MEA03: Managed Compliance with External Requirements

MEA03 requires you to identify the external requirements that apply to your enterprise IT environment, translate them into concrete controls, and continuously monitor evidence that those controls operate as intended. To operationalize it fast, stand up a single system of record that maps obligations to controls, assigns owners, tracks changes, and produces audit-ready proof on demand. ¹

Key takeaways:

• Maintain an authoritative inventory of external requirements and map each to specific controls and control owners. ¹
• Run a repeatable compliance monitoring cadence that produces evidence, exceptions, and remediation tracking. ²
• Your biggest risk is “paper compliance”: policies exist, but operating evidence is missing or not traceable to obligations. ¹

MEA03: Managed Compliance with External Requirements is the COBIT objective that forces discipline around a problem most audit findings trace back to: you cannot prove you consistently meet the external rules you claim to follow. In practice, MEA03 is less about writing new policies and more about building a working compliance operating system for IT: one place to list applicable obligations, one method to translate them into control requirements, and one repeatable way to collect evidence and respond to change. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat MEA03 like a production workflow. Define what counts as an “external requirement” for your organization (laws, regulations, contracts, customer requirements, and applicable standards), appoint accountable owners, and build a traceable line from requirement → control → test → evidence → issue → remediation. Then make it routine: change detection, periodic self-assessments, and management reporting that highlights exceptions early. ²

This page gives requirement-level implementation guidance for the target keyword “mea03: managed compliance with external requirements requirement,” with a focus on what auditors ask for and what evidence you need to keep.

What MEA03 means in plain English

MEA03 expects you to run compliance like an operational process, not a yearly scramble. That means:

• You know which external requirements apply to your IT environment.
• You convert those requirements into enforceable controls and procedures.
• You monitor compliance, retain evidence, manage exceptions, and respond to changes in requirements. ¹

If you can’t answer “What requirements apply?” and “Show me proof you meet them” without a multi-week effort, you are not operating MEA03 effectively. ²

Who it applies to

Entity scope: Enterprise IT organizations implementing COBIT-aligned governance and assurance expectations. ¹

Operational scope (typical):

• Central IT (infrastructure, endpoints, identity, network, monitoring)
• Security and privacy functions
• Product engineering delivering customer-facing systems
• IT service management (change, incident, problem, configuration)
• Procurement and third-party management where contracts impose obligations
• Any system in scope for external audits, customer assessments, or regulatory exams ²

Third-party angle: MEA03 often breaks at the boundary between your controls and third parties’ controls. If an external requirement is satisfied partly by a third party (cloud provider, payroll processor, MSSP), you still need documented responsibility, assurance, and evidence. ¹

Regulatory text

Excerpt (provided): “COBIT 2019 objective MEA03 implementation expectation.” ¹

Operator interpretation: COBIT is setting an implementation expectation: establish and operate a managed process that identifies external compliance obligations, translates them into internal control requirements, and monitors adherence with evidence and remediation. Treat “external requirements” broadly: binding laws/regulations, contractual obligations, and externally imposed standards you claim to meet. ¹

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

1) Establish your “external requirements” inventory (system of record)

Create a controlled register that becomes the authoritative list of applicable obligations. Minimum fields:

• Requirement name (e.g., contract clause set, regulatory domain, customer security addendum)
• Applicability rationale (why it applies, what systems/processes are in scope)
• Obligation statements (written in testable language)
• Effective date and change history
• Business owner (accountable) and control owner (responsible)
• Evidence expectations (what proves compliance)
• Link to mapped controls and tests ¹

Practical tip: If the register is a spreadsheet, you need strict document control. If it’s in a GRC tool, you need governance for taxonomy, approvals, and field definitions.

2) Translate obligations into control requirements you can test

For each obligation statement, define:

• Control objective (what must be true)
• Control activity (what people/systems do)
• Frequency/trigger (event-based, release-based, periodic)
• Tooling/system(s) of record
• Who approves exceptions
• How you test it (design + operating effectiveness) ²

Example mapping (simplified):

• Obligation: “Access must be removed promptly upon termination.”
• Control activity: HR termination feed triggers identity deprovisioning workflow; weekly reconciliation report reviewed by IT owner.
• Evidence: Deprovision tickets + reconciliation report + reviewer sign-off.

3) Assign ownership and build a RACI that holds up in an audit

Auditors look for named accountability. Create a RACI for:

• Requirement intake and applicability decisions
• Control design and updates
• Evidence production and retention
• Control testing and issue management
• Exception approvals and risk acceptance ¹

Hangup to avoid: “Security owns compliance.” Security can run the program, but control owners usually sit in IT operations, engineering, and business process teams.

4) Implement a compliance monitoring cadence

MEA03 requires active management, not passive documentation. Put these routines on a calendar with owners:

• Change detection: monitor for changes in laws, contracts, customer requirements, and standards you claim.
• Control performance monitoring: verify controls ran (not just that they exist).
• Exception management: document, approve, time-box, and track remediation.
• Management reporting: produce a concise view of compliance status, exceptions, and systemic control gaps. ²

Evidence rule: every recurring control needs a repeatable evidence package. If evidence is ad hoc, it will fail under scrutiny.

5) Define evidence standards and retention rules

Set minimum evidence quality criteria:

• Traceable to control and obligation
• Time-bounded (shows “when”)
• Attributable (shows “who” approved/reviewed)
• Tamper-evident where feasible (system logs, immutable storage, ticketing audit trails)
• Consistent naming and storage location ¹

6) Test, record results, and remediate like an operator

Create a lightweight test plan:

• Control design review (does it meet the obligation)
• Operating effectiveness sampling (did it run)
• Findings severity, root cause, corrective action, due dates
• Retest evidence ²

MEA03 will fail if you can’t show a closed loop from exception → remediation → retest.

Required evidence and artifacts to retain (audit-ready checklist)

Maintain these artifacts in a controlled repository:

• External requirements register with version history and approvals ¹
• Obligation-to-control mapping (control matrix)
• Control narratives/procedures with owners and triggers
• Evidence index (what evidence exists, where it lives, who produced it)
• Control operation evidence (tickets, logs, screenshots with context, approvals)
• Exception register with approvals and expiration dates
• Issue remediation plans, status, and retest results
• Management reports and meeting minutes where compliance status is reviewed ²

If you adopt Daydream to manage this, configure it so the requirement register, mapping, and evidence index are generated from the same workflow. The goal is one traceable chain, not separate documents that drift.

Common exam/audit questions and hangups

Auditors and assessors tend to press on these areas:

• “Show me your complete list of external requirements and why each applies.” ¹
• “How do you know when requirements change, and how fast do you respond?”
• “Pick one obligation and walk me through: control, owner, evidence, exceptions, remediation.”
• “Where is evidence stored, and how do you prevent missing months/periods?”
• “Which controls depend on third parties, and what assurance do you obtain?” ²

Hangup: teams present policy PDFs. Auditors ask for operating evidence. Bring both, but lead with evidence.

Frequent implementation mistakes (and how to avoid them)

1. Requirement register exists, but no applicability logic.
   Fix: require a written applicability rationale and scoping statement per requirement. ¹

2. Controls mapped at too high a level (“Access control policy”).
   Fix: map to testable control activities (“Joiner/mover/leaver workflow,” “Privileged access review,” “MFA enforcement configuration”). ²

3. Evidence is scattered and inconsistent.
   Fix: create an evidence index and standard naming; enforce it through the ticketing/GRC workflow. ¹

4. Exceptions are informal (“we accepted the risk”).
   Fix: run a formal exception workflow with approver, scope, compensating controls, and expiry. ²

5. Third-party dependencies ignored.
   Fix: document shared responsibility, contract obligations, and assurance artifacts for each dependent control. ¹

Enforcement context and risk implications

COBIT itself is a framework, so MEA03 is usually evaluated through internal audit, external assurance, customer audits, or regulatory exams that expect governed IT compliance. The operational risk is predictable:

• Missed requirements changes create control drift.
• Weak evidence discipline causes audit findings even when teams “do the work.”
• Unmanaged exceptions become repeat findings and raise governance concerns. ¹

Treat MEA03 as a resilience and auditability requirement: you want proof on demand, plus early warning when compliance degrades. ²

Practical 30/60/90-day execution plan

First 30 days (stabilize and make scope explicit)

• Appoint MEA03 process owner and define RACI for requirement intake, control ownership, and evidence production. ¹
• Build the external requirements register structure and load your highest-impact obligations first (regulatory, major customer contracts, critical standards you attest to). ²
• Define evidence standards: where stored, naming, reviewer sign-off expectations. ¹

Days 31–60 (map to controls and start monitoring)

• Map each obligation to specific controls and assign control owners with named backups. ¹
• Create an evidence index per control and run the first evidence collection cycle.
• Stand up exception workflow: intake, approval, expiry, and remediation tracking. ²

Days 61–90 (prove operation and close gaps)

• Perform a focused operating effectiveness test over the controls mapped to the highest-risk obligations; record results and remediate failures. ²
• Produce management reporting: top exceptions, overdue remediation, repeated control failures, and third-party dependency gaps. ¹
• Run a change-detection drill: simulate a requirement change and show update to controls, comms to owners, and evidence plan update. ¹

Ongoing (run it as BAU)

• Keep the register current, refresh mappings when systems/processes change, and retain evidence continuously. ²

Frequently Asked Questions

What counts as an “external requirement” for MEA03?

Treat it as any binding obligation outside your organization that your IT services must meet: laws/regulations, contractual clauses, and external standards you claim to follow. Document your definition and apply it consistently in your register. ¹

How deep does the mapping need to go from requirement to controls?

Deep enough that a tester can pick an obligation and identify specific control activities, owners, and evidence without interpretation. High-level policy mapping usually fails because it is not testable. ²

What evidence do auditors expect most often?

They ask for proof the control ran: approvals, tickets, logs, reconciliations, and review sign-offs tied to dates and owners. Store evidence so it is traceable to both the control and the underlying obligation. ¹

How do we handle requirements that are partially owned by a third party?

Document shared responsibility, then collect assurance aligned to the dependent controls (contract terms, attestations, audit reports, or performance evidence). Track gaps as issues with owners and remediation plans. ²

We have policies and annual risk assessments. Why isn’t that enough for MEA03?

MEA03 expects active compliance management: monitoring, evidence, exceptions, and response to change. Policies support the program, but operating evidence and issue closure prove it works. ¹

What is the fastest way to get MEA03 audit-ready without burning out control owners?

Standardize evidence packages per control and automate collection where possible through systems of record (ticketing, identity platforms, logging). A tool like Daydream helps by keeping the requirement register, mappings, and evidence requests in one workflow so nothing depends on heroics. ¹

Footnotes

1. ISACA COBIT overview

2. OSA COBIT 2019 objective mapping