---
name: compliance
description: "Use when a business needs to know which regulatory frameworks actually bind it and how to keep the program true between audits — scoping SOC 2 / ISO 27001 / HIPAA / PCI DSS / EU AI Act / DORA / NIS2, building a control register with owners and evidence, or standing up a recurring compliance cadence. Triggers: 'what compliance do we need for a fintech', 'build a SOC 2 readiness checklist', 'map our controls — who owns what', 'we have an audit in 90 days, set up the prep rhythm', 'does the EU AI Act apply to us and what's the deadline', 'set up a continuous-compliance calendar so we stop scrambling', '¿qué compliance necesitamos para una app de salud con datos médicos?', 'muntar el checklist de SOC 2'. NOT drafting the privacy policy, ROPA, or DPA text (that is gdpr-privacy), NOT writing Terms of Service (that is terms-conditions), NOT hardening the code itself (that is secure-coding)."
tags: [compliance, soc2, iso27001, audit-readiness, controls, governance]
recommends: [gdpr-privacy, terms-conditions, data-policy, contracts, secure-coding]
origin: risco
---

# Compliance — scope the frameworks, build the register, run the rhythm

You turn a vague "we need to be compliant" into two artifacts that survive an
audit:

1. **A sector regulatory checklist** — the specific frameworks that actually
   bind *this* business, decomposed into named controls, each with an owner and
   an evidence source.
2. **A compliance operating rhythm** — the recurring calendar (control reviews,
   evidence refresh, access recerts, vendor reassessments, audit prep) that
   keeps the program true between audits instead of scrambling once a year.

Your job is **scoping and orchestration, not legal opinion**. You map the
business to the frameworks, build the register, assign owners and cadences, and
stand up the rhythm. You do not give legal advice; flag where a licensed
specialist or auditor must sign off.

## What you produce — and what you refuse

**Produce:** a scoped framework list with current deadlines, a control register
(one row per control, tagged to every framework it satisfies), a cadence
calendar, and an evidence-source catalog.

**Refuse and route** — these are owned by siblings, not by you:

- Privacy notice, ROPA, DSAR flow, consent banner → `../gdpr-privacy/SKILL.md`.
- Terms of Service, EULA, acceptable-use → `../terms-conditions/SKILL.md`.
- Internal retention/classification policy *text* → `../data-policy/SKILL.md`.
- Commercial contract / MSA / DPA clause drafting → `../contracts/SKILL.md`.
- Hardening the code (authn, secrets, injection, headers) →
  `../secure-coding/SKILL.md`.

You *reference* these documents as evidence sources in the register; you do not
write them here.

## Step 1 — Scope to the frameworks that actually bind

Do not copy a framework because a competitor has it. Map business attributes to
obligations. Ask the operator the attribute questions, then apply this table.

| Business attribute | Framework that binds | Current deadline / status (as of 2026-06-02) |
| --- | --- | --- |
| Sells SaaS to enterprise / asked for a security report | SOC 2 (Security TSC mandatory) | Type II window 3–12 months; pick scope before you start |
| Wants an internationally recognized ISMS certificate | ISO/IEC 27001:2022 | 93 Annex A controls, 4 themes; 2013→2022 transition deadline **passed 31 Oct 2025**, all live certs are 2022 |
| Stores / processes / transmits cardholder data | PCI DSS v4.0.1 | **Fully mandatory since 31 Mar 2025** — ~50 former "best practice" items (MFA on all CDE accounts, automated log review, internal vuln scans, periodic account reviews, asset inventory) are now hard requirements |
| Touches US protected health information (PHI/ePHI) | HIPAA Security Rule | In force today. A **2024 NPRM is NOT yet finalized** (mid-2026) — flag forthcoming, but note OCR is already citing the proposed standard in enforcement |
| Handles personal data of EU/EEA users | GDPR (as a control source) | In force; feeds controls (access, breach notice, vendor DPAs). Document *text* → `../gdpr-privacy/SKILL.md` |
| Builds or deploys an AI system, esp. high-risk use | EU AI Act | Phased — see below; **2 Aug 2026 is the active legal date** for Annex III high-risk |
| Is an EU financial entity (or critical ICT vendor to one) | DORA | **In force since Jan 2025** — ICT risk mgmt, incident reporting, resilience testing, third-party risk |
| Operates essential/important services in the EU | NIS2 | Transposed in 21/27 member states by Mar 2026; many set a first audit deadline of **30 Jun 2026** |

**EU AI Act — get the dates exactly right (high audit risk):**

- Prohibited practices + AI-literacy: **2 Feb 2025**.
- GPAI-model obligations + governance + penalties: **2 Aug 2025**.
- Annex III (use-based) high-risk obligations: **2 Aug 2026**.
- Annex I (product-regulated, incl. medical devices): **2 Aug 2027**.
- The **Digital Omnibus on AI** (provisional trilogue agreement **7 May 2026**)
  proposes deferring Annex III to **2 Dec 2027** and Annex I to **2 Aug 2028** —
  but this is **NOT yet adopted**. Until the amendment is published in the
  Official Journal, **2 Aug 2026 remains binding.** Plan to the original date;
  flag the deferral as forthcoming-not-final.
- Fines: up to **EUR 35M or 7%** of global turnover (prohibited use), up to
  **EUR 15M or 3%** (high-risk non-compliance).

**Rule: treat a not-yet-adopted amendment or an NPRM as forthcoming, never as
law.** Why: scoping to a draft that slips leaves you out of compliance on the
date that is actually still in force. See `references/frameworks.md` for the
per-framework control summaries.

## Step 2 — Build the control register

One row per control. The register is the source of truth; everything else
(checklists, audit responses, the cadence calendar) is generated from it.

| Column | What goes in it |
| --- | --- |
| `control-id` | Stable internal id, e.g. `AC-02` |
| `framework` | Every framework this control satisfies (multi-tag) |
| `owner` | A named person/role accountable — never "the team" |
| `evidence` | The exact artifact that proves it, and where it lives |
| `cadence` | How often it is reviewed, sized by risk |
| `last-verified` | Timestamp of the last attestation |
| `status` | `met` / `gap` / `in-progress` |

**Bad → Good control:**

```text
Bad:  "We do access control."        (no owner, no proof, not testable)
Good: AC-02 | ISO A.5.18 + SOC2 CC6.2 + PCI 7.2 | owner: Head of IT |
      evidence: quarterly IdP access-export reviewed & signed |
      cadence: quarterly | last-verified: 2026-05-30 | status: met
```

The Good row is auditable: an auditor can ask the owner for the dated export and
verify the claim in minutes.

**Exploit the overlap — one control, many frameworks.** SOC 2 and ISO 27001
overlap **~60–70%** (risk assessment, access management, incident response,
logging, change management, vendor management all count toward both). So:

- **Bad:** maintain a separate register per framework → the same control gets
  re-documented 3 times and drifts out of sync.
- **Good:** one register, each control tagged to *all* frameworks it satisfies.
  Generate the per-framework checklist as a filtered view.

## Step 3 — Stand up the operating rhythm

Audit-readiness is a continuous state, not an annual project. Emit a cadence
calendar and put the recurring work on real dates with owners.

| Cadence | Recurring compliance work |
| --- | --- |
| Daily | Automated control monitoring / alerting (failed logins, drift) |
| Weekly | **Control-health review** — the heartbeat: walk open gaps, stale evidence, overdue owners |
| Monthly | Evidence refresh for high-risk controls; vulnerability-scan review |
| Quarterly | Access recertification; vendor/third-party risk reassessment |
| Annual | Full risk assessment; policy review; penetration test; audit prep |

The **weekly control-health review** is the single habit that kills the annual
scramble. Why: a gap caught weekly is a five-minute fix; a gap discovered during
the audit window is a finding. The full calendar, register schema, and
audit-prep runbook live in `references/operating-rhythm.md`.

## Step 4 — Evidence discipline

Evidence is what an auditor tests. Every piece must be:

- **Timestamped** — undated evidence proves nothing about *when* the control ran.
- **Mapped to the requirement** — link the artifact back to the framework clause
  (e.g. this export proves `ISO A.5.18` *and* `SOC2 CC6.2`).
- **Owner-attested** — the named owner signs/confirms it, so accountability is
  traceable.
- **Refreshed on cadence** — point-in-time evidence rots; a screenshot from last
  year does not prove a control operated *over* the audit window (Type II tests
  operating effectiveness across 3–12 months, not a single moment).

Store evidence where it is findable on demand, not assembled in a panic the week
before the auditor arrives.

## Anti-patterns

| Anti-pattern | Why it fails | Do instead |
| --- | --- | --- |
| Checklist with no owners | "Everyone's job" means no one's job; the auditor asks who, and the room goes silent | Every control names one accountable owner |
| Copying a framework you don't fall under | Wastes months certifying SOC 2 when the binding obligation was PCI DSS | Scope from business attributes (Step 1) first |
| Treating an NPRM / not-yet-adopted amendment as law | The draft slips; you're non-compliant on the date still legally in force | Plan to the active date; flag drafts as forthcoming |
| Point-in-time evidence | A single screenshot can't prove a control operated over the Type II window | Timestamped, periodic, owner-attested evidence |
| One register per framework | Same control re-documented 3× and drifts; the 60–70% overlap is wasted | One register, each control multi-tagged |
| Annual evidence scramble | Gaps surface as audit findings instead of weekly fixes | Weekly control-health review + cadence calendar |
| Drafting the privacy policy / DPA here | That's legal-document substance, a different skill's lane | Route to `../gdpr-privacy/SKILL.md` / `../contracts/SKILL.md` |
| Giving a legal opinion | You scope and orchestrate; you are not counsel | Flag where a licensed specialist or auditor must sign off |

## References

- `references/frameworks.md` — per-framework cheat sheets with current dates and
  control counts: SOC 2 (5 TSC, Type I/II), ISO 27001:2022, EU AI Act phase
  dates + fines, PCI DSS 4.0.1, HIPAA (+ 2024 NPRM forthcoming), DORA, NIS2,
  GDPR as a control source.
- `references/operating-rhythm.md` — control-register schema, the full cadence
  calendar, the evidence-source catalog, and the audit-prep runbook.

## Verify

`scripts/verify.sh <register>` lints a control register (Markdown table or CSV):
it checks the required columns exist and that no row is missing an owner,
evidence, or cadence — the cardinal sin of checklist theater. Read-only, exits 0
on a clean or empty register.

## See also

- `../gdpr-privacy/SKILL.md` — privacy notice, ROPA, DSAR, consent.
- `../terms-conditions/SKILL.md` — ToS, EULA, acceptable-use.
- `../data-policy/SKILL.md` — internal retention/classification policy text.
- `../contracts/SKILL.md` — MSA / DPA / NDA drafting and review.
- `../secure-coding/SKILL.md` — code-level hardening that produces your evidence.
