CHAPTER 11: GRC Strategy and Maturity

TL;DR – Key Takeaways from Chapter 11

i. GRC maturity is uneven by design
Different domains mature at different speeds; strategy should reflect reality, not force uniformity.
ii. Progress comes from shared objects and loops
Consistent data and repeatable workflows matter more than advanced tooling.
iii. Maturity models should guide focus, not score teams
The value is prioritisation and direction, not benchmarking for its own sake.
iv. Strategy emerges when GRC informs decisions
A mature programme shapes investment, trade-offs, and direction, not just reporting.

A maturity model is not a scorecard for marketing or an excuse to add complexity.

It should help you:

1. Describe your current state in language stakeholders recognize
2. Agree the next sensible step, not an ideal end state you cannot reach
3. Make trade-offs clear: where you will standardize, automate, or invest next
4. Keep tooling, process, and people changes aligned over time
5. Tie improvements back to the program loop (design, implement, improve) and the execution loop (intake, execute, record)

The model below is designed to match what we see in real organizations, not a perfect linear journey. Some teams start in the middle. Others are advanced in one domain and basic in another.

You can think of GRC maturity in seven broad stages:

1. Manual and disjointed
2. Standardized and documented
3. Selective automation
4. Continuous assurance
5. Defined GRC
6. Strategy and resilience
7. Led by intelligence

You do not need to use these labels verbatim in your organization, but the patterns they describe are useful when planning.

Most organizations don’t move neatly through A → B → C → D → E. It is more like completing a jigsaw puzzle:

1. You start by finding the edges: the shared objects, roles, and basic lifecycles
2. Then you build floating islands where the pressure is highest (for example, cyber or TPRM)
3. Over time, those islands connect as services, risks, controls, vendors, and evidence are brought into the same picture

The maturity model needs to allow for that variation. It is normal for some domains to be at Stage 2 while others are at Stage 4 or 5.

Typical signs:

1. Risks, controls, issues, and vendors are managed in separate spreadsheets and inboxes
2. Each domain (cyber, compliance, audit, privacy, TPRM) has its own way of working
3. Reporting is reactive and labor-intensive; data is rarely trusted or reused

Your focus here:

1. Establish the common objects and language from GRC Fundamentals
2. Introduce the idea of program and execution loops, even if still manual
3. Consolidate at least one key list (for example, services, risks, or vendors) into a shared view
4. Begin capturing issues and actions in one place

At this stage, success is simply “one version of the basics” instead of many.

Typical signs:

1. Core processes (risk assessments, policy approvals, vendor onboarding) are documented
2. A basic internal control framework exists, even if it’s still rough
3. There is some alignment on risk scales and definitions

Your focus here:

1. Tighten and rationalize the internal control framework so it reflects how you actually operate
2. Standardize a small set of lifecycles (for example, risk, TPRM, incidents, regulatory change) using the shared model
3. Agree simple, scenario-based risk descriptions and consistent scales
4. Start moving high-friction workflows into a GRC platform to avoid duplication

The goal is to move from “every team does it differently” to “we do it the same way, even if still manual.”

Typical signs:

1. Key workflows are in a GRC platform, but many processes remain manual
2. Some evidence and assessments are captured in structured forms
3. Reporting is easier but still requires manual clean-up and interpretation

Your focus here:

1. Use automation and AI where it removes the most friction in the execution loop (document intake, mapping, reminders, routing), while keeping humans in control of judgments in the program loop
2. Strengthen the issues and actions register as the single source of truth for remediation across risk, compliance, cyber, TPRM, privacy, and audit
3. Make sure data structures in the platform mirror the model in this guide:
1. Services and processes
2. Entities and regions
3. Risks and scenarios
4. Obligations and controls
5. Vendors and engagements
6. Issues, actions, and evidence

At this stage, the priority is to remove repetitive admin, not to automate decisions.

Typical signs:

1. Control testing and assurance are planned with a multi-year view
2. There is a visible link between top risks, key controls, and assurance coverage
3. Some technical signals are used to monitor control health between audits

Your focus here:

1. Tighten integration between internal audit, second-line assurance, and operational testing, using the shared issues and actions backbone
2. Expand continuous control monitoring concepts where they make sense, especially for technical and configuration-based controls
3. Make sure findings from all forms of assurance feed into the same data model and are traceable to:
1. Service(s) affected
2. Risk scenarios and top risks
3. Controls and obligations
4. Vendors and engagements where relevant

Continuous assurance at this stage means “steady, predictable feedback loops,” not real-time automation everywhere.

Typical signs:

1. GRC is recognised as a shared capability, not just a collection of projects
   
   
2. Roles and responsibilities across the business, GRC specialists, leadership, and assurance are clear and widely understood
   
   
3. The GRC platform is used consistently across key domains

Your focus here:

1. Align GRC strategy with business objectives and risk appetite, not just regulatory demands
2. Use the maturity model to plan improvements by domain (for example, moving TPRM from Stage 2 to 3 while enterprise risk moves from 3 to 4)
3. Start measuring outcomes in terms of risk, resilience, and trust, not just activity counts (number of assessments, policies, or findings)
4. Use the shared objects and lifecycles as the default way to design new processes and integrate new tools

At this stage, the conversation shifts from “what are we doing?” to “is it making a difference?”

Typical signs:

1. Top risks, resilience themes, and investment decisions are clearly linked
2. Third-party, cyber, privacy, and continuity work is coordinated around critical services
3. GRC is part of strategic planning, M&A, and major transformation programs

Your focus here:

1. Use your GRC data (scenarios, incidents, issues, metrics) to shape strategic choices:
1. Where to expand
2. Where to partner or outsource
3. Where to simplify or exit
2. Embed risk and resilience thinking in product, change, and procurement processes from the start
3. Develop playbooks for major shocks that draw on the full program:
1. Risk and enterprise top risks
2. Continuity and crisis management
3. Security and privacy
4. Third parties and supply chain
5. Communications and stakeholders

Here, GRC becomes a way to test and refine strategy, not just report on it.

Typical signs:

1. Data from across GRC and security is used to forecast and simulate risk under different conditions
2. Targeted AI assistance helps summarize, prioritize, and route work, while humans own judgments and approvals
3. Leadership uses GRC insights as part of regular performance and strategy discussions

Your focus here:

1. Strengthen data quality and shared models so analytics and AI have something solid to work on:
1. Clean, linked objects (services, risks, controls, vendors, evidence)
2. Clear ownership and lifecycle states
2. Introduce agentic patterns carefully for administrative and triage tasks with clear guardrails, approvals, and auditability
3. Keep governance, transparency, and human oversight central as you scale intelligent assistance

Not every organization needs to reach this stage in every domain. The goal is to know where this approach would genuinely add value and where simpler methods are enough.

Few programs move cleanly from Stage 1 to Stage 7. In practice:

1. Cyber may be at Stage 4 while TPRM is at Stage 2
2. Privacy might be strong on documentation (Stage 2–3) but weak on integration with enterprise risk
3. Some regions or entities may have more advanced practices than others

You can use the maturity model:

1. Per domain (cyber, TPRM, privacy, enterprise risk, internal audit)
2. Per region or business unit
3. For the overall GRC program

What matters is that you know where you are, what the next step looks like, and how it plays through the program and execution loops—not that you score highly in every box.

This chapter pulls together themes from the rest of the guide:

1. Use Risk Management Excellence and Enterprise and Operational Risk to shape top-risk and appetite discussions at each stage.
2. Use Compliance and Internal Control Framework and Regulatory Change Management to define what “good enough” looks like for obligations and controls as you mature.
3. Use Cyber Risk and Resilience, Third-Party Risk Management, and Data Privacy and Protection to understand how domain capabilities move through the stages at different speeds.
4. Use Internal Audit Integration to align assurance work, themes, and findings with maturity goals rather than treating audits as separate events.

Handled this way, the maturity model becomes a navigation tool for the whole guide.

To use this maturity model in your own program:

1. Run a simple self-assessment across a few domains using the stage descriptions
2. Validate the assessment with a small group of stakeholders from the first, second, and third line
3. Agree one or two improvements per domain for the next 12–18 months, rather than trying to move everything at once
4. Make sure each improvement clearly links back to:
1. Shared objects (services, risks, controls, vendors, evidence)
2. The program and execution loops
3. Outcomes you can explain in terms of risk, resilience, and trust
5. Use your GRC platform to track maturity-related actions and metrics alongside day-to-day work

Handled this way, GRC maturity becomes a tool for focus and alignment, not just a slide in a board pack.

Continue to Chapter 12 - Glossary of GRC Terms