Compensating Controls: Definition, Examples and Guidance

Overview

What Are SCF Compensating Controls?

Secure Controls Framework (SCF) compensating controls are suggested alternatives for when a primary control cannot be implemented as written. The free SCF workbook suggests two possible compensating controls, each with a written justification, for every control that is eligible to have one.

A compensating control is a physical, administrative or technical safeguard implemented in place of a deficient control, providing equivalent or comparable protection. It addresses the same underlying risk objective through a different mechanism and holds residual risk at an acceptable level until the primary control can be implemented.

A Starting Point, Not A Decision

The SCF publishes possible compensating controls. Whether one is adequate for an organization's environment, and whether an assessor or regulator will accept it, remains an organizational decision argued on the facts of that environment.

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Audience

Who Are SCF Compensating Controls For?

The suggestions give organizations and assessors a common reference rather than each inventing one.

Organizations

The people who build and run a control set use the suggestions as a starting point when a control cannot be implemented as written.

Assessors

Assessors weigh whether a compensating control covers the original risk and designate the control as an Alternative Control, which is separate from Not Applicable.

Structure

How Are They Organized In The Workbook?

Compensating controls are a set of columns on the main tab of the free SCF workbook, so there is nothing separate to download. Next to each control are its Relative Control Weighting, the risk if it is not implemented, and two suggested compensating controls. Each suggestion is an existing SCF control with its own framework mappings and a written justification.

Column heading	What it holds	How to use it
SCF #, SCF Control, Secure Controls Framework (SCF) Control Description	The primary control	Find the control that cannot be implemented as written
Legacy SCF #	The control's number before SCF 2026.3	Find a control cited by an older number
Relative Control Weighting	A score from 1 to 10. A 10 is a material control.	Check this first. A 10 means no compensating control.
Risk if Primary Control Not Implemented	For an eligible control: the exposure without it, including the risks and threats it maps to. For a material control: a statement that it is not eligible.	The risk the compensating control has to address
Possible Compensating Control #1, Compensating Control #1 Name, Compensating Control # 1 Description	The SCF # of the first suggested control, its name and its own control description	Evaluate it against the environment
Compensating Control #1 Justification	Why that control compensates for the primary one	The starting point for the organization's own justification
Possible Compensating Control #2, Compensating Control #2 Name, Compensating Control # 2 Description, Compensating Control #2 Justification	The same four fields for the second suggestion	Evaluate it the same way

Implementation

How Do Organizations Use Them?

Using a compensating control follows five phases.

Confirm The Need

A compensating control is for a primary control that is technically infeasible, operationally impractical, cost-prohibitive or temporarily unavailable during a phased implementation. A control that is only inconvenient or not yet scheduled does not qualify.

Step 1

Check Eligibility

The Relative Control Weighting column shows whether the control can have a compensating control at all. A control weighted 10 is material and has to be implemented.

Step 2

Evaluate The Options

The Risk if Primary Control Not Implemented column states the risk the alternative has to address. The organization weighs both suggestions against that risk and its environment, and may decide neither is sufficient.

Steps 3 and 4

Decide And Document

Leadership, rather than the control owner, evaluates each proposed compensating control. The record captures the alternatives considered, the one selected and its justification, how it addresses the risk, and when the primary control is expected to be implemented.

Step 5

Validate And Track

An assessor validates the compensating control as applicable, reasonable, and implemented and operating properly. The organization tracks it, for example in a Plan of Action and Milestones (POA&M), until the primary control is in place.

Step 6

The risk statement, both suggestions and their justifications for every eligible control are in the SCF workbook.

Common Misuse

What Compensating Controls Are Not

A compensating control is not:

✓

A shortcut: It is not a way around an unmet requirement. Treating the published options as a ready list of alternatives is a dangerous mindset.

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A control enhancement: A compensating control is an alternative implementation that achieves equivalent protection; an enhancement is an additional safeguard beyond the baseline. Blurring the two leads to claimed coverage that does not exist.

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Risk acceptance: Accepting the risk of an unimplemented control is a leadership decision, not an alternative control put in place.

✓

A Not Applicable decision: A control that cannot apply to anything in scope is Not Applicable (N/A), an assessment designation separate from Alternative Control.

Where a compensating control is and is not acceptable:

Acceptable	Not acceptable
Legacy systems that cannot support modern controls, such as antimalware or file integrity monitoring	Avoiding cost or effort without a justification that would withstand outside scrutiny
Regulatory conflicts, for example over cryptographic module requirements	Risk acceptance below the management level required, in a way that violates the organization's risk appetite
Technology limitations, such as embedded software that cannot be patched	An alternative control that does not actually provide equivalent or comparable risk mitigation

Eligibility

Material Controls Have No Substitute

A control with a Relative Control Weighting of 10 is a material control: its absence or failure could have a material impact, and it is "not capable of having compensating controls." The workbook marks each one not eligible, since its deficiency or absence would be a material weakness.

Defining materiality is an executive leadership determination, not a cybersecurity one. The SCF Council sets the threshold as a deficiency, or combination of deficiencies, in cybersecurity or data protection controls (across the supply chain) where it is probable that reasonable threats will not be prevented or detected in a timely manner that directly, or indirectly, affects assurance that the organization can adhere to its stated risk tolerance.

Material controls in SCF 2026.3 include:

GOV-04

Publishing Security, Compliance & Resilience Documentation

Mechanisms exist to establish, maintain and disseminate policies, standards and procedures necessary for secure, compliant and resilient capabilities.

GOV-14

State-Sponsored Espionage

Mechanisms exist to constrain the host government's ability to leverage the organization's Technology Assets, Applications and/or Services (TAAS) for economic or political espionage and/or cyberwarfare activities.

CFG-04

Secure Baseline Configurations

Mechanisms exist to develop, document and maintain secure baseline configurations for Technology Assets, Applications and/or Services (TAAS) that are consistent with industry-accepted hardening standards.

IAC-04

User Provisioning & De-Provisioning

Mechanisms exist to utilize a formal user registration and de-registration process that governs the assignment of access rights.

Material Controls

Where a control is marked not eligible, the correct response is to implement it, not to look for a substitute. Treating a material control as satisfied by a compensating control misrepresents the organization's risk position.

Example

Compensating Controls For Multi-Factor Authentication

IAC-37 Multi-Factor Authentication (MFA), numbered IAC-06 before SCF 2026.3, is weighted 9 and eligible. Without MFA, credentials may be phished, replayed, guessed or stolen, allowing unauthorized actors to authenticate as trusted identities.

NET-03

Boundary Protection

Network-level access restriction that limits attacker reach and lateral movement across the environment.

MON-16

Anomalous Behavior

Detective monitoring that identifies unauthorized, anomalous or non-compliant activity that MFA would have prevented.

Neither option restores what MFA does. Boundary Protection narrows where a stolen credential can be used, and Anomalous Behavior shortens the time before misuse is noticed. That gap is the trade-off the organization has to document and the assessor has to weigh.

Column	What it says for IAC-37
SCF #	IAC-37
Legacy SCF #	IAC-06
SCF Control	Multi-Factor Authentication (MFA)
Control description	Automated mechanisms exist to enforce Multi-Factor Authentication (MFA) for: (1) Remote network access; (2) Third-party Technology Assets, Applications and/or Services (TAAS); and/ or (3) Non-console access to critical TAAS that store, transmit and/or process sensitive and/or regulated data.
Relative Control Weighting	9 (not material, so compensating controls are allowed)
Risk if Primary Control Not Implemented	Without Multi-Factor Authentication (MFA), credentials may be phished, replayed, guessed or stolen, allowing unauthorized actors to authenticate as trusted identities. Based on the risk and threat mapping for this control, this deficiency most likely exposes the organization to Unauthorized Access (R-AC-4), Identity Compromise / Impersonation (R-AC-5), and most likely increases susceptibility to Malicious Cyber Activity (MT-2), Technical / Mechanical Failure (MT-10).
Possible Compensating Control #1	NET-03 Boundary Protection
Compensating Control # 1 Description	Mechanisms exist to monitor and control communications at the external network boundary and at key internal boundaries within the network.
Compensating Control #1 Justification	Boundary Protection (NET-03) provides network-level access restriction that compensates for the absence of Multi-Factor Authentication (MFA) (IAC-37) by limiting attacker reach and lateral movement opportunities across the environment. Given the technology-focused nature of this control, this compensating control targets the same underlying risk objective through an alternative approach, helping to maintain an acceptable level of residual risk until the primary control can be implemented.
Possible Compensating Control #2	MON-16 Anomalous Behavior
Compensating Control # 2 Description	Mechanisms exist to utilize User & Entity Behavior Analytics (UEBA) and/or User Activity Monitoring (UAM) solutions to detect and respond to anomalous behavior that could indicate account compromise or other malicious activities.
Compensating Control #2 Justification	Anomalous Behavior (MON-16) provides detective monitoring capability that compensates for the absence of Multi-Factor Authentication (MFA) (IAC-37) by identifying unauthorized, anomalous, or non-compliant activity that the primary control would have prevented. Given the technology-focused nature of this control, this compensating control targets the same underlying risk objective through an alternative approach, helping to maintain an acceptable level of residual risk until the primary control can be implemented.

Compensating Controls: What They Are and How to Use Them