BAI05: Managed Organizational Change

The bai05: managed organizational change requirement expects you to run organizational change like a controlled process: define ownership, assess impacts, prepare stakeholders, train users, manage resistance, and retain evidence that change achieved intended outcomes without unacceptable risk. Operationalize it by standardizing change impact assessments, communications, training, and post-change validation, all mapped to BAI05.

Key takeaways:

• Treat org change as a governed control with named owners, defined triggers, and measurable acceptance criteria ¹.
• Evidence matters: approvals, impact assessments, comms, training completion, and post-change effectiveness checks must be retained and easy to produce ².
• Most audit findings come from “we did it” without artifacts, or changes pushed through IT change management without people/process readiness.

BAI05 sits in the gap between “we changed the system” and “the business actually adopted the change without breaking controls.” Many organizations have IT change management (tickets, CAB approvals, implementation logs) but fail BAI05 because organizational change introduces operational risk: users follow workarounds, roles drift, approvals break, or new processes bypass compliance steps.

For a Compliance Officer, CCO, or GRC lead, the fastest way to operationalize BAI05 is to define what counts as an “organizational change,” require a lightweight impact assessment before approval, and insist on adoption evidence after rollout. That means connecting HR, IT, Security, Operations, and process owners to a single workflow with clear decision rights.

This page gives requirement-level implementation guidance: who must do what, what artifacts to retain, and what auditors typically ask for. It also provides a practical execution plan and common failure modes to avoid. The goal is exam-ready proof that organizational change is managed, not improvised, consistent with COBIT’s BAI05 objective expectation ³.

Regulatory text

Framework excerpt (provided): “COBIT 2019 objective BAI05 implementation expectation.” ³

Operator interpretation (what you must do): You must implement a repeatable organizational change management capability that:

• Defines ownership and governance for organizational change (who approves, who executes, who verifies).
• Assesses impacts and readiness before change (process, control, people, skills, access, third-party dependencies).
• Communicates, trains, and supports affected stakeholders so the new way of working becomes the normal way of working.
• Validates outcomes after rollout (adoption, control effectiveness, issues, remediation).
• Retains evidence mapped to BAI05 so you can prove design and operation ³.

Plain-English requirement summary

Manage organizational change so the business adopts it safely. Don’t rely on informal emails or “training happened.” Run it as a controlled process with documented decisions, stakeholder engagement, training, and post-change verification.

Who it applies to

Entities: Enterprise IT organizations and any organization using COBIT for governance and control assurance ¹.
Operational contexts where BAI05 is triggered:

• Major process changes (order-to-cash, onboarding, incident response workflow)
• New systems or significant system redesigns that change user behavior
• Role or responsibility changes (new approvals, segregation of duties changes)
• Outsourcing/insourcing moves that alter how work is performed by employees or third parties
• Policy or control changes that require behavior change (MFA rollout, new access request process)

Functions typically involved:

• Process owners (business), IT/service owners, Security, GRC, HR/Learning, Internal Audit, and impacted operational teams.

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

1) Define scope and triggers for “organizational change”

Create a short definition that is operational:

• “Any change that alters roles, responsibilities, workflows, approvals, required training, or how controls are executed.” Add trigger examples (above) so teams self-identify.

Decision point: If a change only affects infrastructure with no user/process impact, route it through IT change management only. If it changes workflows, approvals, roles, or control steps, it must also follow BAI05.

2) Assign ownership and decision rights

Document:

• BAI05 Process Owner (often GRC or an operational excellence leader)
• Change Sponsor (business accountable executive)
• Change Manager (person coordinating comms/training/readiness)
• Control owners who must sign off when controls change (access, approvals, recordkeeping)

Use a simple RACI and publish it in your governance repository. The minimum bar is that people can name the owner and show where responsibilities are documented ¹.

3) Standardize an Organizational Change Impact Assessment (OCIA)

Make this a required step before approval. Keep it concise, but complete.

OCIA checklist (minimum fields):

• What is changing (process/system/policy)?
• Who is impacted (teams, regions, third parties, customers if relevant)?
• Control impact: what control steps change, what evidence changes, what approvals change?
• Access/SoD impact: new roles, role removals, privileged access changes
• Data impact: new data elements, retention changes, reporting changes
• Training need: who needs training; how completion will be tracked
• Cutover approach and backout/contingency
• Success criteria: measurable adoption/quality checks (examples below)

Route the OCIA for approvals. If the change affects regulated processes, require GRC sign-off. If it affects access or SoD, require Security/IAM sign-off.

4) Build a change plan that includes communications + training

Auditors will test whether you planned for adoption, not just deployment.

Change plan components:

• Stakeholder map (primary users, approvers, downstream teams, third parties)
• Communications plan (what, when, channel, owner)
• Training plan (materials, delivery, tracking method, job aids)
• Hypercare/support plan (where users go when confused; how issues are triaged)

Practical examples of “success criteria” that create evidence:

• New workflow tickets show required fields populated
• Approval steps executed in the new system, not via email
• Exception rate tracked and reviewed by process owner (Choose criteria you can measure with system reports or sampling.)

5) Execute readiness checks before cutover

Require a “go/no-go” gate with documented confirmation:

• Training content published
• Key users trained (or training assigned)
• Updated procedures and job aids available
• Updated control narratives and evidence instructions updated (if applicable)
• Help desk and second-line support briefed

This is where many teams fail: they cut over because the system is ready, while operations is not.

6) Validate adoption and control operation after rollout

Run a post-change validation tailored to risk:

• Sample transactions to confirm the new process is followed
• Confirm evidence is being generated and retained (screenshots, logs, approvals)
• Confirm SoD/access is correct
• Track issues and remediation actions to closure

Retain a short “post-implementation review” memo that ties back to the success criteria and any residual risks.

7) Map artifacts to BAI05 and make retrieval easy

Your control objective is not only to “do” change management, but to prove it with evidence mapped to the requirement ². Create a BAI05 evidence index (a folder structure or GRC system record type) that points to each change’s OCIA, approvals, comms, training, and validation.

Where Daydream fits naturally: If you struggle with evidence sprawl, Daydream can centralize BAI05 ownership, required artifacts, and audit-ready mapping so each organizational change record is complete before it can be marked done.

Required evidence and artifacts to retain

Keep artifacts proportional to change risk, but retain at least:

• BAI05 policy/procedure (how organizational change is managed) ¹
• RACI / ownership record
• OCIA (impact and readiness assessment) with approvals
• Communications artifacts (announcement, release notes, stakeholder updates)
• Training artifacts (materials, attendance/completion record, job aids)
• Updated procedures / SOPs and control narratives (if controls changed)
• Go/no-go or readiness sign-off
• Post-implementation review, adoption metrics or sampling results
• Issue log and remediation tracking

Common exam/audit questions and hangups

Auditors usually test two things: governance and evidence of operation.

• “Show me your last organizational change. Where is the impact assessment and approval?”
• “How did you decide who needed training, and how do you know they completed it?”
• “What controls changed, and how did you update the evidence instructions?”
• “How do you know the new process is being followed rather than bypassed?”
• “Who owns BAI05? Who can stop a change if readiness is insufficient?”

Hangup: Teams present IT change tickets only. If those tickets don’t address training/adoption/control operation, you have a BAI05 gap even if IT change management is strong.

Frequent implementation mistakes and how to avoid them

1. Treating BAI05 as communications only
   Fix: Require OCIA + post-change validation, not just announcements.

2. No defined trigger, so changes bypass the process
   Fix: Publish triggers and embed them into intake forms (project kickoff, CAB, service requests).

3. Training is informal and untracked
   Fix: Track completion in an LMS or ticketing workflow; retain completion exports or reports.

4. Controls change but narratives/evidence don’t
   Fix: Add a required OCIA field: “Does this change control steps or evidence?” Route to control owners.

5. No closure criteria
   Fix: Define success criteria before rollout and write them into the change plan; validate after.

Risk implications (why examiners care)

Unmanaged organizational change leads to predictable control failures: approvals move to side channels, recordkeeping becomes inconsistent, access expands without review, and teams invent workarounds. Those failures can convert a well-designed control into a non-operating control, which shows up as audit findings and can drive broader assurance issues tied to governance and operational resilience ¹.

Practical 30/60/90-day execution plan

First 30 days (stabilize the minimum viable process)

• Name the BAI05 owner and publish a RACI.
• Write a one-page BAI05 procedure: scope, triggers, required steps, required artifacts ¹.
• Build an OCIA template and an evidence index (folder structure or GRC workflow).
• Pilot on one in-flight change with meaningful operational impact.

Days 31–60 (embed into intake and approvals)

• Add BAI05 trigger questions to project kickoff and change intake forms.
• Define approval routing for control-impacting changes (GRC/Security/IAM).
• Create standard training and comms templates, including a completion tracking method.
• Start a lightweight post-implementation review practice tied to success criteria.

Days 61–90 (operate, measure, and make it audit-proof)

• Run two to three changes end-to-end through the process; fix bottlenecks.
• Create a recurring review (monthly or per-release) to confirm evidence completeness and adoption checks.
• Build an audit-ready “BAI05 evidence pack” export pattern: policy, RACI, and a sample of completed change records mapped to artifacts ².
• If evidence collection is inconsistent across teams, centralize it in Daydream so each change cannot close without required artifacts.

Frequently Asked Questions

Does BAI05 replace IT change management (e.g., CAB and change tickets)?

No. BAI05 covers the people/process adoption side that IT change management often misses. If a change impacts workflows, roles, approvals, or control execution, run both in parallel and cross-link the records.

What counts as “organizational change” in practice?

Any change that alters how work is performed or controlled: new approvals, new roles, new required evidence, new systems that change user steps, or outsourcing changes that move tasks to a third party.

How much documentation is enough?

Enough to prove you assessed impacts, prepared stakeholders, and validated outcomes. Scale artifacts to risk, but always retain an OCIA, approvals, training/comms proof, and a post-change validation record.

Our training is “optional” because teams are busy. Can that still pass?

Only if the change does not introduce new required behaviors or control steps. If control operation depends on people following a new process, you need tracked training or another verified readiness mechanism.

How do we show adoption without building a metrics program?

Use sampling and existing system reports. For example, sample completed transactions to confirm required approvals and evidence fields are present, and retain the sampling worksheet with sign-off.

Where do third parties fit in BAI05?

If a third party performs or influences a changed workflow, include them in the impact assessment, communications, and readiness plan, and retain evidence of their acknowledgment or training where relevant.

Footnotes

1. ISACA COBIT overview

2. OSA COBIT 2019 objective mapping

3. ISACA COBIT overview; OSA COBIT 2019 objective mapping