1. Purpose
The Regulatory Compliance Register identifies the laws, regulations, regulatory requirements, contractual obligations, and other compliance requirements applicable to the organization.
It provides a central record of:
- What requirements apply
- Why they apply
- Which business activities they affect
- Who owns them
- What controls address them
- What evidence demonstrates compliance
- When they were last reviewed
The register should be used as a living document and updated when there are changes to the organization’s business, technology, customers, jurisdictions, or applicable requirements.
2. What Should Be Included?
Depending on the organization, the register may include:
- Laws
- Regulations
- Regulatory guidelines
- Industry requirements
- Government requirements
- Customer contractual requirements
- Security requirements in contracts
- Privacy requirements
- Licensing requirements
- Certification requirements
- Internal compliance commitments
The organization should include only requirements that are actually applicable to its business.
3. Regulatory Compliance Register
| ID | Requirement / Regulation | Jurisdiction | Requirement Type | Why Applicable | Business Area | Key Requirement | Control / Process | Owner | Evidence | Review Frequency | Last Reviewed | Status |
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| REG-001 | [Law / Regulation] | India | Privacy | Organization processes personal data | Privacy | Data protection requirements | Privacy Program | Privacy Lead | Privacy records | Annual | [Date] | Applicable |
| REG-002 | [Regulation] | [Country] | Cybersecurity | Customer contract / operations | Security | Security controls | ISMS | Security Lead | ISMS evidence | Annual | [Date] | Applicable |
| REG-003 | [Regulation] | [Jurisdiction] | Industry | Organization operates in regulated sector | Compliance | Regulatory requirements | Compliance Process | Compliance Lead | Compliance reports | Quarterly | [Date] | Applicable |
| REG-004 | [Contract Requirement] | [Customer] | Contractual | Customer contract | Customer Security | Security notification | Incident Management | Security Lead | Incident records | Contract review | [Date] | Applicable |
4. Recommended Register Fields
Requirement ID
Assign a unique identifier.
Example:
REG-001
REG-002
REG-003
This makes it easier to reference requirements in risk assessments, audits, policies, and compliance reports.
Requirement Name
Record the official name of the law, regulation, standard, contractual requirement, or other obligation.
Examples may include:
- Data protection legislation
- Cybersecurity regulation
- Industry regulation
- Customer security requirements
- Contractual security clauses
Jurisdiction
Record where the requirement applies.
Examples:
- India
- United States
- European Union
- United Kingdom
- Specific U.S. state
- Customer-specific jurisdiction
A company operating internationally should not assume that a requirement applies globally simply because it has customers in that jurisdiction.
Requirement Type
Suggested categories:
- Law
- Regulation
- Regulatory Guidance
- Industry Requirement
- Contractual Requirement
- Customer Requirement
- Certification Requirement
- Internal Requirement
Applicability
Document why the requirement applies.
For example:
“The organization processes personal information of individuals in the applicable jurisdiction.”
or:
“The organization provides services to a regulated financial-services customer and the customer contract contains specific security requirements.”
This is important because an auditor should be able to understand the basis for including the requirement.
5. Business Area
Identify the part of the organization affected.
Examples:
- Information Security
- Privacy
- HR
- Finance
- Procurement
- Engineering
- IT
- Cloud Operations
- Sales
- Customer Support
- Product
- Physical Security
6. Key Requirement
Summarize what the organization needs to do.
Avoid copying entire legislation or regulations into the register.
Instead, record concise requirements such as:
- Maintain appropriate security controls.
- Protect personal information.
- Maintain required records.
- Report certain incidents within applicable timeframes.
- Restrict access to authorized personnel.
- Retain records for the required period.
- Implement contractual security requirements.
The detailed legal interpretation should be maintained in appropriate legal/compliance documentation where necessary.
7. Control / Process
Identify the organizational process or control used to address the requirement.
Examples:
| Requirement | Control / Process |
|---|---|
| Personal data protection | Privacy Management |
| Access restriction | Access Control |
| Security incidents | Incident Management |
| Supplier requirements | Supplier Security |
| Data retention | Records Retention |
| Security monitoring | Logging & Monitoring |
| Business continuity | Business Continuity |
| Employee obligations | HR Security |
This creates a useful relationship:
Requirement → Risk → Control → Evidence
8. Requirement Owner
Assign a responsible person or function.
Possible owners:
- Compliance Manager
- Privacy Lead
- Security Lead
- Legal
- HR
- IT
- Finance
- Procurement
- CTO
- Business Owner
The owner is responsible for monitoring the requirement and coordinating compliance activities.
9. Evidence
Identify what demonstrates that the requirement is being addressed.
Examples:
- Policies
- Procedures
- Risk assessments
- Access reviews
- Training records
- Security logs
- Contracts
- Supplier assessments
- Incident records
- Audit reports
- Compliance assessments
- Management review records
Avoid simply writing “Policy” for every requirement.
Where possible, identify operational evidence showing that the requirement is actually implemented.
10. Review Frequency
Define an appropriate review frequency.
Examples:
- Monthly
- Quarterly
- Semi-annually
- Annually
- Contract renewal
- Regulatory change
- Business change
The frequency should depend on the nature and risk of the requirement.
11. Last Reviewed
Record the date on which the requirement was last reviewed.
Example:
30-Sep-2026
12. Status
Suggested values:
- Applicable – Compliant
- Applicable – Action Required
- Applicable – Under Review
- Partially Implemented
- Not Yet Implemented
- Not Applicable
- Retired
13. Applicability Assessment
Not every regulation applies to every organization.
The organization should assess applicability using factors such as:
Geography
Where does the organization operate?
Customers
Where are customers located?
Individuals
Whose personal data is processed?
Industry
Does the organization operate in a regulated sector?
Services
What products or services are provided?
Data
What types of information are processed?
Contracts
What security or compliance obligations have customers imposed?
Technology
Does the organization use systems or services subject to specific requirements?
14. Example – SaaS Startup
Consider an India-based SaaS company serving customers in India, the United States, and Europe.
Its compliance register might contain categories such as:
| Requirement Area | Applicability Question |
|---|---|
| Indian privacy requirements | Does the company process personal data in India? |
| Overseas privacy requirements | Does the company’s activity create obligations in other jurisdictions? |
| Customer contractual requirements | Do customer contracts contain security/privacy obligations? |
| Payment requirements | Does the company process payment-card information? |
| Financial-sector requirements | Does the company provide services to regulated financial entities? |
| Employment requirements | Does the company process employee information? |
| Cybersecurity requirements | Are there applicable cybersecurity reporting or security obligations? |
The organization should perform an actual applicability assessment rather than automatically marking every regulation as applicable.
15. Regulatory Change Monitoring
The organization should establish a process for identifying changes to applicable requirements.
Sources may include:
- Government websites
- Regulatory authority websites
- Legal counsel
- Compliance advisors
- Industry associations
- Customer contractual updates
- Regulatory notifications
- Official regulatory newsletters
When a change is identified:
Identify Change
↓
Assess Applicability
↓
Determine Impact
↓
Identify Required Changes
↓
Assign Owner
↓
Implement Changes
↓
Collect Evidence
↓
Update Register
16. Regulatory Change Record
A separate change log can be useful.
| Change ID | Requirement | Change Identified | Impact | Action Required | Owner | Due Date | Status |
|---|---|---|---|---|---|---|---|
| RC-001 | [Requirement] | [Description] | High | Update privacy process | Privacy Lead | [Date] | Open |
| RC-002 | [Requirement] | [Description] | Medium | Update contract language | Legal | [Date] | Closed |
This provides evidence that regulatory changes are actively monitored rather than simply listed.
17. Compliance Gap Assessment
When a requirement changes or a new requirement becomes applicable, perform a gap assessment.
Example:
| Requirement | Current State | Gap | Action | Owner | Target Date |
|---|---|---|---|---|---|
| Data retention | Retention periods documented | Review required | Update retention schedule | Privacy | [Date] |
| Breach notification | Procedure exists | Regulatory deadline needs review | Update procedure | Legal | [Date] |
| Supplier security | Supplier review performed | Contract clause missing | Update contracts | Procurement | [Date] |
18. Relationship With the Risk Register
Regulatory requirements can create information security risks.
Example:
Regulatory Requirement
Personal information must be appropriately protected.
↓
Business Risk
Unauthorized access to personal information.
↓
Risk Assessment
Likelihood × Impact
↓
Risk Treatment
Strengthen access control.
↓
Control
MFA + least privilege + access reviews.
↓
Evidence
Access review records + IAM configuration + authentication logs.
This creates a traceable relationship between compliance requirements and information security risk management.
19. Relationship With the Statement of Applicability
Where a regulatory requirement creates an information-security control requirement, the organization should consider whether the necessary control is addressed through:
- Annex A controls
- Other controls
- Existing business processes
- Contractual controls
- Organization-specific controls
The SoA should reflect the controls that are necessary for the organization’s ISMS, rather than treating the Regulatory Compliance Register as a substitute for the risk assessment or SoA.
20. Regulatory Compliance vs ISO 27001
These are different concepts.
| ISO 27001 | Regulatory Compliance |
|---|---|
| Establishes an information security management system | Addresses specific legal/regulatory obligations |
| Risk-based | Requirement-based |
| Organization defines its ISMS methodology | Requirements come from applicable external sources |
| Uses risk treatment to determine necessary controls | May mandate specific obligations |
| Includes continual improvement | May require specific reporting, retention, privacy, or security activities |
ISO 27001 compliance does not automatically mean that the organization complies with every applicable law or regulation.
21. Regulatory Compliance and Contracts
Customer contracts can create important security obligations even when they are not laws or regulations.
Examples:
- Security incident notification
- Data protection requirements
- Encryption requirements
- Access control
- Security testing
- Audit rights
- Data retention
- Data deletion
- Business continuity
- Supplier restrictions
These requirements should be tracked where they create obligations for the organization.
22. Audit Evidence
An auditor may examine:
- Regulatory Compliance Register
- Applicability assessments
- Regulatory change records
- Legal/compliance reviews
- Contracts
- Policies and procedures
- Risk assessments
- Compliance assessments
- Internal audit results
- Regulatory correspondence
- Incident notification records
- Corrective action records
- Management review records
The auditor may ask:
“How does the organization know which legal, regulatory, contractual, and other requirements apply to its information security activities?”
The register should provide a clear answer.
23. Startup-Friendly Implementation
A small organization does not need hundreds of pages of legal analysis.
A practical approach is:
Step 1
Identify jurisdictions and business activities.
Step 2
Identify relevant laws, regulations, and contracts.
Step 3
Document why each requirement applies.
Step 4
Summarize the relevant security/privacy obligation.
Step 5
Map the requirement to an owner and process.
Step 6
Identify evidence.
Step 7
Monitor changes.
Step 8
Review the register periodically.
Step 9
Update the risk assessment and controls when requirements change.
24. Quick Compliance Register Checklist
- Applicable jurisdictions identified
- Relevant laws identified
- Relevant regulations identified
- Industry requirements identified
- Customer contractual requirements identified
- Applicability assessed
- Requirement owners assigned
- Security/privacy obligations documented
- Controls/processes mapped
- Evidence identified
- Regulatory change monitoring defined
- Review frequency defined
- Last review date recorded
- Changes tracked
- Compliance gaps tracked
- Risk Register updated when required
- Management informed of significant compliance issues
25. Final Principle
The Regulatory Compliance Register should answer five questions:
What requirements apply to us?
Why do they apply?
What do we need to do?
Who is responsible?
How can we demonstrate compliance?
The practical compliance chain is:
Requirement → Applicability → Obligation → Risk → Control → Owner → Evidence → Review → Improvement