Continual improvement

Continual improvement is the “prove you got better” requirement in ISO 22301. A BCMS can look mature on paper while drifting operationally: outdated recovery assumptions, recurring test failures, unaddressed supplier weaknesses, and lessons learned that never make it into plans. Auditors and customers look for a disciplined feedback loop that converts disruption signals into measurable changes.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat continual improvement like a control system, not a principle. You need defined triggers (what creates an improvement item), a single intake and triage mechanism, a corrective action process with root cause analysis, governance to force decisions, and evidence that changes landed in procedures, plans, training, and testing.

This page gives requirement-level guidance to implement the continual improvement requirement quickly: who owns what, the minimum process steps, what artifacts to retain, and how to answer the questions that show up in ISO 22301 audits and customer due diligence. Where the ISO standard text is licensed, this guidance relies on the public ISO overview and implementation intent ¹.

Regulatory text

Provided excerpt (summary-level, not the licensed text): “Baseline implementation-intent summary derived from publicly available framework overviews; licensed standard text is not reproduced in this record.” The requirement intent is to “Improve continuity program effectiveness through review and corrective actions.” ¹

What the operator must do:
You must maintain a managed process to identify BCMS deficiencies and improvement opportunities, implement corrective actions, and confirm those actions are effective. In practice, this means you can show: (1) how issues are discovered, (2) how fixes are prioritized and approved, (3) how fixes are implemented, and (4) how you validated the fix and updated the BCMS so the issue does not repeat ¹.

Plain-English interpretation of the continual improvement requirement

“Continual improvement requirement” means your continuity program cannot be static. Every exercise, incident, audit, change in business operations, or third-party failure should produce one of two outcomes:

1. No change needed, with a recorded rationale, or
2. A tracked improvement item that is assigned, implemented, verified, and then closed.

Auditors rarely accept “we talked about it” as improvement. They look for closure discipline: root cause, corrective action, and proof that the corrective action actually reduced risk or eliminated the nonconformity.

Who it applies to (entity and operational context)

This applies to any organization operating a BCMS aligned to ISO 22301, especially:

• Critical service operators where outages affect safety, essential services, or regulated commitments.
• Service organizations that must meet customer resilience expectations, contractual RTO/RPO commitments, or assurance requests ¹.

Operationally, it applies across:

• Continuity governance (BCMS management review inputs/outputs)
• Incident management and post-incident reviews
• Exercising and testing programs
• Internal audits and supplier/third-party oversight that affects continuity outcomes

If you outsource key services (cloud hosting, payroll, call centers, managed IT), continual improvement must cover third-party failure modes because they shape your achievable recovery strategies.

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

1) Define scope and ownership

• Assign a BCMS continual improvement owner (often BCMS manager, resilience lead, or GRC owner).
• Define escalation to a decision forum (risk committee, operational resilience council, or BCMS steering group).
• Publish a short Continual Improvement Procedure (2–4 pages) that describes intake, triage, corrective action, verification, and closure.

Operational tip: if ownership is diffuse, nothing closes. Make one role accountable for closure, even if execution is distributed.

2) Establish “improvement triggers” (what creates an item)

Create a list of events that automatically generate an improvement record, such as:

• BC exercise/test failure, partial pass, or major observation
• Incident postmortem or near-miss review findings
• Internal audit nonconformities and observations
• Material business change (new site, new product, M&A, major technology migration)
• Third-party disruption or repeated SLA failures affecting recoverability

Document these triggers in the procedure and in your exercise/incident templates so teams cannot “forget” to log the action.

3) Run a single intake and logging mechanism

Stand up a centralized BCMS Issues and Corrective Actions Register (spreadsheet, GRC tool, ticketing system). Minimum fields:

• Unique ID, date opened, source (exercise/incident/audit/change)
• Description, impacted process/service, impact statement
• Classification: nonconformity vs observation vs improvement
• Owner, approver, due date, priority
• Root cause method (or rationale for not performing deep RCA)
• Corrective action plan and tasks
• Verification method and closure evidence link

If you use Daydream, treat each improvement record like a due diligence-ready work item: tie it to the affected service, third parties involved, and supporting evidence so you can answer customer questionnaires without rebuilding the narrative.

4) Triage and prioritize (so you don’t drown)

Set a triage cadence (weekly or biweekly) and apply simple decision rules:

• High urgency if the issue prevents meeting recovery objectives, breaks a control that supports a critical service, or repeats.
• Medium if it creates single points of failure or gaps in documentation/training.
• Low if it’s editorial, cosmetic, or future-state enhancement.

Capture the priority rationale. Auditors accept risk-based planning when it is documented and consistently applied.

5) Perform corrective action with root cause discipline

For each nonconformity or recurring issue:

• Define containment (what you do now to reduce immediate risk).
• Identify root cause (process gap, training gap, design flaw, third-party dependency, unclear RACI).
• Implement corrective action (update plans, adjust architecture, revise contracts, add training, modify exercise design).
• Implement preventive/structural changes where needed (e.g., add a control gate to change management so BC assumptions update with system changes).

Avoid performative RCA. A short, specific root cause (“exercise script didn’t test dependency X; design review checklist omitted third-party dependency mapping”) beats a vague one (“communication issue”).

6) Verify effectiveness before closure

Closure requires evidence that the fix worked. Acceptable verification methods:

• Re-test in the next exercise cycle with a targeted scenario
• Tabletop validation with objective criteria
• Updated monitoring/alerting and a review showing it runs
• Audit follow-up confirming remediation

Record who verified it and what they reviewed. If effectiveness cannot be verified quickly, keep the item open with an interim milestone.

7) Update the BCMS “system,” not just the plan

Continual improvement must feed back into controlled documentation and operations:

• BC/DR plans, runbooks, call trees
• BIA assumptions and dependency maps
• Exercise program design and schedules
• Training materials and role onboarding
• Third-party requirements (SLAs, notification obligations, testing participation)

If the register closes actions but the controlled documents stay unchanged, auditors see a paper process.

Required evidence and artifacts to retain

Retain evidence that demonstrates the full improvement loop:

Artifact	What it proves	Minimum content
Continual Improvement Procedure	Defined process exists and is used	Triggers, roles, workflow, verification requirements
Issues/Corrective Actions Register	Central control of findings and fixes	Status, owner, due dates, links to evidence
Exercise reports and after-action reviews	Findings are captured from testing	Results, gaps, recommendations, action IDs
Incident postmortems	Real disruptions drive improvements	Timeline, contributing factors, actions
Internal audit reports & follow-ups	Audit findings are remediated	Nonconformities, CAPA, closure verification
Change records tied to BCMS updates	BCMS updates track business change	Impact assessment, approvals, updated docs
Management review minutes	Leadership oversight	Decisions, priorities, resourcing, accepted risks

Store artifacts in a controlled repository with versioning and retention aligned to your BCMS and audit cycle.

Common exam/audit questions and hangups

Expect auditors and customer assessors to probe these areas:

1. “Show me one issue from discovery to closure.” They will sample and trace to evidence.
2. “How do you know corrective actions are effective?” “Completed” is not “effective.”
3. “How do you prevent recurring findings?” Repeat issues signal weak root cause analysis or weak governance.
4. “How do third parties factor into improvements?” If a supplier caused a failure, where is the corrective action (contract, architecture, failover approach, testing)?
5. “What does leadership review and decide?” They want proof that priorities and risk acceptance happen intentionally ¹.

Frequent implementation mistakes and how to avoid them

• Mistake: Treating improvement as an annual exercise-only activity.
  Fix: Log actions from incidents, changes, and third-party events, not just tests.

• Mistake: Closing actions without updating controlled documents.
  Fix: Add a closure checklist requiring links to updated plans/runbooks/training.

• Mistake: No clear verifier.
  Fix: Separate “implementer” from “verifier” for higher-risk actions.

• Mistake: Action registers with no prioritization rationale.
  Fix: Require a short risk rationale and tie priority to service criticality.

• Mistake: Third-party disruptions get filed under “vendor issue” with no BCMS change.
  Fix: Require a BCMS impact assessment for any third-party incident that affects recoverability, including contract terms and dependency mapping updates.

Enforcement context and risk implications

ISO 22301 is a certifiable standard, not a regulator. Your practical risk is commercial and assurance-driven: failed surveillance audits, customer findings, lost deals, or contractual noncompliance when continuity commitments are not met ¹. The operational risk is direct: unresolved corrective actions tend to reappear during real incidents, often with larger blast radius because business change outpaces documentation.

Continual improvement is also one of the easiest areas for assessors to test because it leaves a paper trail. If your register is stale, overdue, or missing effectiveness checks, the gap is visible quickly.

A practical 30/60/90-day execution plan

Days 0–30: Stand up the mechanism

• Publish the Continual Improvement Procedure (owner, triggers, workflow, verification).
• Create the Issues/Corrective Actions Register with required fields and evidence link conventions.
• Import open items from prior exercises, incidents, audits, and customer assessments.
• Set governance: a standing triage meeting and a monthly steering review.

Deliverables: procedure, register, governance calendar, first triage outcomes.

Days 31–60: Drive closure discipline

• Triage all items; assign owners and due dates; document priority rationale.
• For top-risk items, perform root cause analysis and define corrective action plans.
• Start closure verification for any items already implemented but not validated.
• Add a closure checklist and define what “effective” means for common fix types (plan update, technical change, training change, third-party change).

Deliverables: prioritized backlog, CAPA plans for top items, first set of verified closures.

Days 61–90: Prove it works and integrate with operations

• Run a targeted exercise or tabletop that verifies high-risk corrective actions.
• Add BCMS improvement triggers to incident/postmortem templates and change management intake.
• Report metrics internally (qualitative is fine): overdue items, repeats, verification status, key themes.
• Prepare an audit-ready “trace pack” with 2–3 completed examples end-to-end.

Deliverables: verified test results, integrated templates, management review inputs, trace packs.

Frequently Asked Questions

What counts as evidence that we meet the continual improvement requirement?

A working corrective action workflow with records that show discovery, assignment, remediation, and effectiveness verification, plus updates to controlled BCMS artifacts. Auditors will sample items and trace them to exercise reports, postmortems, and updated plans ¹.

Do we need a formal root cause analysis for every improvement item?

No. Reserve deeper RCA for nonconformities, repeat issues, and anything affecting critical services. For minor improvements, document a concise cause and a proportional fix so the record still supports closure discipline.

How do we handle continual improvement for third parties?

Treat third-party disruptions and test failures as BCMS triggers. Record corrective actions that may include contract changes, resilience requirements, alternate suppliers, and participation in joint testing, then verify the change reduced the dependency risk.

What if an action can’t be closed because it needs budget or engineering time?

Keep it open with interim milestones and document the decision path (requested funding, prioritization outcome, compensating controls). Auditors react poorly to “stuck” actions with no governance trail.

How do we show “effectiveness” without running a full-scale test?

Use targeted validation: tabletop with objective pass/fail criteria, evidence of updated monitoring with review, or a focused component test tied to the corrective action. Document what was validated and who approved closure.

Can we manage corrective actions in Jira/ServiceNow instead of a GRC tool?

Yes if you can enforce required fields, link to evidence, track verification, and produce an audit trail. Many teams keep execution in tickets and maintain a BCMS-facing register that points to those tickets for oversight and reporting.

Related compliance topics

• 2025 SEC Marketing Rule Examination Focus Areas
• Access and identity controls
• Access Control (AC)
• Access control and identity discipline
• Access control management

Footnotes

1. ISO 22301 overview