SEC, DORA & NIS2 Compliance: How to Be Audit-Ready with One Common Controls Program

Introduction

If you work in a regulated enterprise right now, you’ve probably had the following thought at least once: Are we doing the same compliance work multiple times—just under different labels? With multiple cybersecurity rules to follow, your compliance team is often running overlapping frameworks in parallel. For example, it's common to see:

• One team focused on SEC cyber disclosure
• Another preparing for DORA compliance
• The third mapping NIS2 requirements

The real pain point for cyber risk and compliance teams isn’t a lack of controls— it’s fragmentation. To add to the complexity, Cyber Risk signals live across multiple security tools, such as Vulnerability Management, Endpoint Detection, Identity and Access Management, ITSM, and more, with no business context to support the process. IT Audit teams struggle because the same controls are tested, documented, and reported in multiple ways, depending on the source of the request. Instead of audit readiness, you end up with:

• Duplicated control testing: The same controls are tested multiple times across frameworks, creating unnecessary work and bottlenecks
• Repeated evidence requests to the same control owners: Control owners get asked for the same artifacts again and again, driving extra cycles, delays, and audit fatigue
• Fragmented remediation tracking: One control gap turns into multiple findings in different trackers, with unclear ownership, inconsistent SLAs, and no single “closure story”
• Inconsistent reporting to leadership: Different teams produce different versions of posture, risk, and progress, making board reporting harder and less credible

Why a Common Controls Program is the Answer?

Most often, the underlying controls are the same for different cybersecurity rules and frameworks. Common controls across frameworks include

• Access management (Who has access to your systems)
• Logging and monitoring (How you detect suspicious activity and maintain an audit trail)
• Incident response (How you handle breaches)
• Third-party oversight (How you manage vendor risk)
• Resilience testing, and recovery (How you prove you can restore services—backups, DR tests, tabletop exercises, and recovery evidence)
• Governance reporting and accountability (How leadership oversees cyber risk—control ownership, approvals, KRIs/KPIs, board reporting, and decision trails)

What changes is how these controls are explained, mapped, and proven.

By building one common controls program and maintaining one evidence trail, you can reuse it for audits, regulators, board reporting, and resilience.

A common controls program is a practical way to run IT compliance without multiplying the work. Strategic control mapping (aligning requirements with internal controls) can reduce manual audit preparation work by 40–70%, freeing teams for higher-value risk work.

What are the Compliance Requirements for SEC, NIST2, and DORA Compliance in 2026?

Before we explore how a common controls framework can help, let’s dive into the SEC, DORA, and NIS2 frameworks, the 2026 requirements, and how they impact your cyber GRC programs.

1. The SEC: Cyber disclosure and “prove your governance” pressure 

   What is SEC?

   The U.S. Securities and Exchange Commission has rules for public companies on when and how to disclose material cyber incidents and on how they govern cyber risk. Under the framework, organizations must show that cyber incidents, risk management, and governance are handled in a disciplined way, with clear accountability and reliable documentation.

   What’s new in 2026?

   The SEC cyber disclosure rule is all about increasingly accountability. After peak enforcement activity in 2024, early 2026 has brought a sharper emphasis on individual accountability (CEO/CISO/CIO) and disclosure accuracy. The SEC’s Cyber and Emerging Technologies Unit (CETU) is now active, focusing on material misrepresentation and governance gaps in disclosures.

   How does it impact your Cyber GRC operations?

   Under SEC rules, cyber risk is now a board-level reporting and governance topic, not just a security issue. You need consistent internal processes to identify and escalate cyber events, maintain defensible documentation, and support accurate reporting, so disclosures are fast, accurate, and defensible (without an evidence scramble).

   Download the eBook: Overview of SEC Cyber Disclosure Rules

   View Infographic: SEC’s New Cybersecurity Rules 2023: Top FAQs Answered

2. DORA: operational resilience is now auditable

   What is DORA?

   The EU Digital Operational Resilience Act (DORA) for financial entities is focused on ICT risk, incident handling, resilience testing, and critical third parties. DORA has been enforced since January 17, 2025.

   DORA is fundamentally about proving that organizations can withstand and recover from digital disruption. It focuses heavily on ICT risk management, incident handling, resilience testing, and third-party oversight, especially around critical service providers.

   What’s new in 2026?

   In 2026, DORA has moved into supervision and audit mode. DORA is now in the “show me proof” stage. A practical pressure point for many organizations is the first Register of Information (RoI) submissions by Q1 2026 (late March), focused on ICT third-party dependencies.

   How does it impact your Cyber GRC operations?

   Many firms are now in the phase where supervisors expect structured proof—not just policies.

   You need governance and audit-ready evidence for resilience—testing plans, results, corrective actions, ongoing oversight of critical ICT vendors, and third-party controls.

   For more insights on how you can be DORA-ready, you can watch this on-demand webinar: Demystifying DORA – Understanding and Preparing for the EU’s Digital Operational Resilience Act

   Download our eBook on DORA compliance.

3. NIS2: broader scope, stronger enforcement, more proof pressure 

   What is NIS2?

   The Network and Information Systems Directive 2 (also called the NIS2 Directive) is an EU directive raising baseline cybersecurity and reporting expectations for essential and important entities. While the directive’s original transposition deadline was October 2024, several national laws were finalized late in 2025.

   What’s new in 2026?

   NIS2 expands scope and raises expectations for security measures, reporting, and oversight. NIS2 is converging on full compliance by Oct 2026. For most impacted entities, Oct 2026 will serve as the real operational deadline to be “fully compliant, demonstrable.”

   How does it impact your Cyber GRC operations?

   For many organizations, it introduces more formal accountability and enforcement pressure, which quickly turns into “we need proof” pressure.

   Your organization needs a structured, repeatable way to demonstrate that security measures are implemented and managed, along with the ability to show progress and corrective action.

   Download our eBook on NIS2 compliance.

The practical overlap: what SEC, DORA, and NIS2 all demand

Even though the regulations are different, the compliance muscle you need for SEC, DORA, and NIS2 compliance is very similar. Across all three, organizations are being pushed to demonstrate:

• Governance and accountability: You need clear ownership, defined roles, approvals, and defensible decision trails
• Risk management discipline: You need a repeatable approach to risk identification, assessment, treatment, and reporting
• Control effectiveness (not just control existence): It is no longer enough to say “we have a policy.” You need evidence that controls operate consistently
• Incident readiness and reporting discipline: You need documented incident processes and audit-ready records when incidents occur
• Third-party oversight: You need risk-based vendor governance, not one-time questionnaires
• Resilience and testing: You need testing plans, outcomes, corrective actions, and evidence of continuous improvement

If you’re nodding along, you’re already at the core of the solution. The simplest model that works is one common controls program and one evidence trail, which will help you:

• Create a single shared control library that represents how your organization actually manages cyber risk and resilience
• Map of SEC, DORA, and NIS2 obligations to that control library (instead of creating new controls per regulation)
• Test controls on a defined cadence (based on risk and criticality)
• Collect evidence once in a centralized repository with time stamps and traceability
• Track remediation in one closed-loop process, so issues are fixed once and closure is provable
• Report on regulation-specific views from the same underlying control and evidence foundation

That’s how “test once, satisfy many” becomes real.

How to Build a Common Controls Program for SEC, DORA, and NIS2: A Step-by-Step Approach

Here is a practical approach to building a common controls program supported by connected workflows:

Step 1: Start with the controls you already have and rationalize

Most organizations already have a large control inventory. The goal is not to create more controls; it is to simplify and harmonize them.

A practical first move is to identify your “core cyber resilience control set”—the controls that repeatedly appear across SEC-related governance reporting, DORA resilience requirements, and NIS2 security measures. Examples of common control areas:

• identity and access management (including privileged access)
• logging, monitoring, and alerting
• vulnerability and patch management
• secure configuration and change governance
• incident response processes and evidence
• backup, recovery, and resilience testing
• third-party risk controls and oversight
• policy governance and approvals

Step 2: Map obligations to controls, not controls to obligations

This is a subtle but important mindset shift. If you start from obligations, you end up with three parallel lists. If you start with controls, you get one operational program.

You can maintain multiple mappings from SEC to controls, DORA to controls, and NIS2 to controls, with the centralized control library remaining the anchor.

The result: You can tell auditors and regulators a consistent story: “Here are our controls. Here is how each regulation maps to them. Here is the evidence.”

Step 3: Define control test cadence and what “good evidence” looks like

Audit readiness is not about collecting everything. It is about collecting the right artifacts in a consistent way. For each control, define:

• who owns it
• how often it is tested
• what evidence is required
• what constitutes as a pass/fail
• what happens when it fails

For example, for privileged access reviews, the evidence might include the access list, approvals, exceptions, and remediation proof.

Step 4: Maintain one evidence trail, so the audit response becomes retrievable

Once evidence is stored centrally and linked to controls and tests, you stop re-collecting it for every audit. You simply package it differently depending on who is asking.

This is where organizations typically feel the biggest productivity gain—because evidence is the hidden cost center of compliance.

Step 5: Run one remediation engine

When a control fails, you want one issue record, one action plan, one owner, one SLA, and one verification outcome, regardless of whether the failure was identified during a DORA-related test or a NIS2 review.

When remediation is centralized, you also gain better reporting: trends, repeat failures, and systemic root causes become visible.

Step 6: Produce regulation-specific “views” from the same system

Once controls, evidence, and remediation are unified, producing SEC/DORA/NIS2 reporting is easier. You can now generate different views from the same/ single source of truth.

Build a Common Controls Program with MetricStream

A common controls strategy only works if the operating model is supported by a system like MetricStream that can maintain traceability and workflows at scale.

MetricStream Cyber GRC is a connected, auditable operating system for cyber governance, risk, and compliance. MetricStream brings together your control library, multi-framework mappings, recurring testing, centralized evidence, issue remediation, and third-party oversight, so you can run a “test once, satisfy many” common controls program and stay audit-ready.

MetricStream supports this approach by enabling:

• A centralized control library and evidence repository: A Single source of truth for risks, controls, policies, vendors, and evidence
• Multi-framework mapping (SEC, DORA, NIS2, plus ISO/NIST): Built-in frameworks and harmonized controls with 800+ controls that support multiple frameworks like ISO/NIST/SOC2/PCI/HIPAA, etc.
• Integrations with 40+ security tool connectors to pull in security signals
• Automated control testing and evidence collection that reduces manual work
• Closed-loop issues and remediation with ownership, SLAs, and verification
• Cyber risk quantification (FAIR-aligned with simulations) to prioritize risks and investment in business terms
• Third-party risk management workflows for vendor oversight (tiering, onboarding, assessments, continuous monitoring, and remediation workflows)
• Dashboards and reporting for executives, auditors, and regulators.

Benefits of Choosing MetricStream to Meet Your Cyber Security Compliance Needs

• If you’re a CISO / VP of Security / Head of InfoSec, what matters is answering the board with confidence: “Are we in control and can we prove it?” MetricStream helps by providing a single executive view of cyber risk and control health, quantified risk in dollar terms, and an audit-ready evidence and remediation trail. The result: 66% faster risk assessments.*
• If you head of Cyber Risk/IT Risk, what matters is turning scanner noise into a clean, prioritized risk register along with getting fixes closed. MetricStream helps you by linking assets, threats/vulnerabilities, controls, issues, and remediation, with integrations to security tools and consistent scoring.
• If you lead GRC / Controls, what matters is stopping duplicate work across frameworks and reducing the “chase” for owners and evidence. MetricStream helps by enabling one common controls program with multiframework mapping, automated assessments, and reusable evidence packs. The result: 40% fewer evidence requests through de-duplication.*
• If you lead Compliance, what matters is staying continuously audit-ready without fire drills every time a standard changes. MetricStream helps with pre-packaged frameworks, recurring control testing, centralized evidence, and regulation-ready audit packs. The result: 50% time savings linking policies to regulations; 39% reduction in control testing time.*
• If you’re in Internal Audit / IT Audit / SOX ITGC, what matters is complete, time-stamped evidence and a clean trail from control, test, finding to closure. MetricStream helps by standardizing testing, centralizing evidence, and tracking remediation with owners and SLAs.
• If you lead Third-Party / Vendor Risk (TPRM), what matters is scaling onboarding and continuous monitoring, without spreadsheets, and actually driving vendor remediation. MetricStream supports vendor tiering, automated due diligence, external risk intelligence integrations, and remediation workflows. The result: 80% faster vendor onboarding; 50% faster/cheaper vendor assessments.*
• If you’re a Control Owner (IT/Security), what matters is fewer repeat evidence requests and clear expectations. MetricStream helps by automating evidence requests/attestations, managing exceptions, and syncing remediation to ITSM tickets.
• If you own Policies / Governance / HR attestations, what matters is proving policies are current, communicated, and attested, without version chaos. MetricStream provides a central policy hub, automated reviews/approvals, attestation tracking, exception management, and policy-to-control mapping.

*Stats based on MetricStream customer responses and GRC Journey Business Value Calculator.

See MetricStream Cyber GRC in action

If you want to see how a common controls program works in practice and how to operationalize “test once, satisfy many” across frameworks like NIST, DORA, and NIS2, request a personalized demo of MetricStream Cyber GRC today! We’ll show you how to unify controls, testing, evidence, remediation, and reporting in one system, so you're always audit-ready!

Request a demo here or Download the RFP