Stick to the status quo

Continue to monitor your controls performance as you currently are. No upfront costs - but leaders face the ever-worsening scenario of manual data correlation and analysis, plus the added risk of missing hidden control gaps or failing audit and compliance checks.

  • No up-front-cost
  • Overly reliant on inaccurate or incomplete data for assurance purposes
  • Manual, time-consuming audit and reporting processes
  • Risk of "false green" aggregated reporting that may look reassuring on the surface but mask data-quality issues, incomplete coverage, or stale feeds from existing tools
  • Unsuitable for regulatory and executive oversight requirements

Buyer's checklist

Why continuing without a controls monitoring program in place is a risk

Continue to manage your controls assurance as you do currently, manually reviewing effectiveness and performance when and where possible.

Audits will remain time-consuming and involve around 1.5 weeks per month of data collection, correlation and analysis. The data you get will almost always be out of date by the time any information reaches its intended audience of executives or external regulators.

With DORA now in force and NIS2 fully applicable, this option is increasingly untenable for regulated entities. Both regulations explicitly require continuous monitoring — not periodic review. Staying with the status quo is not cost-free; it is the acceptance of growing regulatory, legal, and operational risk.

Pros

  • No-up front cost ƒ
  • No additional immediate resource required within three to six months

Cons

  • Leaves business open to control gaps and failures ƒ
  • Regulatory audits remain extremely time consuming
  • Structurally non-compliant with DORA, NIS2, and SEC continuous monitoring requirementsƒ
  • Audit and compliance responses don’t stand up to scrutiny ƒ
  • Lengthy process to provide assurances or report to board ƒ
  • Lack of certainty in overall security reporting and data

Panaseer recommendation

Staying with the current approach may have been viable in the very short-term just two years ago, but in 2026, it is a regulatory liability. DORA explicitly mandates continuous monitoring of ICT systems — not annual audits. NIS2 requires evidence-based compliance monitoring across 18 sectors. Getting ahead of this now will pay dividends. Use CCM principles to guide your automation approach and build the foundation before the regulator comes asking for evidence you don't have.

Excel and ad hoc documentation

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