Cybersecurity governance maturity

The cybersecurity governance maturity requirement means you must assign clear ownership, decision rights, and review checkpoints for your cybersecurity capability maturity scores, and keep evidence that governance operates in practice. Operationalize it by naming accountable owners for each maturity domain, running a recurring governance cadence, approving target maturity levels, and tracking gaps to closure ¹.

Key takeaways:

• Governance maturity is about accountable ownership of maturity scores, not a one-time assessment ¹.
• Auditors look for decision records, cadence, and closed-loop remediation tied to maturity targets ¹.
• Your fastest path is a lightweight governance charter, RACI, and a maturity scorecard with named owners and quarterly checkpoints ¹.

“Cybersecurity governance maturity” is a governance-and-accountability requirement, not a technical control. In the C2M2 framing, you are expected to define who owns cybersecurity capability maturity, how maturity is measured and approved, and how the organization makes decisions based on maturity outcomes ¹.

For a CCO, GRC lead, or security governance owner, the practical question is simple: can you prove that maturity targets are set intentionally, that owners are accountable for results, and that leadership oversight exists with a repeatable cadence? If you cannot produce those artifacts quickly, most maturity efforts degrade into slideware, inconsistent scoring, and unfunded remediation backlogs.

This page gives requirement-level implementation guidance you can put into motion immediately: who should own what, what meetings and decision points to establish, what documents to create, and what evidence to retain so you can pass an audit or internal assurance review. The goal is to move from “we did a maturity assessment” to “we govern maturity like a managed program with accountable outcomes” ¹.

Cybersecurity governance maturity requirement (C2M2): plain-English meaning

Plain-English interpretation: You must define governance and accountability for your cybersecurity capability maturity, meaning someone is responsible for (1) setting maturity targets, (2) owning the scores, (3) approving changes, and (4) driving gaps to closure with leadership visibility ¹.

This requirement is “medium” severity in many programs because it is a force multiplier. Weak governance does not always cause an incident directly, but it reliably causes inconsistent control ownership, poor prioritization, and hard-to-defend risk acceptance decisions.

Regulatory text

C2M2 excerpt (requirement statement): “Define governance and accountability for cybersecurity capability maturity.” ¹

What the operator must do:
You need an operating model that answers, in writing and in practice:

1. Who is accountable for maturity outcomes (by domain and overall) ¹.
2. How maturity is assessed and scored, including how scoring disputes are resolved and who approves the final score ¹.
3. How decisions get made from results (target maturity levels, funding, prioritization, risk acceptance, exception handling) ¹.
4. How often governance occurs and what evidence shows it happened ¹.

Who it applies to (entities and operational context)

C2M2 is widely used by critical infrastructure operators and energy sector organizations as a maturity model for cybersecurity capability evaluation and improvement ¹. Practically, you should treat this requirement as applicable when:

• You run a cybersecurity program with multiple capability areas (policy, risk, identity, incident response, OT/ICS security, third-party risk, etc.).
• You report cyber posture to executives, a board, regulators, customers, insurers, or a critical infrastructure oversight body.
• You rely on third parties for material technology or operations, since maturity governance must assign ownership for third-party-driven gaps as well.

Where it lives operationally: Usually in the intersection of the CISO org (security outcomes), GRC (measurement, evidence, governance), enterprise risk (risk acceptance), and IT/OT leadership (execution and funding).

What you actually need to do (step-by-step)

Use this as a build checklist. Keep it lightweight, but make it auditable.

Step 1: Define the governance scope and maturity “objects”

• Pick the maturity domains/capabilities you will govern (for example, C2M2 domains, or your internal mapping to them) ¹.
• Define what a “maturity score” means in your organization: scoring scale, evidence expectations, and how you handle partial implementation ¹.

Deliverable: Maturity scoring standard (1–3 pages) owned by GRC/security governance.

Step 2: Assign accountable owners (RACI with teeth)

For each maturity domain/capability:

• Assign an Accountable Owner (single name/role) who signs off on the current score and the target score ¹.
• Assign Responsible Executors (IT, security engineering, OT, third party management) for closing gaps.
• Assign Consulted stakeholders (privacy, legal, procurement, internal audit) where maturity claims depend on them.
• Assign Informed leadership (CISO, CRO/ERM, CIO/COO, board committee as applicable).

Rule: Avoid shared accountability. Shared accountability usually produces “everyone thought someone else owned it.”

Deliverable: A RACI matrix that ties each maturity domain to a named accountable owner ¹.

Step 3: Establish governance checkpoints and a cadence

Stand up a governance cadence that is frequent enough to drive decisions and produce evidence:

• A Maturity Review meeting: review scores, evidence quality, scoring disputes, and trend movement.
• A Decision Forum (can be the same meeting if small): approve target maturity levels, approve remediation plans, approve risk acceptances tied to maturity gaps.

Document:

• Agenda template
• Required attendees (by role)
• Inputs (scorecard, evidence pack, gap register)
• Outputs (decisions, actions, owners, due dates)

This directly supports the recommended control: “Establish governance checkpoints and maturity score ownership.” ¹

Deliverables: Meeting charter + recurring calendar invites + decision log format.

Step 4: Set target maturity levels and map them to risk and funding

You need target maturity levels per domain. Targets should reflect:

• Business criticality (crown-jewel systems, OT/ICS environments, regulated data)
• Threat exposure and operational tolerance
• Dependencies on third parties (for example, outsourced SOC, managed OT, SaaS identity)

Then translate targets into:

• A prioritized backlog (gaps that prevent target attainment)
• Funding asks (budget, headcount, third-party spend)
• Risk acceptances for gaps you will not close near-term

Deliverables: Target maturity statement + maturity-to-roadmap mapping.

Step 5: Implement closed-loop tracking from gaps to closure

Create a maturity gap register that includes:

• Current score, target score, and rationale
• Gap description tied to evidence missing or control weakness
• Remediation action(s), owner, due date
• Status and proof of completion
• Residual risk and acceptance (if applicable)

Deliverables: Gap register + remediation tickets/epics in your work system + link to evidence.

Step 6: Evidence readiness (“show me” test)

Run a self-check where you pretend you are the examiner:

• Can you show who owns each domain score?
• Can you show the last governance checkpoint occurred and what it decided?
• Can you show actions were tracked and closed?

If you can’t produce this in a single evidence folder, governance isn’t operating.

Where Daydream fits naturally: If you’re coordinating maturity ownership across multiple teams and third parties, Daydream can function as the system of record for owners, checkpoints, decisions, and the evidence pack so you can answer audits without manual re-assembly.

Required evidence and artifacts to retain

Keep artifacts in an audit-friendly structure (by domain and by meeting date).

Minimum evidence set (operator-ready):

• Governance charter for cybersecurity maturity (scope, roles, authority) ¹
• RACI matrix mapping maturity domains to accountable owners ¹
• Maturity scoring methodology and evidence standard ¹
• Current maturity scorecard with owner sign-off ¹
• Target maturity levels and approval record ¹
• Governance cadence proof: agendas, attendance, minutes, action items ¹
• Decision log (approved scores, targets, exceptions, risk acceptances) ¹
• Gap register and remediation tracking with closure evidence ¹

Common exam/audit questions and hangups

Auditors and internal assurance teams tend to probe these areas:

1. “Who is accountable for the maturity score?”
   Hangup: A team email alias, a committee, or “security” without a named accountable owner.

2. “Show me the last time leadership reviewed maturity results.”
   Hangup: A slide deck exists, but there are no minutes, decisions, or action tracking.

3. “How do you prevent score inflation?”
   Hangup: Scoring is self-attested without evidence thresholds or challenge/approval.

4. “How do maturity gaps translate into funded work?”
   Hangup: Backlog exists, but no linkage to roadmap, budget cycle, or risk register.

5. “What happens when a third party blocks improvement?”
   Hangup: No owner to drive contract changes, compensating controls, or risk acceptance.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	Fix
Treating maturity as an annual assessment	Scores drift; no accountability	Create a recurring governance cadence with a decision log 1
Shared ownership of domains	Decisions stall	Assign one accountable owner per domain 1
No evidence standard	Overstated scores; audit friction	Define “what counts as evidence” per maturity claim 1
Actions not tracked to closure	Governance becomes performative	Use a gap register tied to work tickets and closure proof 1
Targets set without business context	Targets ignored	Approve targets through leadership forum with documented rationale 1

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should not plan around a specific regulator penalty theory. The practical risk is operational: if you cannot show governance and accountability, maturity scores become non-defensible, remediation does not get prioritized, and risk acceptance becomes informal. That is where audit findings and board escalations typically start, even when the underlying technical controls exist.

Practical 30/60/90-day execution plan

This plan assumes you are starting with fragmented ownership and inconsistent maturity scoring.

Days 1–30: Stand up governance and ownership

• Appoint an executive sponsor (often CISO) and a program owner (GRC/security governance).
• Draft and approve a one-page maturity governance charter ¹.
• Build the domain-level RACI with named accountable owners ¹.
• Define scoring and evidence rules (what artifacts are required to claim a score) ¹.
• Publish the first maturity scorecard baseline with owner attestation ¹.

Exit criteria: You can point to owners, a scoring standard, and an approved baseline scorecard.

Days 31–60: Create the decision loop and remediation machinery

• Launch the recurring maturity governance meeting with a fixed agenda.
• Create the decision log and start capturing approvals (scores, targets, exceptions) ¹.
• Build the gap register and connect each gap to a remediation owner and work tracking item ¹.
• Define escalation paths (missed dates, disputed scores, unfunded gaps).

Exit criteria: Governance is producing decisions and a backlog with accountable owners.

Days 61–90: Set targets and prove operational maturity governance

• Facilitate a target-setting workshop with leadership and domain owners.
• Approve target maturity levels and record rationale ¹.
• Perform a quality review of evidence for a subset of domains (spot-check).
• Report maturity movement, open gaps, and risk acceptances to leadership using a consistent format.

Exit criteria: You can demonstrate “measure → decide → execute → evidence” across multiple domains.

Frequently Asked Questions

What’s the minimum I need to show to satisfy the cybersecurity governance maturity requirement?

Show named accountable owners for maturity scores, a repeatable governance cadence, and evidence of decisions and follow-through ¹. If you can produce a scorecard with owner sign-off plus meeting minutes and a decision log, you are in a defensible place.

Does this require board involvement?

C2M2 calls for governance and accountability, but it does not mandate a board-level forum in the provided excerpt ¹. If your risk profile demands it, route summary reporting through an existing risk or audit committee rather than creating a new structure.

How do we handle disagreements about maturity scoring?

Define a scoring methodology with evidence thresholds and an approval authority who can adjudicate disputes ¹. Document disputed items and the final decision in the decision log.

How do third parties fit into maturity governance?

Treat third-party-dependent capabilities as owned outcomes, even if execution is external. Assign an internal accountable owner, then track contract changes, attestations, and compensating controls as part of the gap register ¹.

Can we meet this requirement with spreadsheets and shared drives?

Yes, if ownership, approvals, and evidence are consistent and easy to produce on request ¹. Teams often switch to a system like Daydream when spreadsheets become brittle across multiple domains, business units, and third parties.

What evidence is most commonly missing during audits?

Decision records and proof of follow-through are the common gaps: meeting minutes that show approvals, action items tied to owners, and closure evidence linked to the maturity gap register ¹.

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Footnotes

1. DOE C2M2