In conversations about Regulation S-P, a lot of the discussion tends to focus on controls.
Whether safeguards are in place. Whether tools are deployed. Whether vendors meet baseline requirements.
With Reg S-P now in effect for larger firms and approaching quickly for others, a different question now matters just as much: can your firm explain, demonstrate, and stand behind those controls in an instant — under pressure?
As CFOs, we dread moments when confident plans deteriorate into scrambles for answers. Like it or not, the ability to produce unequivocal evidence is now an operational imperative. So it’s time to start making “prove it” part of every cyber governance activity. Let’s get into it.
Why assuming evidence is covered is a bad move
Under Reg S-P, firms are expected to both safeguard customer information and show how those safeguards are governed, tested, and overseen.
In practice, that means evidence needs to show four things:
- Policies and procedures exist
- Controls operate as intended
- Oversight occurs consistently
- Actions can be demonstrated clearly
Most organizations are comfortable with the first two. The last two tend to reveal strain once programs are tested under real conditions.
Repeat after me: Evidence readiness is less about how much documentation you have and more about how clearly you can explain it under scrutiny.
How evidence pressure shows up
Evidence gaps can be easy to overlook — until timelines are short and requests arrive before teams are fully prepared.
Across organizations, similar patterns appear.
Evidence is dispersed
Artifacts exist, but they live across:
- Shared drives
- Ticketing systems
- Vendor portals
- Individual inboxes
Pulling a coherent record together becomes a massive coordination exercise.
Ownership of proof is unclear
Responsibilities are often implied:
- IT assumes compliance is tracking documentation
- Compliance assumes vendors or MSPs hold operational proof
- Vendors assume governance records live internally
Without a clear owner, evidence quality varies over time.
Records fall out of date
Controls evolve as environments change. Evidence doesn’t always keep pace.
- Policies lag behind technical updates
- Exceptions persist without review
- Exercises occur without documented follow-through
This weakens credibility even when intent and effort are strong.
Demonstration depends on who is asked
Teams understand how things work, but explanations differ.
- The story changes slightly by role
- Proof is assembled differently each time
From an exam or incident standpoint, inconsistency raises questions.
The bottom line is this: We should all expect Reg S-P examiners to skip right past whether or not a control exists — and go straight to who owns it, how it’s reviewed, and how leadership knows it’s still working.
Why evidence responsibility lands on leaders’ desks
When evidence isn’t readily available, the burden moves upward.
Leadership gets involved in:
- Locating artifacts
- Reconstructing timelines
- Reconciling different versions of events
- Responding to follow-up questions
From a finance seat, that time diversion matters. It introduces distraction and uncertainty at moments when you can least afford them.
Evidence readiness reduces that friction by making cyber governance execution defensible without making anyone jump through hoops.
What effective evidence readiness looks like
Strong programs don’t attempt to capture everything. They focus on demonstrating that oversight is real and repeatable.
At a minimum, evidence should show:
- Ownership of policies and procedures
- Operation and testing of key controls
- Vendor oversight activities and follow-up
- Incident response preparation and updates
Equally important, leadership knows where this information lives and how it stays current.
Quick evidence-readiness pressure test
To run a simple evidence posture assessment, ask your teams:
- Can we produce recent vendor oversight artifacts, including findings and closure?
- Can we show the most recent incident response exercise and what changed as a result?
- Can we demonstrate access reviews and how exceptions are tracked?
- Can we explain how alerts escalate and show that process has been tested?
- Can leadership point to a single source of truth without searching?
Hesitation or inconsistency signals the evidence gaps you need to address now.
Strengthen evidence with the resources you already have
In my experience, improving evidence readiness usually comes down to three moves:
- Name an accountable owner. One person ensures evidence exists, stays current, and is explainable across teams and vendors.
- Define a minimal evidence model. Decide what proof matters, where it lives, and how it’s maintained.
- Establish a regular cadence. Periodic reviews prevent last-minute reconstruction and reduce exam friction.
These steps make evidence part of day-to-day operations — which can help make any cyber governance program stronger.
Build evidence confidence before it’s tested
Evidence doesn’t fail all at once — confidence in your cybersecurity governance does.
Under Reg S-P, leadership needs to be able to explain how cyber protection is governed, reviewed, and still working when questions arise.
Our Reg S-P Readiness: Executive Self-Assessment can help teams see whether that level of explainability is built into daily operations — or still depends on last-minute effort.
Ultimately, navigating Reg S-P comes down to building confidence that holds up on demand. Evidence is what makes that possible.