If you work in Governance, Risk, and Compliance (GRC), you are likely familiar with the dreaded cycle of “Audit Fatigue.”

It usually looks something like this: You spend Q1 scrambling to gather evidence for your ISO 27001 surveillance audit. Barely a month later, you are doing the exact same work—interviewing the same engineers and taking screenshots of the same settings—to satisfy your SOC 2 auditors. By the time Q4 rolls around, you’re doing it all over again for a specialized customer assessment or HIPAA compliance.

You are testing the same controls three different times to satisfy three different frameworks. This isn’t just inefficient; it’s a recipe for burnout.

The solution isn’t to work harder or hire more analysts. The solution is to build a Common Control Framework (CCF) using a policy crosswalk.

The “Hub and Spoke” Model

The most effective way to build a CCF is to adopt a “Hub and Spoke” model.

In this model, you choose one gold-standard framework to be your “Hub”—your single source of truth. For most US-based companies, the best candidate for this is the NIST Cybersecurity Framework (CSF) or NIST SP 800-53.

Why NIST? Because it is comprehensive, free, and widely recognized. Once you have your NIST-based policies written (the Hub), you map them out to the specific requirements of other regulations (the Spokes), such as SOC 2, ISO 27001, PCI-DSS, or GDPR.

How the Crosswalk Works in Practice

Let’s look at a specific example: Multi-Factor Authentication (MFA).

Without a crosswalk, you might have a “SOC 2 Access Policy” and a separate “ISO Access Policy.” With a crosswalk, you have a single “Enterprise Access Control Policy” based on NIST.

1. The Master Control (The Hub): You define your control based on NIST PR.AC-7: Users are authenticated commensurate with the risk of the transaction (e.g., MFA).
2. The Mapping (The Spokes): You tag this single control in your GRC tool or spreadsheet to show that it satisfies:
   • SOC 2: CC6.1 (Logical Access)
   • ISO 27001: A.9.4.2 (Secure Log-on Procedures)
   • HIPAA: §164.312(d) (Person or Entity Authentication)
   • PCI-DSS: Requirement 8.3 (MFA for non-console access)

The “Test Once, Comply Many” Advantage

The true ROI of the crosswalk comes during audit season.

When the SOC 2 auditor asks, “Show me evidence that remote users use MFA,” you pull the evidence for your NIST PR.AC-7 control. When the ISO auditor arrives two months later and asks the same question, you don’t need to bug your IT team again. You simply pull the exact same evidence file.

By centralizing your controls, you gain three massive benefits:

1. Consistency: Your policies are uniform across the organization, not fragmented by compliance regime.
2. Efficiency: You reduce evidence collection time by 50% or more.
3. Agility: When a new regulation hits (like a new privacy law), you don’t have to start from scratch. You simply map the new requirements to your existing NIST controls and see where the gaps are.

Stop managing five different security programs. Manage one program, and crosswalk the rest.

---

Discussion

• The Hub Choice: What is the “primary” framework your organization uses as its source of truth? (NIST, ISO, CIS, or something custom?)
• The Tooling: Do you use a dedicated GRC platform (like Drata, Vanta, or Hyperproof) to automate these mappings, or are you managing it in a master spreadsheet?

Sources

• NIST: Audit Crosswalks and Mappings
• Secure Controls Framework (SCF): Integrated Controls
• ComplianceForge: The Case for a Common Control Framework