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What Lockheed Martin’s CMMC Announcement Means for Subcontractors 

by: A-LIGN 02 Jul,2025 3 mins

CMMC

Lockheed Martin, a global leader in defense and aerospace innovation, has recently issued a decisive update regarding its implementation of Cybersecurity Maturity Model Certification (CMMC) requirements. This announcement underscores a critical trend sweeping the defense industry — an increasing push by Department of Defense (DoD) prime contractors to elevate and enforce stringent cybersecurity standards among their subcontractors.  

If you’re a business working with or aspiring to work with DoD contractors, you might already feel the pressure of meeting compliance benchmarks. However, this is more than just fine print in a contract: CMMC compliance is becoming a non-negotiable gateway to participating in defense supply chains. And as timelines tighten, early preparation could mean the difference between securing future opportunities and facing disqualification. 

The bigger picture: Prime contractors raising the bar 

For years, cyber threats have escalated in sophistication and frequency, threatening national security and the integrity of the defense supply chain. Recognizing the stakes, the DoD launched CMMC as a way to standardize cybersecurity practices across all organizations working with sensitive federal information.  

Prime contractors like Lockheed Martin are tasked with ensuring their entire network of subcontractors and suppliers meets these strict cybersecurity requirements as single gap in compliance anywhere along the supply chain could lead to devastating security breaches. This strategic shift by primes not only secures their operations but also reflects the DoD’s unwavering commitment to safeguarding controlled unclassified information (CUI). 

By tightening requirements, prime contractors are signaling that every link in the chain must be fortified. Subcontractors, especially smaller firms with fewer resources, are now facing a unique and urgent challenge to align with these standards or risk their place in the defense ecosystem. 

Why the urgency? 

The DoD is implementing CMMC requirements incrementally, but new updates like Lockheed Martin’s announcement make one thing crystal clear: the time to act is now. Compliance is no longer optional, and waiting until deadlines are looming can result in significant setbacks.  

Failing to prepare early could leave your organization at risk of losing critical contracts, disrupting your business operations, and even tarnishing your reputation. Additionally, as more primes adopt these standards, organizations without a proactive compliance plan will find themselves left behind in favor of those already meeting or exceeding requirements.  

Early adoption of CMMC compliance offers exciting opportunities as well. Compliant businesses strengthen their credibility, appeal to risk-averse primes, and position themselves as leaders within the defense community. By acting on CMMC now, you’re creating a robust foundation for long-term success. 

Steps to get started with CMMC  

Understanding where to begin your CMMC compliance journey can feel overwhelming, but breaking it down into actionable steps can simplify the process. Here’s how your organization can tackle CMMC today: 

Understand  

Read the CMMC final rule, understand program requirements, review DoD’s resources, and familiarize yourself with the practices outlined in the model for each of the CMMC levels.  

Identify  

Identify your CMMC level and the assets in scope for your CMMC assessment. As a part of this step, you should also complete a gap assessment to identify any areas where there are gaps in your compliance.  

Prepare  

Develop an implementation plan to address vulnerabilities found in the gap assessment. Prepare for the C3PAO assessment by gathering evidence and preparing for interview questions. During this stage, you may want to undergo a mock audit.  

Assess  

Following the CyberAB’s CMMC Assessment Process, the C3PAO will review documentation and complete interviews with your team before putting together the final report. If you’ve done the appropriate pre-work, gap assessments, and mock assessments, your team should be well prepared for this step in the process.  

Improve  

After receiving your certification, the work continues. Plan for continuous improvement and ensure you understand the next steps for future assessments.   

A-LIGN’s role in CMMC compliance  

Navigating compliance on your own can be complex, but partnering with experts like A-LIGN can streamline your roadmap to success. As a top C3PAO with over 20 years of experience, A-LIGN has completed over 1,000 NIST-based assessments, including FedRAMP, GovRAMP, NIST 800-171. Our trusted team of experts equips businesses with the tools, training, and guidance needed to confidently achieve compliance and securely scale their operations.  

By collaborating with a trusted advisor, you not only save time and resources but gain peace of mind knowing you’re meeting prime contractor expectations and DoD mandates. 

Act today or be left behind  

Lockheed Martin’s latest announcement isn’t just another update, it represents an inflection point for subcontractors across the defense industry. The window to prepare for CMMC compliance is closing, and organizations that proactively align with these standards now will have a competitive advantage.  

Don’t wait until it’s too late. Start preparing for CMMC today. Strengthen your cybersecurity posture, secure future business opportunities, and ensure your place in a resilient supply chain that safeguards America’s security. 

CMMC Phase 1: Why Contractors Shouldn’t Bet Everything on Self-Attestation

by: Matt Bruggeman 3 mins

CMMC

As CMMC enters its official rollout, many defense contractors are treating Phase 1 as a 12-month grace period — a window where self-attestation will be the only requirement for compliance with Level 2. And while that’s technically what the baseline rule allows, there’s a critical detail many are missing: 

DoD contracting officers have discretion to require third-party CMMC certifications — even during Phase 1. 

This is explicitly stated in the 32 CFR rule, but many organizations are moving forward as if self-attestation is guaranteed. Here’s why that’s a risky assumption — and how you can prepare accordingly. 

The costly misconception about CMMC timing 

Here’s where many companies are getting it wrong. A common belief is that CMMC certification isn’t needed until 12 months after 48 CFR rule becomes final. While this phased rollout timeline applies in general, an important detail tucked into the 32 CFR CMMC Program Rule states that DoD Program Managers will have discretion over requiring Level 2 CMMC Certification—even during the first 12 months.   

Yes, you read that right. According to the rule: 

“Phase 1. DoD intends to include the requirement for CMMC Statuses of Level 1 (Self) or Level 2 (Self)… DoD may also, at its discretion, include the requirement for CMMC Status of Level 2 (C3PAO) in place of the Level 2 (Self) CMMC Status for applicable DoD solicitations and contracts.”  

(Source: 32 CFR Part 170.3 e (1) – Cybersecurity Maturity Model Certification (CMMC) Program Rule) 

That final sentence is the most important — and often overlooked. 

Key takeaway:  

If your CMMC strategy revolves around hoping DoD Program Managers won’t enforce certification requirements early, you’re taking significant risks with your pipeline.  

What this means in practice 

Here’s what’s happening on the ground: 

  • Many primes are already flowing down CMMC certification requirements to their subs, regardless of phase. 
  • We’ve seen early RFIs and RFPs include CMMC language — including third-party certification expectations. 
  • With the 48 CFR rule expected to be finalized later this year, DoD contract officers could require CMMC Level 2 Certifications immediately thereafter. 

Bottom line: the rules may allow for self-attestation, but your contract may not. 

The risk of misreading phase 1 

Contractors who assume that Phase 1 guarantees a 12-month reprieve from C3PAO involvement are setting themselves up for: 

  • Contract risks: Organizations risk bid disqualification due to lack of a required third-party certification. 
  • Competitive disadvantage: Proactive competitors will be certified and ready to go. Delaying your own certification gives them the edge to secure more opportunities you could have been eligible for.   
  • Cost surges: The longer you wait, the higher the demand for certification services will be. This could lead to inflated service costs and fewer available resources as deadlines get closer.   
  • Lost trust: Primes and customers can lose trust, knowing that a contract’s status was unable to be awarded due to your lack of preparedness when the requirements come. 

How contractors can prepare 

Proactive organizations are avoiding the “wait and see” mindset. Here’s what we recommend through A-LIGN’s 5 Steps to CMMC Compliance: 

  • Understand: Read the program requirements and familiarize yourself with the practices outlined in the model for each of the CMMC levels.  
  • Identify: Based on your level, you must identify your scope and any gaps in compliance.  
  • Prepare: Develop an implementation plan and prepare for the C3PAO assessment 
  • Assess: Your C3PAO will complete the CMMC assessment for certification.  
  • Improve: Perform annual self-assessments before renewing your 3-year CMMC certification 

Final word

Phase 1 of CMMC’s rollout is not a blanket exemption from certification. It’s a flexible phase that gives the DoD — and contracting officers — room to assess risk and require certification when they see fit. 

Don’t leave your compliance future up to chance. By taking proactive steps now, you’re not only protecting your pipeline but also safeguarding your reputation as a trusted partner in the defense supply chain.   

Need help navigating your CMMC strategy? Schedule a consultation with our team of experts and ensure your organization is equipped to succeed.   

Guide: How to Transfer ISO Certification Bodies 

by: A-LIGN 25 Jun,2025 5 mins

Audit QualityISO 27001ISO 42001

Your compliance team dedicates time and mental energy toward securing the best quality ISO certifications to keep your organization in good standing. But things don’t always work out with your certification body. Keep reading to learn about the process of transferring your company’s ISO certificates to a new auditor. 

Why would you transfer your ISO certificate? 

There are a number of reasons you may want to change your current auditor: 

  • Inefficient audit process 
  • Poor communication 
  • Unsatisfactory final report and certificate 
  • Consolidating your audit cycles 

If any of these sound familiar, you may be heading towards making the decision to finding a new audit partner. But it doesn’t have to be overwhelming. The right partner will make it all worth your while. 

Who is eligible to transfer their certificate? 

While you might think the answer to this is anyone – it’s not. There are a few criteria that should be met before committing to a certificate transfer: 

  • Accredited certification body: If you’re looking to transfer to an accredited auditor, your certificate must be from an accredited certification body with valid accredited standards. 
  • Enough time: This process may take a few weeks to collect the documentation and coordinate with the prior certification body. Pay attention to the timeline for required surveillance audits so that you don’t allow your certificate to suspend of expire. Plan ahead so you have plenty of time for the transfer. 
  • Certificate scope: Transferring your certificate doesn’t mean you get to expand the scope or locations of your audit, it must stay the same or be a reduced scope for you to move from one auditor to another. You can add more locations or additional scope in your next audit cycle. 

What is the process for transferring ISO certificates? 

The process for transferring your ISO certificate can be tedious, but the right audit partner will simplify the transition. Take the time to understand what documents you should prepare and how to navigate the steps to transfer auditors to reduce stress and streamline the process. 

Preparation 

It should come as no surprise that you will need to gather documents before transferring auditors. First, it’s imperative that you verify the validity of your certificate. You cannot transfer certificates from an unaccredited certification body to an accredited one. Luckily, the International Accreditation Forum (IAF) makes it easy to verify the accreditation of your CB with their database – IAF CertSearch.  If you worked with an unaccredited certification body, you’ll need to complete an initial certification audit with an accredited certification body. 

After this step is complete, we recommend checking the expiration date and scope of your ISO certification. If your certification is days or weeks from expiring, now is likely not the time to begin the transfer process. In addition, you should understand that the scope of your audit must stay the same or reduced for the transfer process. A new location or expanded scope may be added after the certificate has been transferred, either during the next audit or as a special audit.  

You should ensure you start this process at least three months before your certificate is at risk of being suspended due to surveillance audits not meeting the required timeline or your certificate expires, preferably more. This is because the process of approving a transfer once you’ve chosen a new certification body can take several weeks. Then, you’ll need to get on the schedule for your next audit. When transferring auditors, it’s particularly important to not rush the process and do it right. 

Transfer Process 

Now that you’ve prepared and verified your certificate, it’s time to get started! 

This step in the process will be very similar to the last time you did it: you will research certification bodies and look for one that aligns with your priorities. We recommend choosing a partner that has an experienced audit team, a high standard of quality, and prioritizes efficiency through technology and audit consolidation. For a comprehensive checklist of questions to ask potential CBs, check out our ISO 27001 Buyer’s Guide. 

Checklist: Questions to ask an assessor 

  • What is your experience with ISO certification audits? 
  • Does your team have experience with multiple ISO certification standards including ISO/IEC 27001, ISO/IEC 42001 or ISO/IEC 27701? 
  • Does your organization conduct other audits such as SOC 2, PCI DSS or HITRUST? 
  • What can I expect during the audit process? 
  • How do you ensure the quality of your audits? 
  • How much will my audit cost? 
  • How long does an ISO audit take with your organization? 
  • Do you have references and case studies from satisfied customers? 

For the complete checklist, download our ISO 27001 Buyer’s Guide. 

Your commitment 

You’ve chosen a new certification body that aligns with your organization’s priorities – congratulations! Here’s what the process will look like at this stage: 

  • Certificate verification: At this time, you will provide your current certificate to your new certification body’s audit team. They will verify its validity and request a transfer from your former CB. This step could take some time, so be prepared to wait. 
  • Review of information: In order to transfer your certificate to a new certification body, a number of items will need to be reviewed in accordance with IAF MD 2: IAF Mandatory Document for the Transfer of Accredited Certification of Management Systems. Your CB will review confirmation of the AB and CB scopes, reasons for transfer, sites that are transferring, previous reports, certificates, audit program, complaints received and additional audits with regulatory bodies. Additionally, your new certification will need to coordinate with the previous certification body to ensure all nonconformities have verified actions in accordance with the severity and that the status of the certificate is not in danger of falling out of active status.   
  • Contract signing: While a contract may be signed prior to a transfer, an amendment will need to be executed if the transfer is not accepted by the certification body.   

Acceptance 

After your former certification body accepts the transfer, your new certification body will issue you an updated certificate on the new CB’s paper. There will be no lapse in coverage if your certificate was valid and the scope is the same. Your ISO certification will now continue through the audit lifecycle. 

If the certification body does not accept the transfer, you will need to start with an initial certification audit. 

Best practices for transferring ISO certificates 

  • Start early: Like we mentioned, give yourself at least three months from the time you choose your new CB to the expiration date of your certificate. You don’t want any lapse in coverage or to have to start the audit process over again! 
  • Ensure the validity of your certificate: IAF makes it easy to check the validity of your certification body. Simply look up your CBs information in their database to confirm accreditation.  
  • Choose a quality partner: You’ve seen the results of choosing the wrong partner. Take the time to choose a partner that meets your standards of quality and aligns with your values in the process. 
  • Now is the time to streamline: Pick a provider that can handle all of your audits and highlight overlaps you didn’t even know existed. This will help your team work smarter, not harder. 

If you’re ready to work with a high-quality audit partner that prioritizes team expertise, technology, and efficiency, A-LIGN may be the choice for you. Contact us today to learn how to get started on the path to a first-class final report. 

What is the EU AI Act? 

by: A-LIGN 23 Jun,2025 4 mins

EMEAISO 42001

The European Union Artificial Intelligence Act is a framework developed by the EU to regulate artificial intelligence development and use. This piece of legislation is relatively new, but its phased approach means companies must take action now. If you’re not sure where to begin with the EU AI Act, read on for our guide to this emerging standard and next steps for becoming compliant. 

What is the EU AI Act and why is it important? 

The EU AI Act is one of the first comprehensive frameworks for regulating AI globally. It defines a risk-based AI classification system and requires companies doing business in the EU to proactively implement compliance measures to avoid legal and operational risks. The act classifies AI applications into four risk categories: unacceptable, high, limited, and minimal, each subject to specific rules or restrictions.  

Who does the EU AI Act apply to? 

The EU AI Act is far-reaching. This standard applies to: 

  • Organizations placing an AI product on the market in the EU 
  • Users of AI products and services in the EU 
  • Providers or users of an AI system intended to be used in the EU 

It’s important to note that the EU AI Act isn’t just for organizations or users based in the EU, but also any organization working, selling, or using AI products in the EU. 

What are the risk categories defined by the EU AI Act? 

The EU AI Act organizes AI products and uses into four risk categories: unacceptable, high risk, limited risk, and minimal risk.  

Unacceptable risk 

This is the most severe level of risk defined by the EU AI Act. According to the European Parliament, the EU AI Act highlights several banned AI applications in the EU including: 

  • Cognitive behavioral manipulation of people or specific vulnerable groups. This includes things like voice-activated toys that could encourage dangerous behavior in children 
  • Social scoring AI: classifying people based on behavior, socio-economic status or personal characteristics 
  • Biometric identification and categorization of people 
  • Real-time and remote biometric identification systems, such as facial recognition in public spaces 

High risk 

This standard considers AI systems that negatively impact safety or fundamental rights as high risk. From there, it breaks these systems into two categories: 

  • AI systems used in products defined by the EU’s product safety legislation like toys, aviation, card, medical devices, and lifts 
  • AI systems that fall into specific area that will have to be registered in an EU database, like education, law enforcement, critical infrastructure, and other related areas. 

Limited risk 

Some AI products and use cases will fall into this category and be subject to transparency requirements. One example of this is ChatGPT. Systems that fall into the limited risk category will need to: 

  • Disclose that its content was generated by AI 
  • Design the model to prevent it from generating illegal content 
  • Publish summaries of copyrighted data used for training 

Minimal or no risk 

Most AI systems will fall into the minimal or no risk category, meaning they have no further legal obligations. 

What is the timeline for compliance? 

The EU AI Act became legally binding on August 1, 2024. However, the requirements in the act will begin to take effect gradually over time with a phased roll out. Key milestones include:  

  • February 2, 2025: Prohibitions on certain AI systems and requirements on AI literacy start to apply.  
  • August 2, 2025: Rules start to apply for notified bodies, GPAI models, governance, confidentiality and penalties.  
  • August 2, 2026: The remainder of the AI Act starts to apply, except for some high-risk AI systems with specific qualifications.  
  • August 2, 2027: All systems, without exception, must meet obligations of the AI Act. 

What are the penalties for noncompliance? 

According to Article 99 of the EU AI Act, the penalties for noncompliance with the prohibition of the AI practices referred to in Article 5 will be subject to administrative fines of up to EUR 35,000,000, or up to 7% of worldwide annual turnover, whichever is higher. 

Noncompliance with any other provisions not laid out in Article 5 will be subject to fines up to EUR 15,000,000 or up to 3% of worldwide annual turnover, whichever is higher. 

The EU AI Act also sets fines for those who supply incomplete, incorrect, or misleading information to notified bodies or national competent authorities when they request information. Those fines can be up to EUR 7,500,000 or up to 1% of worldwide annual turnover, whichever is higher. 

Why ISO 42001 is essential for EU AI Act compliance 

This standard mandates an ongoing governance framework for AI risk management, transparency, and compliance. Unlike one-time risk assessments or ad hoc governance policies, ISO 42001 establishes a systematic, repeatable process for AI compliance, ensuring organizations:  

  • Proactively manage AI risks rather than responding to enforcement actions.  
  • Align AI governance with business operations using structured risk-management frameworks.  
  • Demonstrate compliance through audit-ready documentation and performance evaluation.  

ISO 42001 provides an adaptable compliance framework that evolves alongside regulatory requirements, making it an ideal foundation for AI governance.  Though it is not an approved harmonized standard for AI Act conformity, it does provide the foundation you’ll need to be successful when the final QMS conformity standard is released. 

Next steps 

Companies seeking compliance with the EU AI Act need to act now to avoid penalties and stay ahead of the curve. Enforcement will only intensify over the next two years.  

We recommend reaching out to a high-quality auditor that can help your organization become compliant with the EU AI Act before it’s too late. Organizations that take action now will be best positioned to thrive in the new AI regulatory environment. 

Reach out to A-LIGN today to learn how our team can get your organization on the path to compliance. 

What is FedRAMP 20x? 

by: A-LIGN 16 Jun,2025 3 mins

FedRAMP

The federal cloud landscape is transforming, thanks to FedRAMP 20x. Announced in March 2025, this pilot initiative aims to accelerate the path to FedRAMP authorization, cutting timelines from years to weeks. By simplifying processes and leveraging automation, FedRAMP 20x offers a streamlined, cloud-native approach to security compliance.  

FedRAMP 20x

FedRAMP 20x addresses long-standing challenges in the FedRAMP authorization process. Traditionally, approval took years, requiring extensive documentation and layers of review. FedRAMP 20x aims to simplify this process, approving cloud services in weeks. 

Key improvements include: 

  • Automation of compliance: Using machine-readable processes to reduce manual tasks. 
  • Adoption of industry standards: Aligning with frameworks like SOC 2 and ISO 27001 to leverage existing security investments. 
  • Continuous monitoring: Validating security through real-time data instead of periodic audits. 
  • Direct collaboration: Encouraging more agile relationships between Cloud Service Providers (CSPs) and federal agencies. 
  • Rapid innovation: Eliminating delays to enable faster adoption of secure cloud services. 

This initiative prioritizes flexibility, empowering CSPs and agencies to work more directly and limit bureaucratic bottlenecks. 

Phase 1 pilot program overview

Phase 1 represents a crucial testing ground for FedRAMP 20x, showcasing how streamlined processes and automation can revolutionize cloud compliance for the federal space. 

Quick milestones

The first phase of FedRAMP 20x focuses on low-impact cloud systems. Open to any CSP, it replaces the traditional 325-item control baseline with a list of Key Security Indicators (KSIs). Participants submit machine-readable security documents, assessed by a Third Party Assessment Organization (3PAO). Successful systems can achieve provisional authorization in weeks. 

  • Timeline: Formal submissions started May 30, 2025.  
  • Fast-track approvals: CSPs earning low-impact authorization may gain priority for FedRAMP Moderate authorizations in the next phase. 

Participation criteria 

Providers suited for Phase 1 typically: 

  • Host solutions on FedRAMP-authorized platforms. 
  • Offer simple, internet-facing services. 
  • Maintain strong security through frameworks like SOC 2 or recent federal ATOs. 
  • Partner with a FedRAMP-accredited 3PAO for assessments. 

The removal of the federal sponsorship requirement for low-impact systems widens access, making compliance achievable for emerging providers and small businesses. 

Benefits of FedRAMP 20x

For CSPs targeting the federal market, FedRAMP 20x offers major benefits:

  • Faster approvals: Reduce authorization timelines from years to weeks. 
  • Easier processes: Minimized paperwork and increased automation lower costs and effort. 
  • Self-initiation: No agency sponsor needed for low-impact systems, opening opportunities for smaller providers. 
  • Cloud-native alignment: Requirements are more developer-friendly, focusing on agility and outcomes. 
  • Encouraged innovation: Continuous monitoring ensures new features can roll out quickly without delaying compliance. 

By lowering barriers and fostering competition, FedRAMP 20x brings more providers into the federal sector, supporting rapid technological advancement. 

Getting ready for FedRAMP 20x

To get ready for FedRAMP 20x, CSPs should take these steps: 

  • Learn the new standards: Study the draft KSIs to understand security expectations. 
  • Assess readiness: Compare your current compliance posture to the pilot’s criteria, identifying gaps. 
  • Engage with stakeholders: Join FedRAMP working groups for updates and insights. 
  • Prepare evidence: Plan machine-readable security submissions, working closely with a 3PAO to streamline assessments. 
  • Maintain basics: Continue following FedRAMP Rev.5 guidelines, as traditional routes to authorization remain valid. 

Organizations meeting Phase 1 criteria should consider joining the pilot to gain early access and a competitive edge. Even if you delay participation, investing in automation and compliance improvements now will prepare you for FedRAMP 20x expansion to higher-impact systems. 

How A-LIGN can support your FedRAMP journey

Navigating FedRAMP alone can be challenging. A-LIGN, as a trusted FedRAMP-accredited 3PAO, offers expert guidance for traditional FedRAMP and the 20x pilot. 

  • Readiness assessment: We help identify gaps, align security controls, and prepare your team for FedRAMP requirements. 
  • Assessment and documentation: Our expertise ensures seamless evaluations, minimizing surprises during the submission process. 
  • Continuous monitoring: A-LIGN supports post-authorization security through ongoing assessments and adaptable strategies. 

With FedRAMP 20x reshaping compliance standards, having a knowledgeable partner can make all the difference. We’re committed to supporting you at every stage, from preparation to long-term success. 

Red Teaming Explained 

by: A-LIGN 11 Jun,2025 3 mins

Pen Test

Cyber threats are becoming more sophisticated by the day. For organizations serious about fortifying their defenses, “red teaming” has become an indispensable practice. But what exactly is red teaming, and why does it hold such an important place in modern cybersecurity strategies? 

In this guide, we’ll break down the concept of red teaming, walk you through its process, explain how it differs from penetration testing, and outline its benefits.  

What is red teaming? 

Red teaming is a process used to simulate an adversary’s attack on a system, organization, or network to test its security, resilience, and response capabilities. The “Red Team” is a group of experts who take on the role of an attacker or adversary, attempting to exploit vulnerabilities and identify weaknesses across people, processes, and technologies of an organization. 

Unlike routine security checks, red teaming is a holistic exercise. It evaluates not just technological vulnerabilities but also human and procedural gaps, offering a more comprehensive view of an organization’s readiness. It mimics real-world scenarios, forcing organizations to test their detection, response, and prevention mechanisms under controlled conditions. 

When should you use red teaming? 

Red teaming is especially valuable for organizations that: 

  1. Handle sensitive customer data or intellectual property. 
  2. Operate in highly regulated industries, like finance or healthcare. 
  3. Desire to conduct an advanced security assessment beyond standard penetration testing. 

What is the process of a Red Team exercise?

Red Team exercises are methodical, typically following these six key steps to simulate an attack and assess an organization’s weaknesses: 

1. Define objectives & scope 

Before launching an exercise, it’s critical to establish clear goals and identify boundaries—such as systems, people, or processes—while conducting extensive research to gather information about the target systems, organization, and personnel. 

2. Planning & strategy 

The Red Team begins by developing a detailed plan outlining the methods, tools, and tactics to be used during the red teaming exercise. This step ensures alignment with the agreed scope and objectives. 

3. Attack simulation 

Once potential weaknesses are identified, the Red Team attempts to exploit vulnerabilities using the tactics, techniques, and procedures (TTPs) of real-world adversaries. After gaining initial access, they will maintain persistence and navigate through the network to achieve defined goals, such as accessing sensitive data or critical systems. 

4. Reporting & documentation 

Following the exercise, a comprehensive report is created detailing TTPs, how vulnerabilities were identified, and actionable recommendations to enhance security controls. 

5. Recommendations 

The Red Team will then provide actionable recommendations to mitigate identified risks and strengthen the organization’s defenses. 

6. Post-engagement debrief 

The last step in the process is to conduct a thorough review of the exercise with stakeholders, highlighting lessons learned and discussing the implementation of mitigation strategies. 

How is red teaming different from penetration testing?

Although both focus on ensuring organizations are protected against cybersecurity threats, the two services play different roles. 

Penetration testing focuses on identifying and exploiting specific vulnerabilities within a defined scope. It simulates attacks to evaluate the security of specific systems, networks, or applications. 

Red teaming, however, takes a more comprehensive approach. It simulates real-world cyberattacks to assess an organization’s overall security posture. These engagements use multiple TTPs to replicate the methods of advanced adversaries. 

What are the benefits of red teaming? 

Red teaming offers significant benefits for organizations serious about cybersecurity: 

  1. Proactively identify and resolve risk 
    Red teaming goes beyond basic assessments to uncover critical vulnerabilities and provide deeper insight into your organization’s unique systems, culture, and weaknesses. This proactive approach helps identify and resolve potential risks before they can be exploited, protecting your organization from costly breaches and disruptions. 
  1. Deeper security alignment with industry standards 
    Effective internal red team exercises aren’t just about fixing vulnerabilities. They also ensure your security strategies align with industry standards and regulatory requirements, particularly those set by frameworks like FedRAMP and ISO 27001. Achieving compliance with FedRAMP Rev 5 requirements is simplified through a proven, ironclad process that ensures success. 
  1. Enhanced incident response  
    Conducting regular red team exercises sharpens incident response capabilities. It creates realistic, high-pressure scenarios where teams can practice detecting and mitigating threats, building stronger, more agile response capabilities over time. 
  1. Comprehensive security evaluation 
    Unlike traditional vulnerability scans, red teaming evaluates your organization holistically. It goes beyond technical defenses to assess workflows and overall readiness to handle sophisticated threats. 

Red teaming is the future of proactive cyber defense

As cyber threats grow more sophisticated, so must an organization’s defenses. Red teaming helps security professionals and IT managers go beyond checkbox compliance to truly assess and improve their resilience to attacks. By simulating real-world scenarios, red teaming provides a 360-degree view of security posture. 

Want to take your cybersecurity to the next level? Our certified Red Teamers are equipped with the deep knowledge and credentials. With a track record of zero rejections and seamless acceptance, we ensure your red teaming exercise is compliant, efficient, and delivers without delays.  Contact us today to get started.  

ISO 27001 as a Strategic Foundation for EMEA Compliance

by: Patrick Sullivan 04 Jun,2025 4 mins

EMEAISO 27001

Across the EU and broader EMEA region, regulations such as the EU AI Act, DORA, and NIS2 are redefining what security, privacy, and operational resilience require. According to our 2025 Compliance Benchmark Report, 85% of UKI businesses anticipate changes to their compliance strategy as these regulations come into force. These frameworks do not only mandate control, they also require traceability, oversight, and measurable performance. Organizations that treat compliance as a checklist will find themselves reacting to audits, buyer concerns, and enforcement notices. Conversely, organizations that adopt a system-based approach have an opportunity to align security and privacy with business resilience, buyer trust, and growth. 

Instead of responding to each demand separately, organizations should use ISO/IEC 27001:2022 to build a structured system that addresses many needs at once. ISO 27001 establishes a management system that enables businesses to systematically govern, operate, and improve their information security programs. When extended with ISO/IEC 27701, the system also supports global privacy obligations. 

For an overview of ISO 27001 and how it structures security governance, see our dedicated primer, ISO 27001: Everything You Need to Know. 

As a brief summary, ISO 27001 is the international standard for building an Information Security Management System (ISMS). It defines a structured approach to: 

  • Identify and treat information security risks 
  • Define leadership roles and responsibilities 
  • Set measurable security objectives 
  • Document policies and operational controls 
  • Continuously monitor, evaluate, and improve 

ISO 27001 is not a checklist of technical tools, but a full management system focused on how security is governed and maintained across your organization. 

How ISO 27001 supports internal stakeholders 

Internal leadership needs confidence that security and privacy risks are being properly managed. An ISO 27001-aligned ISMS creates that confidence by: 

  • Assigning clear ownership for information security 
  • Aligning security objectives with business goals 
  • Ensuring risk assessments are conducted regularly 
  • Requiring internal audits and leadership reviews 
  • Driving continual improvement over time 

The ISMS creates a predictable and verifiable framework that leadership can rely on for reporting, decision-making, and accountability. 

How ISO 27001 addresses customer requirements 

Many customer contracts now require evidence of strong information security and privacy practices. An ISO 27001-certified ISMS helps meet these requirements by: 

  • Providing globally recognized certification to reference during contract negotiations 
  • Supplying standardized evidence such as a Statement of Applicability and audit results 
  • Documenting incident response, access control, and supplier management processes 
  • Reducing the time and complexity of customer security reviews 

When organizations add ISO 27701 to the ISMS, they also meet privacy-related contractual obligations such as data subject rights management, consent tracking, and lawful processing requirements. 

How ISO 27001 helps meet regulatory obligations 

New regulations are setting higher standards for security and resilience. ISO 27001, combined with ISO 27701, provides a strong operational foundation for compliance with: 

DORA (Digital Operational Resilience Act) 

For financial services and critical ICT providers in the EU, DORA requires organizations to manage ICT risks, test resilience, oversee third parties, and report incidents. ISO 27001 supports these activities by: 

  • Establishing governance for ICT risk 
  • Requiring ongoing risk assessments and treatment plans 
  • Building formalized incident response and monitoring processes 
  • Supporting third-party risk management through supplier controls 

NIS2 (Network and Information Security Directive) 

NIS2 expands cybersecurity obligations across essential and important sectors. ISO 27001 aligns with NIS2 by:

  • Documenting organizational risk management practices 
  • Formalizing business continuity and incident response 
  • Enforcing supply chain risk management measures 
  • Requiring evidence of security testing and audits 

DSA (Digital Services Act) 

While DSA is primarily focused on content moderation and systemic risk in digital platforms, ISO 27001 supports operational resilience and user data protection requirements. 

Adding ISO 27701 strengthens the organization’s ability to manage lawful data processing, user consent, and data subject rights under DSA privacy obligations. 

Why privacy management should be included 

Security is only part of the equation. Privacy laws like GDPR, CCPA, and others require organizations to prove that personal data is collected, processed, and protected properly. ISO 27701 extends ISO 27001 by adding: 

  • Lawful basis documentation for personal data processing
  • Procedures for managing consent and data subject rights 
  • Controls for data minimization and purpose limitation 
  • Oversight of third-party data processors  

By implementing ISO 27701 together with ISO 27001, organizations can build a single, integrated system that supports both security and privacy compliance. 

Building a sustainable system 

ISO 27001 is built around the drive for continual improvement. Organizations must regularly review risks, measure performance, conduct internal audits, and update controls. This approach ensures that the ISMS is not a static project. It adapts to new threats, new regulations, and new business priorities without needing to be rebuilt each time external expectations change. A sustainable ISMS gives organizations the operational flexibility needed to stay ahead of customer demands and regulatory shifts.  It offers unlimited capacity to innovate while limiting organizational risk. 

ISO 27001, supported by ISO 27701 for privacy and ISO/IEC 27036-1 for third-party oversight, provides a practical foundation for organizations operating in the EMEA region. It enables clients to address diverse regulatory obligations through a single, scalable system. It also allows them to extend risk management across the supply chain and demonstrate maturity in vendor oversight (TPRM). Organizations that invest in certification now are better positioned to meet buyer expectations, reduce compliance uncertainty, and move confidently into additional regulated markets. 

By building an ISMS, organizations create a single, scalable system that strengthens resilience, reduces compliance costs, and increases trust across stakeholders.  With one “operating system” you can consistently create desired outcomes for your organization while optimizing both risk and costs. 

Understanding ISO 42001: The World’s First AI Management System Standard

by: A-LIGN 02 Jun,2025 6 mins

ISO 42001

Artificial intelligence has revolutionized many industries, but its rapid growth has also brought ethical, privacy, and security concerns. To address these challenges, the International Organization for Standardization (ISO) and the International Electrotechnical Commission (IEC) devised a new standard, ISO/IEC 42001. This standard provides guidance to organizations that design, develop, and deploy AI systems on factors such as transparency, accountability, bias identification and mitigation, safety, and privacy. This article will explore:

  • Key elements of ISO 42001 
  • The benefits of implementing this standard 
  • Stories from organizations successfully instituting ISO 42001 
  • Next steps for businesses 

Structure of ISO 42001 

Like several other ISO/IEC standards, ISO 42001 has several annexes that provide much of the detailed guidance organizations need. Here’s a quick breakdown of these annexes: 

  • Annex A: Management guide for AI system development, including a list of controls 
  • Annex B: Implementation guidance for the AI controls listed in Annex A, including data management processes 
  • Annex C: AI-related organizational objectives and risk sources 
  • Annex D: Domain- and sector-specific standards 

Key themes of ISO 42001 

ISO 42001 covers issues throughout the AI system lifecycle, from the initial concept phase to the final deployment and operation of the system. It is designed to help organizations manage the risks associated with AI and ensure that their AI systems are developed and used responsibly. 

Some of the key requirements covered in the published standard include: 

  • Leadership: Top management should demonstrate leadership and commitment to the AI management system (AIMS) and establish policies and objectives that are consistent with the organization’s strategic direction. 
  • Planning: Identify and assess risks and opportunities associated with AI and develop a plan to address them. 
  • Support: Provide resources and support for the AIMS, including training, awareness, and communication. 
  • Operation: Establish processes and procedures for the development, deployment, and maintenance of AI systems. 
  • Performance evaluation: Monitor, measure, analyze, and evaluate the performance of AI systems and take corrective actions when necessary. 
  • Continual improvement: Continually improve the AIMS, and ensure that it remains relevant and effective. 

Related resources 

ISO 42001 Buyer’s Guide 
The Ultimate Guide to ISO 42001 [WEBINAR] 
Synthesia Earns ISO 42001 Certification with A-LIGN 
Why Early Adoption of ISO 42001 Matters 
ISO 42001 Checklist 

Key themes of ISO 42001  

ISO 42001 covers issues throughout the AI system lifecycle, from the initial concept phase to the final deployment and operation of the system. It is designed to help organizations manage the risks associated with AI and ensure that their AI systems are developed and used responsibly. These key themes may look familiar as you identify the intersection between ISO 27001 and ISO 42001. 

Some of the key requirements covered in the published standard include:  

Leadership: Top management should demonstrate leadership and commitment to the AI management system (AIMS) and establish policies and objectives that are consistent with the organization’s strategic direction.  

Planning: Identify and assess risks and opportunities associated with AI and develop a plan to address them.  

Support: Provide resources and support for the AIMS, including training, awareness, and communication.  

Operation: Establish processes and procedures for the development, deployment, and maintenance of AI systems.  

Performance evaluation: Monitor, measure, analyze, and evaluate the performance of AI systems and take corrective actions when necessary.  

Continual improvement: Continually improve the AIMS, and ensure that it remains relevant and effective.  

Learn more about these requirements and how to start your organization’s compliance journey in our ISO 42001 buyer’s guide. 

Is ISO 42001 mandatory? 

If your organization produces, develops, or uses AI, you may be wondering to what extent you should be scrambling to become certified in ISO 42001. In short, this framework is a voluntary standard and is not legally binding. However, given its significance and emerging recognition, it is highly likely to become the benchmark for AI management systems in the future. Organizations should anticipate possible regulatory developments and consider proactively adopting this framework.

Get the ultimate guide to ISO 42001 in our two-part webinar series. 

Organizational roles and responsibilities 

Effectively implementing ISO 42001 starts with identifying your organization’s role in your current AI ecosystem:

  • AI provider: An organization or entity that provides products or services that uses one or more AI systems. AI providers encompass AI platform providers and AI product or service providers. 
  • AI producer: An organization or entity that designs, develops, tests and deploys products or services that use one or more AI system. This includes AI developers that are concerned with the development of AI services and products. Examples of AI developers include model designers, implementers, computation verifiers, and model verifiers. 
  • AI user: An organization or entity that uses an AI product or service either directly or by its provision to AI users. 

Benefits of implementing ISO 42001 

Though few organizations relish the idea of more audits, there are good reasons to move forward with certification sooner rather than later. (Plus, if you practice strategic compliance and consolidate your audits, adding this standard to your compliance program may be easier than you think.) 

Learn more about the benefits of early adoption of ISO 42001 in our guide. 

Managing AI risks and opportunities  

ISO 42001 provides organizations with a systematic approach to identify, evaluate, and address the risks associated with AI. This can help organizations mitigate the risks of AI and protect themselves from potential harm. 

Competitive advantage 

Implementing this standard enables organizations to showcase their early adopter status, demonstrating their commitment to responsible AI use. This can enhance stakeholders’ trust and distinguish the organization from competitors. 

Streamlined process

By incorporating ISO 42001’s best practices, organizations can streamline their AI processes, identify and rectify vulnerabilities earlier, and reduce the potential financial and reputational costs associated with AI failures. 

Preparing for EU AI Act Compliance with ISO 42001 

The EU AI Act mandates an ongoing governance framework for AI risk management, transparency, and compliance. Unlike one-time risk assessments or ad hoc governance policies, ISO 42001 establishes a systematic, repeatable process for AI compliance, ensuring organizations:  

  • Proactively manage AI risks rather than responding to enforcement actions.  
  • Align AI governance with business operations using structured risk-management frameworks.  
  • Demonstrate compliance through audit-ready documentation and performance evaluation.  

This standard provides an adaptable compliance framework that evolves alongside regulatory requirements, making it an ideal foundation for AI governance.  Though it is not an approved harmonized standard for AI Act conformity, it does provide the foundation you’ll need to be successful when the final QMS conformity standard is released. 

Learn more: How to prepare for the EU AI Act with ISO 42001 

Case study: Synthesia  

London-based Synthesia is the leading AI video platform to enable the creation of studio-quality videos with AI avatars and voiceovers in over 140 languages. 

With an innovative product used by 65,000 clients worldwide, including 70% of Fortune 100 companies, Synthesia aimed to showcase their dedication to responsible AI use and high-quality security practices. To do this, Synthesia partnered with A-LIGN to achieve ISO/IEC 42001 certification and become trailblazers in AI compliance. 

The challenge 

As AI technology progresses, global regulations evolve to address emerging challenges. The EU AI Act set transparency, fairness, and accountability standards for AI systems, prompting Synthesia to proactively adapt and lead in compliance, standing apart from companies slower to react. 

“It was challenging to find the right audit partner, as no firms were yet accredited. We saw A-LIGN as a market leader ready to take on the challenge with us.” 
-Nicolás Barberis, Security Manager 

With robust governance and a strong ethical foundation, Synthesia prioritized data protection, responsible use, and abuse prevention to build customer trust. The EU AI Act became a catalyst for strengthening security measures and meeting the rising expectations for compliance. 

Why A-LIGN 

Synthesia identified A-LIGN as a market leader and trusted collaborator, partnering with them to overcome challenges and achieve certification as a team. 

Moreover, Synthesia recognized that certifications from established organizations like A-LIGN fostered greater trust in the accreditation process. This credibility influenced how Synthesia’s customers perceived certifications, emphasizing the clear advantage of working with reputable and experienced firm. 

Results 

After a successful assessment, Synthesia became the first AI video generation company to become ISO 42001 certified. 

Earning ISO 42001 certification validated Synthesia’s already stringent security practices, which included robust AI governance, supply chain accountability, and adherence to strict obligations. This milestone showcased to the world that Synthesia meets the highest standards for security and compliance. 

The achievement had a positive reputational impact, drawing media coverage and significant interest from customers, vendors, and other stakeholders who were eager to learn about their journey, motivations, and approach. Learn more about Synthesia’s work with A-LIGN. 

ISO 42001: Next steps for businesses 

To navigate the complex landscape of AI governance and compliance, compliance managers should consider the following steps: 

  • Purchase and understand the standard: Obtain a copy of ISO/IEC 42001 and familiarize yourself with its provisions. It is crucial to understand the requirements,  recommendations, and other applicable requirements (i.e. ISO/IEC 22989, ISO/IEC 23894) to effectively implement the standard. 
  • Start internal talks about certification: Initiating conversations about the certification audit process within your organization is essential. Understanding the steps involved and allocating necessary resources will ensure a smooth transition toward ISO 42001 compliance. 
  • Get a readiness assessment: Consider engaging a trusted compliance partner like A-LIGN to conduct a readiness assessment tailored to your organization’s specific needs. This assessment will help identify any potential findings when pursuing this certification. Download our ISO 42001 checklist to ensure your organization is ready to take the next step.

As the AI landscape continues to evolve, embracing ISO 42001 will position businesses as leaders in the field, fostering trust and ensuring the long-term success of AI initiatives. Stay ahead in the AI era by leveraging ISO 42001 and building a solid foundation for your AI management system. Contact us today to get started.

ISO 27001 Implementation: How to Get Started

by: A-LIGN 29 May,2025 5 mins

ISO 27001

New ways to target your information security management security are emerging each day, making an ISO/IEC 27001 certification all the more important. But where do you begin? Check out our guide to ISO 27001 implementation for your organization.

What is ISO 27001 and why does it matter?

ISO 27001 is a standard created by the International Organization for Standardization (ISO) and International Electrotechnical Commission (IEC) that focuses on establishing and developing a strong ISMS within organizations.

It is an internationally used security framework that focuses on data confidentiality, integrity, and availability. ISO 27001 prepares organizations to create a stronger, more holistic approach to data security. 

Step-by-step guide to ISO 27001 implementation

Now that you’ve learned why ISO 27001 is important, you can dive in.

ISO 27001 implementation is a long process, but the result will bring your organization customer trust and protection for your most sensitive data. Here’s how we recommend you get started:

Understand the standard

Go deeper. Understanding the ISO 27001 requirements is key to a successful ISO 27001 implementation. Read up on (or hire an expert to teach you about) the clauses and annexes in this standard and consider which controls apply to your ISMS. This understanding will help you gain buy-in across the business to the importance of this certification. Your organization’s compliance, executive, and IT teams should all be on board to execute changes to meet the standard and complete your ISO 27001 implementation.

Turn to the professionals

After you’ve learned about ISO 27001 and earned buy-in from relevant stakeholders, it’s time to work with the professionals: certification bodies, also called audit firms or audit partners.

Certification bodies come in two forms: accredited and unaccredited.

Accredited certification bodies have completed a rigorous certification process themselves to appropriately issue ISO 27001 certificates while unaccredited certification bodies have not.

This difference can determine which certification body your organization completes its audit with. It’s important to learn whether any of your clients require a certificate from an accredited certification body. Plus, it’s good to know what your audit partner is made up of: their processes, certifications, and more before choosing to work with them on your ISO 27001 implementation.

Beyond these certifications, there are a number of considerations to keep in mind when choosing an audit partner. From experience on the team to the number of certifications the auditor has issued for your chosen framework, there’s a lot to consider. Check out this ISO 27001 buyer’s guide to learn more about what to look for in an assessor.

Select your auditor

After evaluating all your options, it’s time to make a decision. Ensure you’ve picked an audit partner that holds your organization’s values and has experience auditing for companies in your field. Plus, choosing a quality partner is key.

After notifying your chosen partner, you can expect a series of steps to take place:

  • Signing the contract: During this step, you can expect to receive a contract that defines the scope of work you can expect from your auditor. This will detail the systems they plan to test and for what purposes along with legal elements like terms and conditions of the audit.
  • Project kickoff: Kicking off your audit and aligning on timeline is essential. This step ensures every party on either side is in the know about when you can expect certain parts of the audit cycle to take place. Plus, it gets your project moving.
  • Meeting your audit team: Like any successful organization, the most important part of your audit cycle is the people. These relationships are going to carry your organization through your audit and beyond as your auditor becomes a trusted member of your team.
  • Acquaint yourself with the tech: Whether you’ve implemented a GRC platform or your auditor uses in-house technology, it’s beneficial to familiarize yourself with the platforms you’ll be using during the audit cycle to streamline the process.

Begin your audit cycle

Now it’s time to begin your audit cycle for ISO 27001 certification. Your audit partner should walk you through the steps it takes to complete ISO 27001 certification. This is a multi-pronged process, but the general steps include:

  • Optional Pre-Assessment  
  • The Stage 1 Audit  
  • The Stage 2 Audit  
  • A Surveillance Audit  
  • Recertification 

Step 1: Pre-assessment    

The pre-assessment is designed for companies that are undergoing the certification process for the first time. This assessment is only performed on an as-needed basis but is highly recommended prior to the actual audit.   

The pre-assessment involves performing a review of an organization’s scope, policies, procedures, and processes to review any gaps in conformance that may need remediation before the actual certification process begins.   

Step 2: Stage 1 audit   

During a Stage 1 audit, an auditor reviews the high-risk clauses and annex controls of an organization’s ISMS to confirm that it has been established and implemented in conformance with the ISO 27001 standard. This audit also checks to see if the mandatory activities of an ISMS have either been completed prior to starting Stage 2.   

Upon completion, the Stage 1 audit will reveal if an organization is ready to move forward to Stage 2 or if there are any areas of concern regarding policies, procedures, and supporting documentation that may need to be remediated before proceeding.   

Step 3: Stage 2 audit   

The Stage 2 audit tests the conformance of an organization’s ISMS against the ISO 27001 standard. Upon completion of Stage 2, the auditor will determine if an organization is ready for certification.   

If any major nonconformities were identified during the audit, they will need to be remediated by the organization before a certificate can be issued.    

Stage 4: Surveillance audit   

The ISO 27001 certification process doesn’t simply end after a certificate has been issued. For the two years following certification, the auditor will conduct annual surveillance audits to ensure an organization’s ongoing compliance with the ISO 27001 standards. This step ensures your cybersecurity practices are operating at the highest possible level.   

Stage 5: Recertification   

An ISO 27001 certification is valid for three years after the certificate’s issue date. Organizations need to recertify before the certificate’s expiration date or be required to begin the certification process again. Recertification audits review the entire management system, similar to the Stage 2 audit.

This process may require that you make changes to your ISMS and your processes to earn full ISO 27001 certification. This process will not take place overnight, and you will need to keep in close contact with your audit partner to learn how your team handles client information going forward.

After ISO 27001 certification

After your ISO 27001 certification, it’s time for continual improvement. This model is a part of the ISO 27001 standard and ensures that as you add new products or services, these additions are accounted for in your ISMS and the controls you have in place to stay compliant with ISO 27001.

The other follow-up step for ISO 27001 implementation is recertification. An ISO 27001 certificate is valid for three years after the issue date and organizations must recertify before the expiration date or begin the certification process again. Recertification is similar to a Stage 2 audit and reviews the entire management system.

Ready to get started on your ISO 27001 implementation?

As an accredited ISO 27001 certification body, A-LIGN can provide your organization with the experience and guidance needed to achieve certification.  Contact us to get started today.

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