Glossary · Compliance concepts
What is Compensating Control?
Also known as: Alternative Control, Mitigating Control
A compensating control is an alternative safeguard used when an organization cannot implement a required control, but still needs to meet the intent of that requirement. It must provide a comparable level of protection and be formally documented and justified. Compensating controls are most familiar from PCI DSS, where they follow a strict approval process.
Key takeaways
- A compensating control substitutes for a required control that cannot be implemented.
- It must deliver protection comparable to the original requirement, not weaker.
- PCI DSS formalizes compensating controls with a worksheet and annual review.
- Every compensating control needs documented business or technical justification.
- They are meant to be temporary or exceptional, not a permanent shortcut.
When is a compensating control appropriate?
Compensating controls exist for the real-world cases where a prescribed control is genuinely infeasible due to a legitimate technical or documented business constraint. They are not an excuse to skip a control because it is inconvenient.
The concept is most formalized in PCI DSS, which requires organizations to prove that a constraint exists before an alternative is even considered.
The guiding test is intent: the compensating control must satisfy the objective the original requirement was designed to achieve, and ideally go above and beyond the rigor of the requirement it replaces.
What makes a compensating control valid?
A defensible compensating control generally must do four things, and an assessor will probe each one.
- Meet the intent and rigor of the original requirement.
- Provide a similar level of defense, so risk is not materially increased.
- Go beyond other requirements already in place, rather than reusing an existing control.
- Be commensurate with the additional risk created by not meeting the requirement.
In PCI DSS, this reasoning is captured on a compensating control worksheet that documents the constraint, the alternative control, and the validation, and it is reviewed at least annually.
Compensating controls and residual risk
Because a compensating control is rarely an exact substitute, it usually leaves some residual risk that leadership must understand and accept. This makes compensating controls a close cousin of risk treatment.
Treating a compensating control as a permanent solution is a common mistake. Best practice is to revisit it on a defined cadence, confirm the original constraint still applies, and replace it with the standard control once that becomes feasible.
Frequently asked questions
- Is a compensating control a way to avoid a hard requirement?
- No. It is only valid when a legitimate constraint genuinely prevents the standard control, and it must provide comparable protection. Assessors reject compensating controls used merely for convenience.
- How is a compensating control documented in PCI DSS?
- PCI DSS uses a compensating control worksheet that records the constraint, the alternative control, the validation performed, and ongoing maintenance, and it must be reviewed at least annually.
- Do compensating controls apply outside of PCI DSS?
- Yes. The concept appears across frameworks as an alternative or mitigating control, though PCI DSS defines the most formal process for proposing and approving one.
- How long can a compensating control stay in place?
- It should remain only as long as the underlying constraint exists. Organizations are expected to reassess it periodically and adopt the standard control once it becomes feasible.