In brief
Craig Unger of Hyperproof argues that compliance should be a continuous state, not a once-a-year audit snapshot. Because regulations keep shifting, he says companies should standardize one set of controls, tie each control to the company's overall risk, and stop running risk, compliance and AI governance as separate silos.
The tension is between regulators who start, stop and delay rules, and companies that are too busy with audits to improve how they work. Unger's answer is to keep building, express risk in dollars so boards can act on it, and use a five-stage maturity model to decide the next step.
Facts
Stated by the speakers. Each quote matches the transcript, which shows what was said, not that it is true.
Craig Unger says the EU AI Act focuses on documenting AI use and monitoring AI so that it does not suggest harmful outcomes for real people.
“In the EU, you have the AI Act, which is concerning itself with how you document your usage of AI, how you monitor to make sure the AI isn't suggesting things that we wouldn't want to happen to real people.”
0:02:43 · Craig Unger · EU AI Act · 2026
Craig Unger says the first phase of the EU Cyber Resilience Act, which requires reporting of exploited vulnerabilities, became enforceable in September 2026.
“That particular mandate has actually come into being and is enforceable on September of this year.”
0:03:05 · Craig Unger · Cyber Resilience Act · 2026
Craig Unger says a further Cyber Resilience Act phase, covering secure by design, a software bill of materials and vulnerability handling, is due about a year after the recording.
“And then in about a year from now, there's a newer mandate around full application security, secure by design, a secure bill of materials, how you handle vulnerabilities”
0:03:30 · Craig Unger · Cyber Resilience Act · 2027
Craig Unger says Cyber Resilience Act penalties could reach 15 million or 2.5% of global revenue.
“And the penalties are pretty significant. It could be 15 million or as much as 2.5% of your global revenue, your global turnover.”
0:03:30 · Craig Unger · EU penalties · 2026
Craig Unger says the EU's NIS2 cybersecurity directive applies to organizations with fifty or more employees or more than 10 million in turnover, covering about 100,000 organizations.
“NIST two has to be enforced for organizations of fifty or more employees, or organizations that have more than 10 million in turnover, which is 100,000 different organizations.”
0:04:18 · Craig Unger · NIS2 Directive
Craig Unger describes the Cybersecurity Maturity Model Certification (CMMC) as security requirements for all suppliers to the US Department of Defense.
“the CMMC, which is really a set of requirements around how security is handled for all suppliers to the Department of Defense, right?”
0:04:41 · Craig Unger · CMMC
Craig Unger says FedRAMP 20x is a modernization of the FedRAMP program meant to cut the cost of preparing for and undergoing the audit.
“There's a whole new framework called FedRAMP twenty X, and that's a modernization of this, mostly so that you can cut down a bit the costs of actually doing the preparation and the audit”
0:05:04 · Craig Unger · FedRAMP 20x
Craig Unger says he coined the term 'regulatory rubbernecking' about two weeks before the recording.
“This is a term that I came up with like two weeks ago for for another discussion I was doing.”
0:05:27 · Craig Unger · Regulatory rubbernecking · 2026
Craig Unger says that both the EU AI Act and the US CMMC requirements have been slowed down while governments reconsider the right requirements.
“including the EU AI Act and including CMMC in the USA, that have been slowed down so that the government could go back and say”
0:05:58 · Craig Unger · Regulatory delays · 2026
Craig Unger says that Hyperproof's busy customers often report being too busy with audits to automate their compliance work.
“a lot of what we hear back is we're so busy doing audits, we don't have the time to automate, right?”
0:08:40 · Craig Unger · Audit automation
Craig Unger says Hyperproof's products include automations that pull in data from a customer's whole environment and test it.
“we have in our products, we have automations that you can use to bring in data from your whole environment, you can test it, all that stuff.”
0:08:20 · Craig Unger · Product automation
Craig Unger says that organizations want to stay compliant continuously, but are typically audited only once a year, which drives odd behavior.
“So we want to do that continuously, but we're audited once a year.”
0:10:38 · Craig Unger · Audit cadence
Craig Unger says a company's board very likely has an audit member assigned to oversee the organization.
“the board itself, which will very, very likely have an audit member that's actually assigned to the organization.”
0:13:22 · Craig Unger · Board oversight
Craig Unger defines controls as the processes a company runs to mitigate threats, which reduce the risk that materializes.
“the controls that you're using, which are really just the fancy name for the processes that you're running in your company, those are meant to actually attack the threats.”
0:16:24 · Craig Unger · Controls and risk
Craig Unger says some organizations justify compliance costs by the dollar amount of risk the activity reduces.
“some organizations tend to look at the compliance activity and the costs associated with running that compliance activity as justified by the risk that it reduces.”
0:18:29 · Craig Unger · Risk quantification
Craig Unger says regulators want to see that a human is involved at the right moment when AI is used in compliance workflows.
“this is an important part of what the regulatory agencies want to see. And I mentioned it earlier, they want to see that the human is in the loop, right at the right time.”
0:20:00 · Craig Unger · Human oversight
Craig Unger says the first stage of Hyperproof's five-stage maturity model is ad hoc compliance, with little written down and no central governance.
“The first is when you look at your organization and you say that compliance is ad hoc.”
0:22:41 · Craig Unger · Maturity model
Craig Unger describes the standardized stage of the maturity model as one set of controls mapped to multiple frameworks and requirements.
“I set up one set of controls. I map it to multiple requirements because that's my one set of controls.”
0:23:28 · Craig Unger · Standardized controls
Craig Unger says the 'integrated' fourth stage of the maturity model connects policies, controls and risks and breaks down silos.
“Policy talks to controls, controls are mapped to risks, you know, all of these things in the way that we talked about.”
0:24:20 · Craig Unger · Integrated stage
Craig Unger says the final 'optimized' stage uses AI and long-running agents to surface issues before outside parties raise them.
“AI is on the lookout. You have long running agents. They're actually showing you different things that really need to be addressed in the organization.”
0:24:49 · Craig Unger · Optimized stage
Craig Unger says he has both built compliance software and services and personally performed compliance work inside organizations.
“I've not only, you know, been involved in creating compliance software and services, but I've also done it for organizations.”
0:25:22 · Craig Unger · Unger background