Business continuity governance

“Business continuity governance” is the control plane for your continuity program. If you cannot show who owns business continuity, who approves priorities, and how leadership reviews performance, your plans will look like documents without authority. ISO 22301 expects a managed system: objectives, accountability, oversight, and continual improvement ¹. Governance is where those expectations become operational.

For a Compliance Officer, CCO, or GRC lead, governance is also the fastest way to reduce audit risk. Auditors and customers often tolerate an imperfect plan if they see strong ownership, a disciplined review process, and a trackable improvement backlog. They do not tolerate ambiguity about accountability, scope, or decision-making, especially where the organization provides critical services or acts as a service organization ¹.

This page focuses on requirement-level implementation guidance for the business continuity governance requirement: what it means in plain English, who it applies to, what you need to build, what evidence to retain, and how to execute in a 30/60/90-day plan. It is written to help you operationalize quickly and withstand scrutiny without turning governance into bureaucracy.

Regulatory text

Provided excerpt (not the licensed standard text): “Baseline implementation-intent summary derived from publicly available framework overviews; licensed standard text is not reproduced in this record.” The requirement intent is: “Establish governance for business continuity objectives and accountability.” ¹

What the operator must do:
You must create a governance structure that:

• Sets and approves business continuity objectives (what outcomes you must achieve and how you measure them).
• Assigns accountability (who is responsible for the program, for business unit execution, and for oversight).
• Operates on a routine cadence (reviews, decisions, action tracking) with documented outputs that demonstrate control and improvement ¹.

Plain-English interpretation (what auditors actually look for)

A workable interpretation of the business continuity governance requirement is:

1. Someone senior owns the program. There is an executive sponsor with authority to prioritize remediation, resolve conflicts between functions, and accept residual risk.
2. A defined group runs oversight. A continuity steering committee (or equivalent forum) exists with a documented charter, defined membership, and clear decision rights.
3. Objectives are explicit and reviewed. Continuity objectives are written down, approved, measured, and revisited after tests, incidents, major changes, or risk shifts.
4. Accountability is assigned to the line. Business units own their recovery requirements and plans; the BCMS function coordinates and challenges.
5. Evidence exists. Governance is not a slide deck; it is minutes, actions, approvals, and management review outputs that show the system operates.

If you can’t show these elements, the continuity program becomes “best effort,” and that is the gap this requirement targets.

Who it applies to (entities and operational context)

This requirement applies broadly to organizations aligning to ISO 22301, with common relevance for:

• Critical service operators (internal shared services, infrastructure, operations centers, payment operations, claims operations, logistics operations) where downtime affects safety, financial stability, or customer commitments ¹.
• Service organizations (SaaS, managed services, BPO, fintech processors, data processors) where continuity is a contractual and assurance expectation ¹.

Operationally, it applies wherever continuity decisions are made:

• Cross-functional dependencies (IT, security, facilities, HR, legal, procurement, product).
• Outsourced and third-party supported services (cloud providers, MSPs, call centers, critical suppliers).
• Business lines with defined recovery expectations (RTO/RPO targets, service-level commitments, customer impact tolerances).

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

The fastest way to implement the business continuity governance requirement is to build a minimal governance system that can scale.

Step 1: Appoint accountable owners (named, not generic)

• Assign an executive sponsor (single name, title).
• Assign a BCMS owner/program lead (single name, title) responsible for coordination, reporting, and control maintenance.
• Assign business unit continuity owners for each in-scope process/service.
• Assign risk acceptance authority (often the sponsor or a risk committee) for documented exceptions.

Deliverable: BCMS governance RACI and role descriptions.

Step 2: Create a continuity governance forum with decision rights

Stand up a steering committee or governance council. Keep it lightweight, but real.

• Define membership (business, IT, security, operations, facilities, procurement/third-party risk as needed).
• Define decision rights: approve policy, approve objectives, approve scope, accept exceptions, prioritize remediation, approve test schedule and major findings remediation.
• Define escalation routes (e.g., to enterprise risk committee).

Deliverable: Committee charter + annual agenda.

Step 3: Publish a business continuity policy (approved and communicated)

Your policy should be short and enforceable:

• Purpose and scope (what services/processes are covered).
• Governance model (who does what).
• Requirement to perform BIA, define strategies, maintain plans, test/exercise, train, and track corrective actions.
• Required reporting and review routines.

Deliverable: Approved policy with version control and communication record.

Step 4: Define continuity objectives and how you measure them

Translate “continuity” into objectives leadership can approve and monitor. Examples:

• Timeliness objectives (recovery targets per critical service).
• Coverage objectives (which services must have current plans and tests).
• Corrective action objectives (closure expectations for high-risk findings).
• Third-party dependency objectives (critical third parties have validated continuity commitments).

Write objectives in a way that allows evidence: a metric, an owner, and a reporting cadence.

Deliverable: Documented objectives register + KPI/KRI definitions.

Step 5: Implement management review and action tracking

Governance must produce outputs:

• Review KPI/KRI performance and exceptions.
• Review exercise results and real incident learnings.
• Review major changes (new systems, outsourcing, org changes) that require BIA/plan updates.
• Approve remediation priorities and due dates.
• Track actions to closure with owners and status.

Use an action log with: ID, finding, risk rating (if you use one), owner, due date, status, closure evidence.

Deliverable: Meeting minutes + action log + management review record.

Step 6: Integrate governance with third-party risk and change management

Continuity governance fails if it ignores dependencies.

• Require procurement/third-party risk to flag critical third parties to the continuity program.
• Require change management to notify BCMS of changes that affect recovery assumptions (data center moves, cloud architecture changes, new critical supplier, workforce model shifts).
• Include third-party continuity requirements in onboarding and renewals (BC clauses, testing participation, notification expectations).

Deliverable: Documented integration points (process maps or SOPs) and sample workflows/tickets.

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

Retain artifacts that prove both design (structure exists) and operation (it runs).

Evidence	What it proves	Minimum content to retain
Business continuity policy	Governance intent and requirements	Approval, version history, distribution/communication record
Governance/steering committee charter	Decision rights and oversight	Scope, membership, quorum/decision rules, escalation path
RACI / role descriptions	Accountability	Named roles, responsibilities, backups/delegates
Continuity objectives register	Objectives exist and are managed	Objectives, owners, metrics, review cadence
Meeting minutes and attendance	Governance operates	Decisions, approvals, exceptions, action assignments
Management review record	Leadership review and improvement	Inputs reviewed, outputs decided, follow-ups assigned
Action log / corrective action tracker	Continual improvement	Owner, due date, status, closure evidence
Exception/risk acceptance records	Controlled deviations	Rationale, approvals, compensating controls, expiry date

If you manage evidence in Daydream, map each artifact to the business continuity governance requirement so you can answer audits with a single evidence pack instead of ad hoc document collection.

Common exam/audit questions and hangups

Auditors tend to press on “who decides” and “show me proof it happened.”

Questions you should be ready to answer

• Who is accountable for the BCMS and who can approve BC objectives and scope?
• Show the policy approval and the last time it was reviewed.
• Show steering committee minutes for the last review cycle and the action log.
• How do you track and close findings from exercises or incidents?
• How do you govern third-party dependencies for critical services?
• How do major business/technology changes trigger continuity updates?

Hangups that create findings

• A committee exists but has no charter, no minutes, or no decisions recorded.
• Objectives exist but are not measurable or not reviewed.
• Action items are recorded but not closed with evidence.
• Business lines claim ownership, but approvals and exception sign-offs are missing.

Frequent implementation mistakes and how to avoid them

1. Governance that’s all structure, no operation. Fix: require minutes, decisions, and an action log for every forum.
2. No decision rights. Fix: put explicit approval authority in the charter (policy, objectives, exception acceptance, remediation priority).
3. BC owned only by IT. Fix: assign business process owners; IT is a dependency owner, not the sole accountable party.
4. Objectives that cannot be evidenced. Fix: every objective needs an owner, a metric, and a reporting source.
5. Third parties ignored. Fix: define “critical third party” criteria and require continuity clauses and review as part of procurement and renewals.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite enforcement outcomes.

Practically, weak governance increases:

• Operational resilience risk: recovery priorities conflict, and remediation stalls without executive arbitration.
• Assurance risk: customers and auditors view continuity artifacts as “paper program” without management oversight.
• Third-party risk: outsourced dependencies fail in real events because no one owned the end-to-end service recovery assumptions.

ISO 22301 is often used for certification or customer assurance ¹. Governance is one of the fastest areas where an assessor can conclude the management system is not functioning as intended.

Practical 30/60/90-day execution plan

This plan assumes you are building governance from scratch or formalizing an informal program.

Days 1–30: Stand up the minimum viable governance

• Name the executive sponsor and BCMS owner; publish interim role assignments.
• Draft and approve the business continuity policy (version 1).
• Create the steering committee charter; schedule the first meeting.
• Build the objectives register (initial objectives, owners, reporting sources).
• Set up an action log template and evidence repository structure.

Exit criteria: Policy approved, charter approved, first meeting held, action log opened.

Days 31–60: Make governance operational and auditable

• Hold at least one steering committee meeting with recorded decisions and assigned actions.
• Define and document escalation and exception/risk acceptance workflow.
• Integrate continuity triggers into change management (document how changes route to BCMS).
• Integrate with third-party risk intake (define how critical third parties are identified and reviewed).
• Start management review format (agenda, required inputs, required outputs).

Exit criteria: Minutes exist, actions are tracked, exception path works, integrations documented.

Days 61–90: Prove repeatability and close initial gaps

• Run a management review session and produce a management review record.
• Use governance to approve the continuity program roadmap (BIA schedule, testing schedule, remediation plan).
• Close initial action items with evidence; document overdue-item escalation.
• Validate reporting: confirm metrics pull from authoritative sources and are presented consistently.
• Prepare an “audit pack” for the business continuity governance requirement (policy, charter, RACI, objectives, minutes, action log, management review).

Exit criteria: You can answer audit questions with a single evidence pack and show operating rhythm.

Frequently Asked Questions

Who should own business continuity governance: CIO, COO, or CISO?

Assign the executive sponsor based on who owns the end-to-end service outcomes and can resolve priority conflicts across business and technology. Many programs place the BCMS owner in risk/GRC while keeping executive sponsorship with operations or enterprise risk, depending on your operating model.

Do we need a formal committee, or can we use an existing risk committee?

You can use an existing forum if it has documented decision rights for continuity, a defined agenda that covers BCMS topics, and retained minutes and actions. If the existing committee cannot consistently address continuity decisions, create a dedicated steering committee with a tight charter.

What is the minimum evidence an auditor will accept for governance?

Expect to provide an approved policy, role assignments (RACI), a governance charter, and proof of operation through minutes and an action log. Add a management review record to show leadership oversight and continual improvement ¹.

How do we govern third-party dependencies without boiling the ocean?

Start with “critical third parties” that support critical services, then require continuity clauses, notification expectations, and periodic review through procurement and renewals. Track gaps as governance actions and escalate when business owners accept residual risk.

How often should governance meet?

Set a cadence that matches your change rate and service criticality, then document it in the charter and follow it. If you miss meetings, document why and reschedule; auditors care about repeatability and accountability.

Where does Daydream help in this requirement?

Daydream can act as the system of record for governance evidence by mapping the policy, charter, minutes, objectives, and action log to the business continuity governance requirement. That reduces audit scramble and makes it easier to prove the control operates consistently.

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Footnotes

1. ISO 22301 overview