What is the primary objective of **ISO 37301**?

**ISO 37301 specifies requirements for establishing, implementing, maintaining, and continually improving an effective **Compliance Management System (CMS)**.** Published on 13 April 2021 as the first certifiable edition replacing guidance-only ISO 19600, it follows the **High-Level Structure (HLS)** and **Plan-Do-Check-Act (PDCA)** cycle to identify **compliance obligations**, assess **risks and opportunities**, embed a **compliance culture**, and enable third-party certification for organizations of all sizes and sectors.

Who is legally or professionally required to comply with **ISO 37301**?

**No organization is legally required to comply with ISO 37301, as it is a voluntary, certifiable standard applicable to all types, sizes, and sectors.** It supports professional adoption by those facing regulatory complexity, ESG demands, or stakeholder expectations for demonstrable integrity, with **top management** accountable for **leadership commitment**, **resource allocation**, and fostering a **compliance culture** through defined roles like compliance officers.

Does **ISO 37301** require an external audit or third-party certification?

**ISO 37301 enables but does not require external audits or third-party certification.** Certification is available via **accredited bodies** (e.g., ANAB-accredited certification bodies) following a typical three-year cycle with initial assessment and surveillance audits, providing verifiable evidence of CMS conformity to **HLS clauses** like context, planning, operation, and performance evaluation.

How often should an assessment for **ISO 37301** be performed?

**ISO 37301 requires continual performance evaluation through monitoring, measurement, internal audits at planned intervals, and management reviews.** Assessments follow a risk-based frequency, with certification involving surveillance audits typically annually in a three-year cycle, plus continual improvement via **KPIs**, **corrective actions**, and updates like the 2024 **Amd 1:2024** on climate action.

What are the consequences of non-compliance with **ISO 37301**?

**Non-conformity with ISO 37301 within a certified CMS triggers internal corrective actions, root-cause analysis, and potential certification suspension or withdrawal by accredited bodies.** It exposes organizations to heightened **compliance risks** like regulatory fines, reputational damage, or litigation from unaddressed obligations, without direct ISO-imposed penalties as it is voluntary.

An **ISO 37301** be mapped to other international frameworks?

**Yes, ISO 37301 follows the ISO High-Level Structure (HLS or Annex SL), enabling seamless mapping and integration with other ISO management system standards.** Its PDCA cycle and clauses on leadership, planning, support, operation, evaluation, and improvement align for **Integrated Management Systems (IMS)**, reducing duplication in audits and controls.

What is the first step to begin implementing **ISO 37301**?

**The first step is determining the organization's context, including internal/external issues, interested parties' needs, and scope of the CMS.** Secure **top management buy-in**, inventory **compliance obligations** into a centralized register, prioritize material risks, and align with strategic objectives per Clause 4, as outlined in the implementation playbook.

What is the primary objective of **MAS TRM**?

**MAS TRM's primary objective is to establish sound technology risk governance and oversight while maintaining cyber resilience through defence-in-depth and continuous improvement of IT processes to preserve confidentiality, integrity, and availability (CIA) of data and systems.** Per the January 2021 Guidelines (Preface 1.4), it promotes proportional practices for financial institutions (FIs) supervised by the Monetary Authority of Singapore (MAS), addressing digital transformation risks like cyber threats and interconnected ecosystem weaknesses.

Who is legally or professionally required to comply with **MAS TRM**?

**MAS TRM applies to all financial institutions (FIs) supervised by MAS, including banks, insurers, capital market intermediaries, payment service providers, and fintech sandbox participants.** Implementation must be commensurate with risk, complexity, and technologies used (Section 2.2); boards and senior management bear accountability for oversight and escalation (Section 3.1).

Does **MAS TRM** require an external audit or third-party certification?

**MAS TRM mandates an independent internal audit function to assess controls, governance, and risk management effectiveness (Sections 3.1.7, 15), but does not require external audits or third-party certification.** FIs may incorporate industry standards for assurance; MAS considers observance of Guidelines' spirit during supervision (Section 2.2).

How often should an assessment for **MAS TRM** be performed?

**MAS TRM requires regular, risk-commensurate assessments, including annual penetration testing for Internet-accessible systems (Section 13.2.4), periodic vulnerability assessments (Section 13.1.1), annual DR plan reviews (Section 8.2.2), and ongoing monitoring of policies, risks, and controls (Sections 3.2.1, 4.1.5).** Frequency scales with criticality, changes, and threats.

What are the consequences of non-compliance with **MAS TRM**?

**Non-compliance with MAS TRM exposes FIs to supervisory actions including fines, license conditions, revocations, and executive prohibitions, as MAS evaluates Guideline observance in supervision (Section 2.2).** Examples include S$27.45M fines for AML/CFT lapses tied to tech gaps and CMS license revocation for governance failures.

An **MAS TRM** be mapped to other international frameworks?

**Yes, MAS TRM aligns with frameworks like NIST CSF 2.0 and ISO 27001 through shared principles of governance, risk lifecycle (identify-assess-treat-monitor), defence-in-depth, and CIA protection (Sections 2.3, 4).** FIs should incorporate best practices proportionally (Section 3.2.1).

What is the first step to begin implementing **MAS TRM**?

**The first step is board approval of a technology risk appetite/tolerance statement and establishment of a TRM framework with independent oversight (Sections 3.1.7, 4.1).** This includes appointing CIO/CISO roles and creating an information asset inventory (Sections 3.1.3, 3.3).

ISO 37301 vs MAS TRM

Standards Comparison

ISO 37301

Voluntary

2021

International standard for compliance management systems

MAS TRM

Mandatory

2021

Singapore guidelines for financial technology risk management.

Quick Verdict

ISO 37301 provides certifiable CMS requirements for all organizations globally, while MAS TRM enforces technology risk guidelines for Singapore FIs. Companies adopt ISO 37301 for universal compliance assurance; MAS TRM to meet supervisory expectations and avoid fines.

Compliance Management

ISO 37301

ISO 37301:2021 Compliance management systems – Requirements with guidance

Cost

€€€€

Complexity

High

Implementation Time

12-18 months

Key Features

Certifiable requirements standard replacing guidance-only ISO 19600
High-Level Structure for integration with ISO 9001/14001/27001
Risk-based compliance obligations assessment and planning
Leadership commitment and organizational culture emphasis
Mandatory confidential whistleblowing channels with protections

Technology Risk Management

MAS TRM

MAS Technology Risk Management Guidelines

Cost

€€€€

Complexity

Medium

Implementation Time

12-18 months

Key Features

Board and senior management accountability for oversight
Proportional controls based on risk and criticality
Third-party risk assessment and ongoing assurance
Defence-in-depth cyber resilience requirements
Annual penetration testing for internet-facing systems

Detailed Analysis

A comprehensive look at the specific requirements, scope, and impact of each standard.

ISO 37301 Details

What It Is

ISO 37301:2021 – Compliance management systems – Requirements with guidance for use is a certifiable international standard for establishing, implementing, maintaining, and improving effective compliance management systems (CMS). It applies to all organization sizes and sectors, using a risk-based approach and Plan-Do-Check-Act (PDCA) cycle aligned with ISO High-Level Structure (HLS).

Key Components

Core clauses: context, leadership, planning, support, operation, performance evaluation, improvement.
Emphasizes leadership commitment, risk assessment, whistleblowing protections, internal audits, and continual improvement.
Built on HLS for integration; companion standards like ISO 37302 for measurement.
Third-party certification via accredited bodies (e.g., ANAB).

Why Organizations Use It

Demonstrates systematic compliance to regulators, investors, partners.
Reduces risks of fines, reputational damage; supports ESG/SDGs.
Enhances culture of integrity, stakeholder trust.
Competitive edge through certification; aligns with regulatory complexity.

Implementation Overview

Phased: gap analysis, compliance register, training, audits.
Scalable for SMEs/large enterprises; 3-year certification cycle.
Global applicability; 2024 amendment adds climate action. (178 words)

MAS TRM Details

What It Is

MAS Technology Risk Management (TRM) Guidelines (revised January 2021) are supervisory guidelines issued by the Monetary Authority of Singapore (MAS). They provide principles-based guidance for managing technology and cyber risks in financial institutions (FIs), emphasizing proportional implementation based on risk profile, complexity, and service criticality to ensure confidentiality, integrity, and availability (CIA).

Key Components

Covers 15 sections: governance, risk frameworks, secure development, IT service management, resilience, access controls, cryptography, data/infrastructure security, cyber operations, assessments, online services, and audit.
Synthesizes 12 core principles like board accountability, asset inventory, third-party oversight, and defence-in-depth.
No fixed controls; focuses on outcomes with independent assurance.

Why Organizations Use It

Mandatory supervisory consideration for Singapore FIs to avoid enforcement.
Enhances resilience, reduces cyber incidents, builds trust.
Supports digital transformation while managing ecosystem risks.

Implementation Overview

Risk-based: inventory assets, assess risks, deploy controls, test resilience.
Applies to all MAS-supervised FIs; scalable by size.
Requires board-approved strategies, audits; no formal certification.

Key Differences

Aspect	ISO 37301	MAS TRM
Scope	Compliance management systems across all obligations	Technology and cyber risks in financial services
Industry	All sectors, global applicability	Singapore financial institutions only
Nature	Certifiable international standard, voluntary	Supervisory guidelines, enforceable through supervision
Testing	Internal audits, management reviews, certification audits	Penetration testing, vulnerability assessments, DR tests
Penalties	Loss of certification, no legal penalties	Fines, license revocation, executive prohibitions

Scope

ISO 37301

Compliance management systems across all obligations

MAS TRM

Technology and cyber risks in financial services

Industry

ISO 37301

All sectors, global applicability

MAS TRM

Singapore financial institutions only

Nature

ISO 37301

Certifiable international standard, voluntary

MAS TRM

Supervisory guidelines, enforceable through supervision

Testing

ISO 37301

Internal audits, management reviews, certification audits

MAS TRM

Penetration testing, vulnerability assessments, DR tests

Penalties

ISO 37301

Loss of certification, no legal penalties

MAS TRM

Fines, license revocation, executive prohibitions

Frequently Asked Questions

Common questions about ISO 37301 and MAS TRM

ISO 37301 FAQ

MAS TRM FAQ

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ISO 37301

MAS TRM

Quick Verdict

ISO 37301

Key Features

MAS TRM

Key Features

Detailed Analysis

ISO 37301 Details

What It Is

Key Components

Why Organizations Use It

Implementation Overview

MAS TRM Details

What It Is

Key Components

Why Organizations Use It

Implementation Overview

Key Differences

Scope

Industry

Nature

Testing

Penalties

Frequently Asked Questions

ISO 37301 FAQ

What is the primary objective of ISO 37301?

Who is legally or professionally required to comply with ISO 37301?

Does ISO 37301 require an external audit or third-party certification?

How often should an assessment for ISO 37301 be performed?

What are the consequences of non-compliance with ISO 37301?

An ISO 37301 be mapped to other international frameworks?

What is the first step to begin implementing ISO 37301?

MAS TRM FAQ

What is the primary objective of MAS TRM?

Who is legally or professionally required to comply with MAS TRM?

Does MAS TRM require an external audit or third-party certification?

How often should an assessment for MAS TRM be performed?

What are the consequences of non-compliance with MAS TRM?

An MAS TRM be mapped to other international frameworks?

What is the first step to begin implementing MAS TRM?

You Might also be Interested in These Articles...

Singapore PDPA Implementation Guide: Mastering Part 6A Breach Notification Thresholds and Timelines from Primary Statute

NIST CSF 2.0: Key Enhancements and How They Address Evolving Cyber Threats

Proving CIS Controls v8.1 Works: A KPI & Evidence Framework for Board Reporting, Audits, and Continuous Assurance

Run Maturity Assessments with GRADUM

Check out these other Gradum.io Standards Comparison Pages

ISO 21001 vs ISO 30301

ISO 26000 vs MLPS 2.0 (Multi-Level Protection Scheme)

DORA vs REACH