You don't need a crystal ball

For a long time, the implicit expectation on GRC leaders was to see change coming. Read the regulatory tea leaves early enough, and you could get ahead of it. That expectation is becoming less useful by the month, and the conversations I'm in with GRC leaders right now reflect that shift directly.

Regulators are no longer moving in one direction. In some markets, assertiveness is receding, and firms are quietly recalibrating how much they expect to be held to account. In others, regulators are asserting themselves harder, in part as correction, in part in response to the pace of change around them. In a third group, regulators are watching everyone else, borrowing what looks relevant, waiting to see how the position settles before committing to one of their own. There is no longer a single global signal to read. There are several, moving at different speeds, in different directions, and reading all of them accurately at once is no longer a realistic standard to hold yourself to.

I heard something recently, relayed from a closed-door conversation involving the FCA last month, that reframed this well. I wasn't in the room, so I won't put it in quotation marks, but the sentiment was this: the regulator does not expect GRC leaders to have a crystal ball. It does not expect prediction. What it expects is that we do the things we already know we should be doing, and do them well.

That is a narrower, more workable standard than trying to anticipate every divergent signal. It means the testing actually happens, not just the plan to test. It means asking the difficult question in the meeting, not after it. It means the MI is reviewed with real scrutiny, not signed off on trust. It means being in the room when a decision is made, and having the hard conversation when something looks wrong.

None of that requires knowing what a regulator will do in six months. It requires consistency in what is already within your control.

This is the standard I see the strongest GRC leaders holding themselves to at the moment. I'd be interested to hear whether it matches what you're navigating too.

All the best,

Emily