For decades, Governance, Risk, and Compliance (GRC) has been a world of paper, spreadsheets, and periodic audits. It’s a world where a team of auditors descends once a year, armed with checklists, to interview teams, collect evidence, and ultimately produce a report that is often outdated the moment it’s printed.
We treated compliance as a snapshot in time, a necessary, but often dreaded, event.
In the age of the cloud, continuous deployment, and ephemeral infrastructure, this model is not just outdated; it’s broken. Research consistently shows that traditional, periodic audits are insufficient for detecting threats and ensuring continuous compliance in dynamic cloud environments (Karakasilioti et al., 2024; Rahman et al., 2024). The speed of modern software development has outpaced the speed of the traditional audit. A system that was compliant at 9 AM on Monday might be non-compliant by noon, thanks to a single misconfigured deployment script.
The future of GRC isn’t a better spreadsheet or a more detailed checklist. The future is code.
Welcome to Compliance-as-Code (CaC).
What is Compliance-as-Code? #
Compliance-as-Code is a simple but profound idea: define your compliance requirements as a set of programmable, machine-readable rules, and then automate the process of checking your systems against those rules.
Instead of a human auditor manually checking if an S3 bucket is private, you write a script that programmatically asks the AWS API, “Is this bucket public?” Instead of a policy document stating “All servers must be patched,” you have a configuration management tool that defines the required patch level as an attribute of the server itself.
This isn’t just about automation; it’s a fundamental philosophical shift. It moves compliance from a reactive, after-the-fact activity performed by a separate team, to a proactive, integrated part of the engineering lifecycle.
Three Pillars of the CaC Revolution #
This shift is happening because the traditional model fails to address the realities of modern IT. The literature points to a critical gap: a lack of standardized, real-world testing methodologies makes it difficult for organizations to assess their true compliance posture (Madan, Dave & Tandon, 2016). Compliance-as-Code directly addresses this gap in three key areas:
1. The Mandate for Continuity #
Traditional manual security audits are, by nature, periodic, typically conducted quarterly or annually. This approach fails to account for the ongoing, dynamic changes in cloud environments, leaving institutions vulnerable between assessments. Regulations like the EU’s Digital Operational Resilience Act (DORA) explicitly recognize this shortcoming by mandating continuous monitoring and risk management.
Compliance-as-Code meets this mandate head-on. By integrating compliance checks directly into the CI/CD pipeline, organizations can achieve a state of continuous validation. Before a single line of infrastructure code is deployed, it can be automatically scanned against a library of compliance rules. This transforms compliance from a slow, lagging indicator into a real-time, preventative control.
2. The Evidence of Scale #
The sheer scale and complexity of modern cloud environments make manual auditing technically infeasible. A single enterprise might have thousands of virtual machines, hundreds of databases, and millions of configuration settings. As my thesis research confirmed, programmatic analysis is the only viable method for comprehensive assessment.
My experimental study involved developing a Python-based scanner using the Boto3 SDK. The objective was to programmatically assess an AWS environment against DORA requirements. This tool could systematically analyze S3, EC2, IAM, and VPC configurations, a task involving thousands of API calls and data points in a matter of minutes. A human team would require weeks to achieve a fraction of this coverage, and with a much higher probability of error. This empirically demonstrates that to manage compliance at cloud scale, code is not an option; it is a necessity.
3. The Power of Collaboration #
The traditional audit process often creates a culture of friction. Developers may see auditors as a roadblock, and auditors may see developers as a source of non-compliance. This siloed approach is inefficient and counterproductive.
Compliance-as-Code reframes the conversation by creating a shared, transparent foundation. The compliance rules are no longer a mysterious document held by the GRC team; they are a codebase, stored in a Git repository, open for anyone to see, question, and contribute to. When a compliance check fails in the pipeline, it’s not an accusation; it’s a failed test.
This makes compliance a shared engineering problem. As my thesis project demonstrated, the output of a scanner can be visualized in an interactive dashboard (using Streamlit) or a PDF report, providing actionable insights for all stakeholders. This creates a common language, enabling developers and GRC teams to collaborate on remediation, fostering a culture of shared ownership.
The Path Forward #
Making the transition to Compliance-as-Code requires a new set of skills and a new mindset.
- GRC professionals must learn the basics of scripting and APIs. They need to be able to read and understand policy-as-code languages to translate regulatory text into testable rules.
- Developers and DevOps engineers must embrace security and compliance as a core part of their job, the “Sec” in DevSecOps. They must see compliance rules not as arbitrary restrictions, but as essential design constraints for building resilient systems.
The future of GRC is not about replacing auditors with robots. It’s about empowering them with better tools and integrating their expertise directly into the systems they are charged with overseeing. It’s about transforming compliance from a periodic, manual chore into a continuous, automated, and collaborative discipline.
The checkbox is dead. Long live the code.
References #
- Jansson, I. (2021). Continuous Compliance Automation in AWS cloud environment. [online] www.doria.fi. Available at: https://www.doria.fi/handle/10024/181213.
- Karakasilioti, G.M. (2024). Supporting the digital operational resilience of the financial sector : the EU’s DORA Digital Operational Resilience Act. [online] dione.lib.unipi.gr. Available at: https://dione.lib.unipi.gr/xmlui/handle/unipi/16273.
- Madan, M., Dave, M. and Tandon, A. (2016). Challenges in Testing of Cloud Based Application. ResearchGate, 5(1), pp.2277–9043.
- Rahman, A., Ashrafuzzaman, M., Jim, M.M.I. and Sultana, R. (2024). Cloud Security Posture Management Automating Risk Identification and Response in Cloud Infrastructures. ACADEMIC JOURNAL ON SCIENCE, TECHNOLOGY, ENGINEERING & MATHEMATICS EDUCATION, 4(3), pp.151–162.
- Torkura, K.A., Sukmana, M.I.H., Cheng, F. and Meinel, C. (2021). Continuous auditing and threat detection in multi-cloud infrastructure. Computers & Security, 102, p.102124.