Beyond Compliance: Why UK Organizations Need More Than a Platform to Meet Provision 29
Rick Lemieux – Co-Founder and Chief Product Officer of the DVMS Institute
Introduction: From Compliance to Assurance
Provision 29 of the United Kingdom’s cyber and digital governance expectations represents a significant evolution in how organizations are expected to manage cybersecurity and resilience.
It is not simply a compliance obligation—it is a performance mandate. Provision 29 aligns closely with the six core functions of the NIST Cybersecurity Framework (CSF) 2.0—Govern, Identify, Protect, Detect, Respond, and Recover—each designed to ensure that organizations operate with governed, risk-informed, and continuously improving resilience postures.
While many organizations believe that implementing a digital platform or compliance tool will suffice to meet these requirements, this belief fundamentally misunderstands the intent of Provision 29. Compliance platforms can document controls, manage risk registers, or automate reporting, but they cannot build a culture of assurance, accountability, and continual improvement.
To truly fulfill Provision 29, UK organizations require an operational architecture—such as the Digital Value Management System (DVMS)—that integrates governance, assurance, and learning into a single, adaptive system.
Governance and Assurance: Leadership Beyond Tools
Provision 29 emphasizes that leadership must set clear risk management strategies, define accountability, and maintain oversight over cyber-risk activities. These expectations demand more than dashboards and compliance checklists; they require systems that make governance actionable and assurance measurable.
A platform may display compliance metrics, but governance is about intent—ensuring that policies and roles are translated into real-world behavior. The DVMS approach, with its “Govern” and “Assure” capabilities, operationalizes this intent by creating a closed feedback loop between policy and execution. Governance sets direction, while assurance verifies that the organization is “doing the right things the right way.”
This dual-loop model transforms oversight into a continuous, data-informed process. Rather than static compliance reports, leadership receives living assurance—evidence that strategy, risk, and operations remain aligned. This dynamic governance capability fulfills the core spirit of Provision 29 by demonstrating transparent accountability and evidence-based leadership rather than periodic conformity.
Strategy and Risk Integration: From Fragmentation to Alignment
Provision 29 calls for the integration of cybersecurity into enterprise risk management, treating it as a business enabler rather than a compliance burden. Traditional compliance platforms often treat cybersecurity as a separate function, managing threats and controls independently of strategic planning. This fragmentation undermines resilience because it disconnects risk from the value creation process.
The DVMS unites strategy and risk management into what it calls “strategy-risk”—a single decision system where business objectives, risk appetite, and constraints coexist. This integration ensures that every investment, process, and initiative aligns with both business value and acceptable risk tolerance.
Through its “Plan” and “Design” capabilities, the DVMS translates governance policies into measurable objectives and embeds them into the organizational architecture—its systems, workflows, and culture. This design-driven approach means security and resilience are built in, not bolted on. It enables organizations to demonstrate that cybersecurity governance is contextually grounded, strategically integrated, and continuously improved—precisely what Provision 29 expects.
Continuous Resilience: Operationalizing Change and Execution
Compliance platforms are static—they record the present state of controls but struggle to manage change dynamically. Provision 29, however, requires organizations to monitor, adapt, and improve their cyber resilience continuously. This expectation shifts the focus from compliance to evidence-based continuous assurance.
The DVMS addresses this through its “Change” and “Execute” capabilities, which together create a governance and execution loop. “Change” reflects an organization’s adaptive capability—the ability to evolve processes, behaviors, and controls in response to new threats or insights. “Execute” ensures that day-to-day operations deliver secure, resilient outcomes across people, processes, and technology.
This cycle of change and execution operationalizes the NIST CSF’s Identify–Protect–Detect–Respond–Recover functions in a coordinated, ongoing manner. Rather than achieving compliance once a year, organizations demonstrate continual improvement through measurable performance outcomes. In essence, DVMS enables UK organizations to replace episodic compliance audits with ongoing evidence of resilience—a direct embodiment of Provision 29’s intent.
Innovation as a Governance Capability
Provision 29 and NIST CSF 2.0 both recognize the necessity of learning and adaptation. In a rapidly evolving threat landscape, no compliance platform can anticipate every new risk. Therefore, organizations must embed innovation—not as a side function but as a core governance mechanism.
The DVMS’s “Innovate” capability provides a structured method for continuous learning and improvement. It identifies four levels of innovation—incremental, sustaining, adaptive, and disruptive—each contributing to growth in maturity. Using the Goal–Question–Metric (GQM) approach, DVMS transforms innovation from an abstract ideal into quantifiable behavior. Metrics track how governance evolves, how assurance processes adapt, and how organizational culture learns.
This capability ensures that learning is not reactive but anticipatory. It empowers organizations to proactively evolve their governance structures, transforming Provision 29’s call for continual improvement into a measurable, cultural norm.
Culture as a Measurable Asset
Perhaps the most overlooked aspect of Provision 29 is culture. The regulation implicitly requires that cybersecurity and governance be underpinned by human and organizational factors, including communication, collaboration, and learning. No technology platform can create these dynamics.
The DVMS addresses this through its 3D Knowledge Model, which makes culture observable and measurable. The model’s three axes—Knowledge Flow (past–present–future learning), Collaboration Flow (cross-functional cooperation), and Alignment Flow (strategic-operational coherence)—visualize how knowledge and decision-making flow through the enterprise.
By transforming cultural elements into measurable components of governance, the DVMS enables leadership to monitor how effectively teams learn from the past, collaborate in the present, and align for the future. This makes cultural assurance as tangible as operational assurance, fulfilling Provision 29’s expectation for accountability and continual learning.
The Create–Protect–Deliver Cycle: A Living System of Assurance
Underlying the DVMS architecture is the Create–Protect–Deliver (CPD) model—a behavioral engine that ensures all activities contribute to value creation and protection simultaneously. This cycle mirrors the concurrent nature of the NIST CSF functions and provides a practical mechanism for implementing Provision 29 outcomes.
In this model:
- Create represents innovation and the generation of digital value.
- Protect embeds assurance and resilience into every activity.
- Deliver ensures strategic outcomes translate into measurable stakeholder value.
Unlike the linear “plan-implement-comply” sequence typical of compliance tools, the DVMS CPD Model operates as a dynamic feedback loop. It ensures that governance, assurance, and learning remain in sync at all times. As a result, organizations demonstrate not just compliance but continual alignment between risk management, performance, and culture—a hallmark of Provision 29 maturity
Why Platforms Fall Short
Compliance platforms serve an essential but limited purpose. They help automate reporting, centralize evidence, and standardize workflows. Yet they cannot achieve the behavioral transformation that Provision 29 requires. Compliance can be automated, but assurance must be lived.
Platforms manage information; systems like DVMS manage relationships—between strategy and risk, policy and execution, leadership and culture. Provision 29 is not about having the right tool but about demonstrating that cybersecurity and resilience are governed, assured, and continually improved through a living system of feedback and accountability.
This is why UK organizations need more than platforms—they need systems that integrate human judgment, organizational learning, and dynamic governance. The DVMS achieves this by embedding assurance into the DNA of operations rather than layering it on top of them.
Conclusion: Assurance by Design
Provision 29 marks the UK government’s shift from compliance to assurance, from control-checking to outcome-measuring. While compliance platforms can help track activities, they cannot ensure that governance intent translates into resilient performance.
The Digital Value Management System bridges that gap. It unifies governance, assurance, and culture into one adaptive overlay system that operationalizes the outcomes of Provision 29 and the NIST CSF 2.0. It makes governance measurable, assurance continuous, and learning a cultural practice.
For UK organizations, the path to compliance with Provision 29 does not lie in acquiring another platform but in adopting an assurance system that evolves with their business. By doing so, they not only fulfill the letter of Provision 29 but also its spirit—to become trusted, resilient, and performance-assured digital enterprises capable of thriving in uncertainty.
About the Author
Rick Lemieux
Co-Founder and Chief Product Officer of the DVMS Institute
Rick has 40+ years of passion and experience creating solutions to give organizations a competitive edge in their service markets. In 2015, Rick was identified as one of the top five IT Entrepreneurs in the State of Rhode Island by the TECH 10 awards for developing innovative training and mentoring solutions for boards, senior executives, and operational stakeholders.
DVMS Cyber Resilience Professional Accredited Certification Training
Designing an Overlay System for Governing Cyber Resilience Through Assured Evidence and Transparent Accountability (GRAA) Across Complex Digital Ecosystems
From Visibility to Viability – The Dual Pillars of Cyber Resilience
Explainer Video – The Dual Pillars of Cyber Resilience
As enterprises accelerated their adoption of complex, cloud-native architectures, they encountered a new order of complexity. Infrastructure dissolved into services, workloads became ephemeral, and security boundaries blurred. In that environment, Wiz emerged as a transformational force in cloud technical security, offering radical visibility and risk prioritization across multi-cloud ecosystems.
At the same time, a broader and more consequential challenge emerged, one that extends well beyond isolated technical misconfigurations or discrete vulnerabilities.
Modern organizations function as dynamic, highly interconnected digital ecosystems shaped by siloed frameworks, technologies, applications, processes, data flows, and human actors, all operating in continuous interaction. Within this complexity, risks and outcomes are not confined to individual components; they arise from the relationships and dependencies between them.
This is the domain in which the Digital Value Management System® (DVMS) operates.
While Wiz redefined how organizations see and secure cloud environments, DVMS is redefining how enterprises govern, assure, and account for cyber resilience as an integrated dimension of digital business performance.
The Digital Value Management System® (DVMS)
Explainer Video – What is a Digital Value Management System (DVMS)
The DVMS is an overlay management system that governs cyber resilience through assured evidence and transparent accountability (GRAA) across complex digital systems.
At its core, the DVMS is a simple but powerful integration of:
- Governance Intent – shared expectations and accountabilities
- Operational Capabilities – how the digital business performs under stress
- Assurance Evidence – proof that outcomes are achieved and accountable
- Cultural Learning – for governance and operational fine-tuning
The DVMS GRAA Engine
Explainer Video – How a DVMS GRAA Engine Works
The overlay GRAA engine is powered by four DVMS models:
Create, Protect, and Deliver (CPD) – The CPD Model™ is a systems-based model within the DVMS that links strategy-risk and governance to execution to create, protect, and deliver digital business value as an integrated, continuously adaptive capability.
Minimum Viable Capabilities (MVC) – The Minimum Viable Capabilities (MVCs) model supports the seven essential, system-level organizational capabilities—Govern, Assure, Plan, Design, Change, Execute, and Innovate—required to reliably create, protect, and deliver digital business value in alignment with strategy-risk intent.
3D Knowledge (3DK) – The 3D Knowledge Model is a systems-thinking framework that maps team knowledge over time (past, present, future), cross-team collaboration, and alignment to strategic intent to ensure that organizational behavior, learning, and execution remain integrated and adaptive in delivering digital business value.
Question Outcome / Question Metric (QO/QM) – The QO/QM approach supports governance as testable intent by defining a clear Question Outcome (QO), the specific value or resilience condition that must be true at a given boundary, and pairing it with one or more Question Metrics (QM) that provide observable, decision-relevant evidence that the system can actually create, protect, and deliver that outcome under complex, living system operating conditions
The models then work together to operationalize the capabilities below that will govern the organization’s cyber resilience through assured evidence and transparent accountability
A Governance Overlay that replaces fragmentation with unity. The DVMS provides organizations with a structured way to connect strategy with day-to-day execution. Leaders gain a consistent mechanism to direct, measure, and validate performance across every system responsible for digital value.
A Behavioral Engine that drives high-trust, high-velocity decision-making. The DVMS embeds decision models and behavioral patterns that help teams think clearly and act confidently, even in uncertain situations. It is engineered to reduce friction, prevent blame-based cultures, and strengthen organizational reliability.
A Learning System that makes culture measurable, adaptable, and scalable. Culture becomes a managed asset—not an abstract concept. The DVMS provides a repeatable way to observe behavior, collect evidence, learn from outcomes, and evolve faster than threats, disruptions, or market shifts.
DVMS Benefits – Organizational and Leadership
Explainer Video – DVMS Organization and Leadership Benefits
Instead of replacing existing operational frameworks and platforms, the DVMS elevates them, connecting and contextualizing their data into actionable intelligence that enables organizations to:
- Maintain Operational Stability Amidst Constant Digital Disruption
- Deliver Digital Value and Trust Across Complex Digital Ecosystems
- Satisfy Critical Regulatory and Certification Requirements
- Leverage Cyber Resilience as a Competitive Advantage
For the CEO, the DVMS provides a clear line of sight between digital operations, business performance, and strategic outcomes—turning governance and resilience into enablers of growth and innovation rather than cost centers.
For the Board of Directors, the DVMS provides ongoing assurance that the organization’s digital assets, operations, and ecosystem are governed, protected, and resilient—supported by evidence-based reporting that directly links operational integrity to enterprise value and stakeholder trust.
For the CIO, CRO, CISO, and Auditors, the DVMS provides a unified approach to organizational digital value management, operational resilience, and regulatory compliance.
DVMS – Accredited Certification Training Programs
Explainer Video – The DVMS Training Pathway to Cyber Resilience
The DVMS Institute’s certification training programs equip leaders, practitioners, and employees with the skills to build a management architecture for governing, assuring, and accounting for resilience in complex digital ecosystems.
Through structured learning, applied certification, and authoritative publications, the Institute teaches a disciplined, outcome-driven approach to managing resilience as an integrated dimension of digital business performance.
DVMS Cyber Resilience Awareness Training
The DVMS Cyber Resilience Awareness non-certification course and its accompanying body of knowledge publication educate all employees on the fundamentals of digital business, its associated risks, the NIST Cybersecurity Framework, and their role within a shared model of governance, resilience, assurance, and accountability for resilience in complex digital ecosystems.
DVMS NISTCSF Cyber Resilience Foundation Certification Training
The DVMS NISTCSF Cyber Resilience Foundation certification training course and its accompanying body of knowledge publications provide ITSM, GRC, Cybersecurity, and Business professionals with a detailed understanding of the NIST Cybersecurity Framework and its role in a shared model of governance, resilience, assurance, and accountability for achieving resilience in complex digital ecosystems.
DVMS Cyber Resilience Practitioner Certification Training
The DVMS Practitioner certification training course and its accompanying body of knowledge publications teach ITSM, GRC, Cybersecurity, and Business practitioners how to build a unified governance, resilience, assurance, and accountability system designed to operationalize resilience in complex digital ecosystems.
Launching A DVMS Program
Explainer Video – Scaling a DVMS Program
The DVMS FastTrack is a phased, iterative approach that helps organizations mature a DVMS program over time, rather than trying to do everything simultaneously. This approach breaks the DVMS journey into manageable phases of success.
It all starts with selecting the first digital service you want to make resilient. That service then becomes the blueprint for operationalizing resilience across the remaining digital services.
DVMS Institute White Papers – The Assurance Mandate Series
Explainer Video – From Compliance Rituals to Evidence-Based Resilience
The whitepapers below present a clear progression from compliance-driven thinking to a modern system of Governance, Resilience, Assurance, and Accountability (GRAA). Together, they define an evidence-based approach to building and governing resilient digital enterprises.
The Assurance Mandate Paper explains why traditional compliance artifacts offer reassurance, not proof, and challenges boards to demand evidence that value can be created, protected, and delivered under stress.
The Assurance in Action Paper shows how DVMS turns intent into execution by translating outcomes into Minimum Viable Capabilities, aligning frameworks through the Create–Protect–Deliver model, and producing measurable assurance evidence of real performance.
The Governing by Assurance Paper extends this model to policy and regulation, positioning DVMS as a learning overlay that links governance intent, operational capability, and auditable evidence—enabling outcome-based governance and proof of resilience through measurable performance data.
Company Brochures and Presentation
Explainer Videos
- DVMS Architecture Video: David Moskowitz explains the DVMS System
- DVMS Case Study Video: Dr. Joseph Baugh Shares His DVMS Story.
- DVMS Overlay Model – What is an Overlay Model
- DVMS MVC ZX Model – Powers the CPD
- DVMS CPD Model – Powers DVMS Operations
- DVMS 3D Knowledge Model – Powers the DVMS Culture
- DVMS FastTrack Model – Enables A Phased DVMS Adoption
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