For SaaS companies pursuing enterprise customers, security certifications have become table stakes. But managing multiple frameworks — SOC 2, 

 and beyond — creates operational complexity that drains resources and delays revenue.

A cloud controls framework solves this challenge by establishing unified security controls that simultaneously satisfy multiple certification requirements, transforming compliance from a cost center into a competitive advantage.

The principle is straightforward: Build controls once, certify many times. When organizations design controls to satisfy the common requirements across frameworks, they eliminate duplicate documentation, consolidate evidence collection and streamline audit preparation.

Instead of treating each certification as a separate project, a unified framework captures the significant overlap between standards, enabling faster time-to-certification and sustainable compliance that scales with business growth.

This article covers everything you need to know about implementing a cloud controls framework for certification efficiency:

What a cloud controls framework is and how it differs from individual security standards

The business case for unified controls: cost savings, faster certifications and reduced audit fatigue

A step-by-step implementation roadmap for building your framework

How AI-powered compliance platforms operationalize cloud controls at scale

Frequently asked questions about cloud controls frameworks

 is a structured set of security policies, procedures and technical safeguards designed to protect data and systems in cloud environments while satisfying the requirements of multiple regulatory and certification standards.

Rather than implementing separate controls for each certification, organizations design unified controls that map to common requirements across frameworks.

When properly implemented, a single access control policy can simultaneously satisfy requirements under SOC 2, ISO 27001, 

 and HIPAA, eliminating redundant work while strengthening the overall security posture.

How cloud controls frameworks differ from security standards

Security standards like SOC 2 or ISO 27001 define what organizations must achieve. A cloud controls framework defines how organizations implement and demonstrate those requirements efficiently.

The framework serves as the operational layer that translates multiple standards into practical, testable controls.

ISO 27001 requires organizations to manage access to information assets

SOC 2 requires logical and physical access controls

NIST CSF requires identity management and access control

 consolidates these overlapping requirements into a single access management control with evidence collection that satisfies all three standards.

Common controls framework vs. cloud controls framework

While closely related, these terms serve different contexts. A common controls framework (CCF) is the broader concept: a unified approach to managing controls across any regulatory requirements.

A cloud controls framework applies this approach specifically to cloud computing environments, addressing the unique security considerations of cloud infrastructure, shared responsibility models and cloud-native services.

For SaaS companies, the cloud controls framework incorporates both the CCF methodology and cloud-specific requirements like data residency, encryption in transit and at rest, and cloud provider security configurations.

The business case for unified cloud controls

Building a cloud controls framework requires upfront investment. The return comes through accelerated certifications, reduced operational costs and strategic business benefits.

Organizations pursuing certifications separately face compounding timelines:

SOC 2 Type II usually requires 6-12 months of observation

ISO 27001 implementation typically takes 3-12 months

, PCI DSS or FedRAMP, and the cumulative timeline extends well beyond what growth-stage companies can afford.

A unified framework compresses these timelines by enabling parallel certification efforts. Controls designed for multiple frameworks simultaneously satisfy overlapping requirements. The same access review process that demonstrates SOC 2 compliance also supports ISO 27001 and HIPAA requirements.

Every certification requires evidence collection, stakeholder interviews and auditor engagement. Separate certification programs mean separate audit cycles, multiplying the burden on already stretched compliance and security teams.

A common controls framework consolidates evidence collection. When a single control satisfies multiple requirements, organizations collect evidence once and apply it across frameworks. This reduces not only the direct audit burden but also the operational disruption that comes from constant auditor engagement.

Revenue acceleration through faster security responses

Enterprise sales cycles increasingly depend on security questionnaire response speed. Buyers submit detailed security questionnaires before procurement decisions and slow responses can delay deals or lose them entirely.

Organizations with mature cloud controls frameworks can respond faster because their 

 is centralized and current. Rather than scrambling to gather evidence for each questionnaire, teams access a unified repository that maps controls to common questionnaire requirements.

Discover how unified controls management accelerates SOC 2, ISO 27001 and FedRAMP certifications while reducing audit fatigue.

Build certification-ready controls

Implementing a cloud controls framework: A six-step roadmap

Building an effective framework requires systematic planning and execution. The following roadmap guides organizations from initial assessment through continuous monitoring.

Start by mapping your regulatory landscape. Consider:

 Which certifications do customers currently request? What frameworks do contracts mandate?

 Which certifications will you need as you expand into new markets or customer segments? 

 differ from enterprise-scale programs, but building with growth in mind prevents costly rework.

 Healthcare organizations need HIPAA and potentially HITRUST. Financial services require SOX and potentially PCI DSS. Government contractors need NIST 800-171 or FedRAMP.

Then, document each framework's requirements and begin identifying overlaps.

Step 2: Map control requirements across frameworks

With frameworks identified, create a comprehensive control mapping. For each control domain (access management, data protection, incident response, etc.), document:

Specific requirements from each applicable framework

Common requirements that appear across multiple frameworks

Unique requirements specific to individual frameworks

Evidence requirements for demonstrating compliance

This mapping becomes the foundation for your unified control design. Pay particular attention to terminology differences: what SOC 2 calls "logical access controls" may overlap significantly with ISO 27001's "access control policy" requirements.

Step 3: Assess current state and identify gaps

 against your requirements map. Many organizations already have controls in place that partially satisfy framework requirements but lack formal documentation or evidence collection.

 Which requirements do current controls satisfy? Is documentation sufficient for audit purposes?

 Which requirements are partially addressed? What gaps exist?

 Which requirements have no existing controls?

Prioritize gaps based on risk and certification timeline. Controls that satisfy multiple frameworks or address significant security risks warrant immediate attention.

Step 4: Design and implement unified controls

Design controls that satisfy the most stringent applicable requirement. When SOC 2 requires access reviews every 90 days and ISO 27001 requires annual reviews, design for 90-day reviews. The more stringent control satisfies both frameworks.

 systematically, beginning with foundational controls (access management, change management, incident response) before addressing specialized requirements.

Step 5: Establish evidence collection processes

Sustainable compliance requires automated evidence collection. Manual evidence gathering is labor-intensive, error-prone and creates audit preparation crises.

Define evidence requirements for each control:

 Access logs, configuration reports, vulnerability scans

 Approved change requests, incident tickets, meeting minutes

 Policy acknowledgments, training completions, management certifications

Integrate evidence collection into operational workflows. The best evidence is a byproduct of normal operations, not a separate compliance activity.

Point-in-time audits provide limited assurance. By the time an annual audit identifies a control failure, the gap may have existed for months — creating both security risk and remediation burden. 

 shifts compliance from reactive to proactive by identifying issues as they occur rather than during audit preparation.

Effective monitoring programs combine automated control testing with real-time alerting and dashboard visibility across frameworks. Rather than scrambling to compile evidence before audits, teams maintain audit-ready documentation as a byproduct of normal operations.

Trend analysis surfaces emerging risks before they escalate, while automated testing validates that controls operate as designed without manual intervention. The result is sustainable compliance that improves security posture while reducing the operational burden on compliance teams.

How AI transforms cloud controls management

Traditional approaches to multi-framework compliance can't keep pace with expanding certification requirements and continuous monitoring expectations. By the time teams compile evidence for one audit, requirements may have shifted for another.

Manual spreadsheet-based processes create bottlenecks that delay certifications and drain resources from strategic initiatives.

AI-powered platforms are transforming this reality by enabling unified control management, automated evidence collection and real-time visibility into compliance status across frameworks.

For organizations achieving their first certifications or expanding into new frameworks, 

 provides centralized management across 75+ frameworks, including SOC 2, ISO 27001, NIST, FedRAMP and HIPAA.

The platform's Common Controls Framework capability enables teams to design controls once and automatically map them to multiple certification requirements, eliminating the duplicate documentation that historically consumes compliance team resources.

For companies expanding into public sector markets, FedRAMP-authorized options enable compliance without platform migration, including DoD IL-5 authorization for defense-related opportunities.

And for organizations that require integrated policy governance alongside IT compliance, 

 streamlines policy creation, approval and attestation workflows. Automated employee acknowledgment tracking creates defensible records demonstrating that personnel understand their compliance obligations.

Version control maintains comprehensive audit trails showing how policies evolved over time, essential for demonstrating governance maturity during customer audits and investor due diligence.

Whether you're pursuing your first SOC 2 certification or managing multi-framework compliance across global operations, the objective is to build a compliance function that accelerates revenue rather than constraining it.

Ready to simplify multi-framework compliance? 

 to see how Diligent IT Compliance helps organizations achieve certification faster while reducing audit fatigue.

Cloud controls framework: Build once, certify many times

The three lines of defense model remains one of the most widely adopted frameworks for structuring 

For large organizations managing complex regulatory requirements across multiple jurisdictions, this framework provides the clarity boards and executive teams need to assign accountability, coordinate risk activities and ensure nothing falls through the cracks.

Yet the framework has evolved significantly since its original adoption. 

 released a major update in July 2020, renaming it the "Three Lines Model" to emphasize value creation alongside protection.

This shift reflects a fundamental change in how leading organizations approach risk: moving from purely defensive postures to integrated programs that enable strategic decision-making.

For chief risk officers, chief audit executives and board members navigating this complexity, understanding how the three lines of defense in risk management works — and how to implement it effectively — is essential for building programs that protect and create value.

What the three lines of defense model is and how the IIA's 2020 update changed its focus

How each line functions and interrelates with the others

Common implementation challenges and how to address them

How AI technology supports the three lines of defense

What is the three lines of defense model?

The three lines of defense (often abbreviated as 3LOD or 3LoD) is a risk management framework that structures accountability across three distinct organizational functions. It establishes clear ownership for managing, overseeing and independently assuring risks throughout an enterprise.

The framework was formally defined by the IIA in 2013, though it had been used informally in financial services for nearly a decade prior. Industry associations, including the 

Federation of European Risk Management Associations

European Confederation of Institutes of Internal Auditing

 (ECIIA), helped promote its adoption across sectors.

Today, it serves as a foundational model for 

 (GRC) programs in organizations worldwide.

At its core, the model divides risk responsibilities into:

 Business units and operational managers who own and manage risks daily. They implement controls, execute processes and make risk-informed decisions as part of their operational responsibilities.

Second line (risk and compliance functions):

 Specialized teams including risk management, compliance, financial controls and IT security that oversee the first line's activities. They establish policies, set risk standards and monitor adherence without owning the risks themselves.

 An independent function that provides objective assurance over the effectiveness of governance, risk management and internal controls. Internal audit reports directly to the board or audit committee rather than management.

The board and executive leadership sit above these three lines, setting the organization's risk appetite, defining strategic objectives and holding all three lines accountable for their respective responsibilities.

How the IIA's Three Lines Model differs from the original 3LOD

In July 2020, the IIA released a significant update that renamed the framework as the "Three Lines Model" and introduced several conceptual shifts. The word "defense" was intentionally removed to signal that the model's purpose extends beyond protective measures.

 The updated model explicitly focuses on achieving objectives and creating value, not just protecting against downside risks. This positions risk management as a strategic enabler rather than a compliance burden.

 The 2020 update better articulates how the governing body (board) integrates with the three lines rather than simply sitting above them. Boards are accountable for organizational oversight while delegating responsibility for achieving objectives to management.

 The updated model acknowledges that first and second line roles can be blended in some organizations, particularly smaller ones where dedicated risk teams may not exist. This principles-based approach allows organizations to adapt the model to their structure.

 Perhaps most importantly, the new model emphasizes alignment, collaboration and communication across all lines. Independence doesn't mean isolation. Internal audit, while maintaining objectivity, should actively engage with management and contribute to organizational improvement.

As the IIA noted when releasing the update, risk-based decision-making is as much about seizing opportunities as defensive moves.

This philosophical shift makes the framework more relevant for organizations navigating today's dynamic risk landscape.

Benefits of the three lines of defense model

Organizations that implement the three lines framework effectively realize significant advantages over those relying on ad hoc risk management approaches. These benefits extend beyond compliance to create genuine business value.

The framework eliminates ambiguity about who owns what. When responsibilities are clearly assigned across three lines, risks are less likely to fall through the cracks. Each function understands its role, reducing both duplication of effort and dangerous blind spots.

This clarity proves especially valuable during crises. When incidents occur, organizations with established three lines of defense structures respond faster because escalation paths and decision rights are already defined.

Improved board and stakeholder confidence

 gain confidence when they see a structured risk governance framework. The model provides a common language for discussing risk management maturity with investors, regulators and auditors.

 found that while 71% of directors report regular CISO meetings with boards, only 51% have reviewed processes for incident disclosure and response. Organizations with mature three lines of defense frameworks close this gap by ensuring consistent risk communication reaches the board.

Regulatory alignment and compliance efficiency

Regulators across industries expect organizations to demonstrate structured risk governance. The three lines model aligns with regulatory expectations in financial services, healthcare and other highly regulated sectors.

Rather than building bespoke frameworks for each regulatory requirement, organizations can demonstrate how their 3LOD structure addresses multiple compliance obligations simultaneously.

Enhanced risk visibility and proactive management

When all three lines operate on integrated platforms, organizations gain comprehensive visibility into their risk posture. First line data flows to second line oversight, which informs third line assurance priorities. This integration enables proactive risk management rather than reactive firefighting.

Common challenges in implementing the three lines of defense model

Despite its widespread adoption, organizations frequently struggle to realize the model's full potential. Understanding common pitfalls helps organizations avoid implementation failures.

The most common failure occurs when the model's principles don't translate into defined accountabilities. Organizations may adopt 3LOD terminology without clearly specifying who owns what. This creates coordination challenges, broken processes and inaccurate reporting.

"One of the biggest challenges people have is communicating what they're doing in their risk management program," says Tom Faraday, Senior Director of Product Management at Diligent. Successful implementation requires documented role definitions, RACI matrices and regular reviews to ensure accountability remains clear as organizations evolve.

When the first line views risk management as "someone else's job," the entire model breaks down. This typically happens when 

 functions become so dominant that operational managers defer to them rather than owning their risks.

The first line must take accountability for managing risks, not merely implementing controls that the second line dictates. This requires investment in first line training, clear incentive alignment and leadership that reinforces ownership expectations.

Inherent tension exists between these lines. The first line naturally wants flexibility to take risks that generate returns. The second line errs toward keeping risks below tolerance thresholds. Without effective resolution mechanisms, this conflict can paralyze decision-making or create adversarial relationships.

Successful organizations address this through clear escalation paths, collaborative risk assessment processes and executive leadership that balances risk-taking with prudent oversight.

Some organizations treat internal audit as a periodic compliance exercise rather than an integrated 

 function. When the audit team operates in isolation, it cannot provide the real-time insights and advisory value the model envisions.

The IIA's 2020 update explicitly addresses this, noting that independence doesn't mean isolation. Internal audit should maintain regular interactions with management and ensure its work remains strategically relevant.

Organizations that extract maximum value from the three lines model share common characteristics. These practices distinguish high-performing 

 from those that merely check compliance boxes.

Fragmented reporting from separate risk, compliance and audit functions creates confusion rather than clarity. 

 receive conflicting narratives, making strategic decisions difficult.

"Keep it practical. Keep the ERM program practically designed and not overly complex, through the entire lifecycle of the ERM process. High, medium, low are good enough. Keep your presentations to the board simple. Demonstrate practicality throughout the entire process," advises Maurice L. Crescenzi Jr., Industry Practice Leader at Moody's.

Integrated reporting consolidates information from all three lines into unified views. This requires common risk taxonomies, consistent rating scales and technology platforms that aggregate data across functions.

Traditional quarterly risk reporting creates dangerous lag times between risk emergence and board awareness. Organizations face threats that materialize within days — cyber incidents, supply chain disruptions, regulatory actions — yet boards often receive updates months later.

Data-driven GRC platforms enable continuous monitoring that identifies emerging threats as they develop. Real-time dashboards surface issues requiring immediate attention while providing trend analysis for strategic planning.

Cyber risk illustrates how the three lines should collaborate on emerging threats. According to the 

 by Diligent Institute and Corporate Board Member, business risk has surged to 7.9 out of 10 — a 36% increase since Q1 — with legal and compliance leaders citing information security (32%) and data privacy (28%) as top organizational concerns.

In a properly structured cyber governance program:

 Owns day-to-day security operations, including patch management, access controls and incident response.

 Establishes security policies, conducts vulnerability assessments and monitors compliance with standards like NIST or ISO 27001.

 Independently assesses whether security controls are designed effectively and operating as intended.

This structure ensures comprehensive coverage while maintaining clear accountability. The board receives integrated reporting that translates technical security metrics into business risk terms.

Extend governance to AI and emerging technology

Artificial intelligence presents risk categories that traditional frameworks weren't designed to address — algorithmic bias, data privacy, intellectual property exposure and rapidly evolving regulations across jurisdictions.

"Put AI in your risk register. No one's going to argue with that. Get an AI policy. The board should be asking management for a policy," says Richard Barber, CEO of MindTech Group.

, including model development, testing and deployment. They document training data sources, validate model outputs and maintain records of AI-driven decisions that may face regulatory scrutiny.

 Compliance and ethics functions establish AI use policies, monitor for algorithmic bias and track regulatory developments. They review high-risk AI applications before deployment and ensure third-party AI tools meet organizational standards.

 Internal audit assesses whether AI governance structures actually work. This includes testing data quality controls, evaluating model documentation and verifying that AI risk disclosures align with actual practices.

The key is treating AI like any other enterprise risk — with defined ownership, consistent oversight and independent assurance — rather than allowing it to exist outside established governance structures.

Organizations should periodically assess their 3LOD maturity against industry benchmarks. Annual assessments comparing current capabilities against frameworks like 

 ERM or the IIA's standards reveal gaps and inform resource allocation decisions.

Effective assessments evaluate each line separately and collectively:

For the first line: Do operational managers understand their risk ownership?

For the second line: Are oversight functions coordinated or siloed?

For the third line: Does the internal audit team have sufficient independence and resources?

And critically: How well do the three lines communicate and collaborate?

Document assessment findings, track year-over-year progress and tie improvement initiatives to specific maturity gaps. This creates accountability and demonstrates governance sophistication to boards, regulators and external stakeholders.

Discover how unified GRC platforms eliminate silos between risk, compliance and audit functions while delivering board-ready reporting.

Strengthen your ERM coordination

Managing the coordination challenges documented above requires more than spreadsheets and siloed systems. When first, second and third line functions operate on disconnected platforms, the visibility gaps and communication breakdowns that undermine the model become inevitable.

That's why AI-powered governance technology has become essential infrastructure for organizations operationalizing the three lines framework.

 provides unified governance, risk and compliance management that connects all three lines on shared data and workflows. Rather than maintaining separate risk registers, compliance tracking systems and audit workpapers, organizations access consolidated views of their risk posture.

 strengthens second line oversight through AI-powered risk identification that benchmarks against 180,000+ real-world risks from SEC 10K reports. Moody's credit sentiment scores and external risk intelligence surface emerging threats before they escalate.

Real-time dashboards and heat maps translate complex risk data into board-ready reporting, addressing the communication challenges that plague traditional ERM programs.

Three lines of defense in risk management: A framework for enterprise governance

This article originally appeared in our December 18th edition of the Diligent Minute Newsletter. For more insights like these, delivered straight to your inbox, subscribe 

As we close out 2025, I’ve been reflecting on what this year taught us and the word that comes to mind is “unprecedented.” Insights from the Diligent Institute’s research show how directors navigated multiple unprecedented challenges – often simultaneously – while also driving major change. The lessons we learned this year aren’t just a look back. They can be a compass pointing to the directional shifts boards will need to embrace as governance moves into a faster, more AI-enabled era.

Five governance shifts boards must prepare for in 2026

What will change: Boards will move beyond passive reporting and lean into more 

 Predictive analytics and scenario planning will become part of everyday conversations, helping directors navigate volatility before it hits.


Why? Director confidence hit historic lows in 2025. Our 

 conducted in partnership with Corporate Board Member, landed at just 4.8 out of 10, among the lowest since the pandemic. That’s a wake-up call for faster, smarter decision-making. If you’re curious whether sentiment is shifting, our Q4 results will be live by the time this issue hits your inbox. Check them out to see if optimism is making a comeback.

What will change: Dashboards won’t just summarize risks. They’ll surface them within hours, and crisis protocols will kick in during the first 72. AI-powered assurance will scan massive datasets to catch anomalies as they happen, and directors will be able to ask complex questions in plain language and get instant answers. Oversight will move from reacting after the fact to staying ahead of the curve, a fundamental change in risk management.

 7.9 out of 10. Quarterly updates aren’t enough anymore. Boards need early-warning systems and integrated intelligence to keep pace.

3) AI governance moves to the top of the agenda

What will change: Agentic AI is moving fast, from assisting to acting. Boards will need to build AI literacy, test for bias and keep humans in the loop to manage less visible risks.

Why: Two-thirds of directors used AI tools in 2025, but 

, 57% of respondents said their organizations had deployed AI in one or more areas of the business, but only 36% had audited usage.As AI deployment climbs higher on the priority list for 2026, closing this governance gap is critical.

4) Integration becomes a growth essential

What will change: M&A ambitions will stall without tech integration. Boards that prioritize scalable platforms will unlock faster, cleaner transactions and reduce risk during rapid growth periods as integration readiness becomes a board-level KPI.

 conducted in partnership with Wilson Sonsini and NetSuite, found only 4% of organizations had fully integrated GRC and financial systems.

What will change: Board agendas will shift toward forward-looking conversations powered by predictive analytics and cultural insights. Directors will widen their lens beyond financials to include culture and workforce resilience, using anonymized data to spot risks before they surface.

Why: The ability to anticipate, not just react, will define effective governance in 2026. Boards that lean on AI-driven scenario modeling and continuous feedback loops will stay aligned with fast-changing realities.

Diligent

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Cloud controls framework: Build once, certify many times

Three lines of defense in risk management: A framework for enterprise governance

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