5, 2026.
https://www.fasb.org/standards
The Episcopal Church. Manual of Business Methods in Church Affairs. 2023 edition. Accessed October 5, 2026.
https://www.episcopalchurch.org/wp-content/uploads/2023/03/Manual-of-Business-Methods-2023.1.pdf