Jay Cameron

Senior Director, Product Marketing, Diligent

Enterprise risk management (ERM) trends for 2026

The risk management playbook that worked for the past decade no longer applies. Chief risk officers (CROs), chief information security officers (CISOs) and chief compliance officers (CCOs) are navigating a shift in ERM trends. Risks now move faster than traditional governance processes can contain them and executives face personal liability for failures once blamed on “the organization.”

The gap between expectation and capability is stark. Only 18% of ERM leaders express high confidence in their ability to identify emerging risks, according to Gartner, while third-party involvement in breaches doubled from 15% to 30% per the Verizon 2025 Data Breach Investigations Report (DBIR).

Traditional quarterly reviews and fragmented point solutions cannot address risks that materialize in hours rather than quarters, or threats that cascade through interconnected supply chains faster than manual processes can detect. Yet, opportunity exists for organizations that view risk management as a competitive advantage rather than an administrative burden.

This article examines the critical enterprise risk management trends reshaping the field through 2026, covering:

• What enterprise risk management trends are
• How AI and automation transform risk intelligence from reactive to predictive
• Why executive accountability intensifies with personal liability for CISOs, CROs and CCOs
• The migration from fragmented point solutions to integrated GRC platforms
• How regulatory complexity demands automated compliance intelligence
• Why third-party risk requires continuous monitoring ecosystems

What are enterprise risk management trends for 2026?

Enterprise risk management trends for 2026 focus on transitioning from periodic, reactive risk processes to continuous, AI-enabled intelligence systems that address high-velocity, interconnected threats. Organizations are confronting a shift where risks materialize in hours rather than quarters, executives face personal criminal liability for failures and regulatory complexity has exceeded the capacity of manual compliance approaches.

The critical trends reshaping ERM through 2026 include AI-powered predictive intelligence, intensified executive personal liability, integrated GRC platform consolidation, automated regulatory compliance and continuous third-party risk monitoring.

Each trend below examines the current state, 2026 outlook and specific actions risk leaders should prioritize.

1. AI and automation enable predictive risk intelligence

Artificial intelligence has moved from experimental pilot to operational reality in enterprise risk management. Deloitte's 2025 Tech Value Survey shows 74% of organizations actively investing in AI/GenAI capabilities, allocating an average of 36% of digital initiative budgets to AI technologies.

For ERM professionals, this creates both opportunity and urgency — organizations are investing heavily in AI, but specific ERM applications remain underdeveloped. In fact, the IIA’s 2025 Enhanced ERM study reveals that only 6% use AI to assist in identifying risks.

The implementation gap has multiple dimensions. According to the What Directors Think 2025 report by Diligent Institute, Corporate Board Member and FTI Consulting, which surveyed over 200 public company directors, a third of directors say the biggest challenge with AI is the lack of knowledge and capabilities among their leadership team.

This skills gap ranks as the number one risk of generative AI tools — even ahead of data privacy concerns (29%) and false information (26%).

While 42% of directors see potential in AI's ability to optimize operations and enhance workforce productivity, the implementation reality lags behind strategic interest.

Directors want practical applications, with top opportunities including better data and reporting (38%) and customer service improvements (38%). Meanwhile, Deloitte's AI trends analysis identifies critical obstacles, including unclear use cases, integration challenges with legacy systems and a lack of technical expertise in AI risk management.

Despite these implementation challenges, proven use cases are emerging. Beyond the experimental phase, practical applications include:

• Automated regulatory change management
• Real-time risk identification across complex operational environments
• Predictive risk assessment using historical data and external signals

Looking toward 2026, organizations will move toward agentic AI systems capable of autonomously monitoring risks, triggering alerts and recommending remediation actions.

Deloitte's 2025 Tech Trends report indicates strategic applications include AI-driven scenario analysis and stress testing, automated risk reporting and integration of risk signals across previously siloed systems. The likely outcome? AI governance frameworks will become equally critical as regulatory scrutiny intensifies.

2. Executive accountability and personal liability intensify

The era of diffuse corporate responsibility for risk failures is over. CISOs, CROs, and CCOs now face potential criminal charges, SEC enforcement actions and personal financial liability for risk management failures.

The enforcement precedents are concrete. Recent SEC cases demonstrate a willingness to pursue individual executives with significant penalties, including

• $40,000 civil penalties and three-year industry bars for backdating pre-clearance forms
• $10,000 civil penalties and censure for backdating compliance review documents during an SEC examination

This enforcement environment is elevating risk awareness across the C-suite. The Director Confidence Index by Diligent Institute and Corporate Board Member, which surveyed 126 public company board members in May 2025, found that directors rate the current risk level for U.S. companies at 6.8 out of 10 on a scale where 1 is Negligible and 10 is Significant.

Among general counsel and compliance officers specifically, that perception is even more acute: the GC Risk Index by Diligent Institute and Corporate Board Member shows risk leaders rating the current environment at 7.4 out of 10 — a sharp increase from 5.8 in Q1 2025.

The regulatory framework creates direct personal exposure. The SEC's cybersecurity disclosure rules require public companies to disclose material cybersecurity incidents within four business days of determining materiality on Form 8-K, with executives personally certifying the accuracy.

PwC emphasizes that this timeline necessitates pre-established incident assessment frameworks and clear communication protocols. Europe's NIS2 directive and the Digital Operational Resilience Act (DORA), include provisions for personal liability if organizations fail to meet required standards, with NIS2's Article 20 making managers directly responsible for non-compliance.

Risk executives are responding with defensive strategies. Organizations are securing directors and officers (D&O) insurance with specific cyber liability coverage and implementing comprehensive audit trail capabilities to protect executives while demonstrating governance excellence.

The trajectory is clear: personal liability will continue expanding beyond CISOs to encompass CROs and CCOs more broadly, while D&O insurance premiums rise as insurers reassess risk exposures.

Given this escalating liability environment, risk leaders must take proactive protective measures.

• Document everything: maintain records of risk assessments, board briefings and resource requests
• Establish relationships with personal legal counsel separate from corporate attorneys
• Ensure employment contracts include appropriate indemnification provisions and D&O insurance coverage

3. Integrated GRC platforms replace fragmented risk visibility

Organizations are abandoning fragmented point solutions in favor of unified, integrated platforms that provide holistic visibility. The days of managing risk across nine different GRC platforms are ending.

Traditional GRC implementations suffered from a critical flaw: siloed data. Risk teams managed cyber risk in one system, compliance in another, vendor risk in a third and audit findings in yet another platform. This fragmentation created blind spots, prevented correlation of related risks and consumed enormous time consolidating data for board reporting.

The market momentum reflects urgent demand for consolidation. The global GRC software market reached $38 billion in 2024 and is projected to reach $138 billion by 2030, according to Vista Point Advisors' Q3 2024 report. This represents a 15.4% compound annual growth rate that significantly outpaces general enterprise software growth.

The efficiency gains are measurable. Integrated platforms achieve 25-50% reduction in implementation time and up to 70% reduction in maintenance overhead by eliminating custom integration development, according to the SAP CIO Trends 2025 report.

Yet the IIA Foundation study reveals 59% of organizations still rely on spreadsheets for ERM program management, with only 21% implementing dedicated GRC platforms, creating a substantial opportunity for early adopters to differentiate.

Organizations implementing unified platforms are already seeing results. "We just won a Best in Class award for our ERM program. Diligent helped us bring structure and visibility to our risk reporting—especially for our performance and accountability report," says Curtis McNeil, Architect of the Capitol.

The urgency for platform consolidation is intensifying as board expectations evolve. According to the Director Confidence Index by Diligent Institute and Corporate Board Member, 35% of directors want to make better use of AI tools for real-time data and risk analysis, while 42% seek to increase the frequency of their board's strategy and risk conversations.

The AI readiness factor accelerates consolidation urgency further. Fragmented point solutions cannot deliver the data harmonization required for effective AI deployment in risk management processes.

Organizations planning AI integration must consolidate their GRC architecture first — unified data enables the predictive analytics and automated insights that modern risk management demands.

Platform consolidation will accelerate as organizations recognize that unified risk visibility is existential rather than optional. Cloud-native, AI-powered platforms will dominate new purchases. The primary selection criterion will shift from feature completeness to integration capabilities and the quality of insights generated.

Risk leaders should conduct a candid assessment of the current GRC technology landscape. Calculate the true cost — in both dollars and time — of fragmented systems. When evaluating platforms, prioritize integration capabilities and the vendor's API ecosystem over feature checklists.

4. Regulatory complexity demands automated compliance

The regulatory environment has reached a complexity threshold that renders manual compliance approaches untenable. Tomorrow’s environment is defined by geographic fragmentation, creating both compliance challenges and competitive opportunities for organizations with sophisticated regulatory intelligence capabilities.

The scope of regulatory obligations facing enterprises is staggering. Financial institutions must simultaneously comply with Basel III, DORA, SOX, GDPR, anti-money laundering regulations, sanctions regimes, consumer protection rules and ESG disclosure requirements.

EY's 2025 Global Financial Services Regulatory Outlook identifies increased regulatory fragmentation as a defining characteristic, with diverging approaches to digital assets, AI governance, data protection and capital requirements.

Accelerated timelines compound the complexity:

• DORA requires financial entities to report major ICT incidents within four hours of classification
• NIS2 mandates breach reporting within 24 hours
• The SEC's cybersecurity rules require disclosure within four business days

The European Banking Authority's 2026 Work Programme identifies DORA implementation as a top priority, focusing on ICT risk management and third-party risk oversight, while the Federal Reserve has proposed significant stress testing policy reforms for 2026 with enhanced scenario design disclosure.

The regulatory burden is acute for legal teams specifically. According to the GC Risk Index by Diligent Institute and Corporate Board Member, which polled 71 general counsel, corporate secretaries, compliance and legal officers, 65% selected "changes in the regulatory environment" as a top risk for their company today — ranking well ahead of tariffs and other business concerns.

As one chief legal officer noted in the survey, "It's hard with the shifting landscape to know when/where the next directive or action might come from."

Organizations are responding with technology-enabled compliance strategies:

• AI-driven regulatory change management platforms continuously monitor regulatory updates across jurisdictions, automatically flag relevant changes, assess impact on existing compliance frameworks and suggest policy updates.
• Control automation reduces manual effort while providing auditors with comprehensive, timestamped records of control effectiveness.
• Cross-framework mapping allows single controls to satisfy multiple regulatory requirements, eliminating redundant work.

RegTech adoption will surge as organizations recognize that teams cannot maintain pace with regulatory change velocity. AI-driven regulatory intelligence platforms will become standard components of compliance technology stacks.

The compliance function itself will transform: rather than spending time interpreting regulations and managing spreadsheets, compliance professionals will focus on risk-based decision-making, stakeholder engagement and strategic guidance.

5. Third-party risk: The escalating crisis

The interconnected nature of business ecosystems has transformed third-party risk management from a procurement checkbox to a strategic imperative. Third-party involvement in breaches doubled from 15% to 30% in 2024 according to Verizon’s report, making vendor risk perhaps the most critical enterprise vulnerability.

Traditional third-party risk management relied on point-in-time assessments: annual questionnaires, periodic audits and static risk ratings. This approach worked when vendor relationships were stable and risks evolved slowly. That world no longer exists.

The automation gap is stark. Despite escalating third-party breach involvement, EY's 2025 Global Third-Party Risk Management Survey reveals only 13% of organizations have achieved optimized AI/automation in TPRM programs. This represents a critical vulnerability requiring immediate attention. Gartner identifies a "perfect storm" of factors driving urgency:

• Trade volatility
• Increasing cyberattack frequency
• Expanding regulatory requirements
• Supply chain disruptions

Organizations are responding with technology investments. EY's survey shows prioritization of 31% in AI/ML for enhanced due diligence, 28% in data-driven continuous monitoring and 27% in automation of due diligence processes.

These capabilities enable continuous risk scoring where AI platforms automatically adjust vendor risk scores based on real-time data including cybersecurity ratings, financial health indicators, regulatory violations, media reports and dark web intelligence.

Additionally, regulators are imposing stricter third-party oversight requirements. DORA extends regulatory oversight to third-party ICT providers serving financial institutions, granting financial regulators authority to directly supervise and audit cloud services and other critical vendors. This represents a fundamental shift from vendor risk being solely the financial institution's responsibility to regulators directly overseeing critical service providers.

The 2026 outlook is clear:

• Zero-trust architecture principles will extend to third-party access driven by the doubling of third-party breach involvement
• AI adoption will accelerate as organizations recognize competitive necessity
• Platform consolidation will favor comprehensive vendor risk management solutions that integrate with broader ERM platforms, providing unified visibility across first, third, fourth and fifth-party exposures

6. Cybersecurity governance operates under accountability mandates

The cybersecurity risk landscape for 2026 is defined by mandatory SEC disclosure requirements, unprecedented breach volumes and rising executive personal liability. The margin for delayed response has disappeared.

The breach volume tells the story. The Verizon DBIR analyzed 22,052 security incidents resulting in 12,195 confirmed data breaches — the highest number ever analyzed. Ransomware now appears in 44% of all breaches, up from 32%, while vulnerability exploitation reaches 20% of incidents. This represents material events that trigger immediate disclosure obligations.

The SEC's cybersecurity disclosure rules create direct accountability. Companies must disclose material incidents within four business days on Form 8-K, with annual Form 10-K disclosures describing board oversight processes and cybersecurity expertise. This framework transforms cybersecurity from IT operational concern to board-level governance priority with personal executive certification requirements.

Additionally, board governance requirements have become explicit. Companies must disclose which board committee oversees cybersecurity, whether board members have cybersecurity expertise and processes for informing the board about cyber risks. ISACA's guidance emphasizes that boards must acknowledge their fiduciary duty to govern cyber risks effectively — moving cybersecurity oversight from optional best practice to mandatory governance obligation.

The challenge for boards is translating technical cybersecurity risks into strategic business decisions. ISACA's cyber risk quantification framework enables translation of technical risks into financial impact metrics that boards can evaluate alongside other enterprise risks. This capability is essential: boards cannot fulfill governance obligations without understanding cyber risk in business terms rather than technical jargon.

Organizations need integrated cybersecurity risk management that connects incident response with board reporting and enterprise risk frameworks. The SEC’s four-day disclosure timeline demands:

• Pre-established assessment processes
• Clear escalation protocols
• Board-ready reporting capabilities that function under crisis conditions

7. Navigating the regulatory divergence of ESG and climate risk

The environmental, social and governance (ESG) integration landscape for 2026 is characterized by regulatory divergence between U.S. withdrawal and EU expansion, creating complex compliance requirements for global organizations.

The U.S. SEC ceased defending climate disclosure rules in March 2025, fundamentally altering the U.S. framework. Meanwhile, the European Union has strengthened ESG disclosure mandates through the Corporate Sustainability Reporting Directive (CSRD), requiring large companies and all listed companies (except micro-enterprises) to disclose ESG impacts.

Despite regional divergence, global standards are converging. The Task Force on Climate-related Financial Disclosures (TCFD) formally disbanded in October 2023, with responsibilities transferred to the IFRS Foundation. IFRS S1 and S2 standards became effective for annual reporting periods beginning January 1, 2024.

Organizations must navigate multiple frameworks:

• ISSB for investor-focused financial materiality
• GRI for stakeholder-focused impact materiality
• CSRD for EU regulatory compliance.

This multi-framework reality requires integrated ESG reporting within broader ERM frameworks rather than standalone sustainability programs.

For multinational organizations, the strategic approach is building a flexible reporting infrastructure that adapts to jurisdiction-specific requirements while maintaining consistent data collection.

8. Geopolitical risk elevates to a strategic priority

Geopolitical risk has vaulted from background consideration to primary concern for CROs globally. The World Economic Forum Global Risks Report 2025 characterizes 2025-2026 as a "geopolitical recession" — a fragmented global order with unprecedented risk interconnections.

State-based armed conflict ranks as the #1 immediate risk, alongside geoeconomic confrontation, misinformation and disinformation, and cyber espionage targeting critical infrastructure.

The economic impact is tangible: the IMF projects global growth at 3.2% – 3.1% for 2025-2026, representing a broad-based downshift attributed to trade policy shocks and geopolitical tensions, while J.P. Morgan assesses a 40% probability of recession in the United States during 2025.

These macro-economic headwinds are creating tangible boardroom anxiety. The Director Confidence Index by Diligent Institute and Corporate Board Member found that 81% of public company board members list tariffs as the top business risk today, while 46% cite supply chain and sourcing disruptions as a critical concern — both directly linked to geopolitical tensions.

As one director noted in the survey, "You can't forecast anything in this uncertain environment."

Geopolitical events create effects across multiple risk domains simultaneously. Armed conflicts trigger humanitarian crises, leading to migration pressures, while geoeconomic confrontations cascade into supply chain disruptions contributing to inflation. This risk velocity means rapid onset of policy shocks leave little time to recalibrate.

KPMG recommends enterprises "treat geopolitical risk as an asset as well as a threat" through integrated strategic risk planning, operational resilience building and adaptive capability development. Risk leaders should:

• Conduct a geopolitical risk inventory identifying concentrations in revenue, supply chain, workforce and data storage across geopolitically sensitive regions
• Develop scenario plans for plausible shocks
• Build supply chain alternatives that reduce single-country dependencies for critical inputs

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Summary table: ERM trends, outlook, and recommended governance actions

How Diligent ERM addresses 2026 risk management trends

The convergence of these eight major trends creates both challenges and competitive opportunities for organizations that invest strategically in modern risk management capabilities. For organizations managing enterprise risk management across segments, unified platforms address the velocity, complexity and interconnection challenges documented throughout this analysis.

Diligent ERM provides the integrated platform architecture required to address these interconnected risk domains effectively. The platform establishes a single source of truth for strategic and operational risk, eliminating fragmented visibility and leveraging AI to benchmark against 180,000+ real-world risks from SEC 10K reports — helping organizations stay ahead of emerging threats.

Additionally, real-time reporting through interactive dashboards, heat maps and trend lines supports the continuous monitoring approach that high-velocity risks require.

"We needed to find a solution that would allow us to do the work effectively and efficiently and automate it," says Bronwyn Jesse, Risk & Controls Manager at City of Lethbridge. "Diligent ERM helps highlight risks and emphasize where improvements are needed."

For organizations launching or scaling risk management programs, Diligent's AI Risk Essentials delivers rapid deployment with AI-powered risk identification using SEC 10-K risk data, enabling benchmarking against industry peers and streamlined risk assessments with automated workflows.

This addresses the critical gap where only few organizations currently use AI for risk identification, though many are actively investing in AI capabilities — while providing the quick-start foundation that resource-constrained teams need.

With regulatory fragmentation accelerating globally, Diligent's ACL Analytics enables automated compliance monitoring and comprehensive regulatory intelligence. Organizations can maintain consistent frameworks while adapting to jurisdiction-specific requirements across DORA, CSRD, SEC rules and emerging AI governance mandates.

Risk-informed board reporting with executive dashboards and customizable templates enables the clear communication that executive accountability trends demand.

For risk leaders preparing for 2026's convergent challenges, the question is no longer whether to consolidate ERM technology, but how quickly you can implement platforms that provide the velocity, visibility and accountability that modern risk management demands.

Ready to transform your risk management approach for 2026? Schedule a demo to see how Diligent ERM delivers the integrated platform capabilities that address emerging trends across ERM, AI governance and interconnected risk domains.

FAQs about ERM trends for 2026 and beyond

What are the biggest enterprise risk management trends for 2026?

The most significant enterprise risk management trends for 2026 include:

• AI-powered predictive risk management moving from pilot to production
• Intensified executive accountability with personal liability for CISOs and CROs
• Integrated GRC platforms replacing fragmented point solutions
• Regulatory complexity demanding automated compliance intelligence

In response to this, organizations are implementing continuous risk monitoring to address high-velocity risks that can materialize within hours, and building risk-aware cultures.

How is artificial intelligence changing enterprise risk management?

AI is fundamentally transforming ERM by enabling predictive rather than reactive risk management. Specific applications include automated regulatory change monitoring that continuously scans updates across jurisdictions and assesses impact, AI-powered vendor risk scoring and fraud detection analyzing transaction patterns to identify anomalies instantly.

The key to success is combining AI capabilities with human expertise, ensuring teams can interpret AI insights within a broader operational context rather than blindly accepting algorithmic recommendations.

What should Chief Risk Officers prioritize in 2026?

CROs should prioritize several interconnected areas in 2026:

• Accelerate AI integration across risk domains while establishing governance frameworks to manage risks the technology introduces
• Strengthen operational resilience capabilities beyond cybersecurity alone, preparing for high-velocity disruptions across cyber, third-party, geopolitical and regulatory domains
• Develop geopolitical risk intelligence capabilities with scenario planning
• Ensure personal accountability protection is adequate, including appropriate D&O insurance, clear governance documentation and access to independent legal counsel

Why is executive personal liability increasing?

Executive personal liability is increasing due to converging regulatory, legal and stakeholder pressures. Regulators are shifting from corporate fines to individual accountability, exemplified by SEC charges and criminal convictions of security executives.

Europe's NIS2 directive makes managers directly responsible for non-compliance, requiring personal cybersecurity training. Shareholders are demanding accountability following breaches that harm stock value and reputation, targeting executives with fiduciary responsibility.

Additionally, court systems are more willing to hold individuals liable for negligence or misleading statements to boards and regulators. This trend reflects recognition that without personal consequences, organizations may underinvest in risk management.

Request a demo to explore how Diligent ERM can help you address these interconnected risk domains.