Beyond compliance: ISO as your security and business catalyst

For many years, the Information Security Officer (ISO) was regarded primarily as a necessary constraint on business operations. While the role was indispensable, it was often narrowly focused on ensuring compliance, managing audits, denying requests when risks were deemed unacceptable, and satisfying regulatory requirements.

This paradigm has now changed. In the current landscape characterised by escalating cyber threats, increasing digital reliance, and heightened regulatory demands—particularly with the introduction of the Digital Operational Resilience Act (DORA)—the ISO is rapidly transitioning from a compliance enforcer to a strategic business partner. Progressive organisations are recognising that, when integrated appropriately, information security not only mitigates risk but also enhances organisational resilience, safeguards enterprise value, and delivers competitive advantage. For management and board of directors, this evolution necessitates a fundamental reassessment of how the ISO role is positioned, empowered, and evaluated.

Yet many organisations face a challenging paradox: rising regulatory expectations combined with limited resources, a shortage of specialised talent and the need to balance multiple competing priorities.

The evolving role of the ISO

The traditional ISO focused on controls: policies, standards, audits, and compliance reports. In contrast, the modern ISO focuses on decision-quality.

Today’s leading ISOs translate technical risk into clear business implication by addressing questions such as:

• What is the potential impact of this vulnerability on profit, beyond its effect on systems?
• How might this dependency influence our ability to serve customers during a crisis?
• Which risks are acceptable in pursuit of growth, and which pose existential threats?

Cyber risk is now routinely considered alongside financial, operational, and reputational risks. Boards do not require excessive technical detail; rather, they seek clarity, prioritisation, and informed trade-offs. An ISO who can frame security discussions in the language of strategy, resilience, and value creation becomes a trusted advisor—not merely a compliance enforcer.

Modern organisations expect ISOs to:

• Define and maintain organisation-wide information security strategies
• Articulate cyber and operational risk in business terms
• Demonstrate how security supports strategic objectives
• Lead cross-functional resilience initiatives
  

DORA: A compliance obligation or a strategic imperative?

Regulators across jurisdictions are increasingly explicit and demanding on digital and operational resilience. DORA is frequently framed in technical terms - information and communication technology (ICT) risk frameworks, incident management and reporting, third-party risk management, and resilience testing. However, at its essence, DORA is fundamentally a mandate for business continuity and operational resilience. It compels organisations to confront challenging, board-level questions:

• To what extent are we reliant on digital services beyond our full control?
• Do we clearly understand which systems are critical when all else fails?
• Are we capable of absorbing disruption while maintaining delivery of essential services?
• Can we confidently assert that our suppliers and partners possess the resilience we expect?

These are not merely ICT concerns; they are strategic and fiduciary responsibilities. Organisations that approach DORA as a mere compliance exercise may satisfy baseline requirements yet remain vulnerable. Conversely, those that embrace DORA as a catalyst for transformative change will strengthen their resilience and earn greater trust from customers, regulators, and markets alike. Cybersecurity and resilience are now core leadership responsibilities, making the modern ISO indispensable as a strategic leader safeguarding enterprise continuity.

The challenge of obtaining—and empowering—the right ISO

As expectations rise, many organisations struggle to find and empower the right ISO. The role has evolved at a pace that outstrips the availability of suitable talent. It demands a rare blend of technical expertise, risk acumen, communication skills, and strategic insight— often in short supply. While regulators acknowledge the need for proportionality, they expect firms to ensure the ISO role is adequately resourced relative to their risk profile, with key competencies either in-house or supported externally.

Conclusion

Organisations that thrive under regulations such as DORA will be those that embrace a fundamental truth: resilience is foremost a leadership capability, not merely a technical function. Investing in the right ISO is among the most effective strategies to satisfy regulatory demands while enhancing the organisation’s strategic resilience.

In a landscape where regulatory expectations are rising, threats are evolving rapidly, and trust is increasingly difficult to secure, the ISO role has transcended its traditional support function. It is now a critical leadership position charged with safeguarding not only systems but the organisation’s capacity to operate, compete, and grow.

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More in this series

This article has provided a comprehensive examination of how Information Security Officers (ISOs) are evolving from compliance gatekeepers to strategic business partners, driving both risk mitigation and competitive advantage. In the context of Chapter 3 of the Financial Institutions Rulebook (FIR/03) and European Banking Authority (EBA) Guidelines on outsourcing, this evolution is not merely aspirational—it is a regulatory imperative.

Our series explores critical risk management components essential for financial institutions operating in Malta and the EU.

• Article 1: "Enterprise risk management: Unlocking competitive advantage in Malta’s financial and crypto sectors": explores how disciplined ERM enhances regulatory compliance, protects capital, and builds trust, turning risk into competitive advantage amid evolving regulations. Discover how to strengthen governance and accelerate informed decision-making with effective ERM strategies.
• Article 2: “Third party risk management essentials: Navigating regulatory expectations”: provides a comprehensive framework for assessing, monitoring, and managing third-party relationships in accordance with Chapter 3 of the Financial Institutions Rulebook (FIR/03) and European Banking Authority (EBA) Guidelines on outsourcing.
• This article: “Beyond compliance: ISO as your security and business catalyst”: examines how information security officers (ISOs) are evolving from compliance gatekeepers to strategic partners who drive both risk mitigation and competitive advantage in the context of DORA and evolving cybersecurity threats.