GRC Modernization for SAP-Centric Organizations
A practical guide to architecture, controls, identity, ownership, and ongoing operations for successful governance, risk, and compliance in SAP.
GRC modernization brings your governance model into line with the way your organization operates today. For SAP-centric organizations, that means considering the technology alongside the controls, ownership, identity architecture, and operating processes that determine how risk is managed in practice.
This guide will help you identify where your current model needs to change, understand the architecture choices available, and turn modernization into a practical program of work.
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In this guide
01 — What GRC modernization means in practice
In many SAP-centric organizations, governance capabilities have evolved at different times and for different reasons. SAP GRC may have been introduced to address access risk, enterprise IGA added as the identity environment expanded, and other, separate processes developed for controls, audit, or cloud governance.
Over time, these changes commonly lead to overlapping tools, unclear ownership, duplicated controls, or governance processes that no longer reflect the underlying business. Modernization addresses these accumulated gaps by looking at how the different parts of the GRC environment work together and where they need to change.
For SAP-centric organizations, this usually means looking across five connected areas:
What modernization should achieve
A modern GRC model should be easier to operate, easier to evidence, better connected across systems and teams, and able to adapt as your business changes.
Architecture
Deciding how governance capabilities should be distributed across SAP GRC and SAP IAG, enterprise IGA platforms and privileged-access capabilities. This includes where SAP-native functionality is sufficient and where separate tooling is required.
People and ownership
Making sure risks, controls, access decisions, and remediation activities have clear owners with the authority and information to act.
Controls
Reviewing whether existing controls reflect current business processes, automating them where appropriate, and connecting them more closely to risk and audit.
Identity and access
Coordinating SAP-specific risk and role governance with your wider enterprise identity lifecycle.
Operations
Establishing the processes, review cycles, and governance forums that keep your model current as your business changes.
Key questions to assess your needs
As an existing SAP IdM user, you'll already be familiar with the key functions requiring replacement, including: joiners, movers, leavers (JML); business logic and policies; provisioning processes and workflows; system integrations; attestation, reporting for audit; and SAP-specific integrations.
SAP IdM excels at handling large SAP estates, saving costs through free integration with SAP systems as part of your existing SAP license when only writing to SAP systems, and offering extensive custom scripting and coding to handle complex, organization-specific requirements and highly specialized business logic.
Determining which capabilities are most important to maintain, and which to optimize or evolve, is the first step in selecting a new solution.
Red flags that your GRC model needs attention
The need to modernize often becomes visible through recurring pain points rather than technology alone. These five red flags can show up across ownership, controls, identity, architecture, and day-to-day operations.
Unclear ownership
Risk, control, and access decisions need clear accountability. If responsibilities sit with a small number of specialists, business owners are unsure what they are accountable for, or governance forums review issues without resolving them, the operating model may no longer be working effectively.
Outdated or inefficient controls
Controls can become harder to manage as business processes, systems, and regulations change, particularly in complex environments where gaps between interconnected systems make ownership, execution, and evidence flows harder to manage. Recurring audit findings, duplicated control activity, manual evidence gathering, or controls that no longer reflect the underlying process are all signs that your GRC framework needs to be reviewed.
Fragmented identity and access
Access governance becomes more difficult when SAP, enterprise identity, privileged access, and third-party processes operate separately. Unclear handoffs, repeated approvals, inconsistent risk analysis, or role designs that no longer match job responsibilities suggest the identity model has become disconnected from the wider governance process.
Overlapping technology
GRC environments often grow incrementally, with new tools and capabilities introduced to address individual needs. Over time, SAP GRC or SAP IAG may overlap with enterprise IGA platforms, privileged access management capabilities, or other governance and security tooling. If capabilities are duplicated or underused, or it is unclear which system is responsible for each stage of the governance process, your architecture may need to be rationalized.
Governance that struggles to keep pace
Governance needs to keep working after implementation. If roles and rulesets are rarely reviewed, audit remediation repeatedly becomes a one-off exercise, or new systems and business changes require significant manual effort to bring under control, the operating model is likely too static.
If several of these issues are familiar, the modernization requirement is likely broader than a targeted technology change. Reviewing the wider governance model can help identify where simplification, clearer ownership, better integration, or redesigned controls will have the greatest impact.
02 — Where SAP GRC 2026 fits
For organizations using SAP GRC, GRC 2026 creates a new set of architecture and migration decisions as SAP moves toward a more connected governance platform.
What changes
SAP GRC 2026 brings capabilities including Access Control, Process Control, Risk Management, Audit Management, Business Integrity Screening, UI Masking, and UI Logging onto a unified HANA based platform
For SAP-centric organizations, this changes more than the underlying technology. Modernization planning should therefore evaluate:
HANA and S/4HANA dependencies
HANA and S/4HANA dependencies, including technical prerequisites and the target architecture.
Migration and conversion requirements
Migration and conversion requirements, including what should be migrated, redesigned, or retired.
Deployment model
Whether an embedded or hub-based deployment best fits the SAP landscape and governance model.
Integrations
Which governance capabilities should remain SAP-native, and where SAP IAG, enterprise IGA, privileged access management, or other platforms should fit.
Integration Flows
How integrations, responsibilities, approvals, and evidence should move between SAP GRC and connected governance and identity platforms.
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Control Alignment
Whether existing controls and rulesets still reflect current business processes.
Lifecycle Planning
How maintenance and lifecycle considerations affect the timing and design of modernization.
Digital Improvements
Which capabilities, workflows, and user experiences could be improved through Fiori, automation, analytics, and emerging AI capabilities.
03 — Build your modernization roadmap
A staged approach to modernization helps you prioritize the issues that create the greatest risk or operational friction.
01
Understand
What you do: Establish the baseline needed to make modernization decisions by mapping the current technology, processes, controls, owners, dependencies, pain points, and areas of duplication.
What you produce: A clear view of the issues that need to be addressed and the areas that require deeper analysis.
02
Rationalize
What you do: Remove duplication across platforms, roles and controls, then decide where each governance capability should sit in the target model.
What you produce: An agreed target architecture and ownership model, plus prioritized plans for role and control rationalization.
03
Connect
What you do: Join workflows and information across access, risk, controls, identity, and audit.
What you produce: Defined end-to-end governance processes with clear system and ownership boundaries.
04
Optimize
What you do: Automate high-effort activities, introduce appropriate continuous monitoring, and improve reporting.
What you produce: Reduced manual effort, clearer evidence, faster decisions, and measurable governance performance.
05
Adapt
What you do: Build review and continuous improvement into normal GRC operations.
What you produce: A governance model that can respond to new systems, regulation, business change, and emerging risks without requiring another wholesale redesign.
Need help navigating your IGA future in SAP?
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05 — Set your GRC strategy
Once the architecture is clear, the next step is defining how governance will work around it.
A useful way to structure your GRC strategy is by employing three practical lenses for shaping a modern GRC operating model: People, Protection, and Performance. Or in other words, who owns governance, how risks and controls are managed, and how effectively the model supports the business.
- People
- Protection
- Performance
People
Who owns the decisions?
Modernization changes responsibilities as well as systems. You need clarity over who owns risks, controls, access decisions, remediation, and continuous improvement.
What good looks like
- Risk and control ownership sits with the appropriate business stakeholders.
- Access reviewers receive enough context to make informed decisions.
- Governance forums have clear authority and escalation routes.
- Technical administration is separated from business risk acceptance.
- New responsibilities are supported through change management and training.
- Ownership remains clear after implementation rather than depending on individual specialists.
Questions to ask
- Who owns each major business risk?
- Who is accountable when a control fails?
- Who approves access, and on what information?
- Who can accept an SoD risk?
- Which forum resolves cross-functional governance issues?
- What happens when the business process changes?
Role redesign and governance ownership
Ruralco combined its SAP GRC implementation with role redesign workshops involving process owners and key users, while a newly established governance group oversaw the work and future changes. Access violations fell by 90% in the first year, and clearer roles helped new starters receive the right access first time.
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Protection
How do the controls connect?
Modernization should connect access governance, controls, identity, risk, and audit at process level. The objective is to create a connected governance flow in which risk is identified at the point of decision, the right owner is involved, and evidence follows the process rather than being reconstructed later.
What good looks like
- Access requests pass through the appropriate SAP-specific risk analysis before provisioning.
- SoD conflicts trigger the appropriate approval, remediation, or mitigation process.
- Business owners receive the context needed to make informed risk decisions.
- Access, risk, control, and audit information remains connected throughout the governance process.
- Decisions, mitigations, and evidence remain available for review and audit.
- Changes to users, roles, and responsibilities feed back into ongoing access governance.
- Process controls are linked to the risks and business processes they protect.
- Automated monitoring and structured evidence reduce manual control validation.
Questions to ask
- Where does SAP-specific risk analysis take place?
- How does an access request move from identity lifecycle management through risk analysis, approval, and provisioning?
- Who decides how an identified SoD conflict is resolved or mitigated?
- Can business owners see enough context to make informed risk decisions?
- Where is governance evidence retained?
- What happens when a user's role, responsibilities, or access changes?
- Are process controls clearly linked to the risks and processes they protect?
- Where do system gaps or manual handoffs interrupt the governance process?
Connecting controls and compliance activity
JTI centralized more than 4,500 business process and IT controls using SAP GRC Process Control and introduced automated workflows to support control assessments. This resulted in a more consistent and centralized approach to control management and assessment, ensuring the business can meet all necessary regulatory and commercial requirements while operating across more than 70 countries worldwide.
Performance
How does governance support growth?
Good governance makes controlled business change easier.
When access models are clear and evidence is reliable, decision-makers can move faster with greater confidence. Automation can reduce approval and review effort, while cleaner role models simplify administration and make transformation easier to manage.
KPIs to consider
The measures below are examples of potential KPIs. Select the measures that best reflect your governance objectives, operational priorities, and areas where you need to demonstrate improvement.
- Access request and approval time.
- User onboarding time.
- Review completion rates.
- Number and age of unresolved SoD risks.
- Audit remediation time.
- Manual effort spent gathering control evidence.
- Percentage of controls monitored automatically.
- Recurring audit findings.
- Business participation in governance processes.
Making access governance more efficient
Ørsted migrated more than 6,000 end users from SAP Identity Management (IdM) to SAP GRC for Access Provisioning, redesigning workflows and automating access provisioning, user access reviews, and SoD risk reviews. The new model resulted in reduced provisioning lead times and improved operational efficiency while giving stakeholders greater visibility into access and compliance.
People
Protection
Performance
06 — Deliver modernization
Your GRC strategy becomes tangible through practical modernization workstreams. The right mix of workstreams will depend on the issues you have identified in your current environment.
Refer to the Red Flags featured earlier in the guide for reference on where your model may be under pressure. Then review for the signals below help identify which modernization workstream to prioritize.
Workstream 1
Role and access redesign
Signals
Review roles when:
- Users accumulate unnecessary access over time.
- SoD conflicts are embedded in role design.
- New starters require repeated access changes before they can perform their roles.
- Employees frequently request additional access because their initial roles do not match their responsibilities.
- Managers regularly receive access requests they cannot easily assess or understand.
- Access requests are delayed because the right role or approver is unclear.
- Users retain access after changing roles or responsibilities.
- Access reviews regularly surface unexpected or inappropriate access.
- S/4HANA or organizational change has altered the underlying processes.
Actions
- Analyze actual usage and current job responsibilities.
- Rationalize obsolete and duplicated roles.
- Align roles to clear business functions.
- Review the SoD ruleset against current processes.
- Define ownership for role creation and change.
- Build ongoing role governance into operations.
Outputs
- Roles aligned to current business responsibilities.
- Clear ownership for role design and change.
- A current, risk-aligned SoD ruleset.
- An operating process for ongoing role governance.
Practical rule
When the business process or technical responsibility changes, reassess what that means for access, risk, controls, ownership, and evidence.
Workstream 2
Controls transformation and continuous monitoring
Signals
Review controls when:
- Controls address risks or processes that have changed.
- The same control activity is performed in multiple places.
- Ownership is unclear.
- Evidence collection is heavily manual.
- Control activities or evidence could be monitored or collected automatically.
Actions
- Confirm the risk each control is designed to address.
- Review controls against current business processes.
- Remove duplicated or obsolete control activity.
- Clarify control ownership.
- Identify opportunities for automated monitoring and evidence collection.
- Establish a process for reviewing controls as business processes change.
The aim is a smaller, clearer, risk-aligned control framework rather than simply more automation
Outputs
- A rationalized control framework aligned to current risks and processes.
- Clear control ownership.
- Reduced duplication and manual evidence collection.
- Defined opportunities for continuous monitoring and automation.
Practical rule
When the business process or technical responsibility changes, reassess what that means for access, risk, controls, ownership, and evidence.
Workstream 3
Integrated identity management
Signals
Review identity and access handoffs when:
- Identity and access processes operate across multiple platforms.
- Access requests move between enterprise identity and SAP-specific governance.
- SAP risk analysis is disconnected from the requesting process.
- Rejected or mitigated risks require manual handoffs.
- Role changes do not consistently flow back into enterprise identity governance.
- Privileged or non-human identities are governed differently without clear ownership.
Actions
- Establish where identities are created and maintained.
- Define which platform initiates access requests.
- Establish where SAP risk analysis is performed.
- Define how rejected or mitigated risks are returned to the requesting process.
- Ensure role changes flow back into enterprise identity governance.
- Define how privileged and non-human identities are handled.
Outputs
- Clear ownership and handoffs across identity and SAP governance.
- Connected access request, risk analysis, approval, and provisioning processes.
- Defined governance for privileged and non-human identities.
- Reduced manual handoffs and breaks in the access lifecycle.
Practical rule
When the business process or technical responsibility changes, reassess what that means for access, risk, controls, ownership, and evidence.
Workstream 4
Align governance with SAP transformation
SAP transformation can change the systems, processes, technical responsibilities, and control points that GRC depends on. Governance should therefore be considered across the ERP and cloud transformation, the way SAP is operated and extended, and the connected services around it.
| Change | GRC implication |
|---|---|
S/4HANA transformation |
Reassess processes, roles, authorizations, controls, and SoD rules as the ERP environment changes. |
SAP Cloud / RISE |
Clarify operating responsibilities, integrations, evidence ownership, and governance across SAP-managed and customer-managed services. |
Clean Core and extensibility |
Make sure controls and authorization principles continue to apply across SAP core, extensions, BTP, and connected services. |
SAP landscape and integration changes |
Reassess identity, access, risk, controls, and evidence flows when applications, integrations, or business processes move or change. |
Organizational and business change |
Reassess governance ownership, roles, access, and controls when reorganizations, acquisitions, outsourcing, or new operating models change responsibilities. |
Actions
- Build GRC requirements into SAP transformation planning rather than addressing them after implementation.
- Review roles, controls, integrations, and ownership whenever the SAP architecture or operating model changes.
- Define governance responsibilities and evidence flows across SAP, service providers, and connected platforms.
- Extend authorization and control requirements to new extensions and connected services.
- Include GRC requirements in the design of new SAP cloud services, integrations, and extensions.
Outputs
- Governance aligned to the target SAP architecture and operating model
- Clear ownership and decision rights
- Updated roles, controls, and authorization principles
- Defined evidence and monitoring flows
- Governance requirements incorporated into the target SAP landscape and transformation roadmap
Practical rule
When the business process or technical responsibility changes, reassess what that means for access, risk, controls, ownership, and evidence.
Why is a Good PAM Program So Important?
Customization vs. Simplicity
Evaluate whether your organization needs highly tailored solutions or could benefit from standardizing processes. Customization delivers precision but increases complexity and maintenance costs.
Integration landscape
Complex SAP environments (with 30+ systems) require solutions capable of handling this scale. Verify each solution's capabilities for reading custom SAP tables and available connectors for your applications. Also consider how to balance SAP-specific needs with enterprise-wide identity management requirements.
Business transformation opportunity
Use the IdM migration as a catalyst to break down silos between SAP and enterprise identity management. Consider how process changes could simplify your technical requirements, especially if you're also planning an S/4HANA migration. This decision point presents an opportunity for business process transformation that could simplify technical requirements and reap numerous organization-wide benefits.
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Resource requirements
Assess your team's capabilities against solution requirements to identify gaps in technical implementation skills, business process knowledge, and change management expertise. Consider whether partnerships with implementation experts will be necessary to supplement internal resources.
Common migration pitfalls
Prepare for typical obstacles including undocumented customizations, integration complexity, resource constraints, competing priorities, and dependencies on SAP IdM-specific capabilities. Mitigate risks through a phased migration approach with thorough planning, documentation, and robust testing at each stage.
Use AI as a test of your operating model
As AI assistants and agents become involved in SAP processes, organizations need to assess permissions, approvals, monitoring, accountability, and, where appropriate, the accuracy and completeness of outputs.
This includes determining what identities AI agents use, what permissions they can exercise, who is accountable for their actions, and how those actions are logged and reviewed.
If your existing governance process can absorb those changes and update controls accordingly, the operating model is doing what it should.
Can your governance model absorb Al without needing to be redesigned?
A practical path to GRC modernization
The self-assessment in this guide helps identify where your current GRC model is creating friction, duplication, or gaps. If it highlights areas that need deeper analysis, Turnkey Consulting’s GRC Modernization Assessment provides a structured next step.
The GRC Modernization Assessment establishes a clear baseline across people, process, and technology, identifies gaps and opportunities, and translates the findings into a prioritized, vendor-agnostic modernization roadmap aligned to your SAP strategy and business objectives.
Making the right decisions across all these areas, and then executing a successful program, requires expertise spanning strategic planning, change management, and technical complexity. If you don’t have all those capabilities in-house, then working with an unbiased, expert partner like Turnkey Consulting can be invaluable.
We’ll help you avoid the root causes of PAM failure through comprehensive support from initial assessment through to ongoing managed services. We can provide deep technical expertise, agnostic tool advice, and ensure your program is aligned with your stakeholder needs and business transformation goals.
Ready to put your PAM program on the right track for success? Get in touch with Turnkey’s PAM experts today to discuss your specific needs and objectives.