Beyond the Checkbox: How Maturity Models Strengthen Compliance Resilience

Most compliance teams in regulated industries aren’t starting from scratch — but that doesn’t mean everything’s straightforward. Some obligations are obvious. Others aren’t. Even when the rules are known, the details get messy: overlapping standards, conflicting interpretations, and reliance on tools like spreadsheets that lack shared visibility.

Even when programs seem to be running smoothly, uncertainty lingers. A breach, unanticipated audit findings, or regulatory incident can shift priorities overnight — exposing gaps in oversight, documentation, or response. When your program lives in spreadsheets, emails, and shared drives, how easily can you answer questions like:

• Are we tracking the right details?
• Are we duplicating work across teams?
• Are we improving, or just keeping up?
• Are we exposed to risk from new or emerging changes?

These challenges surface weekly — from attestations or a disruptive incident. But without strong structure, teams stay reactive. Without clear ownership, planning turns into guesswork. And when it’s time to show progress, the answers aren’t always easy to find.

That’s where a maturity model helps — not as a score, but as a strategic tool. It shows where the program stands, where the friction is, and what’s realistic to do next based on current capabilities, team structure, and level of risk.

What mature compliance programs actually look like

A mature compliance program doesn’t mean every process is highly complex or every control is fully automated. It means the fundamentals are clear, obligations are documented, ownership is defined, and accountability is built into how the work gets done. As a business, what do we need to be concerned about from a regulatory perspective?

• Who is accountable for what?
• Are we operating in compliance?
• Where are our gaps?
• Do we have the information readily available to answer key questions from regulators, executives, or the board?
• What compliance risks could disrupt the way we do business?

Good programs can answer those questions without a scramble. Each obligation is mapped to the right policies and controls. Owners understand what’s expected of them and when. A risk-

based testing program is in place, and evidence is easy to find when regulators or leadership ask for it.

Mature programs don’t move faster because they have more people; they move smarter because everyone knows where they stand. They respond to regulatory shifts without derailing what’s already in place — because the core structure is stable, and the team knows what to adjust.

Maturity evolves across each process area — from listing obligations to mapping controls, assigning owners, and managing risk. A team might be advanced in tracking regulatory changes but still maturing in how they assess control effectiveness.

For example:

• Obligations may start with a static list but mature into a dynamic register supported by horizon-scanning tools and automated updates.
• Ownership may begin at a high level but become more granular and role-specific as the program matures.
• Risk practices can evolve from simple assessments to aggregated models that support consistent decision-making.

Testing may start informally — or not at all — but as programs mature, it becomes more structured and deliberate, often evolving into audit routines and automated reviews informed by risk indicators.

The 4 stages of building a stronger compliance program

Compliance programs rarely start from a blank slate. Most build maturity in response to pressure — a new regulation, a missed audit, or a board question no one was prepared to answer.

But what matters is what happens next. Can your team connect the dots between obligations, controls, and how those requirements impact different areas of the business? Can they explain what’s working, what’s overdue, and what still needs attention? That’s what separates reactive programs from ones that are built to last.

These stages show how maturity builds in layers — not all at once, but through iterations that strengthen structure, accountability, and insight. And that maturity doesn’t always follow a straight line. Teams may advance quickly in one phase, like regulatory tracking, but lag in others like testing or ownership.

Maturity models reflect real what real programs look like: sometimes inconsistent, often evolving. Some teams use them to plan what to fix. Others use them to show progress or make the case for more support. They help teams focus effort, allocate resources, and make better decisions with what they already have.

It’s also worth identifying where the program lacks structure or visibility and where integrated

insights from risk, audit, or compliance functions can accelerate progress.

No matter where you start, each phase offers a chance to deepen visibility, reinforce accountability, and reduce uncertainty — not just for compliance, but across the business.

Stage 1: Identifying obligations

Every strong compliance program starts with one question: What are we actually responsible for? That sounds simple, but it's where a lot of teams hit pause. Without a shared, reliable record of your obligations, everything else risks being reactive.

At early maturity, that might mean knowing your regulators and having a basic list of obligations. More advanced teams go further — with structured obligation registers, automated updates, alerts for changes, and horizon scanning tools to anticipate what’s coming.

Start with the obligations that drive filings, audits, or questions from leadership, and the ones that pose the biggest risk to your organization. Ownership is foundational. Early-stage programs often know what’s required but haven’t assigned accountability. As maturity builds, organizations move from broad responsibility to role-specific ownership — ensuring each obligation is not just tracked, but actively managed. When ownership is defined up front, it becomes easier to maintain consistency and drive accountability across the business.

Most teams use Excel to get started because it’s flexible and fast. The focus here is getting to a place where the team has a centralized, living source of truth, where the team can confidently answer:

• What regulations apply to us?
• Are we equipped to keep the list current and accurate as things change?
• Who is responsible for maintaining the obligations inventory?
• How are we informing the business of regulatory changes that could impact operations or cause disruption?

At higher maturity, compliance proactively assesses the impact of regulatory shifts, engages relevant business functions, and ensures upcoming changes are addressed before they become issues.

Stage 2: Connecting obligations to practice

Once your obligations are documented, the next step is enabling the business to recognize which requirements apply to their function — and take clear accountability for meeting them. From there, controls are tied to those activities, documented, and assigned to the right roles.

Controls turn compliance requirements into business actions. They’re often linked to documented policies, procedures, and best practices that show how obligations are met. At

early maturity, they may be informal or inconsistent. As programs grow, controls become clearer, owned, and integrated — not just for audits, but to help the business operate within its risk tolerance.

At a foundational level, that might mean knowing which teams own which high-level topics or regulatory themes. As maturity builds, ownership becomes more granular — tied to roles, not individuals — and risk alignment sharpens.

Controls are where compliance turns into action. Once the business understands what’s required, controls and policies show how those requirements are met. At lower maturity, controls may exist but lack documentation or clear owners. More advanced programs evaluate controls not just for existence, but for effectiveness — asking whether they’re fit for purpose, consistently followed, and aligned to actual business operations.

Compliance’s role isn’t to enforce execution, but to enable it by informing teams of their obligations, highlighting gaps, and flagging regulatory changes that may impact operations.

As teams begin evaluating how obligations are fulfilled, early patterns emerge — like outdated policies, control gaps, or reliance on undocumented practices. These signs create the foundation for formal testing and deeper insight later on.

A more mature program doesn’t just document what’s happening — it evaluates how each control addresses the obligation. Is there a clear “who, what, where, when, and how”? Is ownership tied to a role, not a person? Does the process reflect reality — and can it be repeated under pressure?

You don’t need a perfect program. You need a defensible one — where controls reflect actual practices, ownership is established, and processes are consistent and repeatable.

Stage 3: From self-assessments to risk insight

Once your program is mapped, the next step is testing how well it holds up. That means looking at controls and asking: Are they working? Are they still the right fit? What’s missing?

Self-assessments are often the starting point. They help teams flag outdated controls, missing documentation, or places where processes rely too heavily on memory.

As programs evolve, teams implement key risk indicators (KRIs), key control indicators (KCIs), and automate evidence collection to get a clearer, real-time view of performance. Some use basic checklists; others rely on aggregated risk models to guide decisions.

The goal isn’t to catch everything — it’s to build a habit of looking. Risk doesn’t always live where expected. Past incidents or close calls often reveal blind spots that standard testing can miss — making them valuable inputs for assessing where controls or oversight need to improve. By reviewing how compliance actually works across the business, you spot gaps before they turn into issues — and prioritize the areas that need attention or investment.

You’re ready to move forward when your team isn’t just listing controls — you’re evaluating their design, testing performance, and seeing where the risk really lies. With structured testing approach in place, reporting becomes a key tool for communicating readiness, highlighting risk, and demonstrating progress to stakeholders.

Stage 4: Testing, automation, and insights

Once structured testing is in place, Teams expand it through automation, internal audit, and risk-based prioritization, shifting from manual checks to scalable assurance. Testing maturity varies. Some teams skip it entirely, while others rely on internal audit or structured routines. Either way, the goal is the same: validate that what’s been documented and self-assessed

reflects how the business actually operates. Testing helps teams move from assumption to evidence.

More advanced teams use best practices audit, automation, and risk indicators to flag areas outside of tolerance — not just check a box. Automation streamlines testing, flags overdue reviews, and reduces manual evidence collection — so the team can focus on higher-risk areas. It also simplifies reporting, surfacing key trends, exceptions, and risk concentrations automatically, so teams can provide leadership and regulators with timely, consistent updates.

At this stage, testing becomes smarter — using real-time risk signals to prioritize reviews and highlight exceptions that actually matter. Risk events, breaches, or escalations can trigger additional review cycles or risk assessments — reinforcing that real-world disruptions should directly shape how testing is prioritized.

AI adds clarity. It suggests test scripts, spots control gaps, and surfaces trends across assessments. It shifts focus from chasing data to acting on insight.

You’ll know this stage is taking hold when testing is risk-driven, automation cuts busywork, and your program offers insight, not just answers. That’s when you move from managing tasks to managing risk.

How AI can support every stage of maturity

AI isn’t reserved for mature programs or big budgets — you don’t need to earn your way into using it. When you’re building the foundation, AI helps reduce the time spent researching rules. It flags what applies based on industry, scans for updates, and tracks changes in one place.

It can help evaluate existing controls, suggest test scripts, flag weak points, and highlight recurring issues. By connecting data across assessments, AI helps identify patterns in risk and control performance, and points out where the program needs to shift. You get more time to focus on analysis instead of administration.

AI helps reduce manual effort and focus resources where they’re needed most, whether you’re building structure or refining performance.

How maturity models simplify compliance programs

Most teams don’t get the chance to pause and rebuild the program. Regulations change. New risks pop up, leadership priorities shift. Teams are often expected to mature without more time, people, or tools. Compliance maturity doesn’t happen all at once. Progress comes in phases, building structure, reinforcing accountability, and focusing on what matters most.

A maturity model doesn’t fix all of that. But it does give you a clear picture of where things stand, what’s already working, what’s behind, and where the gaps are. It keeps the team focused — even when resources are tight.

The goal isn’t to chase perfection. It’s being able to point to the right things at the right time through clear ownership, documentation, and follow-through. Reporting becomes the mechanism that ties those elements together, surfacing what's working, where attention is needed, and how the program is evolving.

Mature programs don’t just execute well; they communicate clearly — using reporting to surface trends, demonstrate accountability, and support strategic decisions. That’s the real value: giving your team direction based on what’s working, not judgment for what’s not. When you’re ready to bring in more structure, Resolver’s GRC Suite helps you build on what’s already working, without adding complexity. You don’t need to start over. You just need a clear next step that fits how your team works today.