Challenges in risk assessment in 2026
The more things change, the more they remain the same. Every year, you look at your governance, risk and compliance (GRC) program with renewed optimism. This is the year you will figure it out. This is the year when things get easier. By December, you are left looking back on the shifting priorities that distracted your team, the new regulations where you had to quickly react, and the sense that January is right around the corner, so you can try again.
Of course, if this was simply an annual problem neatly mapped out against a calendar, maybe we could get there more easily. Rather, it’s a continuous cycle that blurs the line between old and new challenges. GRC professionals experience a kind of imposter syndrome within the community where they feel constant obligation to use more automation, test the newest AI, review more data, comply with the newest framework, and yet so many have not mastered the fundamentals. How can we advance our programs if we don’t have the foundation?
The GRC imposter syndrome – doing everything except the essentials
GRC imposter syndrome is the pervasive feeling among risk and compliance professionals that their programs must constantly evolve faster than everyone else’s. This manifests within our business in several ways.
- Chasing the coolest new acronym or AI tool instead of understanding basic ownership and accountability. If your process doesn’t work manually, it will not work automatically either. You can’t skip to the finish line.
- Your program focuses on proving maturity rather than informing action within the business. The point of the risk assessment isn’t to produce a dashboard. The point of the risk assessment is to understand uncertainty within the business and where mitigation is needed to achieve your business outcomes.
- Benchmarking against peers instead of establishing your business’s risk appetite and setting your risk tolerance, then aligning your risk activity to those specific attributes. While the fundamentals of your GRC program might feel the same as everybody else’s, this is where you get to put the finishing touches on your program that really make it work. How does our risk management process align to our priorities, not everybody else’s?
Focus on outcomes over optics. Ask the question “so what?” You produced the coolest new heatmap, dashboard, risk quantification…so what? If your business doesn’t have a clear next step with that data, it’s time to go back to the basics and understand what you’re doing to manage risk, not just report on it.
A significant aspect of GRC imposter syndrome is that GRC professionals are overwhelmed by getting started in the first place. An industry expectation is that you need to start with this robust, perfectly managed risk register that is flawlessly mapped to mitigating controls. The truth is that almost nobody is there, and that the process of GRC should be continuous anyway. Wherever you are is great, and many of you didn’t start with risks at all, did you?
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Risk and Compliance: The chicken and the egg
What came first? Risk or Compliance? Most GRC professionals would tell you it should be Risk, and that seems to be a widely accepted practitioner outcome. However, starting with risk can be really challenging. You need to look at every angle, align risk with business outcomes, engage with every department, prioritize those issues. While risk in business is inherent, starting with risk is proactive in nature, and being proactive is hard.
Why can’t we start with Compliance? After all, this is where a lot of companies are anyway. You had to comply with a regulatory requirement or an annual audit. Naturally, your risk register evolved from compliance gaps, and while it may not be as robust as the proactive risk management crowd, it’s a practical starting point that was born out of necessity.
The truth is that Risk and Compliance are symbiotic in nature, and they grow together. When GRC professionals let perfection get in the way of progress, they ultimately don’t move their program forward and skip the basics. Ultimately, we know this relationship isn’t only necessary but it’s improving. In our 2025 State of Risk & Compliance Report survey, 93% of respondents said compliance was at least engaged to some degree in the risk assessment and management process. As we said at the time, “It appears clear that collaboration between these functions is occurring, but the exact nature of that collaboration may be unsettled.”
Survey insights and the state of 2026 – cracking the egg
Risk and Compliance can no longer evolve separately. At the end of the day, it doesn’t matter how the egg got here – it’s ready to hatch. Topics such as AI governance, data privacy, and ESG are shared concerns across the business, best led by an integrated risk and compliance vision. And when evaluating your GRC program, risk and compliance mature through proper governance.
In the same State of R&C survey, 70% of compliance teams were said to be highly engaged in risk assessment and management. However, only 24% believe their assessment process is effective. 2025 represented convergence without clarity. Functions are working together more, but not necessarily working effectively or efficiently. The connective tissue of the GRC program is still forming in so many organizations and most simply need to lean into that instead of running away or getting overwhelmed.
The real opportunity in 2026 is not about adding more AI or new dashboards, it’s about doing the right things the right way. There is a clear shared purpose between risk and compliance that truly enables a proactive future that has seemed impossible in years past.
Setting the foundation for effective risk assessments
Establish the foundation of your program with three key questions. There is always more to expand upon, but in search of basic concepts, start here:
- What are our business’s strategic objectives? (Business can be replaced by department, program, product – any target in which you might be evaluating risk against.)
- What is our business’s risk appetite? Risk appetite is the amount and type of risk an organization is willing to accept to achieve strategic objectives. Risk appetite is typically stated in a qualitative manner and does not require a complicated process. It is meant to guide executive decision-making and overall prioritization.
- What is our business’s risk tolerance? Risk tolerance is the acceptable level of variation around the risk appetite. If your risk appetite is driving 65 mph, your risk tolerance might be 60-70 mph. If you find yourself going 80 mph, then you likely pursue corrective action and slow down.
Understand your governance framework – who owns the risk assessment and what are the different roles and responsibilities across the organization? This process should also include the “so what?” to your overall process. Why are you doing this assessment to begin with and what is the intended outcome? This will help you establish your scoring approach and the chicken and the egg of risk vs. compliance.
If starting with risk…
- What risks exist that could impede your strategic objectives?
- What stakeholders should contribute to that risk identification, if not explicitly called out in the governance framework?
If starting with compliance…
- What are the key controls to evaluate and where are there gaps?
- How effective is the control if it is in place?
Assign a disposition to each risk – then decide what to do…
- Accept (must be within our risk tolerance)
- Mitigate (ensure owner, timeline, and clear success metric)
- Transfer (typically insurance or outsourcing)
- Avoid (exit an activity, remove from scope)
Beyond the foundation, any solid risk assessment process has a clear understanding of reporting and continuous improvement. Once again – so what? We complete the assessment with a clear understanding of where we have gaps in our program. How do we fill those gaps and improve them systematically? And how do we make this process better next year?
An effective compliance program is one that evolves and improves over time.
– United States Department of Justice Guidance of an Effective Compliance Program
Overcoming the GRC imposter trap
GRC maturity isn’t driven by better processes, it’s driven by culture. Effective programs are top-down in nature.
- Shift your mindset from doing everything, to doing the right things right. It’s not about maturity models; it’s about executing with excellence.
- Simplify your GRC program into practical steps with clearer outcomes. Fewer processes with more accountability and documented ownership. Evaluate the usage of AI for consistency rather than fixing broken manual processes.
- Imperfection is part of a healthy GRC culture. It’s inevitable, but it doesn’t have to be overwhelming. Find comfort in the uncomfortable and recognize it is all part of the journey.
The irony of 2026 is that the biggest breakthroughs in this industry won’t come from AI or analytics, but rather from discipline and focus. If the 2026 version of our GRC programs has a theme, it should be humility. Getting back to the basics will be more impactful than any technological innovation. In the end, organizations that thrive will be those that stop pretending to be ahead.
2026 prediction
In 2026, we will see a significant influx of new GRC providers leading with agentic AI, solving very specific problems that are attractive to buyers. These disruptive providers will find themselves in at least 25% of deals by the second half of 2026. However, fewer than 10% will make it past initial stages of review as information security evaluation intensifies in this new era of GRC + AI. Fundamentally, the providers that can lead you through the basics will prevail.
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