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Compliance software is not a compliance function

By Joe Zhou ·

  • Virtual Compliance Officer
  • Compliance Operation
  • Enterprise Security Review

Software automates the tasks. Someone still has to own the outcome.

For the last few years the compliance industry has been focused on automation. Connect your cloud environment. Collect evidence automatically. Monitor controls. Generate policies. Draft security questionnaire responses.

All of that is useful. But there is a pattern I keep seeing in growing AI and technology companies: they have compliance software, and they still do not have anyone running compliance.

The dashboard tells you a control has failed. It does not decide how urgently it needs to be fixed. It flags missing evidence. It does not chase the right people, judge whether the evidence is sufficient, or explain it to an auditor. It drafts an answer to an enterprise security questionnaire. Someone still has to stand behind that answer.

And when an enterprise customer asks a hard question about your AI architecture, data handling, model providers or governance, somebody has to make a judgement.

That gap between automation and accountability is why we built Complyd around a different model.

The virtual compliance officer

A virtual compliance officer is not another dashboard. It is an accountable compliance function for companies that need to earn enterprise trust but are not ready, or do not need, to build an internal compliance team.

In practice that means we take ownership of:

  • ISO 27001 and ISO 42001 readiness
  • enterprise security reviews
  • evidence and control management
  • customer and vendor due diligence
  • risk management
  • internal and external audit preparation
  • certification body coordination
  • AI governance
  • ongoing compliance operations

The goal is not to produce more compliance activity. The goal is to make sure the work gets done.

Compliance becomes urgent at exactly the wrong time

Most technology companies do not wake up one morning and decide they would like an ISMS. The trigger usually looks more like this. A major customer sends a security questionnaire. Procurement asks whether you are ISO 27001 certified. A bank or a hospital wants to understand how you govern AI. An investor asks for evidence during due diligence. An auditor wants records nobody can immediately locate.

Suddenly the CTO, the engineering lead or the founder becomes the compliance team. And it usually happens at the point the company is trying to move faster.

That is the contradiction. The bigger the opportunity, the more trust the customer requires, and satisfying those requirements pulls your best technical people away from the work that created the opportunity.

Compliance should not become a tax on engineering velocity.

Enterprise trust is the outcome

The industry talks too much about compliance itself. Customers rarely care how many policies you have. They care whether they can trust you.

Can you protect their information? Do you understand your risks? Are your controls actually operating? Can you explain how your AI systems are governed? Can you demonstrate that what you say is supported by evidence? Can their procurement, security and risk teams approve you?

ISO certification, security reviews and AI governance are mechanisms for answering those questions. The outcome is enterprise trust, and for a growing technology company that is now part of the infrastructure required to sell.

Software is part of the answer

This is not an argument against compliance platforms. Automation is valuable when it removes repetitive work. A good system collects evidence from your stack, monitors controls, organises documentation and reduces the manual effort involved in demonstrating compliance. We use automation wherever it makes sense.

The distinction is what sits above it. Think of the compliance stack in three layers.

Layer What sits there Who owns it
Systems Cloud infrastructure, repositories, ticketing, vendors, documentation, business systems Your engineering and operations teams
Automation Evidence collection, control monitoring, workflow reminders, questionnaire assistance Your compliance platform
Ownership What matters, what gets fixed first, whether you are audit ready, how to answer this customer, whether this evidence proves the control, how the requirement applies to your AI architecture, who keeps the program moving after certification Nobody, in most companies

The Systems and Automation layers make compliance more efficient. The Ownership layer is the one that decides anything, and it is the layer the virtual compliance officer owns.

This matters more for AI companies

Traditional compliance frameworks were not written with changing model providers, generative AI applications and increasingly autonomous systems in mind.

An AI software company might depend on several external model providers. A consultancy might be deploying AI inside a customer environment. An agency may handle sensitive customer data across a dozen tools. A technical services company may operate systems that become part of a client's critical workflow. The business models differ. The enterprise trust problem is close to identical.

Customers want to know:

  • what data enters AI systems
  • where that data goes
  • which model providers are involved
  • how models and vendors are assessed
  • what happens when outputs are wrong
  • what humans remain accountable for
  • how AI-related risks are identified and monitored
  • whether security and governance claims can be demonstrated

A policy template does not answer those questions. Someone has to understand the requirement and the technology behind it. That is where the compliance function for AI companies has to evolve.

Certification is not the finish line

Another pattern I see repeatedly is companies treating certification as a project. Get ISO 27001. Pass the audit. Move on.

Except compliance does not stop. Customers keep sending questionnaires. Employees, suppliers and systems change. Evidence goes stale. Risks change. New products launch. Models change. Surveillance audits arrive. New enterprise customers ask different questions. The management system has to keep operating.

So our model is not "get certified". It is map, implement, certify, operate.

First, work out what customers, auditors and regulators actually require. Then build the controls and evidence into the way the company already works. Prepare the program for certification. Then keep the compliance function operating once the certificate is on the wall.

What this looks like in practice

One of our healthcare AI clients needed to move quickly. We took ownership of its ISO 27001 program, guiding the ISMS through to certification while the engineering team kept building the product. After certification, we stayed on to run the compliance function.

That reinforced something I had already seen as a technology leader: compliance works when someone is clearly accountable for it.

One question, from a hospital security assessment

Certification is not where most of the work happens. Here is a better illustration.

That accountability becomes especially important when a customer starts asking detailed questions.

In February 2026, a private hospital group assessed the platform across four security domains, drawing on ISO 27001. It was the kind of assessment you encounter when clinical data is involved.

One question amounted to this: is patient data stored offshore?

A one-word answer would miss the point.

In the workflow being assessed, consultation audio was captured in Australia and sent over an encrypted API to speech-to-text providers in the United States. Those providers operated under a contractual zero data retention commitment: they processed the audio and returned a transcript to the Australian environment without retaining it.

Clinical notes were then generated using AWS Bedrock in the Sydney region. The original audio remained in Australia, with deletion enabled by default.

Explaining that distinction matters. Australian storage and zero offshore retention do not, by themselves, settle whether overseas processing constitutes a cross-border disclosure under APP 8. That requires examining the arrangement, including who retains effective control over the information.

A questionnaire assistant can draft a fluent response in seconds. But someone still has to verify the data flow, check the provider commitments and make sure the answer matches the company’s trust page and privacy policy.

They also need to look beyond the wording of the question. Storage is only part of the picture. Where is the data processed? Who can access it? Which jurisdictions could require its disclosure?

Someone has to stand behind the answer, put their name on it and be there when the hospital’s security team comes back with a follow-up.

That is the work.

Why we built Complyd this way

Before Complyd, I spent most of my career on the other side of the table: building technology companies, selling to enterprise customers, and dealing with the operational reality of security reviews, due diligence and audits.

I know what happens when the compliance requirement lands with an engineering team. The intention is usually "can someone just get this questionnaire done". Then comes another questionnaire. Then ISO. Then vendor due diligence. Then an audit. Then AI governance. Eventually a set of occasional tasks becomes a function.

At that point the company has two choices. Build the function internally, or have someone own it. Complyd exists for the second.

A different model for compliance

The next evolution of compliance will not be a choice between people and software. It will be both. Automation handles more of the repetitive work. Experienced people make the decisions where judgement and accountability matter. Over time, AI will take on substantially more of the compliance workflow.

But the customer should not have to care which task is being done by software, by an agent, or by a compliance professional. The question they care about is simpler: is compliance handled?

That is the product we are building toward. A compliance function that combines technology, automation and accountable ownership, designed for AI and technology companies that need to earn enterprise trust without slowing down delivery.

Software automates the tasks. Complyd owns the outcome.


Is compliance becoming somebody's second job?

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