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How Compliance Interpretation Ownership (CIO) Works

CIO is a governance model for making regulatory interpretation explicit, bounded, and accountable.

The Problem

Regulatory text is often ambiguous. When organizations apply regulations to their operations, they must make interpretive choices. These choices are typically:

  • Hidden — embedded in code, processes, or institutional knowledge
  • Undocumented — no clear record of what was decided or why
  • Unversioned — changes happen without tracking or accountability

The CIO Model

Compliance Interpretation Ownership addresses these problems through a structured approach to documenting and managing regulatory interpretation.

Interpretation Decision Records

IDRs document specific interpretive choices: what regulatory text they apply to, what assumptions were made, and what boundaries exist.

Explicit Ownership

Each interpretation has a clear owner responsible for the interpretive choices and accountable for maintaining the record.

Versioned History

All changes to interpretations are versioned, creating a clear audit trail of how understanding evolved over time.

Bounded Scope

Each interpretation clearly states what it covers and what it does not, preventing scope creep and ensuring clarity.

What CIO Is Not

CIO is a governance framework for interpretation, not a compliance automation tool. It does not:

  • Automate compliance determinations or regulatory outcomes
  • Assert that any interpretation is legally correct or approved
  • Replace the need for legal counsel or regulatory expertise
  • Guarantee regulatory compliance or approval

View Published Interpretations

Explore the Interpretation Decision Records published by Veria to see CIO in practice.

View Interpretations