Sign in

Blog · Coverage and territory · Compliance

Regulatory change coverage: new obligations with no control mapped yet

How a compliance team tracks the gap between regulatory change and control coverage from its own obligation register and change log: obligations added or amended per period, the days each has been live with no mapped control, the business units where unmapped obligations concentrate, the ageing of the mapping backlog, and the identity that every obligation is either mapped, in progress or unmapped with a date.

The short answerEvery regulatory change lands in the obligation register as a new or amended obligation with an effective date. Until a control is mapped to it, the obligation is uncovered, and the days since its effective date with no control is its ageing. Per business unit, the count and ageing of unmapped obligations is the change backlog, and the identity is that every obligation in the register is mapped, in progress with an owner and a date, or unmapped with the days counted. A regulator asking about a change six months old expects the third category to be empty.

A regulatory change is received, reviewed and logged. A year later the regulator asks which control addresses it, and the obligation register shows the obligation with no control beside it. The gap between change and control is measurable from the day the change lands, and it ages. This guide sets out coverage of regulatory change from the register and the change log, the backlog by unit, and the identity.

The measures

Per obligation:

State: mapped, in progress, unmapped Days uncovered = today − effective date, while not mapped Days past target, if in progress with a target date past

Per business unit, per period:

Obligations added or amended Unmapped count and median days uncovered In progress past target

The rows you need

  • Change log: change, received date, effective date, obligation created or amended.
  • Obligation register: obligation, business unit, effective date, mapped controls, mapping owner, target date.
  • Control register: control, obligations, owner, frequency.

Obligation and owner identifiers only.

The assertion

obligations = mapped + in progress + unmapped

Every obligation in one state. An obligation with a control link to a retired control is not mapped; it fails and is listed as mapped to nothing.

A worked backlog

Unit Obligations added or amended, last 12 months Mapped In progress Unmapped Median days uncovered Past target
Payments 41 22 11 8 140 6
Lending 28 25 3 0 1
Treasury 14 9 2 3 210 0

Payments has eight obligations that have been live for an average of five months with no control, and six more whose mapping target has passed. Treasury has three, older still. The regulator's question about a change from last spring has an answer in Lending and not in the other two.

Ageing

Days uncovered Obligations Units
0 to 30 5 Normal: recently effective
31 to 90 3 Backlog
91 to 180 2 Finding
Over 180 4 Payments 2, Treasury 2

Where it goes wrong

Change logged, obligation not created. The change is received and the register never sees it. The join from change log to register is what catches it.

Mapped to a retired control. Looks covered; is not.

In progress forever. No target date; never past it. Require the date.

Register reviewed annually. A change in February is a finding by August.

Every month, the backlog by unit

Mapped once, the change log, the obligation register and the control register produce the states, the ageing and the backlog per unit every month. Covirage builds this from the exports as they are. The compliance page describes the setup, and the obligation coverage guide covers the steady-state coverage measure this feeds into once the mapping is done.

Questions people ask

What counts as mapped?

At least one control in the register linked to the obligation, with the control's owner and testing frequency set. A control linked but never tested is mapped and on the testing cadence list; the mapping measure is about the link.

How is in progress separated from unmapped?

By an owner and a target date recorded against the obligation. In progress with a target date past is its own ageing; unmapped with no owner is the finding. Both are shown, with the days.

Where does the change log come from?

The horizon-scanning or regulatory intelligence feed the firm subscribes to, or the compliance team's own log of changes reviewed. Each entry with a date received and a date effective, joined to the obligation register on the obligation it created or amended.