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Control Institute
Category: Governance and Roles

Compliance Officer

Also known as: Corporate Compliance Officer, Chief Compliance Officer
Simply put

A compliance officer is an employee or professional responsible for making sure an organization follows the laws, regulations, and internal policies that apply to it. In practice, this person oversees the company's compliance activities and helps ensure business processes align with applicable requirements. The specific duties and scope typically vary depending on the organization and the regulations that apply.

Formal definition

A compliance officer is the individual within an organization accountable for overseeing adherence to applicable government laws and regulations, regulatory requirements, and internal policies. Responsibilities generally include monitoring organizational and business processes for regulatory compliance and helping ensure the organization can fulfill its obligations under the laws and regulations that apply to it. The exact scope, qualifications, and duties depend on the organization, its industry, and the applicable regulatory environment, and this role is not defined identically across all frameworks or jurisdictions.

Why it matters

For organizations pursuing SOC 2 attestation or ISO/IEC 27001 certification, the compliance officer is often the person who ensures that regulatory obligations, internal policies, and framework requirements are actively monitored rather than treated as one-time projects. Because a SOC 2 report attests only to the controls and period covered, and an ISO 27001 certificate covers only the defined scope of the ISMS, sustained oversight matters: someone must keep processes aligned with applicable laws and regulations between audits and surveillance activities. The compliance officer typically fills this ongoing accountability gap.

The role also helps translate external requirements into internal practice. As the evidence indicates, a compliance officer is responsible for assuring that an organization can fulfill its duties under whatever laws and regulations apply to it, and for monitoring organizational and business processes for regulatory compliance. In a compliance program, this bridging function reduces the risk that controls exist on paper but are not operating as intended, which is particularly relevant in a SOC 2 Type II engagement that assesses operating effectiveness over a review period.

It is important not to overstate the role's authority or scope. The specific duties, qualifications, and reach of a compliance officer depend on the organization, its industry, and the applicable regulatory environment, and the role is not defined identically across frameworks or jurisdictions. Neither SOC 2 nor ISO 27001 mandates a job title called "compliance officer"; the responsibilities may be distributed across several roles depending on how an organization structures its program.

Who it's relevant to

GRC and Compliance Teams
Governance, risk, and compliance professionals rely on this role to monitor organizational and business processes against applicable laws, regulations, and internal policies. In many organizations, the compliance officer coordinates the day-to-day activities that keep a compliance program functioning between audits and certification cycles.
Executive and Board Leadership
Senior leadership depends on compliance oversight to understand whether the organization can fulfill its regulatory obligations. Because scope and authority vary by organization and industry, leadership typically defines how much responsibility this role carries and how it relates to other governance functions.
Auditors and Assessors
CPA firms performing a SOC 2 examination and certification bodies assessing an ISO 27001 ISMS often interact with whoever holds compliance accountability to understand how policies and controls are monitored. Note that neither framework requires a specific "compliance officer" title, so the relevant point of contact depends on how the organization assigns these responsibilities.
Security and Operations Engineers
Engineers responsible for implementing controls often work with the compliance function to ensure that operational processes remain aligned with applicable requirements. The nature of this collaboration depends on organizational structure and the scope of the applicable regulations or frameworks.

Inside Compliance Officer

Governance and Oversight
The Compliance Officer typically maintains oversight of the organization's control environment, coordinating governance activities across frameworks such as SOC 2 and ISO 27001. This includes ensuring that policies, roles, and responsibilities are defined and that leadership remains informed of compliance posture.
Framework Coordination
In most engagements, the Compliance Officer coordinates preparation for a SOC 2 examination (an attestation performed by a licensed CPA firm under the AICPA SSAE 18 standard) and for ISO/IEC 27001 certification (issued by an accredited certification body against the ISMS requirements). The role manages the distinct evidence and scoping needs of each, recognizing that satisfying one does not automatically satisfy the other.
Scope Definition
The Compliance Officer helps define scope, which drives outcomes for both frameworks. For SOC 2 this includes selecting which Trust Services Criteria apply beyond the required Security (Common Criteria) category, and for ISO 27001 this includes defining the boundaries of the ISMS and informing the Statement of Applicability.
Risk Assessment Support
The role typically supports or facilitates risk assessment activities, which under ISO 27001 inform the selection of Annex A reference controls via the Statement of Applicability, and which help identify the controls addressed in a SOC 2 examination.
Evidence and Audit Liaison
The Compliance Officer often serves as the primary liaison to auditors and certification bodies, coordinating evidence collection over the applicable period (for a SOC 2 Type II, the review period length varies based on scoping decisions) and managing responses to findings.
Continual Improvement and Monitoring
The role generally oversees ongoing monitoring of control operation and, for ISO 27001, supports the continual improvement expectations embedded in the ISMS requirements (clauses 4 through 10), rather than treating compliance as a one-time event.

Common questions

Answers to the questions practitioners most commonly ask about Compliance Officer.

Does the Compliance Officer issue the SOC 2 report or the ISO 27001 certificate?
No. A SOC 2 report is issued by a licensed CPA firm performing an attestation examination under the AICPA SSAE 18 standard, and an ISO/IEC 27001 certificate is issued by an accredited certification body following a certification audit. The Compliance Officer typically coordinates readiness, manages evidence, and serves as the internal point of contact, but does not personally produce the report or grant the certification. Those outcomes come from independent external parties.
If our Compliance Officer gets us through a SOC 2 examination, does that mean we automatically satisfy ISO 27001 too?
Not automatically. SOC 2 and ISO 27001 are distinct frameworks with different structures and objectives, and satisfying one does not by itself satisfy the other. Mapping between the Trust Services Criteria and the ISO 27001 ISMS requirements and Annex A reference controls is possible but partial. A Compliance Officer may leverage overlapping evidence to reduce duplicated effort, but each framework requires its own scoping, assessment, and independent external engagement.
How does a Compliance Officer typically prepare for a SOC 2 Type II engagement?
In most engagements, the Compliance Officer works with stakeholders to confirm scope, including which Trust Services Criteria categories apply beyond the required Security (Common Criteria). Because a Type II assessment evaluates both design and operating effectiveness over a defined review period whose length is set by scoping decisions, the officer generally focuses on ensuring controls operate consistently throughout that period and that supporting evidence is collected continuously rather than assembled at the end.
What role does a Compliance Officer play in maintaining the Statement of Applicability for ISO 27001?
For ISO 27001, the certifiable requirements sit in clauses 4 through 10 (the ISMS requirements), while Annex A lists reference controls selected via a Statement of Applicability informed by the risk assessment. A Compliance Officer commonly coordinates keeping the Statement of Applicability current, documenting which reference controls are included or excluded and the justification, and aligning it with the organization's risk assessment as the ISMS evolves. The applicable control set depends on the edition of the standard in use.
How does a Compliance Officer manage evidence collection across both frameworks?
Depending on scope, a Compliance Officer often maintains a centralized evidence repository and a control mapping so that shared artifacts can support more than one framework where the requirements genuinely overlap. Because such mapping is only partial, the officer typically tracks which evidence satisfies which criteria or clause separately, rather than assuming a single artifact covers both. This helps reduce duplicated effort while preserving the distinct requirements of each engagement.
How should a Compliance Officer communicate the limitations of a completed report or certificate to internal stakeholders?
A Compliance Officer generally clarifies that a SOC 2 report attests only to the controls and the period covered and does not guarantee freedom from breaches, and that an ISO 27001 certificate covers only the defined scope of the ISMS. Communicating these boundaries, along with distinctions from related standards such as SOC 1, SOC 3, ISO 27002, ISO 27017, and ISO 27018 where relevant, helps stakeholders avoid overstating what a given outcome represents.

Common misconceptions

The Compliance Officer's job is done once a SOC 2 report is delivered or an ISO 27001 certificate is issued.
Both outcomes cover only a defined scope and, for a SOC 2 Type II, a defined review period. A SOC 2 report attests only to the controls and period covered and does not guarantee freedom from breaches, and an ISO 27001 certificate covers only the defined ISMS scope. The role typically involves ongoing monitoring and, for ISO 27001, continual improvement between assessments.
A Compliance Officer who achieves SOC 2 has effectively achieved ISO 27001, since the frameworks are equivalent.
The two frameworks are distinct: SOC 2 is an attestation examination resulting in a report, while ISO 27001 is a certification against a management system standard. Mapping between them is possible but partial, and satisfying one does not automatically satisfy the other. The Trust Services Criteria are not the same as ISO 27001 Annex A controls.
The Compliance Officer must implement every Annex A control for ISO 27001 certification.
Annex A lists reference controls that are selected via a Statement of Applicability and informed by the risk assessment, so applicability depends on scope and risk. The certifiable requirements themselves reside in clauses 4 through 10. Note that Annex A was restructured in the 2022 revision, so control counts depend on the edition cited.

Best practices

Maintain separate, clearly labeled workstreams for SOC 2 and ISO 27001 to avoid conflating an attestation report with a certification, and communicate this distinction accurately to stakeholders.
Drive scoping decisions early, confirming which Trust Services Criteria beyond Security apply for SOC 2 and defining the ISMS boundaries and Statement of Applicability for ISO 27001, since scope shapes both outcomes.
Where a SOC 2 Type II is pursued, coordinate with the CPA firm to agree the review period during scoping, recognizing that its length varies rather than assuming a fixed duration.
Use documented risk assessment to inform ISO 27001 Annex A control selection rather than assuming all reference controls are required, and specify the standard version when referencing control counts.
Identify overlapping controls to reuse evidence efficiently across frameworks, while recognizing that mappings are partial and one framework's outcome does not automatically satisfy the other.
Establish ongoing monitoring and continual improvement so that compliance persists beyond the report period or certification date, and communicate clearly that each outcome covers only its defined scope and period.