Why Use Standard Agnostic Controls in Your Compliance Program

Implementing a robust compliance program is one of the most complex and resource-intensive initiatives an organization can undertake. Ensuring that every task, especially control implementation, is effective requires more than just expertise; it requires a strategic and scalable approach to compliance architecture.

One such approach involves standard-agnostic controls. These are controls designed to satisfy requirements from multiple frameworks and standards. By decoupling your controls from individual standards, you can significantly streamline governance, risk, and compliance (GRC) controls efforts.

What Are Standard-Agnostic Controls?

Before diving deeper, it’s important to understand the distinction between requirements and controls in a compliance context:

• Requirement: A specific action or condition mandated by a standard or regulation that an organization must meet.

• Control: A process, procedure, or mechanism used to meet one or more compliance requirements. Standard-agnostic controls are designed to be flexible enough to satisfy multiple requirements across various frameworks.

In short, standard controls in GRC serve as the building blocks of your compliance efforts—but designing them to be standard-agnostic makes them more versatile, scalable, and easier to maintain.

The Case for Standard-Agnostic Controls

Every organization is unique. Regulatory frameworks like ISO 27001, PCI DSS, SOC 2, and NIST CSF were developed with diverse industries, geographies, and organizational sizes in mind. Despite their differences, many of these standards share common requirements around topics such as:

• Access management

• Data security

• Risk assessment

• Incident response

• Business continuity

Instead of building and managing duplicate controls for each framework, you can design controls once and apply them across multiple standards.

Example: ISO 27001 and PCI DSS

Consider the example of an information security policy:

• ISO 27001 Requirement: A.5 — "Information security policies"

• PCI DSS Requirement: 12 — "Maintain a policy that addresses information security for all personnel"

If your organization creates a robust, well-documented information security policy, it can be mapped to fulfill both of these requirements—as long as the control is designed with agnosticism in mind.

Benefits of Using Standard-Agnostic GRC Controls

Implementing standard-agnostic controls within your GRC framework offers several strategic benefits:

1. Efficiency and Cost Reduction

Reduces duplication of effort by allowing teams to focus on developing controls that meet multiple standards simultaneously.

2. Consistency Across the Organization

Standardized, cross-functional controls help enforce consistent processes, reporting, and enforcement.

3. Simplified Audits

Auditors can easily trace controls to multiple compliance requirements, improving transparency and reducing audit preparation time.

4. Future-Proofing Your Program

As your compliance needs evolve—due to regulatory changes or business expansion—you can adapt your existing controls more easily to new frameworks.

Framework Mapping: A Real-World Example

Below is a high-level mapping of the 12 PCI DSS requirements to ISO/IEC 27001:2013 clauses, courtesy of ISACA:

As this diagram illustrates, there is considerable overlap between PCI DSS a payments industry-specific standard, and ISO 27001 a global information security standard. This overlap reinforces the value of designing GRC controls that are not bound to any single standard.

How COBIT, ISO, and ITIL Intersect

The diagram below (from COBIT 5) highlights the relationships and complementary nature of various frameworks and standards.

While ISO 27001 focuses on information security, other standards such as ISO 20000 (IT Service Management), ISO 22301 (Business Continuity), and ITIL also contain overlapping requirements. By implementing standard controls in GRC that cover shared principles like availability, confidentiality, and integrity, your organization can build a more resilient compliance architecture.

Final Thoughts: Building Smarter GRC Programs with Standard-Agnostic Controls

The more your organization matures, the more compliance frameworks it is likely to adopt. Without a strategy for unifying controls across those standards, the complexity and cost of your GRC program can spiral.

Using standard-agnostic controls helps you:

• Reduce operational complexity

• Strengthen compliance posture

• Accelerate implementation timelines

• Improve collaboration across departments

Whether you're managing cybersecurity, privacy, or operational risks, designing flexible GRC controls from the start empowers your organization to meet today’s requirements and scale for tomorrow’s.