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Amjad Masad of Replit: 10x’ing in a Year and Building the Future of Code | Frameworks for Growth
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In this episode
Vanta CEO Christina Cacioppo talks with Amjad Masad, Founder and CEO of Replit, about how persistent ideas evolve into breakout products and how founders can stay scrappy while scaling.
Amjad breaks down how Replit handled early competition, carved out space as one of the first AI-native dev platforms, and sustained momentum in a crowded, fast-moving market.
🔑 Topics covered (timestamps):
00:20 - Introduction
00:41 - Software development trends Amjad is excited about
02:28 - What is Replit
03:21 - How long Amjad has been working on Replit
04:53 - How did Amjad start learning Javascript
06:34 - Why the web felt like the future
08:47 - Why AI feels like the future
12:15 - When models will solve coding
14:24 - How Amjad practices what he does
16:05 - Have the things that cause pain changed
17:22 - How Replit compounded
19:22 - Why Amjad learned SEO
20:12 - The day Replit went viral
24:18 - Navigating skepticism
29:18 - Hiring high agency individuals
35:25 - Replit's innovations being coped by giants
42:36 - Why Amjad wrote an AI manifesto
49:36 - Replit's approach to marketing
52:44 - Amjad's advice for X/Twitter
55:03 - Amjad's thoughts on building community
56:34 - Why powerlifting is similar to building a startup
57:25 - Reading philosophy and influences on AI
1:00:07 - What Amjad would be doing if not working on technology
1:01:43 - Why Amjad chose Foster City
1:03:34 - How Amjad would spend a day with a founder in Foster City
1:04:51 - Unconventional advice for founders
1:08:00 - What Amjad is reading
1:09:34 - The first program Amjad ever wrote
1:09:54 - Amjad's thoughts on layoffs
1:11:26 - Choosing between making Replit bespoke or general
Read the full transcript
Christina:
Welcome to Frameworks for Growth. I'm Christina Cacioppo, CEO and co-founder of Vanta, and I'm here today with Amjad Masad, CEO and co-founder of Replit. So prior to Replit, you built big parts of the JavaScript infrastructure at Facebook. We were batchmates in YC in Winter 18 and have known each other long before then. Thanks so much for joining me today.
Amjad:
Thanks for having me.
Christina:
Amjad, you have been thinking about software development and how to make it easier for almost two decades now.
Amjad:
Yes.
Christina:
What trends are you really excited about now that most of us don't know about yet?
Amjad:
Don’t about yet. I don’t know if people don't know about yet, but I don't think people understand how fast it's coming, how fast software agents are going to get better and better. Right now we have this version two of agents in beta. We're looking at the metrics. It's something like five times better and by the way, version one was released in September.
Christina:
Oh like six months.
Amjad:
Shorter. Yeah, so I think just this year large parts of software engineering is going to be automated. The use cases that we're focused on will especially have tremendous gains because when you're trying to add a software development agent to a big company repository, it's hard for it to make an impact. But with Replit, people are making applications from scratch, so I think agents in general are going to start to work this year. We have reasoning models. It's going to be a really exciting year.
Christina:
Neat. Are you all using agents to build Replit?
Amjad:
Yeah, a little bit. Definitely, we're using Replit agents internally. One of my favorite use cases here is that one of our HR team members, her name is Kelsey, she was looking to replace an org chart software we're using. They all kind of sucked in their own ways.
Christina:
Yes.
Amjad:
So she decided to build her own and three days later she had her own, she had all the features she liked and so not only we are building our software and software engineering team, but agents and Replit agents is making everyone more productive.
Christina:
And what is Replit for folks watching?
Amjad:
Good question. So maybe a year ago my answer would be different, but right now it's totally transformed. Basically it's a way to build software entirely using natural language, so you can just talk to your phone or computer and it will write the code for you. It will set up all the packages and libraries. It will provision cloud databases and storage and all of that and then you can iterate with it. You can change the design, you can add features, you would talk to it as if you're talking to a human engineer and then when you're ready you can deploy it and all of that happens on this one app. We spent the last seven, eight years building all these components and we're the only product on the market that has all these components.
Christina:
You mentioned building for the last seven, eight years, but if I have this right, you've been working on Replit for longer. How long have you been working on Replit or something Replit-shaped?
Amjad:
I think the first Replit-shaped idea was probably 2008, 2009. I was obsessed with programming. I wanted to try all these different programming languages. I wanted to code my phone. I had this Nokia Symbian phone those really big phones. I was obsessed with it. I was like, oh, I really want to code on, it now we have a coding mobile app. The thing that was really annoying about doing homework or learning a new programming language is all the setup you have to do, all the IT chores you have to do. You have to download an IDE, which sometimes gigabytes big and you have to figure out the packages and god forbid you want to share the program, it almost never works on someone else's machine. So at the time everything was going to the cloud. I remember using Gmail at the time and Google Docs and Chrome had just come out and Chrome was really, really powerful. So it was like, oh, why can't we code on the browser? And I thought that'll probably be a weekend project. Little I know here 20 years later I'm working on it, but I did get something out in a weekend and it was like a small sort of sandboxes. You could type a lot of JavaScript and run it and it was already pretty cool.
Christina:
You probably are one of the people most advanced in the world at about JavaScript. How did you start learning JavaScript and not just alert box JavaScript but Chrome, what you can do in new Chrome or 2008 Chrome?
Amjad:
After I finished college back in Jordan, I went to work for Yahoo. Yahoo had just acquired a company, an email company called Maktoob and it was the first big acquisition in Jordan, maybe even in the Arab region. So I went to work there and Yahoo's very well known sort of web, JavaScript shop, so I got really attracted to the language because it had this sort of scripting angle. It was also functional, it was reading a lot of Paul Graham, his essays about program languages and Lisp and all of that. So it was a very interesting language but I also felt like I can have a lot of impact with it. I also felt like it's like a bet on the future and I think this is something I really try to do and I think I have an eye is where the future of technology is headed and I felt like JavaScript is on this trajectory where you had Chrome optimizing it using V8 and you had these web applications like Gmail and Docs and all of that, and so I started really investing in it. And a lot of it is practice. The reason I built Replit is to practice programming. I think you need to just put in the hours and if it is fun for you, you're just going to be obsessed and going to keep doing it.
Christina:
I have so many questions. What was it about the web where you felt like this'll be the future? Because now it sounds so obvious, but Gmail is kind of weird. People wouldn't totally use it. Google Docs had very low adoption—wasn't foregone conclusions.
Amjad:
I started programming in BASIC and then in Visual Basic, and I built my first sort of business when I was a teenager selling VB6 applications.
Christina:
And who'd you sell those to?
Amjad:
Yeah, so I was obsessed with playing Counterstrike and so I would go to these internet LAN cafes and play Counterstrike in LAN with my friends and I was just surprised by how much manual work was going into managing these stores. They'd have a lot of employees and when you go in you'd pay for an hour, they'll write your name down and they have to watch the clock and go tap you on your shoulder. So what I did is I wrote this client server management software and it had security features so that people can only boot up the games or enter browser and was able to sell it to a bunch of stores in Jordan. Throughout all of that, I just learned how painful it is to make and distribute software, and it's also the story behind Replit. It's like for, I actually spent two years when I was 12, 13, started working on it. I only got it to market when I was 15.
Christina:
Replit you mean?
Amjad:
No, no, no, no, BASIC when I was 15, the Visual Basic kind of application. And throughout that I just learned how just painful it is to distribute software. So when I saw the web, the thing I saw, kind of, web applications working, I was like, oh, this is how you distribute applications. You don't have to go buy CDs, you don't have to move software in this way. You just go to a website and that's your application. You can progressively load it and do all these things and also you see all the attention going into it, all these companies kind of optimizing for it and felt like it was the future.
Christina:
And then what is it about AI now or that some of that, because it seems like some of that same, oh this is the future is going off for you?
Amjad:
Yeah, so actually it goes back to my time at Code Academy. So Code Academy is like you can go to it and type in a bit of programming, it'll tell you whether you're doing good or not, you go to the next exercise. And so it's learn by doing programming, and I was trying to give users feedback about their code and I was doing all this sort of manual regex to just check for completeness, and I just felt like I was building all these tools for code and I just felt like, well, a lot of this work is really manual and deep learning was getting good at natural language processing and I felt, well, can't you apply neural networks on code? And I looked at it at the time and there was some initial progress there, but it wasn't there yet. Then at Facebook I was also working on compilers and things like that and I had that urge to kind of go try to figure it out. I played around with certain technologies, it wasn't there yet. I started Replit the company in 2018, 2019—GPT-2 comes out and I felt like, okay, now is the time, I think you can apply natural language processing on code. We have a lot of code data at Replit. We can perhaps fine tune GPT-2 or train the model, but it was a little too early because the tools were not there. It was really painful to do anything with neural networks and especially transformer models. So it wasn't really until GPT-3 that it was obvious that these models are going to be great at code. Now the next thing you had to sort of imagine because you can really do it very well, is agents. One of the first things I did with GPT-3 was have it produce Python code and then having a Python interpreter run the code and I think I was one of the first people to do that and then Langchain came out and they based the code on my experiments and basically the idea was like, okay, if these language models can call tools and external services, you can see the beginning of what we call an agent today. Of course tool calling is not exactly the only thing you need. It's not sufficient, but if the model can do unbounded set of actions, then I think this is what I define as an agent. Being able to do call tools but do an unbounded set of actions until it naturally find halts, comes to a conclusion. And I would say probably that only became true in last year.
Christina:
Okay. I was going to ask, with a specific model with 4o?
Amjad:
Yeah, Sonnet 3.5, I think was the first time you could see a glimpse of agentic behavior. Then they came out with the next version which had computer use, and you could tell they're starting to optimize for long-horizon reasoning and now 3.7 is very, very impressive and I think other companies are following suit.
Christina:
So if you had to guess when will we solve coding with models? When do you think that'll be?
Amjad:
Like I said, I think for the tasks that people use Replit for, so like MicroSaaS, like, I'm entrepreneur spinning up my startup, I'm building internal tools, I'm building microservices and building AI agents, so not super large code bases, not like 10 gigabytes. I think towards the end of the year it'll feel perhaps like a mid-level engineer. It'll feel like you have a software engineer in your pocket, you'll open Replit on your phone and you'll be able to build an application. I mean we already see this. I was in Qatar the other day. I was in a conference and I was walking around and someone stopped me and I was like, Hey, I work at Qatar Airways and I'm not from the region, I don't speak Arabic. So I was at a meeting where everyone's speaking Arabic, so what I did is I pulled out my phone and I asked it to make a translation app using OpenAI Whisper and whatever. And before they ended the meeting, he had the app. He couldn't use it in that exact meeting, but he was able to use it in subsequent meetings. And so the idea of on-demand software is already here is just going to get a lot more reliable towards the end of the year. Now the question of, when do we get to a point where you can wholesale automate big aspects or large aspects of the software engineering team? I think probably product engineering, frontend engineering, some full stack engineering towards the end of this year as well, we're going to see significant impact on that where teams can be a lot smaller, a lot leaner, where you have AI agents running continuously on your code base and I think maybe by 2027 a single entrepreneur could be spending tens of thousands of dollars on virtual employees.
Christina:
Yeah, very neat. I want to go back to something you said when you were talking about making some of your first, or making the Visual Basic apps and scripts and practicing what you did. How do you practice what you do now?
Amjad:
That's a great question. By writing email, and I just wrote on the keyboard.
Christina:
But how do you practice writing the important work emails, even?
Amjad:
An interesting one is public speaking is what I'm doing here is being able to communicate, sort of, complex ideas. And I think you can do that by progressively putting yourself in more and more difficult situations where you're having to improvise. For example, you can commit to a talk but go there unprepared. Maybe that's the final boss, but you can maybe do it with an interview, with a fireside chat, or something like that first and then just progressively make it so that you actually can think on your feet and come up with ideas in real time. So public speaking is one where it's obvious. We have a value at Replit, it's seek pain.
Christina:
Such a founder's value.
Amjad:
It scares a lot of people from joining the company, which I think is a good thing. And the idea behind it is through pain and uncomfort, growth happens. So I think my version of practicing what I do is leaning into the hard and painful parts of it. If I feel like I'm flinching for something, try to override that and do it even harder and put myself in even more uncomfortable situations.
Christina:
Yep. Has it changed what you find yourself flinching from or taking pain from? Has that changed?
Amjad:
Yes. Like, making large changes to the company. I mean obviously the most painful of them is a layoff, but also just, reorgs, change in priorities. They're all painful, especially you can tell people are disappointed and I've gotten better and better at that and it's not like I don't feel people's emotions, I feel them as strongly, but I'm able to frame it in a way in my mind, that I'm doing the best for the company. Sometimes I'm wrong, but I'm often right and we'll end up net better not just for me, for the employees, for the shareholders, and for everyone.
Christina:
That kind of scale in your mind of immediate pain over here or immediate discomfort or displeasure and then longer term it will be or medium term even, it'll be better and the scale goes that way.
Amjad:
Exactly. I mean it's counterintuitive, but seeking pain is actually net reducing pain, right?
Christina:
Yes. Because it doesn't stay there.
Amjad:
Yeah, well delaying pain compounds it.
Christina:
Yes, it's so true. So speaking of things that compound, we met a long time ago, and there were times when—Replit has been around for how long? Replit the website.
Amjad:
2011.
Christina:
2011. And then there were times when maybe, more or less effort into prior to forming company, but it never, always kind of compounded. Why is that? Most people, when they put something on the internet and then don't pay attention to it, everyone else stops paying attention to it too. That's not the Replit story.
Amjad:
I did quite a bit of work initially on SEO, and I did quite a bit of work on promoting it initially. And those things at least used to compound. Right now the web is totally different. I bought this SEO book, which wasn't that helpful actually, like an actual book. I was really interested and I was like, okay, I've been mostly programming and I haven't done any marketing, but I just learned about getting backlinks from authoritative sites and doing all of that. So I started spamming the web. I got Replit’s link in Wikipedia somewhere.
Christina:
That's probably a really good one actually. High domain authority.
Amjad:
Yeah. And then as it got started, it basically just compounds and people started using it. I'll post the first few links on Stack Overflow, then people started using it there.
Christina:
Like, here's your fix, but go see this Replit.
Amjad:
Yeah. I spent three months answering questions using Replit, and then people started doing it. I'm like, okay, that's done. Let's go to the other one. So you want to bootstrap growth and then that's how exponentials happen, right, you bootstrap the thing and it grows slowly, and then more and more people do it, they tell their friends about it, the links get better over time and so on.
Christina:
How did you know that was something you should be doing? Somewhat, I mean Wikipedia specifically, but just backlinks, SEO, how did you know you should learn about all of that?
Amjad:
I was just attracted to the idea of more people using my stuff. There are two reasons I like that. One is I actually just like the challenge, the infrastructure challenge of scaling things. I want more people to use my stuff because I wanted to break and I wanted to fix it. I wanted to learn how to build distributed systems. And so there's sort of a nerdy reason to grow. But I've always loved this feeling—the first time we went viral.
Christina:
Well, tell me about that. You seem like you remember it.
Amjad:
Oh yeah. It was one of the best days in my life. 2008 all the way to 2011, I'm iterating on this idea. And finally it worked. We had a technical breakthrough and we were the first to run Python on a browser.
Christina:
And how'd you do that?
Amjad:
I had the intuition that what I needed to do to run other program languages is to compile them to JavaScript. I was getting really good at JavaScript and getting really good at compilers, and initially I started writing these languages, these interpreters myself. I'm like, I'm going to write Python and JavaScript, and that was a really bad idea that would've taken me another 10 years to do it. But I found this project that was being incubated by Mozilla Research and what they were trying to do is to take a native program, program written in C, and then compile it using LLVM, Apple's kind of compiler toolchain to something called IR, intermediate representation. So not to machine code. So it's just this intermediate representation and someone in Mozilla figured out that, oh, we can turn that intermediate representation into JavaScript fairly easily. That was the idea—by the way, that idea became Wasm and we have it all over the web, and that guy worked on it. So I found it, it was very, very early and it could barely run something like Python. And the main missing things were creating a virtualized environment on the client side. So this is where we contributed to the project. This is where we spend a lot of our time. It's like how do you make it so that JavaScript or the compiled program thinks there's a file system, thinks it's running on Unix. And so we started writing all these APIs. For example, when it tries to reach for a file, we actually go to the server and then fetch that file and bring it all the way back. So instead of going to disk, it's going to the web. So we got to a point where we're running Python. That was a magical thing.
Christina:
I think I remember that, when that happened. When yall did that.
Amjad:
You were trying to build on it, I think, on the open source project, right?
Christina:
Yes, there was this—it was a coffee pun, but it was JavaScript to Java.
Amjad:
Yes, yes. So I tried to launch a few times actually, although we had the second breakthrough, it wasn't really picking up as much as I'd like. I was so surprised. I was like, we had this big thing and almost no one seems to care. So I kept trying to launch, I kept doing it on Twitter, on IRC was still a thing, on Reddit, Hacker News multiple times. Finally, there was one that hit, and I remember the title. It was like, try Python, try Ruby, try Lua all in the browser. And then that got upvoted. It was in Hacker News for like 48 hours and then it started getting picked up on Twitter. Google Plus was still a thing—I'm really dating myself here. And then my friends and I, some of them worked with me on Replit, we were in the desert actually in Petra. We were like, we had been working on this thing for a long time and we kind of wanted to go on a trip and again, we were on these Nokia phones. I mean none of us had iPhones. The Hacker News thread happened and then travel the next day or something like that. And I couldn't enjoy the trip because I kept going to this old Symbian, I dunno what the web used to be called, the web browser used to be called on this and searched Twitter for Replit, just see everyone tweeting about it. And my favorite one was Brenda Ike, the inventor of JavaScript tweeting about Replit. And that was the highlight.
Christina:
Peak moment. It was great. Also, along that early Replit journey and maybe the middle Replit journey, there were people who, or there was also just a lot of skepticism. How did you think about that when you had smart people being like, oh, you can't do this in a web browser. If you do this, no one will want it. It'll always be slower, nevermind running it on a phone.
Amjad:
Yeah, I mean they also had very reasonable arguments. I remember some of my friends and Jordan and colleagues were like, no one's going to download 10 megabytes of JavaScript to run your thing. Which literally it was 10 megabytes to download the Python interpreter, which was a lot at the time, especially on phones and what have you. I think I just naturally, I’m either wired or through upbringing that it actually just makes me want to prove them wrong if someone tries to knock down an idea that I have. And that's often a good trait. Sometimes it's a bad trait because sometimes they're really right and it's a freaking wall and I can't really get through it. So yeah, I think it just comes naturally to me.
Christina:
How can you tell or how soon can you tell if you're up against a, I dunno, wood wall versus a cement wall?
Amjad:
Over time? I mean this is a question of how do you know ground truth. And it's very hard with things like product market fit, what is the market for this? Because there's all these ways in which you can make assumptions about the market or calculate something or convince yourself of something that's strong. And then I think it's sort of this buzzword first principle thinking or a prior thinking and the idea is what are the basic assumptions about people and markets, whatever that would allow me to arrive at whether this is possible or not, or this is something people want or not. For Replit, the need was obvious. It was solving a real use case, but whether people would pay for it was really hard and painful for a long time. And I think I was sort of steadfast in my belief that I could find a business model or I could find a way for people to pay for it. And at some point, I think over the past couple of years I just realized that when you have alternatives that are free and easy, and when your thing has this mass appeal and it's not made for a specific type of professional and it's replaceable, even if it's not easily replaceable, people will go through the pain. If you're going to charge them, they'll go through the pain to replace it. So most people in the world are time rich and sort of money poor, as it were. So they will always trade off, they'll always put in more time and Replit was saving time. And I just realized that we needed to go up market, go to a place where people actually were time-poor and saving them time is a thing that they would want to pay for. And so Replit Agent is the ultimate expression of that because it actually saves you insane amount of time, orders of magnitude of time, and it could be time that you're spending or time a developer that you outsource to is spending and that could be tens of thousands of hundreds of thousands. And we hear that from our customers all the time. Literally two, three orders of magnitude. And so now it's very easy to capture value. We 10x’ed our growth over the past six months.
Christina:
Congrats.
Amjad:
Thank you. I just try to be rigorous in how I, even before looking at data or anything like that, just try to be rigorous in my thinking.
Christina:
Of what you might want to see in the data or what if it goes this way, you'll think this.
Amjad:
And even I would try to form an opinion before I would actually go and try to research and based again on first principle ideas or what I view, what I know about human nature.
Christina:
That’s neat. You've also talked a lot about hiring high agency individuals. What's that mean?
Amjad:
I think in life, the way we're shaped is to continuously shed autonomy in a way where as a child you're probably the least controlled by nature. You're very open, you're learning things, you're playing and you're breaking all the rules and all of that, but over time you're molded into something that is more acceptable to society. You don't want to get in trouble and then you have all this work and school and all of this work and university and you sort of molded in a way of working that is very, it's the same. Everyone sort of works the same because school applies a certain pressure. I think the high agency people tend to be misfits because otherwise you're going to get this sort of the usual corporate drone. The reason is no fault of their own, but they're not actually—they come up in a system where it sort of punishes original thinking and it rewards conformity. The misfits are those who cannot conform and they tend to be weird because of that. It's not that they don't want conform. A lot of them experience a lot of pain in life, and I experienced that myself. I got expelled 20 times from my school and there was all these, I couldn't sit in class and I kept failing because, my grades were always great, but I kept failing because I just simply couldn't sit in class and we had attendance, you had to do the attendance. And so eventually I sort of hacked into the university to try to change my grades.
Christina:
Did that work?
Amjad:
It worked until I got caught.
Christina:
Are we talking like an hour or are we talking like a semester?
Amjad:
No, a few months I went and bought the gown and was going into all these parties and was just ready to graduate and then I got caught, but I felt like I was owed that, to graduate. I always got A's, but I just didn't want to sit in class. Call it ADHD or whatever, I just physically couldn’t. And so I think a lot of people who tend to be high agency have something where it is harder for them to conform. It's not a hundred percent, but I think that's for the most part. So one thing is you should be open to that. You should be open to people who are awkward. You should be open to people who are dropouts. Obviously now Silicon Valley is actually kind of prefers the dropout, but I think just the openness to being able to interview these people is a big step in that direction. And then having a culture that actually could bring in these people and have them be productive.
Christina:
And so do you find actually the you of today, if you couldn't sit through school, can you sit through meetings?
Amjad:
If I'm interested and if I am running the meeting and I am trying to get something out of it, I'll run it with intensity, but the moment it starts going into circles, whatever, I'll immediately tune out. But I also think that that's bad and you should just leave, right? You should end the meeting.
Christina:
We’ll regroup or when we figure out what we want to get out of this.
Amjad:
Yeah, I'm increasingly doing that. I don't feel like these are productive. When I tune out, I think it's a signal that perhaps we shouldn't be in the meeting.
Christina:
Something is off. What is it about the high agency people or the misfitting? It makes it easy to identify these folks, but why are they effective later because of this?
Amjad:
I think a lot of it is questioning conventions and I think working at a startup. One, if you're trying to build something sort of new and bringing something new to the world, that is actually different than what most people used to do. For example, like everyone codes on their desktop computer, no one wants to code on the cloud or you want to change that. So if they're not wired differently in the first place, the conformist thing to do is actually not to join this company. But that also extends to their day-to-day work where they're more inventive. I think that they're able to look at problems and able to solve it in a way that is novel, whereas maybe the regular engineer would take a lot more time or write a lot more code for it, and perhaps the person who's wired differently would actually be able to look at it at a different angle that is not obvious, and invent something. And we have a culture of invention, we've been able to open source a lot of things that we've done, and we've been able to stay lean for a long time because we have these high agency people.
Christina:
So speaking of doing things new, a lot of things Replit has done over the years, whether it's technical innovations or UI patterns or business models, are new and so good they end up getting copied by giants. How do you feel about that?
Amjad:
I feel really bad, actually I used to feel really bad. I think I take it for granted now that it'll happen. It’s still annoying. It's especially annoying when people do not know that we innovated that. A lot of Microsoft products are designed by Replit.
Christina:
Right. How do you feel being the chief designer of the Copilot suite?
Amjad:
Almost a chief marketer. We updated our mission at some point from making programming more accessible to try to make it more ambitious, to creating the next billion developers. And GitHub is now saying that, so I'm both a chief marketer, chief designer at Microsoft.
Christina:
I’m sure the pay for those jobs is quite good.
Amjad:
I haven't gotten ####, so maybe I should ask for that. But over time you resign you yourself to it. But I think it's good to really understand it because you start to know what is moat and what is something that is easily copyable, what is the lead time before people copy things. You sort of have naturally more urgency because you know that it's going to happen. If it's a good idea, people will copy it. We were the first, kind of, at scale software agent back in September and quickly got copied multiple times.
Christina:
Do you have a model now for what is less easy to copy or what lends itself to more of a durable moat?
Amjad:
UI innovations, you can think of them as public goods.
Christina:
If they're good. They will go off into the universe.
Amjad:
Immediately. Immediately within a week we see competitors copying UI innovations that we do, which is sad because we have a really great design team and we really spend a lot of time and energy stressing every pixel. And then those get copied. Things that are trial through fire or things that have a lot of pain associated with them, especially on the infrastructure side, those tend to be harder to copy. What I said earlier about I love reaching scale because I like designing robust systems. And a lot of times that's what it takes, is that we build a system and we drive as much traffic and growth to it to see it break and fix it and become anti-fragile over time. And I think those tend to have, maybe not a lasting advantage, those tend to have a longer lead time before people catch up to it. It might be in the years. I think Replit infrastructure has many years of, because we've dealt with all the abuse, we've dealt with all the security, we've dealt with everything that has to do with running virtual machines in the cloud and giving it to users. It's a really tough problem and anyone who wants to compete with us has to go through all of that. And then lasting advantages are actually really hard. You know this, anyone who's running a business and then starts to get all this competition, you start to think really, really hard about what lasting advantages are. Obviously the buzzword in Silicon Valley is network effects, everyone wants to build network effects. It is actually quite hard to find a way to build network effects. But I think over time as you're running the company, you start finding opportunities to not only differentiate but also differentiate in a lasting way. And there are not that many ways and you can sort of study them. There's this book Seven Powers, and it just tells you, oh, there's seven ways to build moats. And I think it's very, very true.
Christina:
Any advice for a founder starting out early on this topic? It sounds like you've gotten to a more than before state, but for someone who's early on and it's not yet at that pinnacle of enlightenment.
Amjad:
I mean I sort of tend to be sort of a little fatalistic about how these things go. If I were to go and try to give myself advice when I was 20, my 20-year-old self will not listen, tell me to F off or something like that. And so for me personally, you and I have sort of an experience in that where I was like, okay, maybe I can fund Replit through selling to educators. And you were like, no, it's not a good business. I'm like, I'm going to try it anyways.
Christina:
But it seems like it should be. It seems like it should work.
Amjad:
Well sometimes now it's starting to work with AI. I don't know if people know, but you're the first investor, the first angel investor definitely, in Replit.
Christina:
Coffee shop down here in 2016.
Amjad:
2016. So thank you for that. I think for a lot of people it's hard to learn from experience. However, I think you can teach mental models, frameworks, things like that. It's just this simple thing of what we talked about with seek pain. I think it would've helped me a lot because there are many times a lot of bad decisions that I've done with a company tend to be, I know that this is the path, but it's painful. It requires a pivot. It requires letting someone go. It requires and I try to delay it or try to work around it and almost always, I should have done it like a year or two ago. So if I were to have given myself advice as to kind of lean more into the difficult, and by the way, speaking of sort of moats, and I think if you continuously do the difficult thing, I think you're going to perhaps create something that's quite differentiated because it's the path less traveled.
Christina:
I do actually. I believe that and that, I don’t know about you, but trying to shrink the time where I felt like I delayed making a bad decision. I wish I could tell you. I was like, oh, it's 24 hours all the time. I've got a great SLA. Not true, but at least we talk about it in days or weeks and not months or years. And it's just that it goes down over time.
Amjad:
Yes. Yes, exactly.
Christina:
Well, you all wrote an AI manifesto, why'd you do that?
Amjad:
Well, you want it to put a stake in the ground of Replit’s approach to AI. I think we were trying to hire AI engineers and researchers. We have a great team right now and we have to compete with 5 to 10 times the salary that we could pay. And so we wanted to just tell the world and talk about it internally is that this is what we're doing, this is how it's going to be differentiated.
Christina:
And where did that manifest come from? You, I imagine.
Amjad:
Yeah, me and Head of AI, now President, Michele Catasta. We just spend a lot of time actually, we did this big deal with Google that had an AI partnership and Google Cloud partnership. He was the counterpart, the AI researcher at Google. So we spent a lot of time talking about how AI changes programming, over many dinners and many nights. And so when he joined Replit to run AI, we had already explored what was possible together and we were starting from the same starting points and so much so we had this vision and we wanted to put a stake in the ground. We're also not worried about sharing it. A lot of founders tend to be worried.
Christina:
Yeah, like this is not your moat.
Amjad:
Yeah, exactly. I gave a TED talk in October ‘23 about this is what software agents will look like and this is how Replit will build them. I'm continuously surprise how much we got right. Even the UI back then, we're still kind of implementing, even before test time compute or reasoning models came out. One detail from that talk, I was like, well, when you have a software agent and it's struggling, you can pour more compute into it and it’ll do a better job. And so there's all these predictions that turned out to be right. And I think it's what we talked about with my prediction about where the web's going. It's actually doing the work. Not many people do the work of sitting down and thinking about, okay, where is this headed.
Christina:
And what is your take on where it's all headed?
Amjad:
In AI, there's the idea of the singularity where, it comes from physics, where the point for which you can't predict afterwards. We're not really at the singularity. I don't really believe that. However, I think AI agents are going to take off so much, and they're going to change the economy fundamentally. They're going to change how companies work. One prediction about how companies work is that I think companies, the nature of the firm will change. Companies will be hiring generalists. Because anyone can be a software engineer. You have an AI agent that's quite competent.
Christina:
You can vibe code your way to your translation app.
Amjad:
Right. And you can actually vibe code it your way into becoming a good finance. So you can think about it as in video games, there's this character or hero that can adopt any other hero's superpower. And I think this is what companies will be made from, where high agency, generalist people, that are augmented by AI agents that are able to do a lot and get a lot of work done in any given hour or day or even minutes. I think we're at a point where it's really hard to predict what happens next. I can tell you how the technology will progress and I think that, well, here's a few ideas. In the near future, I think we're all going to get more and more comfortable with software being asynchronous.
Christina:
What do you mean asynchronous?
Amjad:
So right now we sit in front of a computer, we're trying to get a task done and we're clicking and spending time there. We're going to be comfortable with modes like deep research, where you're sending off the computer, the AI, to do a lot of work and come back to you.
Christina:
You go get a coffee by the time you're back and settled.
Amjad:
Or you work on something else. So I think this multitasking sort of ADD way of working will be the way of working in the coming months. Replit, right now, we're making that trade off. We're like, well, we can work for 10, 15, 20 minutes. AI can work for 20 minutes. It could produce 10x the results of working two minutes. There's almost like this linear relationship between how many minutes we're spending on recent tokens or whatever with the output, whether it's quality, UI, all of that. And we're finding, we're still kind of validating that. We're finding that our customers are fine with that. We will send them a notification, they'll put in a prompt, and we'll send them a notification when the AI is done working. In my opinion, that's the main modality of working even by Q3 or Q4, many of us will be kicking off these agent workloads and checking on all them or getting coffee or whatever.
Christina:
Okay. How is this different from long build times though, right? Engineers hate long build times. That's kind of what it sounds like.
Amjad:
Yeah, engineers have experienced this for a long time.
Christina:
But generally weren't positive on that experience. But how is it different in an agentic world?
Amjad:
The compiler taking a minute or 10 minutes or an hour is not going to change the quality of my software. An agent taking a minute, 10 minutes, will fundamentally change the quality of the output. So we're going to be constantly making time-quality tradeoffs. Whereas a compiler, you're just going to have to wait. We actually have a choice. And I think more and more people would prefer, I mean there are always the iterative prototyping modality, but for example, on Perplexity, I'm a big user of Perplexity. I almost have the pro-mode always on, right? And I'll put it in a query, I'll go to a different tab and come back to it in a second.
Christina:
It's so interesting hearing you talk about this because Replit, one of the first things, was like, you get your response instantly.
Amjad:
It’s in the name, loop. Yeah, there's some looping, but you're not doing it. The machine is doing it. Literally all those stuff we built, we just switch out the user to an AI. So the AI is doing fast iteration, but you're not.
Christina:
Yep. That's neat. Another way I think Replit's really different is your approach to marketing. And maybe, I don’t know if you're still combing the web for backlinks these days, but how do you think about it today? Especially, to prompt you a little bit, but community, what marketing people call influencer marketing? How do you think about all of that?
Amjad:
Yeah, so early on in running Replit, I found the power of social media. I was able to bootstrap all these products and businesses and open source projects, like being part of React. Bloomberg never wrote about React. Maybe they did recently, but React became the number one framework of the world. React Native became the number one cross-platform development in the world with very little. Even Facebook didn't market it all that much. So you kind of came into this company realizing power of what going direct.
Christina:
As the kids say today.
Amjad:
Yeah, as the buzzword now. I was like, we used to call it tweeting. Yes, exactly. Now it's like going direct. So that was already obvious to me. But also early on in the company, I hired a PR agency, which they have their uses still, to write about a fundraiser or something like that, they took so much of my time and money and it landed in sort of some outlet that no one maybe, like 30 people read it. And I was like, I look at my Twitter and I'm getting hundreds of thousands of views. And then I literally said that on Twitter that went viral. I was like, oh, I paid this much for a PR agency to do this. I didn't get any readership, but on Twitter it was meta thing about it as that Tweet, it's off, went viral. So that was another learning experience and I think it's more fun that way. And I think just watching the experience of people like established founders like Zuck and others where, and I worked at Facebook where they built him up so much and then they turned him down. And I think that's the business model of media, of corporate journalism is building you up. And then after they finish building you up, there's only one way to go. There's only one way to go to generate the same news headlines. And so if they're not building you up, I mean, I get very little coverage on mainstream media. It's a different relationship that you have. You also just have direct relationship with your users, your customers. I get a lot of feedback, especially on X from customers.
Christina:
Actually before you do that on X or Twitter, you're so much better on that platform than most people, very much me included. But how do you think about it? What are your tips?
Amjad:
The first thing I would say is it's about distilling ideas. So right now you can write arbitrary number of characters. I almost never go above the limit because I think it's a feature, not a bug, to be able to distill ideas. So I might spend, on a Tweet that matters, I might spend 30 minutes trying to distill the idea, and it might sometimes be a background task in my head as I go through my day.
Christina:
As your agent is doing other things.
Amjad:
Yeah, I am trying to distill its most potent potential expression. And the other thing, it's about understanding the mode of the platform. So X is one where you're scrolling really fast, maybe LinkedIn is you're not as fast, you're willing to read. And so with X, you're really having to grab attention in the first few words. There's also a thing about X that, drama is something that is very interesting. So fights are very interesting to people. You don't want to be cheesy and unoriginal about it or overly combative or whatever, but there is a sense in which the beefs work. There's a sense in which also sometimes being a little vague works because people will interpret it in different ways. And then there's a viral effect to that because they will apply their own opinion. Like they'll quote Tweet it with their own opinion or their own view of what you said. Also saying things with confidence, although that might not be how you speak in day to day, I think it's a good strategy for Twitter because that generates strong disagreements and strong agreements, and that actually fuels virality as well.
Christina:
Okay, thank you for those tips. What about community?
Amjad:
Yeah, I mean, I would credit a lot of that to Haya, my co-founder. Early on, she really cared about the people, I cared about the machines more. And so I remember even when she started working on it with me, she was like, well, I want to run a survey to learn this thing or that. I was like, why? I can tell you what it is. I built this thing and she would find out things that I wouldn't have imagined about how people use the product and things like that. And since then, we've just had this approach to our community with this empathy and understanding in how people use the product. I'm only one person tweeting, although I have a large audience. But if you want a lot more people carrying the message of Replit, carrying the culture and vision of Replit, you want to create this core group of users that really care about that, and you want invest in them, and you want to create reasons for them to stay with you, create connections so that people feel like their friends in the community as well. That is somewhat of a moat, that is somewhat of a network effect, and you need to keep watering of the plants. And it's like a constant investment to make, which is hard. And it's also hard to find really great community managers, and the founders need to do that a lot of the time.
Christina:
That's neat. Interesting. You're a powerlifter, yeah?
Amjad:
Yeah. I mean, I used to be more so. I've lost a lot of weight, but yes.
Christina:
How is it similar to running a company?
Amjad:
Well, I think progressive overload is very true. And the idea behind power lifting is you increase the weights progressively and you get stronger, and your perceived sort of exertion might stay the same, but you're able to lift more weights. And I think that is very much true. I mean the amount of workload.
Christina:
Pain you can endure.
Amjad:
Stress you can endure over time. All those things are progressive.
Christina:
You've also read more widely on philosophy than your average founder. Does that influence how you think about AI?
Amjad:
Yeah, I spent a lot of time reading about, just the nature of consciousness and actually trying to struggle with that question. Where I think a lot of people, AI researchers, people in the AI space, are just taking it for granted that the consciousness is an immersion phenomenon. We live in this physicalist reality. Like there's only the physical and so there's nothing to explain about consciousness. It's merely emergent. And I don't really believe that. And I think once you sort of dig into the literature and see how far people, philosophers have explored, they don't have answers. That's the problem. So it's like a slog and then eventually you just still remain with the questions, but at least you've asked the question deeply. And it is a very important question now that we're headed into this world where we're going to have AI based employees and so on, are they actually conscious? If we're going to get to AGI, does that thing need to have rights? If we believe that consciousness is emergent, then what makes us so sure that it doesn't have consciousness? I actually think that my view is it's probably not fully emergent. There's probably something special about humans. And I think is probably a view shared mostly with religious people, perhaps. I am not entirely sure. I can sort of speculate as to what is the nature of consciousness or what have you. But I would say it's more likely than not, that consciousness is not this purely physical immersion phenomenon.
Christina:
If folks are curious to explore some of the ideas behind that themselves, where should they go?
Amjad:
Actually, I said all of that and I am going to suggest a book that actually makes the argument that it is emergent, which is Douglas Hofstadter, I Am a Strange Loop. But the reason it's good, it makes the best argument possible for emergence and it's very digestible and at the end I felt like I wasn't convinced.
Christina:
Okay, so that's good. Neat. We've talked about how your dad encouraged some of your early interest in computers. Alternate universe, none of that happened. I dunno. You never found a computer. What would you be doing?
Amjad:
I was interested in poetry and sort of language, literature. So my mom is sort of the opposite of my dad. My dad is your engineer's engineer, and my mom couldn't be further from that. She is very spiritual. She reads literature and poetry and all of that. She introduced me to a lot of that early on, especially Palestinian literature and poetry, which comes from the sort of struggle and it's very, very potent because it's shaped by that. I don't know if I'll be a poet per se, but I think it's plausible that I would be interested in instead of the crafting of code, the crafting of language.
Christina:
Does some of the Palestinian poetry stand up in English? Is there anything folks should check out?
Amjad:
I would say Mahmoud Darwish is the one that's most translatable to English. He might've even written in his own English, so I recommend that.
Christina:
Great. Well, we're talking here at your office in Foster City, which is not San Francisco, it's Foster City. How's Foster City treating you?
Amjad:
Good I mean, look at the view outside.
Christina:
Beautiful. At least 30 degrees warmer.
Amjad:
Right? It's warm. We have this lagoon and we do one-on-ones while walking around the lagoon. I really like it. The sort of big caveat is there's nothing out there.
Christina:
Is that a feature or a bug though?
Amjad:
It's a feature in my opinion. So there's a Costco people can go to get a $1.50 hot dog there, but we try to have everything here. So in the morning we have someone like a barista making coffee. We have lunch and dinner and some select days, cooked by a chef. And as you know, Haya and I really care about what we eat, care about our health and our employee's health, even sometimes when they don't like it or that we only carry good, healthy snacks and everything, people come up to us like, “Oh, I feel like a lot healthier after I joined Replit.” It is certainly a feature that it is a little boring here. And I think the other thing is we're able to think. I feel like there's just, the space allows you to think a little bigger. I feel like San Francisco, you're just cramped. And then the other thing is, in San Francisco, everyone is, there's such a tight feedback loop between everyone and everything that people say, it's like a bubble, but removing yourself from that has actually netted out with more original ideas, I would say.
Christina:
If a founder came and spent a day with you in Foster City, maybe here, maybe out, but what would you do for a day?
Amjad:
I would do a Q&A with a team. So I’m always trying to bring different perspectives, even if it something that is, someone who runs the company totally differently.
Christina:
Just avoid pain constantly.
Amjad:
Yeah, it's like, the company died. We had Mike Knoop the other day from Zapier and they're fully remote company and they do different things quite differently. We like to hear different perspectives. So introducing to the team, have that sort of discussion, maybe go for a walk, maybe sort of show them some of those very intense meetings we have, show them a few demos that we're working on. I remember one of my favorite visits, that was Jack Dorsey visiting Replit in the SF office.
Christina:
I remember hearing about this.
Amjad:
Yeah, we spent four or five hours together and it was basically all of that.
Christina:
That’s great. Any advice for early stage founders that is this truly unconventional?
Amjad:
There are a lot of rules in Silicon Valley that you can just throw away. When a VC tells you that, this is our process, we write checks only this size, we have to take this percentage of the company. None of this is true. They always break their own rules. So that's one. Two, a lot of what people tell you you're supposed to do—a lot of it is actually not good advice. I mean now it's becoming mainstream, but I stopped doing one-on-ones, for example, like, four or five years ago.
Christina:
So way before it was cool.
Amjad:
Yeah, way before it was cool. What I found is one-on-ones tend to be sort of a therapy session, and I found that while, okay, people need to be able to talk to someone, I just found it to be draining for my energy. People have a lot of anxieties and things like that and I try to talk about them in a group setting, but we also have a coach, so I just send people to a coach too. I'd want to talk about work, I want to understand their worries about work, whatever. But I'm not a therapist and it actually takes away from my time and energy, whatever. So a lot of early stage founders, they find themselves constantly doing therapy and I don't think that's a good use of their time.
Christina:
For those that really enjoy it, excellent. But for those that don't.
Amjad:
Yes, there's all these ideas around who you hire, fundraising, you have to hire an executive team now. Again, you can run companies in so many different ways. I visited xAI think a year ago when they were 70 people, and they told me they had no managers. Everyone reported to Elon, and everyone would send Elon weekly status updates.
Christina:
They probably didn't have one-on-ones.
Amjad:
They didn't have one-on-ones. He would come once a week or once however long, and he would sit and sometimes he would do a marathon where he'd do one-on-ones with everyone or do one to a few people per team. And the cool thing about it is, I know one of the early engineers there who's leading go to market now, so they have purely engineering teams. They don't have non-engineers and the engineers are doing the sales and marketing as well. And so that's a fundamentally different way of running a company. That's one of the most successful founders of our generation, if not the most successful, successful. So I will say every rule can be broken, but try to think through things. It's like, obviously just following every advice is bad. Just breaking everything for no reason is bad, but try to think through things, continue to tinker, continue to change things and that's how you learn.
Christina:
Tinkering in the system is a neat analogy.
Amjad:
And it's hard because people don't like change, but they'll deal with it. It's fine.
Christina:
Okay. Rapid fire around for you. What are you reading right now?
Amjad:
Man, I haven't really read all that much recently.
Christina:
Any good children's books?
Amjad:
That's exactly what I've been reading. Just like a very light read. I read Genius Makers about the recent history of deep learning. I read quite a bit of papers and Hacker News, blogs and internal documents. Erewhon? Have you heard of that?
Christina:
No, I don't. I think I've heard of it, but I've not read it.
Amjad:
It’s by Samuel Butler from the 1800s. And it's very interesting because—are you familiar with The Butlerian Jihad?
Christina:
No.
Amjad:
It's from Dune the movie, there are a group of people that don't like machines against AI and they do this thing called butlerian jihad. And it comes from this book. And in this book there is a tribe or a group of people that find that machines are sort of, dysgenic. It was like at the rise of Darwin. So it's a very Darwinian book. The machines make them worse as humans or less fit, and so therefore they're against any machine. And so it is very interesting for our age, as we increasingly replace aspects of ourself with computing and AI.
Christina:
Yep. This is great, I'll check it out. Do you remember the first program you ever wrote?
Amjad:
It must have been a Logo, a Logo program. Logo is this Turtle you can program. I must've been six years old or something like that. And must be something like move left, move right, go down.
Christina:
What about something where, at the time it seemed like a really big deal but in retrospect it was fine?
Amjad:
After we did the layoff last year, I felt like I couldn't bring back the culture of the company. I dunno if you know this, but there's, there's something about layoff that kind of breaks sort of the bubble or the dream. It was like, oh, we're not always…
Christina:
We're not a family.
Amjad:
We’re not a family, we're not always up and to the right. It's going to be a tough decision. My relationship with the company is not unconditional. I felt like, oh, it's going to be this monumental task to try to bring the culture back and I started doing things that I don't think I've ever done, which is try to do events and things like that we do some of those, but the way we built the culture wasn't that. So I was doing the wrong things. And the way to bring the culture is to win, is to work hard, motivate everyone, crush it. And that's what we did. And the culture is stronger than ever, it’s actually more fun and more exciting than ever. We ended up doing the right thing, but the hopelessness that I felt was like nothing I felt during the company because I cherished our culture so much and I felt like I made a lasting damage to it, which turned out not to be the case.
Christina:
And you didn't need to cosplay something you weren't to get it back.
Amjad:
That's right.
Christina:
What about the flip side of that? What was something that kind of didn't seem like a very big deal at the time, but in retrospect ended up being quite important?
Amjad:
Early on, we were building the Replit platform. We sort of had a choice between making Replit more bespoke, where was, supporting maybe one language or one way of building things versus making a general platform that can run any language or any package and all that. And we went with the latter, perhaps it was more like an aesthetic decision, but fast forward and LLMs are on the scene today. And so what are LLMs trained on? They're trained on standards. They're trained on open source, they know how to use a virtual machine, and all of that. And so the fact that we went with a general, more standard platform way of doing things made it so that you can drop an LLM into Replit and it'll just work. Whereas if you look at some of the, maybe let's look at the low-code, no-code platforms, they're all bespoke. And so LLMs haven't really had a big impact on those businesses as much as it had on ours.
Christina:
Yeah, that's very neat. Well, thank you so much for the time, for the conversation this afternoon.
Amjad:
Thank you for having me.
Christina:
We hope you found this conversation as enlightening and fun as we did. Thank you so much for watching. If you're interested for more with Frameworks for Growth, you can find us across the internet as Vanta and at vanta.com. Thanks so much.




Determine if you need to comply with GDPR
Not all organizations are legally required to comply with the GDPR, so it’s important to know how this law applies to your organization. Consider the following:
Do you sell goods or services in the EU or UK?
Do you sell goods or services to EU businesses, consumers, or both?
Do you have employees in the EU or UK?
Do persons from the EU or UK visit your website?
Do you monitor the behavior of persons within the EU?
Document the personal data you process
Because GDPR hinges on the data you collect from consumers and what your business does with that data, you’ll need to get a complete picture of the personal data you’re collecting, processing, or otherwise interacting with. Follow these items to scope out your data practices:
Identify and document every system (i.e. database, application, or vendor) that stores or processes EU- or UK-based personally identifiable information (PII).
Document the retention periods for PII in each system.
Determine whether you collect, store, or process “special categories” of data, including:
Determine whether your documentation meets the GDPR requirements for Records of Processing Activities, that include information on:
Determine whether your documentation includes the following information about processing activities carried out by vendors on your behalf:
Determine your legal grounds for processing data
GDPR establishes conditions that must be met before you can legally collect or process personal data. Make sure your organization is meeting the conditions listed below:
For each category of data and system/application, determine the lawful basis for processing based on one of the following conditions:
Review and update current customer and vendor contracts
For your organization to be fully GDPR compliant, the vendors you use must also maintain the privacy rights of your users’ and those rights should be reflected in your contracts with customers:
Review all customer and in-scope vendor contracts to determine that they have appropriate contract language (i.e. Data Protection Addendums with Standard Contractual Clauses).
Determine if you need a Data Protection Impact Assessment
A Data Protection Impact Assessment (DPIA) is an assessment to determine what risks may arise from your data processing and steps to take to minimize them. Not all organizations need a DPIA, the following items will help you determine if you do:
Identify if your data processing is likely to create high risk to the rights and freedoms of natural persons. Considering if your processing involves any of the following:
Clearly communicate privacy and marketing consent practices
A fundamental element of GDPR compliance is informing consumers of their data privacy rights and requesting consent to collect or process their data. Ensure your website features the following:
A public-facing privacy policy which covers the use of all your products, services, and websites.
Notice to the data subject that include the essential details listed in GDPR Article 13.
Have a clear process for persons to change or withdraw consent.
Update internal privacy policies
Ensure that you have privacy policies that are up to the standards of GDPR:
Update internal privacy notices for EU employees.
Have an employee privacy policy that governs the collection and use of EU and UK employee data.
Determine if you need a data protection officer (DPO) based on one of the following conditions:
Review compliance measures for external data transfers
Under GDPR, you’re responsible for protecting the data that you collect and if that data is transferred. Make your transfer process compliant by following these steps:
If you transfer, store, or process data outside the EU or UK, identify your legal basis for the data transfer. This is most likely covered by the standard contractual clauses.
Perform and document a transfer impact assessment (TIA).
Confirm you comply with additional data subject rights
Ensure you’re complying with the following data subject rights by considering the following questions:
Do you have a process for timely responding to requests for information, modifications, or deletion of PII?
Can you provide the subject information in a concise, transparent, intelligible, and easily accessible form, using clear and plain language?
Do you have a process for correcting or deleting data when requested?
Do you have an internal policy regarding a Compelled Disclosure from Law Enforcement?
Determine if you need an EU-based representative
Depending on how and where your organization is based, you may need a representative for your organization within the European Union. Take these steps to determine if this is necessary:
Determine whether an EU representative is needed. You may not need an EU-rep if the following conditions apply to your organization:
If the above conditions do not apply to you, appoint an EU-based representative.
Identify a lead data protection authority (DPA) if needed
GDPR compliance is supervised by the government of whatever EU member-state you’re operating in. If you’re operating in multiple member-states, you may need to determine who your lead data protection authority is:
Determine if you operate in more than one EU state.
If so, designate the supervisory authority of the main establishment to act as your DPA.
Implement employee training
Every employee in your organization provides a window for hackers to gain access to your systems and data. This is why it's important to train your employees on how to prevent security breaches and maintain data privacy:
Provide appropriate security awareness and privacy training to your staff.
Integrate data breach response requirements
GDPR requires you to create a plan for notifying users and minimizing the impact of a data breach. Examine your data breach response plan, by doing the following:
Create and implement an incident response plan which includes procedures for reporting a breach to EU and UK data subjects as well as appropriate data authorities.
Establish breach reporting policies that comply with all prescribed timelines and include all recipients (i.e. authorities, controllers, and data subjects).
Implement appropriate security measures
Have you implemented encryption of PII at rest and in transit?
Have you implemented pseudonymization?
Have you implemented appropriate physical security controls?
Have you implemented information security policies and procedures?
Can you access EU or UK PII data in the clear?
Do your technical and organizational measures ensure that, by default, only personal data that are necessary for each specific purpose of the processing are processed?
Streamline GDPR compliance with automation
GDPR compliance is an ongoing project that requires consistent upkeep with your system, vendors, and other factors that could break your compliance. Automation can help you stay on top of your ongoing GDPR compliance. The following items can help you streamline and organize your continuous compliance:
Explore tools for automating security and compliance.
Transform manual data collection and observation processes via continuous monitoring.
Download this checklist for easy reference
GDPR compliance FAQs
In this section, we’ve answered some of the most common questions about GDPR compliance:
What are the seven GDPR requirements?
The requirements for GDPR compliance are based on a set of seven key principles:
- Lawfulness, fairness, and transparency
- Purpose limitation
- Data minimization
- Accuracy
- Storage limitations
- Integrity and confidentiality
- Accountability
These are the seven requirements you must uphold to be GDPR compliant.
Is GDPR compliance required in the US?
GDPR compliance is mandatory for some US companies. GDPR compliance is not based on where your organization is located but whose data you collect, store, or process. Regardless of where your organization is based, you must comply with GDPR if you are collecting or processing data from EU residents.
What are the four key components of GDPR?
The four components of GDPR include:
- Data protection principles
- Rights of data subjects
- Legal bases for data processing
- Responsibilities and obligations of data controllers and processors
Safeguard your business with GDPR compliance
If your organization collects data from EU residents, GDPR compliance is mandatory for you. It’s important to follow the steps listed above to protect your business from heavy fines and to respect the data privacy rights of consumers.
Vanta provides compliance automation tools and continuous monitoring capabilities that can help you get and stay GDPR compliant. Learn more about getting GDPR compliance with Vanta.
Pre-work for your SOC 2 compliance
Choose the right type of SOC 2 report:
A SOC 2 Type 1 report assesses how your organization aligns with the security controls and policies outlined in SOC 2
A SOC 2 Type 2 report has all the components of a Type 1 report with the addition of testing your controls over a period of time
The correct report will depend on the requirements or requests of the client or partner that has requested a SOC 2 report
from you
Determine the framework for your SOC 2 report. Of the five Trust Service Criteria in SOC 2, every organization needs to comply with the first criteria (security), but you only need to assess and document the other criteria that apply. Determining your framework involves deciding which Trust Service Criteria and controls are applicable to your business using our Trust Service Criteria Guide.
Estimate the resources you expect to need. This will vary depending on how closely you already align with SOC 2 security controls, but it can include several costs such as:
Compliance software
Engineers and potentially consultants
Security tools, such as access control systems
Administrative resources to draft security policies
Auditing for your compliance certification
Obtain buy in from your organization leadership to provide the resources your SOC 2 compliance will need.
Work toward SOC 2 compliance
Begin with an initial assessment of your system using compliance automation software to determine which necessary controls and practices you have already implemented and which you still need to put in place.
Review your Vanta report to determine any controls and protocols within the “Security” Trust Service Criteria that you do not yet meet and implement these one by one. These are multi-tiered controls across several categories of security, including:
CC1: Control Environment
CC2: Communication and Information
CC3: Risk Assessment
CC4: Monitoring Activities
CC5: Control Activities
CC6: Logical and Physical Access Controls
CC7: System Operations
CC8: Change Management
CC9: Risk Mitigation
Using Vanta’s initial assessment report as a to-do list, address each of the applicable controls in the other Trust Services Criteria that you identified in your initial framework, but that you have not yet implemented.
Using Vanta’s initial assessment report, draft security policies and protocols that adhere to the standards outlined in SOC 2.
Vanta’s tool includes thorough and user-friendly templates to make this simpler and save time for your team.
Run Vanta’s automated compliance software again to determine if you have met all the necessary criteria and controls for your SOC 2 report and to document your compliance with these controls.
Complete a SOC 2 report audit
Select and hire an auditor affiliated with the American Institute of Certified Public Accountants (AICPA), the organization that developed and supports SOC 2.
Complete a readiness assessment with this auditor to determine if you have met the minimum standards to undergo a full audit.
If your readiness assessment indicates that there are SOC 2 controls you need to address before your audit, complete these requirements. However, if you have automated compliance software to guide your preparations and your SOC 2 compliance, this is unlikely.
Undergo a full audit with your SOC 2 report auditor. This may involve weeks or longer of working with your auditor to provide the documentation they need. Vanta simplifies your audit, however, by compiling your compliance evidence and documentation into one platform your auditor can access directly.
When you pass your audit, the auditor will present you with your SOC 2 report to document and verify your compliance.
Maintain your SOC 2 compliance annually
Establish a system or protocol to regularly monitor your SOC 2 compliance and identify any breaches of your compliance, as this can happen with system updates and changes.
Promptly address any gaps in your compliance that arise, rather than waiting until your next audit.
Undergo a SOC 2 re-certification audit each year with your chosen SOC 2 auditor to renew your certification.
Download this checklist for easy reference
Prioritizing Your Security and Opening Doors with SOC 2 Compliance
Information security is a vital priority for any business today from an ethical standpoint and from a business standpoint. Not only could a data breach jeopardize your revenue but many of your future clients and partners may require a SOC 2 report before they consider your organization. Achieving and maintaining your SOC 2 compliance can open countless doors, and you can simplify the process with the help of the checklist above and Vanta s compliance automation software. Request a demo today to learn more about how we can help you protect and grow your organization.
Pre-work for your ISO 42001 compliance
Understand ISO 42001 requirements
Decide on what is the scope of the AIMS
Familiarize yourself with key AI concepts, principles, and lifecycle based on ISO frameworks
Determine if you are a provider, developer, or user of AI systems
Perform initial gap analysis
Using Vanta, asses your in-scope ISO 42001 controls
Identify areas of requirement, development, or adjustment
Secure top management support
Present a business case highlighting the benefits of ISO 42001 certification
Define roles and responsibilities for top management in AIMS implementation
Involve various department heads in the analysis to ensure comprehensive coverage
Work for your ISO 42001 compliance
Appoint a Project Manager
Designate an owner for the ISO 42001 implementation project
Develop a project plan
Outline steps, timelines, and resources needed for AIMS implementation
Integrate the AIMS implementation project within existing organizational processes
Establish the AIMS framework
Define the scope and objectives of the AIMS within the organization
Develop and document AI policies and risk management processes
Based on gap analysis, implement necessary controls for AIMS
Ensure integration of AIMS with other management systems and requirements
Create an AIMS statement of applicability (SOA)
Promote competence and awareness
Conduct training for stakeholders on AI concepts and ISO 42001 requirements
Raise awareness about the importance and benefits of AIMS
Implement AIMS controls
Create an AI policy
Define the process for reporting concerns about AI systems
Identify, document, and manage resources for AI systems
Ensure tooling and computing resources for AI systems are adequately documented
Conduct an AI system impact assessment exercise
Ensure that objectives are documented for the design and development of AI systems
Create a process for responsible design and development of AI systems
Ensure that AI system deployment, operation, and monitoring are documented and executed according to your AIMS
Define and implement data management processes for AI systems
Assess and document the quality of data for AI systems
Ensure that system documentation and information for users is provided and accessible
Document and follow the processes for the responsible use of AI systems
Clearly allocate and document responsibilities with third parties
Conduct internal audits
Regularly assess compliance with ISO 42001 and the effectiveness of AIMS
Management review
Review AIMS performance and compliance with top management
Address any non conformities and areas for improvement
Prepare for your external audit
Work with A-LIGN as your ISO 42001 certification body
Engage A-LIGN, a leading ISO certification body, to conduct your audit
Prepare documentation
Ensure all AIMS documentation is up to date and accessible
Pre-audit meeting
Prepare a list of questions and clarifications regarding the audit process
Initial sales process
Discuss the scope of the audit in detail to ensure full preparedness
Conduct a pre-certification audit (optional)
Consider a pre-certification audit to identify any remaining gaps
The ISO 42001 audit
Engage in the certification audit
Collaborate with A-LIGN auditors, providing necessary information and access
Designate a team member as the point of contact for auditors to streamline communication
Organize walkthroughs to discuss your AIMS processes and procedures, including facilities (if applicable)
Address audit findings
Plan for immediate, short-term, and long-term corrective actions based on the audit report
Celebrate the audit success with your team and publicly promote your certification
Continuous improvement
Establish a continuous improvement team to oversee progress post-certification
Continuously improve the AIMS, leveraging lessons learned and feedback
Integrate ISO 42001 compliance metrics into regular management reviews
Keys to success
Leverage Vanta s readiness capabilities and A-LIGN s expertise for an efficient and high-quality audit experience from
readiness to report
Incorporate AIMS within the business strategy and daily operations
Apply continuous improvement to enhance AIMS over time
Avoid integrating new technologies during the initial AIMS implementation
Engage interested parties and maintain their support throughout
Highlight the completion of the audit to demonstrate trust with customers, partners, and other key stakeholders
Download this checklist for easy reference
Demonstrating secure AI practices with ISO 42001
The rapid adoption of AI has driven innovation and opportunities for growth — and with it, new risks for the companies that manage the data that power these technologies. These companies have not had a way to demonstrate trust to their customers and show that they are deploying AI securely and safely. Achieving ISO 42001 compliance helps to demonstrate this trust through a third-party verifiable way and opens the doors to time-savings, more deals, and expedited sales processes. The above checklist simplifies the process of becoming ISO 42001 compliant by leveraging the power of Vanta's continuous compliance software. Request a demo today to learn more about how Vanta can help you streamline the path to ISO 42001.
Develop a roadmap for your ISMS implementation and ISO 27001 certification
Implement Plan, Do, Check, Act (PDCA) process to recognize challenges and identify gaps for remediation
Consider the costs of ISO 27001 certification relative to your organization’s size and number of employees.
Use project planning tools like project management software, Gantt charts, or Kanban boards.
Define the scope of work from planning to completion.
Determine the scope of your organization’s ISMS
Decide which business areas are covered by your ISMS and which ones are out of scope
Consider additional security controls for processes that are required to pass ISMS-protected information across the trust boundary.
Communicate the scope of your ISMS to stakeholders.
Establish an ISMS team and assign roles
Select engineers and technical staff with experience in information security to construct and implement the security controls needed for ISO 27001.
Build a governance team with management oversight.
Incorporate key members of top management (senior leadership and executive management) and assign responsibility for strategy and resource allocation.
If you have a large team, consider assigning a dedicated project manager to track progress and expedite implementation.
Align the team on the following:
The planning steps you’ve already taken
The scope of the ISMS
Which team members are responsible for which aspects of the project
Conduct an inventory of information assets
Consider all assets where information is stored, processed, and accessible
- Record information assets: data and people
- Record physical assets: laptops, servers, and physical building locations
- Record intangible assets: intellectual property, brand, and reputation
Assign to each asset a classification and owner responsible for ensuring the asset is appropriately inventoried, classified, protected, and handled
Meet with your team to discuss this inventory and ensure that everyone is aligned.
Perform a risk assessment
Establish and document a risk-management framework to ensure consistency
Identify scenarios in which information, systems, or services could be compromised
Determine likelihood or frequency with which these scenarios could occur
Evaluate potential impact of each scenario on confidentiality, integrity, or availability of information, systems, and services
Rank risk scenarios based on overall risk to the organization’s objectives
Develop a risk register
Record and manage your organization’s risks that you identified during your risk assessment.
Summarize each identified risk
Indicate the impact and likelihood of each risk.
Rank risk scenarios based on overall risk to the organization’s objectives.
Document a risk treatment plan
Design a response for each risk, known as a risk treatment.
Assign an owner to each identified risk and each risk mitigation activity.
Establish target timelines for completion of risk treatment activities.
Implement your risk mitigation treatment plan and track the progress of each task.
Complete the Statement of Applicability
Review the 93 controls listed in Annex A.
Select the controls that are relevant to the risks you identified in your risk assessment.
Complete the Statement of Applicability listing all Annex A controls, justifying inclusion or exclusion of each control in your ISMS implementation.
Implement ISMS policies, controls and continuously assess risk
Assign owners to each of the security controls to be implemented.
Figure out a way to track the progress and goals for each control.
Build a framework for establishing, implementing, maintaining, and continually improving the ISMS.
Include information or references to supporting documentation regarding:
- Information Security Objectives
- Leadership and Commitment
- Roles, Responsibilities, and Authorities
- Approach to Assessing and Treating Risk
- Control of Documented Information
- Communication
- Internal Audit
- Management Review
- Corrective Action and Continual Improvement
- Policy Violations
- All of the Annex A controls that you have selected
Establish employee training and awareness programs
Define expectations for personnel regarding their role in ISMS maintenance.
Train personnel on common threats facing your organization and how to respond.
Establish disciplinary or sanctions policies or processes for personnel found out of compliance with information security requirements.
Make security training part of the onboarding process for new employees.
Conduct regular training to ensure awareness of new policies and procedures.
Conduct regular management reviews
Plan reviews at least once per year. Consider a quarterly review cycle if your organization is large or if your infrastructure is changing frequently.
Ensure the ISMS and its objectives continue to be effective.
Verify that senior management stays informed.
Ensure risks or deficiencies can be promptly addressed.
Assemble ISO 27001 required documents
Review the ISO 27001 Required Documents and Records list.
Customize policy templates with organization-specific policies, process, and language.
Perform an ISO 27001 internal audit.
Examine each of the requirements from Annex A that you deemed applicable in your ISMS' Statement of Applicability and verify that you have each in place.
Assign in-house employees to conduct the internal audit, specifically employees who were not involved in the ISMS development and maintenance or hire an independent third party.
Share internal audit results, including nonconformities, with the ISMS team and senior management.
Address any issues your internal audit identified before proceeding with the external audit.
Verify compliance with the requirements from Annex A deemed applicable in your ISMS' Statement of Applicability.
Undergo external audit of ISMS to obtain ISO 27001 certification.
Select an independent ISO 27001 auditor.
Complete the Stage 1 Audit consisting of an extensive documentation review; obtain the auditor’s feedback regarding your readiness to move to the Stage 2 Audit.
Complete the Stage 2 Audit consisting of tests performed on the ISMS to ensure proper design, implementation, and ongoing functionality; evaluate fairness, suitability, and effective implementation and operation of controls.
Address any nonconformities.
Ensure that all requirements of the ISO 27001 standard are addressed.
Ensure your organization is following the processes that it has specified and documented.
Ensure your organization is upholding contractual requirements with third parties.
Address specific nonconformities identified by the ISO 27001 auditor.
Receive auditor’s formal validation following resolution of nonconformities.
Plan for subsequent ISO 27001 audits and surveillance audits.
Perform a full ISO 27001 audit once every three years
Prepare to perform surveillance audits in the second and third years of the Certification Cycle
Consider streamlining ISO 27001 certification with automation.
Transform manual data collection and observation processes into automated and continuous system monitoring
Identify and close any gaps in ISMS implementation in a timely manner
Learn more about achieving ISO 27001 certification with Vanta
Book an ISO 27001 demo with Vanta
Download this checklist for easy reference
Prioritizing your security and opening doors with ISO 27001 compliance
Information security is a vital priority for any business today from an ethical standpoint and from a business standpoint. Not only could a data breach jeopardize your revenue, but many of your future clients and partners may require an ISO 27001 report before they consider your organization. Achieving and maintaining your ISO 27001 compliance can open countless doors, and you can simplify the process with the help of the checklist above and Vanta’s compliance automation software.
Request a demo today to learn more about how we can help you protect and grow your organization.
Develop a roadmap for your ISMS implementation and ISO 27001 certification
Implement Plan, Do, Check, Act (PDCA) process to recognize challenges and identify gaps for remediation
Consider the costs of ISO 27001 certification relative to your organization’s size and number of employees.
Use project planning tools like project management software, Gantt charts, or Kanban boards.
Define the scope of work from planning to completion.
Determine the scope of your organization’s ISMS
Decide which business areas are covered by your ISMS and which ones are out of scope
Consider additional security controls for processes that are required to pass ISMS-protected information across the trust boundary.
Communicate the scope of your ISMS to stakeholders.
Establish an ISMS team and assign roles
Select engineers and technical staff with experience in information security to construct and implement the security controls needed for ISO 27001.
Build a governance team with management oversight.
Incorporate key members of top management (senior leadership and executive management) and assign responsibility for strategy and resource allocation.
If you have a large team, consider assigning a dedicated project manager to track progress and expedite implementation.
Align the team on the following:
The planning steps you’ve already taken
The scope of the ISMS
Which team members are responsible for which aspects of the project
Conduct an inventory of information assets
Consider all assets where information is stored, processed, and accessible
- Record information assets: data and people
- Record physical assets: laptops, servers, and physical building locations
- Record intangible assets: intellectual property, brand, and reputation
Assign to each asset a classification and owner responsible for ensuring the asset is appropriately inventoried, classified, protected, and handled
Meet with your team to discuss this inventory and ensure that everyone is aligned.
Perform a risk assessment
Establish and document a risk-management framework to ensure consistency
Identify scenarios in which information, systems, or services could be compromised
Determine likelihood or frequency with which these scenarios could occur
Evaluate potential impact of each scenario on confidentiality, integrity, or availability of information, systems, and services
Rank risk scenarios based on overall risk to the organization’s objectives
Develop a risk register
Record and manage your organization’s risks that you identified during your risk assessment.
Summarize each identified risk
Indicate the impact and likelihood of each risk.
Rank risk scenarios based on overall risk to the organization’s objectives.
Document a risk treatment plan
Design a response for each risk, known as a risk treatment.
Assign an owner to each identified risk and each risk mitigation activity.
Establish target timelines for completion of risk treatment activities.
Implement your risk mitigation treatment plan and track the progress of each task.
Complete the Statement of Applicability
Review the 93 controls listed in Annex A.
Select the controls that are relevant to the risks you identified in your risk assessment.
Complete the Statement of Applicability listing all Annex A controls, justifying inclusion or exclusion of each control in your ISMS implementation.
Implement ISMS policies, controls and continuously assess risk
Assign owners to each of the security controls to be implemented.
Figure out a way to track the progress and goals for each control.
Build a framework for establishing, implementing, maintaining, and continually improving the ISMS.
Include information or references to supporting documentation regarding:
- Information Security Objectives
- Leadership and Commitment
- Roles, Responsibilities, and Authorities
- Approach to Assessing and Treating Risk
- Control of Documented Information
- Communication
- Internal Audit
- Management Review
- Corrective Action and Continual Improvement
- Policy Violations
- All of the Annex A controls that you have selected
Establish employee training and awareness programs
Define expectations for personnel regarding their role in ISMS maintenance.
Train personnel on common threats facing your organization and how to respond.
Establish disciplinary or sanctions policies or processes for personnel found out of compliance with information security requirements.
Make security training part of the onboarding process for new employees.
Conduct regular training to ensure awareness of new policies and procedures.
Conduct regular management reviews
Plan reviews at least once per year. Consider a quarterly review cycle if your organization is large or if your infrastructure is changing frequently.
Ensure the ISMS and its objectives continue to be effective.
Verify that senior management stays informed.
Ensure risks or deficiencies can be promptly addressed.
Assemble ISO 27001 required documents
Review the ISO 27001 Required Documents and Records list.
Customize policy templates with organization-specific policies, process, and language.
Perform an ISO 27001 internal audit.
Examine each of the requirements from Annex A that you deemed applicable in your ISMS' Statement of Applicability and verify that you have each in place.
Assign in-house employees to conduct the internal audit, specifically employees who were not involved in the ISMS development and maintenance or hire an independent third party.
Share internal audit results, including nonconformities, with the ISMS team and senior management.
Address any issues your internal audit identified before proceeding with the external audit.
Verify compliance with the requirements from Annex A deemed applicable in your ISMS' Statement of Applicability.
Undergo external audit of ISMS to obtain ISO 27001 certification.
Select an independent ISO 27001 auditor.
Complete the Stage 1 Audit consisting of an extensive documentation review; obtain the auditor’s feedback regarding your readiness to move to the Stage 2 Audit.
Complete the Stage 2 Audit consisting of tests performed on the ISMS to ensure proper design, implementation, and ongoing functionality; evaluate fairness, suitability, and effective implementation and operation of controls.
Address any nonconformities.
Ensure that all requirements of the ISO 27001 standard are addressed.
Ensure your organization is following the processes that it has specified and documented.
Ensure your organization is upholding contractual requirements with third parties.
Address specific nonconformities identified by the ISO 27001 auditor.
Receive auditor’s formal validation following resolution of nonconformities.
Plan for subsequent ISO 27001 audits and surveillance audits.
Perform a full ISO 27001 audit once every three years
Prepare to perform surveillance audits in the second and third years of the Certification Cycle
Consider streamlining ISO 27001 certification with automation.
Transform manual data collection and observation processes into automated and continuous system monitoring
Identify and close any gaps in ISMS implementation in a timely manner
Learn more about achieving ISO 27001 certification with Vanta
Book an ISO 27001 demo with Vanta
Download this checklist for easy reference
Download NowPlan strategically when scheduling and timing your audit
Sometimes, the biggest roadblock to scheduling an audit is knowing where to start. Here are a few tips for taking your first big step in the audit process.
Check into your chosen firm’s availability. Small auditing firms tend to have more limited time and need more advance notice, while larger firms have more resources and, therefore, more availability. However, larger firms can cost more to hire.
Give yourself enough time before the audit. In many cases, audits don’t just check to see if you’ve done an activity once; they look for evidence of continuous controls. Plan to collect consistent evidence over at least three months to demonstrate this.
Choose a dedicated team or team member who will be available throughout the audit. Your auditor will need a go-to person to provide all the proper information and be available for any follow-up questions. Check calendars of others stakeholders involved with the audit controls to ensure they’ll be present when you schedule your audit on-site or live sessions.
Be aware of commitments and deadlines. You will likely sign a statement of work (SOW) when you schedule an audit. Your team is responsible for meeting all the deadlines outlined in this SOW. The auditor will need the correct information from your team in a timely manner to do their job.
Pro tip: Make sure your team understands the difference between the “audit window” or “review period” and the length of the audit itself. The “audit window” is the timeframe the auditors will use to gauge if you’ve been consistent with your controls. Typically, they require three months or more. This time period is different from the 1-4 weeks that the auditor will be inside your organization, conducting the audit itself.
Prepare your team in advance
Once you’ve scheduled your audit, it’s time to work with your team and assign tasks to the appropriate owners. An audit requires participation from several teams, from engineering to IT to sales. Here are a few ways to prepare these teams for audit-related activities:
Know which framework(s) you’re working towards and communicate the requirements to your team. If you’re going to work towards multiple frameworks simultaneously, identify overlaps so you don’t duplicate work. A tool like Vanta helps break down requirements and map them to action items.
Understand which evidence each team needs to provide. Next, communicate requirements and deadlines to each department. It’s a good idea to use a central hub that can show all preparation activities and who is responsible for each one.
Inform your team why this is an important activity so they understand that the time and commitment are worthwhile for them. Connect it to outcomes and KPIs that matter to their teams whenever possible. Audits ultimately prove your company’s commitment to security and trust, and meeting a framework can be the difference between growing your business and missing out on opportunities.
Communicate to your team that the goal is progress, not perfection. If it’s your first time getting audited against a particular framework, you probably won’t get a perfect score, and that’s okay! Instead, make it your goal to set a baseline for meeting the framework, then find ways to improve your controls over time.
Pro tip: As you and your team prepare for the audit, remember to do your due diligence before the auditor even arrives. Get to know exactly how your controls align with the framework and be realistic about which shortcomings you expect the auditor will likely find. That way, you won’t be surprised by the audit’s findings.
Manage your evidence
As your team prepares for an audit, collecting evidence of your activities is just as important as completing the activities themselves. For example, you will likely need to draft formal security policies and protocols (for example, this is one of the requirements for SOC 2). But you can’t just say, “We have the required security policies.” You’ll need to provide your auditor with a hard copy of your policies. And this is just one of the many controls they will require you to prove with documentation.
Managing evidence gets complicated quickly, considering how many documents your auditor will require. So, it’s your job to make sure that evidence is organized and ready as soon as the auditor asks for it. Here are a few tips for compiling the proper evidence to be fully prepared when the auditor arrives:
Ensure your evidence shows consistency —not just point-in-time or static documentation. You should be able to prove that you’ve maintained the proper controls throughout your audit window. A tool like Vanta that supports continuous controls monitoring can help with this.
Compile and store your documentation in a way that simplifies sharing the relevant evidence with the auditor. You want to spend as little time as possible chasing down specific documents or screenshots during the audit. Getting organized beforehand means far less stress for your team when the auditor begins their assessment. Vanta can help you stay on top of your documentation by storing all documents in a centralized location and automatically updating data with real-time changes.
Get to know your evidence inside and out. You shouldn’t be surprised by anything that your auditor finds. It helps to use a governance, risk, and compliance (GRC) automation tool to parse through the documentation and summarize findings. This way, you have a consolidated view of evidence rather than a bunch of disparate documents and files that are hard to consume at once.
Be transparent and upfront with your evidence. Don’t try to shape a specific story or alter the truth by showing more or less documents to an auditor. Honesty is always the best policy in these cases, especially considering the potential consequences of lying in an audit. Altering the truth can significantly impact the integrity of your company, or even prevent you from requesting audits in the future.
Pro tip: Be transparent without embellishing the truth when the auditor arrives. Let your evidence speak for itself. You might think this goes without saying, but the temptation to overshare or embellish can get the best of anyone when the audit actually begins.
Work closely with your auditor
Many organizations enter the auditing process with concerns about their relationship with the auditor. Fortunately, in most cases, the process will be less like a test proctored by an intimidating professor and more of a back-and-forth conversation with an industry expert who knows best how to get you to your goals.
Here’s some advice for working with your auditor and making it a better experience for both of you:
Look for specialization. Find an auditor specializing in the framework(s) you’re working toward. You can start by asking for recommendations within your industry—Vanta’s network of trusted auditors is a great place to start.
Help your auditor understand your business. You will need to guide them through the ins and outs of your organization, including where your controls reside and which insights they provide to your business. They won't know where to start assessing your controls if they don’t understand your organization or GRC processes and tools.
Treat the audit like a conversation. In most cases, your auditor will be inside your organization for a few weeks to months, and during that time, it should become a back-and-forth working relationship. The auditor will likely ask you for specific evidence over time, and you will work with them directly to provide each piece of information they need, and so on.
Maintain the relationship with your auditor afterward. They can serve as a helpful resource as you build out your GRC initiatives and continuously maintain and improve compliance over time. While auditors can’t give direct advice on how to do something, most are more than willing to help wherever they can. For example, if you plan to change your tech stack, employee policies, etc., consider asking your auditor how these changes will impact future audits before committing to the change.
Pro tip: Keep in mind that it’s common practice to switch your auditor every few years to avoid bias. But once you’ve found a firm and auditor you like, you can always ask them for recommendations and referrals to find your next auditor.
Take your audit results to the next level
An audit isn’t just a one-and-done activity—it’s the beginning of a journey toward a stronger security posture over time. To get the most out of your audit findings, prepare your team to work on the following initiatives after the audit is done:
Share your new compliance status with the right audiences. Many businesses rely use a public-facing site (like Vanta Trust Center) to display their real-time GRC efforts. Your prospective customers can then use this data to expedite security questionnaires and provide proof points to key decision-makers.
Track KPIs that show your response to the gaps that your auditor finds. The specifics of these KPIs will depend on your particular business, priorities, etc. In general, they should center around risk reduction and remediation efforts. For instance, if you have any findings, opportunities for improvement (OFI), or nonconformities listed in your report, track the response to these insights over time. How are you changing processes? What new tools have you implemented?
Consider conducting a readiness assessment between formal external audits. Businesses will typically either hire a third party or pick a team member who isn’t involved in any GRC activities to perform this type of audit. The best way to incorporate readiness assessments into your processes without causing business disruption is to use continuous monitoring to get an instant snapshot of all existing controls.
Treat your audit like a jumping-off point for security initiatives. Meeting a particular framework doesn’t necessarily equate to bulletproof security. For example, a compliance framework often doesn’t account for emerging threats. Still, consistently meeting the controls listed in a framework is a great starting point for establishing a strong security culture throughout your organization.
Foster a strong security culture. As you respond to your audit findings and implement stronger GRC controls, your team members need to understand why specific controls exist and how to play a role in meeting them. Ultimately, this is all about fostering a strong security and risk management culture throughout your organization. Consider rolling out security training and tracking KPIs such as phishing drill click-through rates and training completion rates. This will help demonstrate progress for future audits as well as improving your organization’s security posture.
Pro tip: Keep in mind that it’s common practice to switch your auditor every few years to avoid bias. But once you’ve found a firm and auditor you like, you can always ask them for recommendations and referrals to find your next auditor.
Anatomy of an audit report
Knowing what to expect when you finally get that audit report can help you set expectations for internal and external stakeholders ahead of time. Here’s what the typical audit report should contain:
- Executive summary: A high-level recap of the report’s purpose, the standard/framework in question, etc.
- Scope: An in-depth description of the scope that the audit covered. For example, was it a corporate-wide evaluation, a test on a specific application, or something else?
- Testing information: A detailed list of all tests the auditor ran, such as policy reviews, artifact evaluations, and on-site observations.
- Testing results: A report on the results of these tests, including any exceptions.
- Management responses: The management team’s explanations as to why an exception exists and how they will respond to it in the future.
- Conclusion: The auditor’s opinion on the assessment. Keep in mind that this area of the report will rank the company by maturity, not as a pass or fail.
While compliance audits can feel overwhelming because of the time and resources that they require, they offer your team the unique opportunity to start a journey toward stronger security and deeper customer trust. Plus, tasks like scheduling, managing evidence, and working with your auditor don’t have to feel so daunting if you go into your next audit with the right expectations and preparation.
Confirm which CMMC level your business needs
The first step of the CMMC program and becoming CMMC certified is confirming what CMMC level you’re on. Here are a few ways you can confirm what level your business needs.
Determine the type of data you handle. If you handle FCI, you’ll likely fall under level 1, whereas if you handle CUI, you will be under level 2 or 3. If you handle a variety of FCI and CUI information, you must be certified at the level encompassing all the information you handle.
Check your contract. If you currently have a contract, reach out to your contracting officer. They can help determine your level and the requirements to remain compliant. As you bid on future contracts, the DoD will specify the required CMMC level and assessment type for eligibility in the solicitation and resulting contract.
Perform a self-assessment. If you don’t currently have a contract, but hope to in the future, the best thing you can do is perform a self-assessment of your systems. This ensures you meet the necessary security requirements and have implemented proper controls to protect sensitive information. It will also give you an idea of what level you’re at.
Establish your FCI and CUI boundaries
Once you confirm what level of certification you need, your next step is to figure out what systems, processes, and data—referred to as assets—fall under CMMC requirements. The DoD refers to this process as establishing your boundaries for FCI and CUI.
Review boundaries and assessment scope guidelines for your CMMC level. Each level has set boundaries and assets based on the information that’s handled. Once you know your level, you can review general guidelines for assessment scope.
Identify in-scope assets. For each level, there will be set assets that are considered in scope. Depending on the certification you’re seeking, you’ll need to identify all assets that process, store, or transmit FCI or CUI data. This includes all people, technology, facilities, and external service providers. For levels 2 and 3, this also includes specialized assets, security protection assets, and contractor risk managed assets.
Document in-scope assets. Once you’ve identified all assets in scope, you’ll need to document them. Documentation includes creating an asset inventory and providing a network diagram, which will be a part of your official assessment.
Pro tip: At each level, any asset that isn’t in scope is considered out-of-scope, meaning it doesn’t need to be documented during an assessment. For more information on what assets are considered in and out of scope, the DoD has scoping guidelines for each level.
Perform a gap assessment
Once you’ve established your CUI and FCI boundaries and your organization’s current status, you’ll want to conduct a gap assessment, also known as a CMMC gap analysis, to identify areas where your organization is falling short. A good gap assessment helps reduce the stress of prepping for CMMC certification since it’ll show you any areas or processes you need to focus on to pass level assessments and get certified. To perform a gap assessment, you’ll want to:
Identify and document existing controls. Map your current security controls to the objectives outlined in the CMMC framework. This includes documenting asset treatment in a system security plan (SSP).
Identify and document controls not yet satisfied. Identify and review controls that you haven’t yet satisfied. You’ll want to pay close attention to this step as these controls need to be addressed and satisfied to pass certification during an official assessment.
Pro tip: As you complete your gap assessment, you’ll likely need to collaborate with stakeholders across the business to ensure you have up-to-date information. Improper documentation or oversight of required controls could result in your organization not meeting CMMC certification requirements.
Create and execute a plan of action and milestones
As you work through the steps of planning and preparing for CMMC certification, you’ll also need a Plan of Action and Milestones (POA&M).
Create a POA&M. A POA&M allows companies to create a roadmap for improvement with details on what to prioritize, steps for action, who’s responsible for them, resources needed, and deadlines. Any company seeking CMMC certification can complete a POA&M after their gap assessment.
Execute your POA&M. The actions and steps outlined in your POA&M should make the process easier. But, take it step by step. Attempting to remediate every action at once makes it hard to track progress. It could also result in accidentally overlooking important steps, security gaps, or unresolved issues, which can impact your official assessment.
Regularly monitor progress and gather evidence. As you begin implementing new controls, document and monitor progress. This includes validating control design and regularly reviewing your progress against milestones. You’ll also want to gather evidence surrounding them. Evidence should include steps you’ve taken to implement controls and any results from it. If controls result in new policies and procedures, document those as well.
Pro tip: Along with completing a POA&M, you should document your Supplier Performance Risk System (SPRS) score. An SPRS score ranges from -230 to +110 and helps the DoD understand how well a contractor is protecting sensitive data and government information. Determining your SPRS score can ensure you focus on the right areas when working towards CMMC certification.
Conduct assessment
If you’ve completed steps one through six, conducting the assessment should go smoothly. Ideally, you’ve addressed all security gaps and areas of improvement in your POA&M, so there shouldn’t be any surprises during the official assessment. Like most of the CMMC certification process, the type of assessment you conduct will depend on your level.
Level 1
Conduct a self-assessment against level 1 security requirements. Level 1 only requires a self-assessment.
Gather and prepare evidence. A self-assessment requires the submission of documents and evidence, such as policy and process documents, training materials, and planning documents. It also requires interviews with employees and testing to ensure processes are followed.
Ensure all level 1 security requirements are met or marked as “not applicable.” To achieve level 1, all security requirements must be met or not applicable, with results entered into the SPRS.
Level 2
Determine which assessment is required. Level 2 has two types of assessments, a self-assessment or a certification assessment. Self-assessments for level 2 are the same as level 1. For a certification assessment, a C3PAO must complete it.
Gather and prepare evidence. The documents, interviews, and testing laid out in level 1 are required for level 2 certification.
Determine if you’re eligible for a conditional or final level 2. A level 2 assessment can result in a conditional or final level 2. A conditional level 2 will require a POA&M. To achieve level 2, all security requirements must be met or not applicable.
Update your POA&M for final certification if you receive a conditional level 2. To achieve a final level 2, you must complete or close out your POA&M within 180 days.
Level 3
Achieve final level 2 certification with a C3PAO. Level 3 requires two assessments. Both must be completed to achieve level 3 certification. The first assessment is achieving final level 2 with a C3PAO.
Complete an assessment with the Defense Contract Management Agency (DCMA) DIBCAC. This assessment is based on level 3 requirements. The DCMA DIBCAC assessment can result in a conditional or final certification.
Update your POA&M for final certification if you receive a conditional level 3. To achieve final level 3, you must complete or close out your POA&M in 180 days.
Pro tip: Keep in mind that it’s common practice to switch your auditor every few years to avoid bias. But once you’ve found a firm and auditor you like, you can always ask them for recommendations and referrals to find your next auditor.
Maintain certification
After putting in the work to officially become CMMC certified, you’ll need to maintain your certification. Due to the quickly evolving nature of cybersecurity, the DoD requires CMMC-certified organizations to review their controls and affirm compliance annually. Depending on your level, assessments take place annually or every three years.
Level 1
Complete a self-assessment annually. Similar to initial certification, you must complete the self-assessment and enter it into the SPRS every year.
Complete an annual affirmation. The annual affirmation verifies compliance with the 15 basic safeguarding requirements in FAR clause 52.204-21, Basic Safeguarding of Covered Contractor Information Systems.
Level 2
Complete an annual affirmation. For both self and C3PAO certifications, an annual affirmation verifying compliance with the 110 security requirements in NIST SP 800-171 Revision 2, Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations needs to be completed and entered into the SPRS.
Complete a self- or C3PAO assessment every three years. Results of a self assessment must be entered into the SPRS. C3PAO results must be entered into the CMMC Enterprise Mission Assurance Support Service (eMASS).
Level 3
Complete an affirmation annually. An annual affirmation must be completed to verify compliance with the 24 identified requirements from NIST SP 800-172 and entered into the SPRS.
Complete a DIBCAC assessment every three years. Results of a DIBCAC assessment must be entered into CMMC eMASS.
How Vanta makes CMMC certification easier
While CMMC certification can feel overwhelming, having tools to help you prepare for and maintain certification is key.
Vanta makes it easier to meet CMMC requirements across all three levels. Through a centralized platform, Vanta can guide you through the step-by-step process of obtaining and monitoring your CMMC implementation.
Additionally, Vanta’s extended partner network offers hands-on support to ensure you can successfully implement CMMC and conduct assessments to renew contracts and win new business.
A note from Vanta: Vanta is not a law firm, and this article does not constitute or contain legal advice or create an attorney-client relationship. When determining your obligations and compliance with respect to relevant laws and regulations, you should consult a licensed attorney.
Starting your healthcare compliance program
Starting a healthcare compliance program may seem complex, particularly if you’re new to security and compliance. But with the right approach, it can become a clear and manageable process. Investing in building a strong foundation now will set your organization up for future scale and success.
Evaluate your business needs: Start by assessing your organization’s compliance drivers including the following questions:
- Do you collect or process PHI? If yes, HIPAA compliance is mandatory.
- Have clients or prospects ever asked you about compliance with HIPAA or other industry security standards?
- Do your competitors maintain HIPAA compliance or other security standards such as SOC 2, ISO 27001, or HITRUST?
Confirm your PHI scope and data flows: Map out how PHI is collected, processed, transmitted, and stored. You’ll want to minimize PHI exposure across systems and vendors and implement the principle of least privilege and minimum necessary use, in alignment with both HIPAA and broader information security best practices to help reduce risk.
Engage legal counsel and define key roles: As noted above, HIPAA compliance is a legal obligation if your organization handles PHI in any way. You’ll want to review and define your role as a Covered Entity or Business Associate and involve legal counsel early in the process to help guide your regulatory compliance scope and strategy.
Get HIPAA-ready: To prepare for HIPAA compliance, start by implementing baseline technical and administrative safeguards, such as enabling automatic session timeouts and screen locks, encryption at rest and in transit, multi-factor authentication (MFA) enforcement, and least privilege access configurations. Next, establish policies covering various domains such as access control, incident response, breach notification, mobile device management, as well as patient privacy, rights, and related disclosures. From a third-party perspective, ensure you sign Business Associate Agreements (BAAs) with all third parties that handle PHI, and conduct vendor risk assessments to validate their HIPAA compliance posture.
Layer additional frameworks for audit assurance: To strengthen your healthcare compliance program and meet growing customer expectations, consider additional frameworks such as SOC 2 or ISO 27001/27017. These standards provide a more structured and auditable foundation for your compliance practices, and when paired with HIPAA, they enhance your security and privacy posture while also signaling to customers and prospects that you’re prepared to meet their expectations for trust.
Accelerate compliance with the right technology: Instead of relying on manual processes and spreadsheets, choose a platform that streamlines and automates your path to audit readiness—especially if you're working with a lean team. To accelerate sales conversations, build an external-facing trust center to proactively showcase your security posture and healthcare compliance to prospects. You can enhance your trust center by automating security questionnaires with AI-powered responses.
Pro tip: Vanta simplifies your healthcare compliance journey by outlining exactly what’s needed to get audit-ready. Vanta identifies gaps, shows you how to fix them, and automates the process.
Scaling your healthcare program
As your business grows, your compliance program needs to scale with it. Whether you're expanding your team, adding new systems, or selling to larger customers, complexity increases—and so does the need for a more mature and efficient approach to security and compliance. This phase is about operationalizing your program with the right frameworks, tools, and processes to stay ahead of risk while maintaining velocity.
Identify efficiency gaps: Growth introduces new challenges: more people, more tools, and more moving parts. As your business scales, your current compliance processes may not be able to keep up with the additional complexity and operational overhead. Assess your maturity needs by asking the following questions:
- Is your company expanding rapidly or pursuing enterprise clients?
- Are you adding more tools or systems to your environment?
- Is it becoming harder to track compliance status across teams or frameworks?
If you answered yes to any of these questions, then it's time to shift from a foundational program to a scalable and more integrated model.
Mature your program with more prescriptive frameworks: While HIPAA is a necessary baseline, it’s not designed to provide the depth of guidance needed for large-scale or highly regulated operations. As expectations increase, consider layering in additional frameworks that provide further structure, auditability, and credibility.
- HITRUST: Offers tiered, prescriptive certification paths (e1, i1, r2) tailored to healthcare use cases and often required by enterprise customers, such as large health providers.
- NIST CSF: Helps align with cybersecurity risk management best practices, especially if you plan to work in the public sector.
- NIST AI RMF or ISO 42001: If you're incorporating AI, these frameworks support responsible AI governance and risk management.
Centralize and automate compliance workflows: As complexity grows, fragmented workflows and manual tracking break down. Implementing a trust management platform can help you reduce operational overhead and improve visibility by:
- Enabling cross-mapping of controls, so you only have to test once across multiple frameworks, such as between HIPAA, SOC 2, HITRUST, ISO 27001, etc.
- Running automated tests to continuously monitor your controls for failure risks and streamline year-round audit readiness.
- Sending alerts when gaps are identified, and providing clear remediation steps.
Strengthen vendor risk management: Your risk surface grows with every third-party vendor you add. Taking a proactive approach to vendor management not only protects your sensitive data, such as PHI, but also signals maturity to your customers and partners. This includes:
- Building a centralized inventory of all vendors that handle PHI or your sensitive and critical systems.
- Tracking BAAs, SOC 2 reports, and other security and privacy documentation
- Automating vendor risk reviews and renewal cycles to ensure continuous oversight.
Stay ahead of emerging regulation: The healthcare regulatory environment continues to evolve, especially with the rise of AI and ongoing threats to PHI. To stay compliant over time, keep an eye on:
- Updates to regulations, such as HIPAA. Examples include the upcoming Security Rule update.
- New laws such as Healthcare Cybersecurity Act, which may introduce new federal expectations for providers and vendors.
Additionally, build time into your roadmap for regular gap assessments and policy reviews. Staying proactive helps you reduce risk, avoid fire drills, and respond to change with confidence.
Build trust and drive growth with Vanta
Vanta automates HIPAA, HITRUST, SOC 2, and 35+ other frameworks to help you simplify compliance, strengthen security, and boost efficiency—all in one place. Reduce manual work and monitor compliance continuously, reducing the hassle of screenshots and spreadsheets. And as your business grows, Vanta scales with you, helping you save time on evidence collection with 375+ integrations and automatic cross-mapping between frameworks.
Learn more about Vanta for Healthcare.
A note from Vanta: Vanta is not a law firm, and this article does not constitute or contain legal advice or create an attorney-client relationship. When determining your obligations and compliance with respect to relevant laws and regulations, you should consult a licensed attorney.
Understand your risk level
The first step to becoming AI Act compliant is to understand your risk level. The AI Act specifies four categories to determine this:
Unacceptable: This class of AI is considered a clear threat to those who use it, with harmful features aimed at manipulation and exploitation. It is prohibited as a result.
High: High-risk AI poses serious safety and health risks, and potentially interferes with people’s fundamental rights. However, these cases can reach the market if they meet strict security obligations.
Limited: This category covers AI with specific transparency requirements, e.g. chatbots that must inform users that they are interacting with AI.
Minimal (no risk): This AI poses minimal or no risk to people with the majority of AI use cases across Europe falling into this category.
Understanding your risk level isn’t just about your organisation though – it’s about those you work with. You should therefore extend your AI risk categorisation to the third-party vendors you work with.
Understand the AI risk level of your third-party vendors and the AI they’re using.
Understand the AI risk level AI of your AI-driven vendors, such as LLM providers
Meet regulation requirements and establish AI risk management
The next step is to work on the AI Act regulation requirements as per your risk level to ensure you are compliant. You must ensure this covers best practices around:
- User research
- System architecture related to your AI system
- Data collection and model training to insure integrity and quality of your AI systems are maintained
- Documentation to be able to explain your AI risk management system
- Feedback mechanisms
Comply with the NIST AI RMF: Regardless of your risk level, you should establish and maintain an AI risk management system–one that includes mitigation strategies. An effective method of doing this is to follow the NIST AI Risk Management Framework. As part of this, you should leverage technical measures for risk mitigation and human-performed activities such as risk management software, automation and even AI itself. But you should also establish human oversight mechanisms for risk management to ensure you are bringing human oversight and accountability.
Obtain the right technical documentation
It is important to obtain the right documentation to support compliance assessment. A good place to start is with an Information Security Management System (ISMS). This establishes a systematic approach to managing your organization’s information security, and a structured approach to integrating information security into your business processes.
Helping to manage and minimise risks to acceptable levels will increase your organization’s resiliency against evolving security threats and ensures the confidentiality, integrity, and availability of organizational and customer information. The scope of an organization’s ISMS can be as small or as large as is necessary. The ISO 27001 standard defines which documents must exist at a minimum.
Plan your ISMS: Put a team and a roadmap together to implement ISMS policies and controls, and continuously assess risk.
Meet the ISO 27001 standard: ISO 27001 is a go-to standard that aligns with global and EU-specific data protection regulations like the GDPR. You can find our ISO 27001 Compliance Checklist here.
To become AI Act compliant, you should establish an Artificial Intelligence Management System (AIMS). ISO 42001 is a great place to start as it is the international standard for establishing, implementing and maintaining an effective AIMS:
Plan your AIMS: Assign a project leader and put a team and roadmap together to implement your AIMS. Our ISO 42001 checklist is a great place to kick this off in the right way.
Earn ISO 42001 certification: ISO 42001 certification demonstrates to customers, partners and regulators that you’re using AI responsibly, ethically and transparently.
To truly demonstrate trust, companies should go beyond the standard. For fintechs, and other financial institutions, this might look like compliance with the Digital Operational Resilience Act (DORA) framework.
Comply with the DORA framework: Not strictly part of the AI Act, the DORA is a relatively new EU framework for ensuring enhanced cybersecurity and operational resilience of financial entities operating in the Union.
Pro tip: You can find out more about DORA and how Vanta can help fintechs scale trust in our free guide–Fortifying Fintech: Security must-haves for Europe’s trailblazers.
Establish data governance
Data governance is essential to maintaining trust and companies must ensure the confidentiality, availability and integrity of the information they handle.
The data used by AI is not just about quality, however–it is about the transparency surrounding how you use it. More and more organisations are training AI models on a mix of customer and synthetic data. What’s more, without a formal data processing agreement (DPA) that prohibits vendors from using customer data to train their AI models, companies risk threats coming from third-parties too.
Ensure you have a formal DPA with your third-party vendors.
Ensure the quality of your data for training, validation, and testing of AI systems.
Ensure your data is accurate, representative and complete.
Ensure customers are given an opt-out option for training AI with their customer data.
Build with trust and transparency
In the AI era, trust and transparency are essential. Customers must have easy access to appropriate information about your company and products, e.g. characteristics, capabilities, limitations, potential risks.
This can be an all-consuming process for security teams, which is why we launched Trust Center – a hassle-free way for companies to demonstrate trust in real-time. Because earning security credentials is only half of the job–to demonstrate trust, you have to communicate them too.
Set up a process to collect evidence to demonstrate compliance: Demonstrating compliance can come with a lot of chaos. But Vanta can help you to automatically gather the evidence you need – taking the strain off your security team.
Communicate security credentials: Use Vanta’s Trust Center to communicate your security credentials to customers, demonstrate trust and turn good security into good business.
Embrace continuous compliance
Forward-thinking organisations won’t stop at the AI Act. They’ll go beyond point-in-time checks towards a holistic and continuous approach to monitoring. This is the practice of ensuring that you’re properly meeting compliance standards you’ve committed to on an ongoing basis – not just at the time of an audit. This approach is integral to establishing appropriate levels of cybersecurity, accuracy and robustness.
Embrace continuous compliance: The path to continuously monitoring your systems looks like checking for compliance gaps on a daily basis – and relying on automation to cut the amount of manual work this involves.
Continuous compliance will ensure you are in a good position to monitor for updates from the European Commission and that you remain agile to the broader risk landscape. But it will also bring reputational benefits and a welcome boost to your bottom line.
Streamline your EU AI Act compliance with Vanta
Vanta is the fastest way to become AI Act compliant, strengthen your cybersecurity posture, and build trust. Vanta’s trust management platform provides organisations with the capabilities and guidance required to efficiently and effectively achieve AI Act compliance. It provides a centralised view of your compliance and security posture by continuously monitoring the critical tools and services your business runs on. Get in touch with our team today.
Pre-work for your Cyber Essentials certification
Evaluate your need for Cyber Essentials. You can assess whether you need a Cyber Essentials certification based on the following criteria:
Do you collect or process sensitive or personal data from UK residents?
Have you ever been asked about Cyber Essentials by clients or prospects?
Do your competitors have Cyber Essentials certification?
Are you working with companies that provide public services in the UK?
Choose the right Cyber Essentials certification. Although both versions of the Cyber Essentials frameworks have the same requirements, Cyber Essentials Plus involves a third-party audit and technical testing. As a result, Cyber Essentials Plus provides an extra layer of security validation beyond the self-assessment in the standard Cyber Essentials certification.
Do you need Cyber Essentials or Cyber Essentials Plus?
Here are some helpful considerations for deciding whether to pursue the Cyber Essentials certification or Cyber Essentials Plus:
Determine your budget. Cyber Essentials Plus is more expensive than Cyber Essentials because of the external audit and higher security assurance. Pricing for Cyber Essentials ranges from £320 to £600 (plus VAT). Cyber Essentials Plus does not have a fixed pricing structure, but estimates start at £1,499 (plus VAT) and increase based on your organisation’s size and complexity. Learn more about Cyber Essentials costs.
Assess your time and team resources. Cyber Essentials Plus requires more time and bandwidth and takes longer to complete, especially for smaller companies (or security teams) with limited internal resources.
Understand your stakeholders’ concerns. The Cyber Essentials Plus third-party audit requirement enables you to demonstrate your commitment to enterprise-wide data security and assure stakeholders who may have security concerns.
Define customer requirements. Cyber Essentials Plus is required to win UK government contracts. It may also be required to conduct business with certain companies in the UK, such as those looking to prevent potential supply chain-related cyber threats from impacting their operations.
Evaluate your infrastructure size and complexity. Larger, more complex entities whose interconnected assets and operations are at high risk of being disrupted by cyber threats may benefit from Cyber Essentials Plus. Its rigour ensures reliable safeguards protect this infrastructure.
Estimate the volume and sensitivity of stored data. Companies that handle vast amounts of sensitive data (such as PHI in healthcare) may gain higher assurance with Cyber Essentials Plus.
Prepare for your Cyber Essentials certification
First, identify your Cyber Essentials requirements.
Obtaining a Cyber Essentials certification requires you to implement controls across five categories:
Firewalls: All firewalls deployed to system boundaries, endpoints, servers, cloud services, and other critical infrastructure entry points should have the correct security configurations, access controls, and security rules.
Secure configurations: All configurations applied to endpoints and networked services should reduce exploitable vulnerabilities while enabling the completion of business-critical services.
User access controls: Access to all user accounts should require authorisation, and only the people who need access to specific endpoints, services, or applications to complete business tasks should have access. Consider using time-bound or just-in-time access and implementing the principle of least privilege (PoLP) to tighten user access controls.
Malware protection: Administrators should establish the appropriate security mechanisms to prevent malware intrusion via known and unknown sources. They should also educate employees and third parties on the risks of malware and ransomware and how to avoid social engineering scams.
Security updates: All devices and software at risk for security flaws should be updated regularly to ensure their configurations are secure and in alignment with recommended industry/manufacturer security standards.
Gap analysis and remediation
Conduct a gap analysis. Evaluate IT infrastructure for gaps in the above control categories.
Document gaps and develop a remediation plan. Documenting the gaps identified and proposing actionable steps to rectify them is critical.
Address gaps that could lead to security vulnerabilities. Following a gap analysis, you may need to remediate sources of exploitable vulnerabilities.
Examples of remediation steps include:
Changing default administrative passwords into stronger, unique ones
Deactivating unnecessary user accounts that are not currently in use
Scheduling automatic system and network security updates
Implementing multi-factor authentication for all user accounts
Installing anti-malware software on all devices
Test all applicable controls. It’s critical to monitor devices and networks to verify the effectiveness of implemented controls in preparation for assessment. Test your controls and make sure they are functioning properly.
Document findings from system monitoring. It’s also helpful to record all the information from monitoring in an organised, shareable report format to keep track of it. Doing so manually is a challenge for any organisation, which is where automation solutions, like Vanta, help reduce these burdens and enable organisations to scale their security monitoring capabilities as they grow.
Complete the self-assessment (for Cyber Essentials)
After you’ve identified the Cyber Essentials requirements that apply to your organisation and remediated any security gaps, the next step towards becoming Cyber Essentials certified is to complete the self-assessment, which is required even when you’re aiming for the Cyber Essentials Plus certification. Here are the steps our team of compliance experts recommend taking:
Prepare for the Cyber Essentials self-assessment. Train all parties involved in the certification process so they are on the same page regarding Cyber Essentials documentation. Building and maintaining a security awareness culture is crucial for your organisation to fully comply with Cyber Essential security guidelines during its day-to-day operations beyond preparing for the Cyber Essentials self-assessment (or audit, if you choose to pursue Cyber Essentials Plus).
Conduct the self-assessment questionnaire. (SAQ). When ready, you can complete an online SAQ and have a senior team member validate it to get the Cyber Essentials certificate. It’s essential to be accurate and truthful when answering questions to ensure alignment with the necessary standards for obtaining the certificate.
Use online readiness tools to prepare for the test. Tools like the IASME Cyber Essentials Readiness Tool provide free questions to help you assess the posture of your company’s controls and their impact on your business operations. These questions are designed to inform you about your current readiness so you can develop a tailored action plan for the Cyber Essentials audit.
Decide whether you need the Cyber Essentials Plus audit. You can choose to obtain the Cyber Essentials Plus certification immediately after the Cyber Essentials self-assessment or in the following months. While you must complete just the self-assessment to obtain the Cyber Essentials certification, you’ll also need to complete and pass an external audit to receive the Cyber Essentials Plus certification.
Complete the external audit for Cyber Essentials Plus
Prepare for the Cyber Essentials Plus audit. If you want to obtain a Cyber Essentials Plus certification, you should ensure your SAQ was certified within three months of applying for the Cyber Essentials Plus.
Identify an independent assessor: Work with a highly-trained assessor to verify that all currently implemented controls align with the Cyber Essentials Plus requirements.
Review audit findings and implement remedial actions (if any): Address any gaps identified during the independent assessment within a set period.
Obtain Cyber Essentials Plus certification: A successful Cyber Essentials Plus certification provides a certificate valid for 12 months following the assessment pass date. Then, you can become designated as a CE-certified company, opening new business opportunities in the private sector or with the UK government.
Maintain ongoing Cyber Essentials or Cyber Essentials Plus certification
Monitor your IT infrastructure regularly. Organisations need continuous internal assessments to verify adherence to the Cyber Essentials security guidelines. As systems and networks age, they are exposed to more vulnerabilities. So, you need to review your existing security configurations and ensure they still match the rigorous standards of the Cyber Essentials or Cyber Essentials Plus program.
Renew your Cyber Essentials certification.The Cyber Essentials and Cyber Essentials Plus certifications expire after 12 months and must be renewed yearly. Renewing these certifications helps you maintain your designation as a Cyber Essentials-certified company and provides assurance to current and future stakeholders.
Implement zero-trust principles. As the cyber risk environment becomes more complex, consider implementing zero trust across systems and networks to keep your data safe. New technologies are constantly emerging, meaning cybercriminals are also looking for the easiest gaps to exploit to access sensitive data for malicious gain.
Streamline Cyber Essentials certification with Vanta
A strong security posture will enable organisations to build customer trust and expand business to or within the UK. However, it’s cumbersome to manually keep track of all the processes necessary to obtain Cyber Essentials or Cyber Essentials Plus certification.
Fortunately, Vanta automates up to 70% of the UK Cyber Essentials process (including evidence collection), dramatically simplifying the compliance process. This enables teams to focus on strengthening their security programs without redundancy.
Plus, with Vanta, you don’t need to duplicate your compliance efforts across multiple frameworks. UK Cyber Essentials has significant overlap with frameworks like ISO 27001. If you’re already compliant with ISO 27001, you don’t need to reinvent the wheel; Vanta automatically cross-references other frameworks and surfaces any overlapping controls that you already have in place.
Vanta’s trust management expertise can help startups and early-stage companies in the UK build and optimise their security programs to obtain the Cyber Essentials certification. Thousands of global customers rely on Vanta’s real-time, transparent trust management platform to demonstrate their focus on security and privacy to stakeholders.
Learn more about how Vanta automates Cyber Essentials compliance.
Prework
Determine if CPS 234 is right for your organisation. If your organisation operates in Australia and is in an APRA-regulated industry or works with APRA-regulated entities, you’ll need to get CPS 234 compliant. If you aren’t required to be CPS 234 compliant, consider whether it’s beneficial for your business to align with the standard based on your customers and industry.
Take the time to understand the requirements and regulations. CPS 234 is a comprehensive compliance framework. Organisations need to follow and meet stringent information security practices to comply. While this checklist will take you through everything you need to know, understanding what CPS 234 means before you start can help you navigate the process.
Address gaps that could lead to security vulnerabilities. Compliance with CPS 234 includes involving key stakeholders and educating them on their part in the process. In many cases, each role is responsible for the steps in this checklist, including identifying assets and controls, implementing additional controls, and maintaining compliance with the framework. Positions that should be involved in the process are:
Board of Directors: Holds ultimate responsibility for the entity's information security. The board has to ensure the company maintains strict information security measures.
Senior Management: Oversees the implementation and maintenance of information security measures.
Information Security Personnel: Individuals tasked with the operational aspects of information security, including monitoring, incident response, and compliance.
Identify assets and assess controls
Identify and inventory all assets. As you start to implement CPS 234, you’ll need to identify and inventory all of your information assets. Along with your organisation’s assets, you’ll also need to identify and inventory the assets of any third-party vendors. This includes, but is not limited to:
Customer data
Financial records
IT equipment, like computers, servers, and network devices
Cloud systems
Data hosted by cloud providers
Information hosted by third-party vendors
Classify all assets. Once assets are identified and inventoried, they must be classified based on their importance, including their criticality and sensitivity. This includes how likely a security incident involving this asset could impact the business or customer. When reviewing and classifying assets, confirm whether noncritical or nonsensitive assets could impact your critical and sensitive assets. If so, they should be included.
Assess controls. Identifying and assessing your security controls means making sure they can effectively protect your sensitive and critical information assets. In this step, you’ll want to ask several questions to make sure you have the right controls, like:
Are there any current or potential threats that could impact your systems or information security assets?
Do the most critical and sensitive assets have more robust controls than less critical and sensitive assets?
What lifecycle stage is the information asset in? Is it new, used daily, or no longer in use?
How would a security incident or cyberattack impact your assets? Would any be compromised?
Do third-party vendors or other companies you work with secure your data with robust security controls?
Pro tip: Consider performing a mapping exercise to align CPS 234 controls with other standards, like ISO 27001 and SOC 2, if your organisation maintains multiple frameworks.
Implement controls. If you identify a gap or weakness in security controls, you’ll want to implement more robust standards in this step. After documenting, assessing, and prioritizing risks associated with the weakness, you’ll create a plan to fix it. Once the fix and security controls are implemented, you’ll complete testing to verify the fix and document every step you took for any future audits or reviews.
Pro tip: Consider performing a mapping exercise to align CPS 234 controls with other standards, like ISO 27001 and SOC 2, if your organisation maintains multiple frameworks.
Manage third-party risks and incident response
Properly manage all third-party risks. A key part of information security is that third-party risks are consistently managed and maintained. Organisations should confirm that third parties comply with information security standards when processing your data and accessing assets. Third parties should also have security control measures in place to mitigate risk related to security compliance.
Have a strong incident response plan. Your organisation should have a comprehensive incident response plan. The plan should cover how your organisation detects and responds to information security incidents. The plan should also include key stakeholders' roles and responsibilities during an incident. Incident response plans must be reviewed annually to make sure they are effective.
Monitor, test, and maintain compliance
Monitor and audit controls. For a comprehensive view of your organisation’s security posture, controls should be continuously monitored for effectiveness through internal audits, including controls managed by third parties. Monitoring and auditing controls can prevent unknown vulnerabilities or gaps that could impact assets.
Implement a systematic testing program. To comply with CPS 234, organisations need to implement a systematic testing program to assess the security of its controls. The frequency and type of testing should align with emerging and existing vulnerabilities and threats, the criticality and sensitivity of information assets, and the potential consequences of an information security incident.
Report to the Board. The Board must be kept informed of material information security matters. Establish a reporting mechanism to ensure the Board is regularly informed of the organisation’s information security posture, incidents, and improvements.
Continue to follow APRA regulations. If there is a security incident, organisations must notify APRA as soon as possible, but no later than 72 hours after becoming aware of a material security incident, to remain compliant. Additionally, they must inform APRA within 10 business days if they identify a material information security control weakness that cannot be remedied promptly.
Pro tip: It’s essential that APRA-regulated businesses maintain compliance with CPS 234. Noncompliance can result in hefty fines and operational and business restrictions, including direct legal consequences for senior executives.
How Vanta can help with CPS 234 implementation
Whether you’re becoming CPS 234 compliant or looking for an easier way to maintain it, Vanta can help. Vanta automates the prep work for CPS 234 compliance by centralizing requirements and guidance in one tool. Vanta also provides continuous monitoring, providing an additional layer of security to build customer trust.
Vanta can make your journey to CPS 234 compliance easier, helping your team scale faster while maintaining safety and security.
Talk to us today.
A note from Vanta: Vanta is not a law firm, and this article does not constitute or contain legal advice or create an attorney-client relationship. When determining your obligations and compliance with respect to relevant laws and regulations, you should consult a licensed attorney.
Pre-work for your HITRUST certification
Align your goals: Ensure that pursuing a HITRUST certification aligns with your business goals and programs
Find internal stakeholders: Identify key stakeholders within your organization, such as champions who can drive internal buy-in, and a project owner to drive the certification process
Educate leadership: Educate your team, executives, and the board on the HITRUST process, implied changes, and the added value to your organization of attaining certification
Work for your HITRUST certification
Understand the HITRUST CSF: Familiarize yourself with the control requirements of the HITRUST CSF
Identify compliance needs: Determine your organization's specific compliance requirements
Select appropriate HITRUST assessment type: Choose between e1, i1, or r2 assessment, according to needs of your business and your risk profile
Use Vanta to streamline the assessment: Use Vanta to identify and remediate gaps in your compliance program
Find an external assessor: Work with Vanta to select a HITRUST Validated Assessor—A-LIGN, Prescient Assurance, or Insight Assurance—to guide you through and to conduct your Readiness assessment
Purchase MyCSF subscription: Work with Vanta to initiate the procurement process for your Validated Assessor, MyCSF subscription, and report credit (if required)
Attend the HITRUST course: Gain insights and guidance through HITRUST’s New Customer Orientation
Define assessment scope: Identify the areas and systems to be included in the assessment and communicate the intended timeline of certification to your chosen Validated Assessor
Perform initial assessment: Work with your external assessor to identify gaps using Vanta
Initiate inheritance plans: Create plans for internal or external inheritance of controls
Make inheritance requests: Submit inheritance requests via the MyCSF platform
Secure QA date: Schedule a date for post-submission HITRUST QA review
Remediation
Resolve gaps: Use Vanta to identify and remediate any evidence gaps identified during the readiness assessment
The Validated Assessment
Provide evidence: Collect and submit necessary evidence to your external assessor
Finalize inheritance: Confirm all inheritance plans
Support External Assessor: Be available for any additional validation requests
Address issues: Resolve any issues noted during the pre-submission QA
Submission and Review
Submit assessment: Submit the relevant evidence to your chosen Validated Assessor to input into MyCSF for HITRUST to review
Support QA process: Be available to assist your external assessor with any QA queries
Certification
Review certification report: Check and approve the draft certification report
Ensuring compliance over time and beyond
Ongoing Monitoring
Remediate gaps: Use Vanta to continue to monitor your state of compliance and continue to close gaps
Plan for the next assessment
Future planning: Prepare for your next HITRUST assessment to maintain compliance, manage risks, and enhance security —
leveraging inheritance where appropriate
Advancing your assessment: Consider expanding your security posture by exploring the different levels within the HITRUSTecosystem — from e1 to i1 and i1 to r2
Leverage the business benefits of HITRUST certification, including
Commercial compliance: Satisfy customer, contractual requirements or preferences for HITRUST certification
Market access: Gain access to new or additional markets that require or prefer HITRUST certification
Market differentiator: Demonstrate the highest level of security posture as a vendor or partner
Risk mitigation: Adopt proven, repeatable, and measurable methods ensure significant risk reduction in certified environments
(only 0.64% of experienced breaches over two years)
Value creation: Improve potential valuation with investors and shareholders
Liability reduction: Protect yourself and your organization by using a prescriptive, complete, and proven framework to plan,
build, execute, and validate your cybersecurity program instead of building your own
Regulatory compliance: Reuse and restate HITRUST validated controls using HIPAA, SOC 2, ISO 27001, GDRP, and others to reduce compliance efforts
Download this checklist for easy reference
Download NowScoping and assessment planning
Determine business requirements
Identify which customers or partners require HITRUST certification
Document specific contractual obligations related to HITRUST
Clarify which assessment level (e1, i1, or r2) is needed to meet requirements
Define certification scope
Identify systems and applications that store, process, or transmit sensitive data
Document data flows within and outside the organization
Determine which business units and facilities are in scope
Map organizational structure and roles involved in maintaining controls
Build your HITRUST roadmap
Create a 24-36 month progression plan (typically e1 → r2)
Set realistic timeline milestones based on organizational readiness
Allocate budget for assessment, tools, and potential remediation
Identify resources needed for each phase of certification
Governance and resource alignment
Establish executive sponsorship
Secure leadership buy-in for the HITRUST certification initiative
Define executive roles in oversight and governance
Establish a reporting structure for compliance progress
Assemble your HITRUST team
Designate a HITRUST program manager
Identify control owners across departments (IT, HR, Legal, etc.)
Consider hiring or contracting specialized HITRUST expertise
Establish regular coordination meetings for the compliance team
Select implementation partners
Evaluate HITRUST-experienced consultants (like Workstreet)
Choose your HITRUST Assessor Organization
Implement a compliance management platform (like Vanta)
Gap assessment and remediation planning
Perform initial gap analysis
Assess current policies against HITRUST policy requirements
Evaluate existing procedures against HITRUST's prescriptive requirements
Identify gaps in documentation and evidence collection
Document technical control deficiencies
Develop remediation strategy
Prioritize gaps based on risk and implementation complexity
Create detailed remediation plans with owners and deadlines
Establish tracking mechanism for remediation progress
Allocate resources for policy development and technical remediation
Address HITRUST's most common challenge areas
Ensure policies and procedures are prescriptive and align with implementation
Create process to maintain evidence of security awareness training
Establish robust vulnerability management program with clear timelines
Implement comprehensive access control and review processes
Develop detailed business continuity and disaster recovery plans
Implementation and evidence collection
Develop and revise documentation
Revise policies to meet HITRUST's prescriptive requirements
Ensure procedures are detailed enough to guide actual implementation
Develop supporting materials (training, forms, templates)
Establish access control and approval processes
Implement technical controls
Address identified technical gaps from assessment
Leverage Vanta to validate technical implementations meet HITRUST requirements
Document configuration settings and technical specifications
Perform testing to ensure controls operate as intended
Establish evidence collection process
Set up automated evidence collection through Vanta
Create calendar for manual evidence collection requirements
Implement evidence storage and organization system
Document evidence collection procedures for control owners
Pre-assessment validation
Conduct internal readiness assessment
Perform mock assessment of all controls
Validate evidence completeness and quality
Test understanding of control owners who may be interviewed
Review scoring potential based on HITRUST's strict scoring criteria
Refine implementation based on findings
Address any identified weaknesses from internal assessment
Strengthen documentation where needed
Collect additional evidence for problematic controls
Conduct follow-up validation on remediated areas
Remediating and testing controls
Run tests on new and existing controls
Prepare for assessor engagement
Organize evidence package for assessor review
Brief control owners on assessment process and expectations
Schedule key stakeholders for availability during assessment
Create communication plan for assessment period
Working with Vanta and Workstreet breaks down barriers to building and operating a successful HITRUST program.
As Vanta's largest services partner, Workstreet brings specialized knowledge to your HITRUST journey:
- Strategic planning: Build a realistic roadmap from e1 to r2 certification over a 24-36 month timeline
- Policy development: Create the prescriptive documentation HITRUST demands without starting from scratch
- Implementation guidance: Navigate the strict scoring requirements that catch many organizations by surprise
- Assessment management: Coordinate with assessors and prepare your team for interviews and evidence reviews
- Remediation support: Address gaps efficiently with proven approaches from our extensive experience
See how Workstreet can take you from zero to compliant on Vanta in under 30 days.
Determine which annual audits and assessments are required for your company
Perform a readiness assessment and evaluate your security against HIPAA requirements
Review the U.S. Dept of Health and Human Services Office for Civil Rights Audit Protocol
Conduct required HIPAA compliance audits and assessments
Perform and document ongoing technical and non-technical evaluations, internally or in partnership with a third-party security and compliance team like Vanta
Document your plans and put them into action
Document every step of building, implementing, and assessing your compliance program
Vanta’s automated compliance reporting can streamline planning and documentation
Appoint a security and compliance point person in your company
Designate an employee as your HIPAA Compliance Officer
Schedule annual HIPAA training for all employees
Distribute HIPAA policies and procedures and ensure staff read and attest to their review
Document employee trainings and other compliance activities
Thoroughly document employee training processes, activities, and attestations
Establish and communicate clear breach report processes
to all employees
Ensure that staff understand what constitutes a HIPAA breach, and how to report a breach
Implement systems to track security incidents, and to document and report all breaches
Institute an annual review process
Annually assess compliance activities against theHIPAA Rules and updates to HIPAA
Continuously assess and manage risk
Build a year-round risk management program and integrate continuous monitoring
Understand the ins and outs of HIPAA compliance— and the costs of noncompliance
Download this checklist for easy reference
Download Now
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