🚀 Rethinking Risk Governance: Alternatives to 3 Lines of Defense

Traditional “Three Lines of Defense” (3LoD) frameworks—where business units hold risks, compliance oversees, and audit assures—have been criticized for encouraging silos, compliance theater, and limited strategic integration (riskleadershipnetwork.com, www2.deloitte.com). Today’s dynamic business environments call for more fluid, integrated models. 

 

🔁 1. Forrester’s Continuous Risk Management (CRM) Model 

Forrester proposes a holistic, lifecycle-aligned model that bridges strategy and performance: 

• Two phases in each lifecycle stage: plan, assess, decide, and act 

• Iterative stakeholder engagement, linking risk decisions directly to strategic objectives 

• Domain-agnostic approach, enabling uniform risk taxonomy and value-focused decisions (forrester.com) 

Why it works: It eliminates silos by integrating risk governance directly into strategic cycles—making risk a continuous part of operations. 

 

🎯 2. ISO 31000: Principles‑Based Risk Governance 

ISO 31000 (2018) emphasizes risk as a value-creation enabler, embedding leadership responsibility and integrating risk processes into organizational structure: 

• Core principles: leadership commitment, customized framework, iterative improvement 

• Framework elements: context, risk assessment, treatment, reporting, monitoring, improvement (en.wikipedia.org) 

Why it works: Offers flexibility across sectors, aligning risk management with existing management systems and strategy—without imposing rigid roles. 

 

🏛️ 3. COSO ERM Integrated Framework 

COSO’s ERM model frames risk governance across five interlinked domains: 

1. Governance & culture 

1. Strategy & objective-setting 

1. Performance & risk response 

1. Information, communication & reporting 

1. Review & revision (investopedia.com, investopedia.com) 

Why it works: Clearly connects governance structures (boards, risk committees) to risk appetite and strategic planning—rather than separating oversight into lines. 

 

🧩 4. COBIT & IT‑Embedded Risk Governance 

For technology-dependent organizations, COBIT offers control objectives and governance for IT risks, integrated with enterprise-wide risk: 

• IT governance framework with alignment to ISO/IEC 38500 and Risk IT 

• Focus on integrating IT risk oversight into strategic decision making (en.wikipedia.org) 

Why it works: Breaks down silos by embedding critical IT and cyber risk management into board-level governance. 

 

🔄 5. Blended, Principle‑Based Model (IIA Three‑Lines Evolution) 

The IIA has modernized the original 3LoD into a model based on six principles: 

• Governing body accountability 

• Clear roles—though not rigid silos 

• Risk management as a shared, values-driven process (mayerbrown.com, en.wikipedia.org) 

Why it works: This blend emphasizes flexibility, integration, and shared responsibility—reducing friction between lines. 

 

✅ Comparative Snapshot 

Model	Integration with Strategy	Governance Style	Key Strength
Forrester CRM	✔ Throughout strategy-performance cycles	Iterative via stakeholders	Value-focused, dynamic
ISO 31000	✔ Leadership and culture at core	Principles-based risk integration	Flexible, scalable
COSO ERM	✔ Links risk & objectives	Board-led, structured	Strategic oversight clarity
COBIT	✔ Embedded in IT/tech strategy	IT control governance	Tech risk alignment
IIA Evolution	✔ Encourages cross-functional roles	Principle-driven, adaptable	Breaks down silos

 

⚙️ Implementing an Alternative Framework 

1. Clarify expectations — Define risk appetite and culture at the board level. 

1. Select a model or hybrid — Choose Forrester, ISO 31000, COSO ERM, COBIT, or IIA principles based on context. 

1. Embed into strategy and governance — Risk should be part of planning, budgets, KPIs, and performance management. 

1. Define clear roles and feedback loops — Move beyond “lines” to dynamic responsibility allocation. 

1. Leverage technology — Use ERM or GRC platforms to track risk lifecycle, responsibilities, metrics. 

1. Review and evolve — Build regular review processes into strategic cycles to adjust as business evolves. 

 

🧠 Final Takeaways 

• The classic 3LoD model is being superseded by more agile, integrated approaches. 

• Models like Forrester CRM, ISO 31000, COSO ERM, COBIT, and IIA’s evolved version advocate for culture-led, principle-based, and strategically aligned risk governance. 

• The goal is a living ecosystem—where risk is managed with strategy and operations, not in spite of them. 

Discussion prompt: 

 What risk governance model does your organization use? Are you exploring integrated, principle-based frameworks over the traditional Lines model? Share your approach and outcomes below!