How to Plan and Implement a GRC Program: A Step-by-Step Guide for GRC Professionals
Cyber threats are increasing, regulatory frameworks are tightening, and corporate accountability is under a global microscope. In 2024 alone, the average cost of non-compliance reached $14.8 million—a 45% increase over the past five years—according to a Ponemon Institute study. Simultaneously, Gartner reports that 70% of organizations have experienced at least one third-party risk incident in the past year that disrupted operations or led to compliance breaches.
From the implementation of the EU’s Digital Operational Resilience Act (DORA) to the SEC’s new cyber disclosure rules, today’s GRC landscape is evolving faster than ever. Boards and executive teams are no longer asking if a Governance, Risk, and Compliance (GRC) program is needed—they’re asking how quickly it can be implemented, and how mature it is.
In this environment, a well-designed GRC program isn’t just a check-the-box exercise; it’s a business enabler. It equips organizations to anticipate risk, comply with regulatory mandates, foster ethical behavior, and respond with agility in the face of disruption.
This post offers an eight-step roadmap to help you plan, build, and operationalize a GRC program that aligns with your organization’s goals—and positions it for long-term resilience and success.
Step 1: Assess Organizational Needs and Objectives
Begin with a thorough assessment of your organization’s strategic goals, regulatory obligations, and risk landscape.
This includes:
Identifying applicable legal and regulatory frameworks
Reviewing internal policies, industry standards, and contractual requirements
Understanding operational vulnerabilities and business-specific risks
Engage key stakeholders—executive leadership, risk owners, compliance officers, and department heads—to ensure alignment across all business functions.
Step 2: Define the Scope and Key Components
Define the scope of your GRC program based on the assessment. This includes specifying:
Core focus areas (e.g., regulatory compliance, risk management, internal controls)
Essential components such as policy frameworks, risk assessment methodologies, issue tracking, and reporting mechanisms
Ensure all components align with organizational structure and are scalable across departments.
Step 3: Establish Governance and Accountability
Strong governance is the backbone of any GRC program.
Establish a framework that clearly defines:
Roles and responsibilities across leadership and functional units
A designated GRC program owner or team
Decision-making protocols and escalation paths
Executive sponsorship is critical. Leaders must champion the initiative and foster a culture of accountability throughout the enterprise.
Step 4: Develop and Formalize Policies and Procedures
Develop comprehensive policies and procedures that serve as the foundation for GRC activities.
These should:
Be aligned with regulatory requirements and industry best practices
Cover areas such as data privacy, third-party risk, incident response, and internal audits
Be accessible and regularly updated to reflect changes in law or operations
Provide targeted training to ensure all employees understand their roles in supporting these policies.
Step 5: Implement Risk Assessment and Mitigation Strategies
Conduct regular enterprise-wide risk assessments to:
Identify and prioritize risks by impact and likelihood
Map risks to internal controls and business objectives
Define mitigation plans with clear owners, actions, and timelines
Integrate risk management into day-to-day operations and review mitigation strategies routinely to remain agile in the face of new threats.
Step 6: Establish Monitoring and Reporting Mechanisms
Create a compliance monitoring and reporting framework to:
Track adherence to regulatory and internal requirements
Measure performance using key risk indicators (KRIs) and key performance indicators (KPIs)
Conduct periodic audits and maturity assessments
Use dashboards and reports to provide transparency and inform strategic decisions at all levels of the organization.
Step 7: Promote Training and Awareness
Continuous training reinforces a culture of compliance and risk ownership.
Establish programs that:
Educate all employees on GRC principles, policies, and expected behaviors
Offer role-based training for high-risk functions
Use regular communications to highlight updates, lessons learned, and compliance success stories
A strong awareness culture reduces the risk of human error and improves policy adherence.
Step 8: Evaluate and Continuously Improve the Program
A successful GRC program evolves with the organization. Establish a review cadence to:
Analyze GRC performance through internal assessments and stakeholder feedback
Reassess risk appetite and control effectiveness
Identify and act on opportunities for process optimization and automation
Promote a mindset of continuous improvement to ensure long-term relevance and impact.
Conclusion
Implementing a GRC program is a strategic endeavor that requires intentional planning, broad stakeholder engagement, and continuous oversight. By following a structured approach, organizations can create a resilient GRC framework that not only ensures compliance but also enhances decision-making, builds trust, and supports long-term business objectives.
Whether you are launching a new GRC initiative or refining an existing one, this step-by-step guide serves as a foundation for building a mature and agile GRC program.
References
OCEG. (2012). GRC Capability Model (Red Book) 2.0.
https://www.oceg.org
COSO. (2017). Enterprise Risk Management—Integrating with Strategy and Performance.
https://www.coso.org
ISO. (2018). ISO 31000:2018, Risk management – Guidelines.
https://www.iso.org
Institute of Internal Auditors (IIA). (2020). Three Lines Model.
https://www.theiia.org