A GRC platform is not ordinary software. It holds the risk register, the control weaknesses you have not fixed yet, incident records and regulator correspondence. For a bank, insurer or critical infrastructure operator it is also increasingly the system the board relies on to see whether risk is inside appetite. That makes the buying decision two decisions. The first is whether the platform can give executives and the board a true, current picture of risk. The second is whether the contract, service levels and hosting will stand up to your regulator. This checklist of GRC platform requirements covers both, using the rules that apply across Australia, New Zealand, Singapore, Malaysia, Hong Kong and the Gulf in September 2026.
What the platform must do for executives and the board
Start with outcomes, not features. Supervisors now expect evidence that controls work between audits, that risks are measured against appetite, and that the board sees the same picture as the people running the controls. Five capabilities separate a GRC platform that supports that from a document store with workflows.
| Capability | What to require | Why it matters |
|---|---|---|
| Continuous assurance | Automated control tests and evidence collection from source systems (identity, cloud, ticketing, vulnerability tools), with timestamps and owners; control status that updates as evidence arrives, not only at audit time | Turns annual attestation into current proof, and cuts the evidence scramble before every audit |
| KPIs and KRIs with thresholds | Indicators linked to risk appetite statements, with green, amber and red thresholds, trend history, and automatic escalation to the risk owner when a limit is breached | The board approves appetite; KRIs show whether the organisation is inside it |
| Dashboards for each stakeholder | Role-based views from the same data: board and risk committee, CEO and executives, CRO and compliance, control owners, internal audit, and regulator-ready exports | Each audience needs a different level of detail, but one version of the truth |
| Operational to enterprise risk mapping | Risks, controls and incidents at process level that roll up to enterprise risk categories and appetite, with critical operations linked to their people, technology, data and suppliers | Lets executives see how a failed control or supplier outage moves an enterprise risk, and supports CPS 230 tolerance levels |
| Issue and action tracking | Findings, control weaknesses and remediation actions with owners, due dates and ageing, visible up to the board | Overdue high-rated issues are one of the first things supervisors ask about |
A useful test in any demonstration: ask the vendor to take one failed control, show the KRI it moves, the enterprise risk that changes rating, and how the change appears on the board dashboard. If that takes more than a few clicks, or needs a spreadsheet, the platform will not carry board reporting. Our guide to board KRIs and quarterly reporting covers which indicators to put in front of directors.
Your GRC vendor may be a material service provider
Before negotiating, check how your regulator will classify the vendor, because that decides which contract terms are mandatory.
- Australia. Under APRA's CPS 230, as amended with effect from 1 July 2026, providers of risk management, core technology and internal audit services are material service providers unless the entity can justify otherwise (paragraph 49(d)). A platform that runs your risk register and control testing will often fall into that category.
- Singapore. MAS's Guidelines on Outsourcing (Banks), effective 11 December 2024, treat outsourcing all or substantially all of risk management or internal control functions as material (Annex 1), and Notice 658 treats SaaS as an outsourced relevant service.
- The Gulf. SAMA's Rules on Outsourcing require a no-objection for material outsourcing, and the CBUAE's new Operational Risk Management Regulation (Circular 1/2026, in force 14 September 2026) requires a non-objection before outsourcing that could significantly affect critical operations.
Classification is each entity's own judgement, but assume the strictest likely outcome when you draft the contract. It is far easier to include regulator clauses at signing than to retrofit them at renewal.
Contract clauses to require
Most regional regulators converge on the same core terms. The table uses the Australian and Singapore wording as anchors; Gulf regulators ask for broadly the same list.
| Clause | What to ask for | Regulatory anchor |
|---|---|---|
| Scope and service levels | Services, service levels and how they are measured, written into the agreement, not a web page that can change | CPS 230 para 53(a); MAS Guidelines 3.4.2(a) and (b) |
| Data ownership and control | You own all data, configurations, custom frameworks, evidence and the audit trail; the vendor uses it only to deliver the service | CPS 230 para 53(b); CBUAE Outsourcing Regulation Art 5 |
| Audit and regulator access | Audit rights for you, your auditors and every relevant regulator, including on-site visits, with no cap on regulator requests | CPS 230 para 54; MAS Guidelines 3.9.2; SAMA Rules Arts 33 to 34 |
| Sub-contractors | A list of sub-processors and their locations, advance notice of changes with a right to object, and vendor liability for their failures | CPS 230 para 53(d) and (e); MAS Guidelines 3.5 |
| Incident notification | Suspected incidents reported within 1 hour of detection (see the next section), with a named 24x7 contact and forensic cooperation | MAS Guidelines 3.4.2(g); CPS 234 para 35 |
| Business continuity | Tested DR plan, results shared annually, and your right to include the vendor in your own BCP tests | CPS 230 para 43; MAS Guidelines 3.4.2(d) |
| Termination and exit | Termination for default, regulator direction or data breach; a transition period; full export in open formats including evidence files, metadata and the audit trail | CPS 230 paras 53(g) and 55(d); MAS Guidelines 3.4.3; NCA ECC 4-2-3 |
| Deletion | Secure deletion of all copies, including backups, within a set period after exit, confirmed in writing | MAS Notice 658 para 7.1; NCA ECC 4-1-2 |
| AI features | No training of any model on your data; AI features optional per module; AI sub-processors and hosting disclosed; ISO/IEC 42001 evidence where AI is used | Emerging expectation; PSPF generative AI advisory for Australian agencies |
| Regulatory content updates | Where the vendor supplies framework libraries, committed update times after a regulator publishes changes, with version history and no silent overwrite of your mappings | CPS 230 para 53(c): the agreement must let you meet your compliance obligations |
| Liability and insurance | A higher liability cap for data and confidentiality breaches than for general claims, and evidence of cyber and professional indemnity cover | CPS 230 para 53(b); CBUAE Outsourcing Standards 5.1 |
Two traps are common. Standard SaaS terms often let the vendor change sub-processors or hosting by updating a web page; replace that with notice and a right to object. And many templates define service credits as the sole remedy; regulated buyers need termination rights for repeated failure as well.
SLAs that match your regulator's clocks
Service levels only matter if they are faster than the obligations they support. Three numbers deserve attention.
- Availability. A 99.9% monthly commitment allows about 8.8 hours of downtime a year; 99.95% allows about 4.4 hours. MAS and BNM limit unscheduled downtime of critical systems to 4 hours in any 12 months. If the platform supports incident reporting or a critical operation, ask for at least 99.95%, measured at the application, with capped maintenance windows outside your business hours.
- Recovery. CPS 230 requires tolerance levels for maximum disruption time and maximum data loss (paragraph 37), and MAS expects a 4-hour recovery time for critical systems. Put recovery point and recovery time objectives in the contract; for a platform used in incidents, one hour of data loss and four hours of recovery are reasonable asks.
- Incident notification. Vendor terms often say "without undue delay following determination", which can consume your whole reporting window before you hear anything. Require notice of suspected incidents within one hour of detection.
| Regulator or law | Reporting clock | Source |
|---|---|---|
| MAS (Singapore), QCB (Qatar), CBB (Bahrain), CBK (Kuwait) | 1 hour for relevant or critical incidents | MAS Notice FSM-N05; QCB, CBB and CBK rules |
| BNM (Malaysia) | 2 hours for cyber incidents | BNM operational risk reporting |
| CBUAE (UAE) | 4 hours, summary within 24 hours | Circular 1/2026, Art 15 |
| SOCI Act (Australia) | 12 hours for critical incidents | Section 30BC |
| APRA CPS 234, Saudi PDPL | 72 hours | CPS 234 para 35; PDPL Implementing Regulation Art 24 |
Data residency and sovereignty commitments
Data residency is where data is stored and processed. Data sovereignty is whose laws can compel access to it, which depends on who controls the provider as well as where the servers are. A regulated buyer needs commitments on both.
Some jurisdictions mandate in-country hosting outright:
- Saudi Arabia. CST regulations prohibit moving government agency data outside the Kingdom for any purpose, including backup, and SAMA's Cyber Security Framework expects financial institutions to use cloud located in the Kingdom unless SAMA approves otherwise.
- UAE. The CBUAE requires the master system of record, including confidential data, to stay in the UAE; from 14 September 2026 that applies to all licensed financial institutions.
- Qatar. QCB's Cloud Computing Regulation requires personal and financial information to be processed within Qatar.
- Australian and New Zealand government. Commonwealth entities must use certified hosting providers for classified and sensitive data, and New Zealand agencies are expected to keep RESTRICTED information onshore where a suitable service exists.
Singapore, Malaysia and Hong Kong do not mandate localisation for financial institutions, but they do require that the regulator's access is never impeded. MAS's guidelines say banks should not outsource to jurisdictions where prompt access by MAS may be impeded (paragraph 3.10.2). In Australia, APRA must be told before a material arrangement puts data or personnel offshore (CPS 230 paragraph 60(b)).
Whatever the jurisdiction, ask for: named regions for primary data, backups, disaster recovery, logs and support tooling; no change without your prior written consent; customer-managed encryption keys for the most sensitive data; vendor support access that is approved, logged and, where required, performed from in-country staff; and notice of government access requests where the law allows it. For the strictest cases, a platform you can run inside your own data centre or sovereign cloud removes most of the question.
Assurance evidence to ask for
- ISO/IEC 27001:2022, with a scope that names the product and hosting you are buying. Certificates to the 2013 edition stopped being valid after 31 October 2025.
- SOC 2 Type II covering at least six months, with a bridge letter for the gap to today and any carved-out sub-service organisations listed.
- Cloud and privacy standards where relevant: ISO/IEC 27017 (new 2026 edition), 27018 and 27701.
- ISO/IEC 42001 if the platform uses AI to map controls or draft content.
- Local schemes: an IRAP assessment for Australian government work (an assessment, not a certification), CST registration and NCA cloud controls in Saudi Arabia, and DESC CSP certification for Dubai government.
- Annual penetration test of the application, with a summary shared and remediation dates.
For the supplier register, due diligence and exit testing that sit around this contract, see our guide to a single third-party risk register for CPS 230, MAS and CBUAE, and for continuous evidence collection, collecting evidence once for ECC, ISO 27001 and SOC 2.
How GRCLens meets these requirements
GRCLens brings controls, risks, incidents, suppliers and evidence into one model, so control results and KRIs roll up from operational risks to enterprise risk and appetite, with role-based views for the board, executives, risk teams, control owners and auditors. One control set maps across frameworks including CPS 230, CPS 234, MAS TRM, NCA ECC, SAMA and ISO 27001, and the platform can be hosted in-region or deployed inside your own infrastructure where residency rules require it. Request a demonstration and test it against this checklist.
Frequently asked questions
What should a GRC platform RFP include?
Four parts: the capabilities the board and executives need (continuous assurance, KPIs and KRIs, stakeholder dashboards and operational to enterprise risk mapping), the contract clauses your regulator requires, service levels that beat your reporting clocks, and data residency and sovereignty commitments.
Is a GRC platform vendor a material service provider under CPS 230?
Often. CPS 230 paragraph 49(d) treats providers of risk management services as material unless the entity can justify otherwise, and the reasons for any exception should be documented and approved.
What uptime SLA should a regulated entity require from a GRC platform?
At least 99.9% monthly, and 99.95% if the platform supports incident reporting or a critical operation. Measure at the application, cap maintenance windows, and keep termination rights for repeated failures.
What is the difference between data residency and data sovereignty?
Residency is where data is stored and processed. Sovereignty is which country's laws can compel access to it, which depends on who controls the provider. Contracts should cover both.
How Security Solution Consultants can help
Security Solution Consultants helps banks, insurers, government agencies and critical infrastructure operators write GRC and security platform requirements, run RFPs and negotiate the regulator clauses into the contract. See our security compliance services and enterprise risk management services, or request a GRCLens demonstration.
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