We've compiled resources on enterprise risk management (ERM) frameworks and models. You’ll learn how to develop a custom ERM framework, gain insight into key criteria and components, and find expert advice on mapping your framework to your customer's needs.
Enterprise risk management frameworks relay crucial risk management principles. You can use an ERM framework as a communication tool for identifying, analyzing, responding to, and controlling internal and external risks. An ERM framework provides structured feedback and guidance to business units, executive management, and board members implementing and managing ERM programs.
ERM frameworks help establish a consistent risk management culture, regardless of employee turnover or industry standards. They guide risk management functions and help enterprises manage complexity, visualize risk, assign ownership, and define responsibility for assessing and monitoring risk controls. A custom ERM framework supports the enterprise in integrating risk management into significant business activities and functions.
The strategic framework you choose will depend on your industry, business goals, organizational structure, technology infrastructure, and available resources. Some frameworks are more applicable to enterprise-scale businesses, while others provide more customizable, scenario-based approaches to an organization's specific ERM needs.
There is also a subset of strategic enterprise risk management frameworks — for example, some may better fit the needs of highly regulated industries like finance and healthcare. You can use any of these as a starting point to build a custom ERM framework.
The Casualty Actuarial Society (CAS) is an international credentialing and professional education entity. The organization focuses exclusively on property and casualty risks in insurance, reinsurance, finance, and enterprise risk management.
The CAS, Society of Actuaries (SOA), and Canadian Institute of Actuaries (CIA) sponsor a risk management website with ERM education resources. The committee organizes the ERM framework by risk type and a sequential risk management process.
The four risk types are defined as follows:
The CAS risk management process involves the following seven sequential steps:
The steps in the risk management process might apply to each risk individually. The checklist below is based on the committee's ERM framework grid in the aggregate.
In 2017, COSO published an updated ERM framework, Enterprise Risk Management—Integrating with Strategy and Performance, to address the importance of ERM in strategic enterprise planning and performance. This updated model accounts for the increased complexity of modern business environments.
The Committee of Sponsoring Organizations of the Treadway Commission (COSO) is a joint initiative of five private-sector organizations dedicated to offering thought leadership by cultivating comprehensive frameworks and guidance on enterprise risk management, internal control, and fraud deterrence. Below are the organizations that sponsor and fund the COSO private sector initiative:
COSO incorporated the Sarbanes-Oxley Act (SOX) legislation for risk management guidelines into its ERM framework. This integration made the COSO framework popular with large corporations, banks, and financial institutions subject to extensive legal codes and high-risk business.
The updated COSO framework includes five interrelated enterprise risk management components. These components include 20 principles that cover practices from governance to monitoring, regardless of enterprise scale, industry, or type of organization.
The following components of the widely-used ERM framework fits business models, not independent risk management processes:
The following table summarizes the updated COSO ERM Framework control components and principles.
The International Organization for Standardization (ISO) 31000:2018 ERM framework is a cyclical risk management process that incorporates integrating, designing, implementing, evaluating, and improving the ERM process.
The ISO 31000 model is reviewed every five years to account for market evolution and changes to business complexity. This framework covers various risks and is customizable for organizations, regardless of size, industry, or sector. To learn more about this model and download free templates and matrixes, read “ISO 31000: Matrixes, Checklists, Registers and Templates.”
The ISO/IEC 27001 ERM Model
The ISO/IEC 27001 security standard provides requirements for information security management systems (ISMS). More than a dozen security standards provide physical and technical information risk management controls for ERM programs. Digital enterprises in various industries adopt ISO 27001 to manage financial, intellectual property, and internal data security.
COBIT (2019) is a flexible IT governance and management framework created by the Information Systems Audit and Control Association (ISACA). The conceptual framework is a popular choice for managing risk in a digitized enterprise environment.
COBIT provides a risk management model for large enterprise business capabilities and a model to fit specific areas of small to medium enterprises. Managing information and technology risk is no longer limited to the IT department, due to the integration of IT in every aspect of modern business operations.
“We look at COBIT and COSO at the top down level as we're putting together our program,” says Michael Fraser, CEO and Chief Architect at Refactr, a Seattle-based startup that provides a DevSecOps automation platform that offers IT-as-code services and DevOps-friendly features made for cybersecurity. “We're also looking at how those map to every control that we looked at in those frameworks. Is that something that we can automate internally? Is it something that requires a manual process? We build that content for our customers and check to make sure that this is a dynamic program that works for us and for the customer,” he says.
COBIT is a flexible umbrella framework for creating an ERM framework with processes that align business and IT goals to prevent risk management silos across an enterprise. The framework identifies the following three core principles for building a governance and management framework:
There are also six core requirements for an enterprise IT governance system that an organization can adapt and design to fit an ERM framework:
The National Institute of Standards and Technology (NIST) is a U.S. federal government agency (U.S. Department of Commerce). The NIST framework is a cybersecurity framework used by private enterprises doing business with the U.S. government agencies, such as the Department of Defense (DoD).
The NIST framework model focuses on using business drivers to guide cybersecurity activities and risk management with three components:
The NIST framework provides a globally recognized standard for cybersecurity guidelines and best practices that apply to enterprise-scale organizations with critical infrastructure to protect. The framework is a flexible model for creating an ERM framework for organizations that rely on technology, are concerned with data privacy, and that manage risk associated with the latest digital workforce trends.
"The Center for Internet Security maps a lot of its framework or benchmarks to NIST and ISO and maps those to an ERM framework,” explains Fraser. “Everything is interconnected because you're trying to mitigate risk. You're also trying to check boxes for a particular scenario — whether that's for an audit or for a customer that wants us to practice due diligence to meet their risk management standards.”
The nonprofit risk management society (RIMS) Risk Maturity Model (RMM) assessment consists of 68 readiness indicators that describe 25 competency drivers for seven critical ERM attributes to benchmark organizations against industry peers, track progress, and help execute an action plan.
The RIMS RMM framework identifies the following seven key attributes of ERM competency:
Evaluate each attribute using a scale of five maturity levels: nonexistent, ad hoc (level one), initial (level two), repeatable (level three), managed (level four), and leadership (level five). The RIMS RMM framework is a flexible model that is compatible with customized ERM frameworks based on the international ISO 31000:2018 standard, the updated COSO ERM framework, or the COBIT framework.
“There's not a one-size-fits-all framework, and you’ll start realizing you need something different,” says Michael Fraser of Refactr. “That's what we found at Refactr, but we're unique because we help organizations create the automation that they want to use to help them with these particular frameworks.”
“The risk management frameworks out there are guides to help you understand what you need to do in a standardized way,” Fraser continues. “So, there's something universal that you can work with that other people understand. They [the standard frameworks] are there to help you build your security program and not there to be this bar you never reach.”
Fraser advises asking if the framework is good enough for your organization to do business with your target customers. The most critical piece of advice comes down to the why — i.e., “Why do you need an enterprise risk management framework?”
“A lot of these risk frameworks are antiquated in what they talk about,” he says. “With more people working from home, you don't necessarily have the corporate networks. What if you're born in the cloud or a 100 percent remote, cloud-native company?”
“Risk management is the overarching discipline in cybersecurity, and the focus tends to be on the technology aspects. But, for the enterprise, it's how to attract and retain profitable clients,” explains Sean Cordero, an Advisor to Refactr. “One of the things that gets lost for some organizations is the explosion of cloud-delivered services. Cloud architecture enables a way of doing things now that has little to no relevance to the way things were done.”
Cordero advises addressing some difficult questions before creating a custom risk framework. Ask the following questions: Is anyone going to use this ERM framework? Is it going to help move the needle from an industry perspective? Take a step back and assess what the risk is and what matters, using three simple inputs to prioritize strategic risk management, before implementing a custom ERM framework.
“First, look at what is required by the law. Second, identify what your customers are going to need, which will depend on the type of organization,” says Cordero. “If you're maintaining sensitive data for your customers and they care about that sensitive data, focus on the confidentiality aspects, whether that's encryption or a multitude of ways to get there. Finally, determine what you value as an organization. What are you okay with when considering your clients and your business? This is a very introspective thing that is sometimes missed. If you do it, you will suss out clearly where to focus and can then select the appropriate risk management framework or approach.”
Developing a custom ERM framework helps implement a risk management strategy, align business objectives, and promote risk-based decision-making. But, customizing an ERM framework to fit internal objectives, customer needs, industry regulations, IT governance, and internal audit standards doesn't have to be overwhelming.
The following roadmap for developing a custom ERM framework is based on existing management and operational risk frameworks, ERM models, and input from industry experts. Use this step-by-step process to develop and implement a custom ERM program. To learn more about ERM implementation, see our “Guide to Enterprise Risk Management Implementation.”
Select stakeholders across different business units and management for the ERM steering committee. The overall effectiveness of a custom ERM framework depends on support from all management levels, particularly executive leadership, senior management, and the board of directors.
Build a cross-functional ERM team to drive buy-in at various operational levels and impact the culture. The ERM team sets business objectives, and develops a risk profile and a risk appetite statement (RAS) based on the threats and opportunities within their expertise.
Stage One Questions:
Recognize and plan for risk events — internal and external threats and opportunities that create doubt and may affect business outcomes. Use your risk profile and RAS to align the business strategy with risk identification.
The ERM framework is the playbook for identifying and addressing risks that threaten business objectives. Use it as a guide to distinguish risk threats from risk opportunities that may lead to achieving desired outcomes. Map risk events back to objective setting activities in Stage One and identify internal and external risks. Be sure to include your customer's risk perspective, as well.
Leverage industry best practices and the ERM steering committee’s expertise to guide your analysis of future threats and opportunities.
Stage Two Questions:
Risk assessment sets the foundation for managing risk and determining its probability. This stage is the heavy analysis phase of framework development — in it, you will establish an integrated risk assessment framework.
Use risk assessment and compliance tools like a risk assessment matrix and risk control self-assessments (RCSAs) to plan the assessment methodology. Risk assessment forms are useful for evaluating risk and establishing risk controls, which is the core activity in Stage Four. To learn more about planning a custom risk assessment methodology, see our guide to enterprise risk assessment and analysis.
Stage Three Questions:
Treating risk is the action phase of an ERM framework. This stage involves designing and implementing the control environment and creating a risk mitigation action plan that covers how to respond to each type of risk event identified in previous stages.
Risk owners manage the control environment. Assign roles and responsibilities to risk owners to pinpoint when and how to respond. Determine which business units are affected by and responsible for specific risk controls.
Internal controls are specific actions that risk owners take to respond to threats or leverage opportunities. Align separate internal and external controls based on business objectives, customer requirements, industry legal and regulatory requirements, compliance standards, and governance structures.
ERM Framework Stages of Risk Response
The ERM framework helps you to address various stages of risk response and determine appropriate controls. Your response and mitigation strategy will vary by the type of risk, risk profile, and risk tolerance. The stages of risk response include the following:
Stage Four Questions:
Risk optimization is the final stage. The specific tools you need to optimize risk varies based on resources and overall objectives. Consult your ERM objectives to pick the set of analytics capabilities and reporting technology you need. These should not drive the type of ERM framework you develop.
Monitor and review ERM program performance in order to create a data-driven, objective feedback loop. This iterative loop flows across the enterprise at all levels and in all directions to optimize risk management. Then, use that data to identify areas of opportunity to revise and enhance the ERM program.
Leverage compliance audits that match best practices for your industry and governance requirements. Create a role-based, risk reporting dashboard to track and report on strategic risk objectives, control metrics, and KPIs. Modern ERM software platforms provide cloud-based dashboards with built-in business intelligence and user-friendly reporting features.
Stage Five Questions:
Creating a custom ERM framework involves leveraging risk management best practices, tools, and proven strategy. Incorporate the following risk management tools to develop custom ERM framework components that fit the enterprise’s — and the customer's — needs:
Download Risk Assessment Matrix
Use this risk assessment matrix template to get a quick overview of the relationship between risk probability and severity. The template’s simple color scheme distinguishes between different risk ratings.
James Lam outlines a set of standard criteria for his Continuous ERM Model in the book Implementing Enterprise Risk Management. He combines the components of well-known strategic management frameworks into a customizable communication framework with the following criteria:
Enterprises of all types and sizes face external and internal risks, regardless of industry. However, some ERM frameworks are more prevalent across specific industries due to privacy laws, financial transactions, the regulatory environment, and governance requirements for technology and infrastructure.
This chart is not an exhaustive dataset. Instead, it highlights the popular ERM frameworks and models discussed in this article and the industries that leverage them to create customized ERM programs.
Johnson & Johnson is one of the largest healthcare enterprises in the world. The company created a custom ERM framework, guided by the COSO ERM framework, to address healthcare-specific risks such as reduced business vitality due to healthcare reform.
The Johnson & Johnson ERM framework consists of the following five integrated components:
The popularity of IT managed services, software-as-a-service (SaaS) technology, and cloud computing has created a new dynamic for the digital enterprise. Data breaches and IT security compliance should concern every organization, regardless of industry or size.
COBIT by ISACA helps guide information and technology decisions that support and sustain business objectives. COBIT is comprehensive and provides a governance and management framework for enterprise IT that adds value to all information and technology decision making.
The COBIT framework helps maintain the balance between realizing benefits, optimizing risk, and using IT resources. It consists of a process reference model, a series of governance and management practices, and tools to enable an organization's governance.
The SOC 2 Type 2 ERM Model
SOC 2 Type 2 is an IT compliance and security model that ensures that IT and SaaS vendors (or any technology “as-a-service” provider) securely manage data. This set of criteria, composed of five principles, was developed by the American Institute of CPAs (AICPA). These principles include security, availability, processing integrity, confidentiality, and privacy.
Sean Cordero has seen industry standards and certification bodies rise to meet the demand for less prescriptive, more flexible risk management. He helps lead the core research team for risk control development with the Cloud Security Alliance (CSA), a leading authority in cloud security.
“When you're doing this kind of research, you do it because you want to make a difference,” he says. “It becomes extremely complex to start making changes at scale when you start talking about overarching standards that go through multiple certification bodies where they have an attestation program and third-party validation.”
According to Cordero, the certification process impedes going to market with an MVP or a software feature request.
The combination of lagging standards without frequent updates, changing security processes, and outdated security technology and tools (for example, vulnerability scanners) creates questions that more responsive ERM frameworks might be able to address.
Flexible IT Frameworks
“We're at an interesting inflection point in the security industry,” says Cordero. “Is this a failure of standards, or a failure of technology, or is it both? Because of the inflexibility of certain risk frameworks, or control frameworks, and the existing technology overlaid on top of both, it is almost impossible to enforce the majority of control standards out there.”
Cordero knows firsthand that there's a movement in risk management and security control frameworks to be less prescriptive and provide more implementation guidance through his research work with Cloud Security Alliance.
“We're no longer saying, ‘You must do these 15 things or you don't meet this requirement,’" he explains. "Instead, we're saying, ‘You must use industry-validated encryption for business and customer sensitive information.’ We're not defining ‘business-sensitive.’ That's for you to decide."
Cordero also points out that control standards still provide value. That said, those that just get grandfathered into existing frameworks are not sustainable in a cloud-first world, as they were intended for a different world and a different approach.
Regarding ERM frameworks and the risk management approach to the industry as a whole, Cordero believes one of the things that's always been a problem is the idea of customizing a framework or a control.
“It is ultimately just a baby step of the risk management process,” he says. “The framework might provide validation or insight in terms of the time, money, and resources spent. I would advise companies to think about the fact that you can drive yourself insane trying to take a control framework and figure out how to implement all of this stuff.”
Risk management is a vital part of running an enterprise-scale credit union. Section 704.21 of the National Credit Union Administration's (NCUA) rules and regulations require credit unions to develop and follow an (ERM) policy.
ERM frameworks like COSO enable a holistic view of enterprise risks for financial institutions and credit unions to measure and analyze the risks impacting various functions. A well designed ERM framework provides the corporate board of directors and senior management with a process to determine the following:
The COSO ERM framework was adapted by prominent enterprise financial institutions like Barclays, an international bank, and customized to leverage ERM components that drive business value and meet regulatory compliance standards. Barclays uses their ERM framework to manage the following types of risk:
The Barclays Board Risk Committee is a group of non-executive directors that issue an annual report based on the Barclays ERM framework, financial governance codes, and the disclosure guidance and transparency rules of the financial regulatory bodies in which they operate. The committee is responsible for recommending risk appetite to the board, monitoring Barclays' financial, operational, and legal risk profile, and providing input on financial and operational threats and opportunities.
In 2018, international consulting conglomerate Deloitte created a legal risk management framework. The Deloitte legal ERM framework was developed in response to increased risk management expectations. The framework gives Deloitte a competitive advantage because it controls legal risks across enterprise operations.
The Deloitte legal ERM framework has the following four components:
The insurance industry is still beginning to embrace comprehensive ERM frameworks that do more than meet compliance standards. Most insurers use an internal risk and solvency assessment (ORSA) policy to meet U.S. regulations and governance requirements.
ORSA helps insurers assess risk management capabilities and evaluate market risk, credit and underwriting risk, liquidity risk, and operational risk. However, ORSA is limited to an early stage risk management program for standard compliance compared to comprehensive ERM frameworks like CAS and COSO ERM frameworks.
These frameworks provide systematic risk-return optimization strategies and tools that align with business objectives and provide value for the insurer and their clients. Insurers that embrace ERM frameworks like COSO create comprehensive risk capital models that support risk management as a valuable business strategy.
ERM Model for Insurance Companies
Risk capital models measure the amount of capital an organization needs to meet business objectives, given its risk profile. You can use them to develop risk strategies and compare internal assessments of risk. They can also rate agencies and regulatory requirements for risk capital to determine risk profiles.
Many insurance organizations rely on some form of risk capital models as a form of ERM. Risk modeling helps define risk by gathering and analyzing data that provides insights on the interactions or risk and business objectives. Risk capital models help provide a framework to support an insurance organization's risk profile and risk appetite, and also help establish a risk culture.
U.S. federal agencies and their leaders are responsible for managing enterprise-scale missions that impact various industries. ERM frameworks, like the cybersecurity maturity model certification (CMMC) and FedRamp, help government agencies assess risk and identify threats and opportunities through ERM programs that align with agency goals and objectives.
The CMMC ERM Maturity Model
CMMC is a more recent cybersecurity risk framework developed by the Under Secretary of Defense for Acquisition and Sustainment, the DoD, and other stakeholders to measure the cybersecurity maturity of government agencies and industry organizations doing business with the federal government. The model provides maturity processes, cybersecurity best practices, and inputs from the security community and multiple security industry frameworks and models.
The CMMC framework uses the following five levels of processes and practices to measure cybersecurity maturity:
The FedRAMP Program
The Federal Risk and Authorization Management Program (FedRAMP) provides a standardized approach to security assessment, authorization, and continuous monitoring for cloud computing products and services. FedRAMP emphasizes cloud security and the protection of federal information when agencies and enterprise partners adopt cloud solutions.
The program supports cloud service providers with an authorization process and maintains a repository of FedRAMP authorizations and reusable security packages. The goal is to facilitate collaboration across government agencies with use cases, tactical cloud-based solutions, and a contractor marketplace.
Refactr works with the DoD and government agencies that require strict risk management frameworks and governance practices. Michael Fraser identifies how the application of Refactr's ERM framework and security programs map between partnerships with the DoD and private enterprise clients.
“In some ways, the DoD is more stringent, but depending upon the type of customer, like a financial firm, they may have requirements that are on par with some of the DoD's requirements,” Fraser explains. “Different government organizations recognize different ERM frameworks, including NIST and COSO. Custom frameworks can satisfy their risk compliance standards as well.
“Whether it's the Air Force or a cybersecurity vendor, there's a set of requirements that you have to be able to provide, with the information they understand, that verifies that you use some sort of risk framework. A cybersecurity vendor probably works within multiple different frameworks. The key is to have enough information to impart due diligence for a security program, while trying to abide by industry best practices that map to a particular framework.”
Continuous Risk Management Models
According to Fraser, there are points in time during audits that use compliance frameworks (like FedRAMP and SOC 2 Type 2) when everything is based upon integrity.
“That's where automation comes in,” Fraser says. “To help get to a certain threshold of automated coverage for a particular framework. That's a sufficient, ongoing due diligence process, even if there are always going to be some manual steps inside of the compliance framework.”
For Fraser, there's a difference between trying to check all the boxes of a compliance audit and having a certain percentage of continuous automation coverage within your risk management and security framework.
Fraser highlights the importance of flexibility and a customer-first perspective. Ask yourself: Do you go for an arduous standard like FedRAMP because it provides the highest compliance standards for an audit, or is SOC 2 Type 2 sufficient? “Customers say, well, you're FedRAMP compliant, cool,” he says. “I'm willing to engage with you, even though you don't have SOC 2 Type 2, because FedRAMP is more arduous, a higher bar.”
Fraser recommends that companies reuse a percentage of their custom ERM framework for future internal needs and customer criteria. “Knowing what you need in the longer term is critical for you to know what you need to within the next 30, 90, or 180 days,” he says.
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