Evidence not bound to specific obligations
Documents and system records exist, but the link to the specific article or control they support is informal. When the regulator asks, the team re-establishes the link under time pressure.
Structure assessments across frameworks, bind evidence to the specific obligations it supports, and record accountable approvals against each conclusion — so audit and regulatory review start from a prepared record rather than a reconstruction. The DORA cockpit on the overview page is one applied scenario of what you'll see here.
Preparation is often one project. Supervisory follow-up is often another. Four frictions recur across DORA, NIS2 and ISO 27001 programmes.
Documents and system records exist, but the link to the specific article or control they support is informal. When the regulator asks, the team re-establishes the link under time pressure.
The same evidence often supports DORA, NIS2, ISO 27001 and internal controls. Without a mapping, the same work is repeated per framework and inconsistencies creep in.
Risk committee minutes, CRO sign-off, delegation chains — all exist, often in separate systems. Pulling them back together for a supervisory query is itself a project.
Each regulatory submission or audit cycle rebuilds the picture of what was decided and on what basis. The institutional record exists in people, not in a connected view.
Follow a regulated bank's compliance team from scope through to a supervisor's post-submission question. The scenario below shows DORA; the same workflow applies to UK NIS and NIS2 programmes, and across Tier 1, Tier 2 and Tier 3 banks. Illustrative, with synthetic data representative of the shape and detail CWORT records.
DORA Chapter II (Articles 5–15) is decomposed into 32 control activities. Each activity is mapped to the internal risk framework and ISO 27001 for reuse. The mapping is explicit, versioned and bound to the regulatory source text.
Technical teams submit evidence per obligation: policy documents, system configurations, test results, independent review logs. Each item is bound to the specific DORA article it supports — not stored as a general file attachment.
The ICT Risk Committee reviews evidence sufficiency per obligation and records judgement on control effectiveness with reasoning. The committee's judgement is captured against the committee as a body, not just as a meeting minute.
The Chief Risk Officer approves the overall DORA posture. CWORT enforces separation of duties — the CRO cannot approve controls they operate. The approval carries role, timestamp and authorisation context (including delegated authority).
The submission is drawn from the live record. Each conclusion is backed by its linked evidence and approval chain. The submission is traceable obligation-by-obligation — the regulator does not just receive a report, they receive a report that references the record behind it.
The lead national regulator asks for the control effectiveness evidence behind Article 9. The team opens the record and returns the original evidence items, the risk committee's judgement, and the CRO approval in the same connected view — prepared from the existing record, not reconstructed.
Each conclusion is anchored to the evidence that supports it, bound to the specific obligation. Not a general file store — a record built for review.
Risk committee judgement, CRO approval and the delegation chain are recorded with role, context and timestamp. SoD is enforced at the approval boundary.
Supervisory follow-ups and audit cycles start from a prepared record rather than a reconstruction. The response is already there, not built under deadline.
Overlapping obligations share evidence and judgement where appropriate, with explicit mapping. The same work covers more frameworks without inconsistency.
CWORT is one governed workflow applied to three audiences. Explore the other two.
A 30-minute walkthrough of the simulated DORA programme above, extended to the framework or supervisory regime that matters most to your team.