ARTICLE
23 February 2026

What "Risk-Based" Compliance Really Looks Like, And Where It Still Breaks Down

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NAVEX

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Most organizations conduct risk assessments and claim to use the results to guide their compliance programs.
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Risk-based compliance is widely adopted – but unevenly executed

Most organizations conduct risk assessments and claim to use the results to guide their compliance programs. However, polling from compliance leaders shows a persistent execution gap. Risk data is often reviewed and documented, but not consistently translated into clear priorities, actionable steps, or board-ready insights. That gap turns "risk-based compliance" into a leadership test, especially when decisions must be explained to boards, regulators, and executives over time.

What is "risk-based compliance?"

Risk-based compliance is an approach to managing compliance programs that identifies, prioritizes, and addresses the risks most likely to affect the organization. In practice, this means using risk assessments to guide decisions about policies, training, monitoring, investigations, and reporting, rather than applying uniform controls across all areas.

A look at recent webinar insights reveals why this approach remains challenging, even for mature programs.

When risk-based compliance becomes a leadership test

Risk-based compliance is not a new concept. Most senior compliance leaders have discussed it for years, and many organizations would say it already informs how their programs operate.

Yet polling and audience questions from a recent NAVEX webinar on top risk and compliance trends revealed a familiar tension. While risk assessments are widely conducted and broadly valued, many organizations still struggle to consistently translate those insights into clear priorities, defensible decisions, and sustained action.

That gap matters, especially for leaders accountable to boards, regulators, and executive teams.

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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