As cloud adoption accelerates, SAP environments are operating at a scale and speed that traditional control frameworks were never designed to handle. Static, periodic reviews can no longer keep pace with real-time transactions and increasingly complex system landscapes. Continuous Controls Monitoring (CCM) has therefore shifted from a best practice to a critical capability, enabling organizations to identify risks proactively, maintain compliance, and strengthen governance in an always-on environment.
Research by the Cloud Security Alliance (CSA) shows that CCM streamlines risk and compliance management by reducing audit costs, automating control testing, and monitoring and centralizing evidence. By delivering insights within hours — rather than quarterly or annually, as with traditional auditing or sample-based testing — CCM provides timely visibility that enables organizations to detect and respond to issues before they escalate.
In this blog, we’ll highlight how CCM works for SAP GRC, exploring the value it delivers across real-time risk visibility, audit readiness, and scalable automation. We’ll also look at how valuable it is for S/4HANA users, addressing accelerated transaction speed, integration complexity, and expanded data availability.
What is continuous controls monitoring (CCM)?
CCM is the automated monitoring of controls on a continuous basis against internal and external rules. It relies on system data that is live or near-real-time and, instead of manual sampling, applies rules to every relevant transaction.
For example, rather than manually sampling 25 invoices at quarter-end, CCM can evaluate 100% of invoices daily against predefined rules. If a transaction breaches those rules, real-time notifications are triggered so that GRC teams can take action, strengthen controls, and prevent recurrence.
CCM is particularly effective for high-volume, system-driven controls such as financial postings, user access changes, configuration monitoring, and Segregation of Duties conflicts, where clear rules can be applied consistently across large data sets.
Because monitoring is continuous and embedded into daily operations, CCM functions first and foremost as a management tool. While it can and does support audit readiness, its primary value lies in providing ongoing operational oversight between audit cycles. The result is a stronger control environment and better protection against risk.
How does traditional controls testing differ from continuous controls monitoring?
Traditional controls testing relies on periodic reviews and transaction sampling. While sampling helps manage time and resource constraints, it inevitably creates blind spots, as not all transactions are examined. As a result, control assurance becomes retrospective rather than real-time, and issues often remain undetected until after financial close — when remediation is more complex, disruptive, and costly.
CCM, by contrast, evaluates all relevant transactions on a continuous basis, triggering same-day alerts and enabling exception-based management. Visibility exists between audits — not just during them.
How is CCM applied in modern SAP environments?
One of the key advantages of CCM for SAP users is scalability across complex system landscapes. Organizations can define a rule once and deploy it across multiple SAP systems —for example in S/4HANA Germany, S/4HANA US, ECC, or other regional environments — rather than configuring each system separately. When requirements change, teams can refine rules or adjust risk thresholds centrally, without repeating updates in every individual system.
Standardized, automated controls that are consistently applied also make it easier to map a single control across multiple frameworks. This can include SOX, NIST, and country-specific regulations, which is particularly important for multinational organizations maintaining global compliance where regulatory requirements often overlap.
In complex SAP environments, the shift from periodic review to continuous oversight across system landscapes delivers broader operational and strategic benefits, including:
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Reduced time spent manually reviewing SAP transactions such as invoices, account postings, user access changes, and configuration updates.
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Greater focus on genuine SAP exceptions — such as duplicate invoices, threshold breaches, SoD conflicts, or unauthorized access — rather than routine transaction sampling.
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Productivity gains through automated rule execution across multiple SAP systems, enabling exception-based management instead of spreadsheet-driven reconciliations.
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Better decision-making and accountability, supported by same-day visibility into control breaches across finance, access management, and system configuration.
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Greater operational confidence for leadership through consistent, system-generated evidence of control effectiveness across complex SAP landscapes.
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Reduced operational, reputational, and executive exposure by identifying control failures early, rather than discovering them during audit cycles.
How to get started with CCM in SAP
At present, most organizations are at an early stage of CCM maturity, where SAP CCM functionality has been enabled within SAP GRC, but without a clear strategy behind its use. Initial adoption is often driven by available system capabilities rather than risk prioritization, leading to automated rules that are not yet consistently governed, aligned to business processes, or clearly owned.
The best way to ensure that visibility, ownership, and alignment gaps are addressed is to consider business objectives right from the outset, so that rework and resistance don’t become issues later on. Key first steps on this journey include:
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Starting with scope rather than tooling
Begin with a risk assessment to identify where CCM will add the most value, rather than enabling automation simply because the functionality exists within SAP GRC. -
Identifying critical processes and high-impact risks
Focus first on areas such as high-volume financial transactions, user access, or configuration changes, where control failure would create meaningful operational or regulatory exposure. -
Focusing on system-driven, automatable controls with high business value
Prioritize controls that rely on structured SAP data and clear rule logic, rather than manual or judgment-based activities that are difficult to automate effectively. -
Aligning controls to real business processes
Ensure each control is mapped to the correct business owner, system landscape, and process flow so it reflects how the organization actually operates. -
Ensuring that not every control is automated
Avoid automating low-frequency or low-impact controls where the development effort outweighs the benefit and retain manual oversight where human judgment is required. -
Securing and clarifying ownership across business, IT, audit, and risk
Define responsibility for rule design, monitoring, and remediation early to prevent delays, alert fatigue, or unclear accountability once CCM is live.
What to focus on as you scale CCM
As organizations move from pilot initiatives to scaled CCM programs, technical design and governance become critical to long-term success. With the right foundations in place, CCM can scale effectively across complex SAP landscapes.
Three areas deserve particular attention:
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Data quality and sources
CCM is only as effective as the data it evaluates. Ensuring accurate, complete, and well-structured data from SAP tables, reports, SAP Queries, and CDS views is essential. Clear filtering and sound data modeling help ensure controls are built on the right information from the outset. -
Rule design
Well-designed rules should reflect the specific risk being addressed and pull only the relevant data required to assess it. Careful calibration helps avoid false positives and alert fatigue, strengthening trust in CCM outputs and driving meaningful action. -
Integration
Where non-SAP systems are in scope, integration should be assessed pragmatically. Standard SAP integrations are typically more straightforward, while external systems may require additional effort to standardize data structures or build custom logic.
When these fundamentals are addressed early, organizations are better positioned to avoid common implementation challenges, including automating too many controls too quickly, over-relying on automation where manual oversight is still required, or treating CCM solely as a compliance exercise rather than an operational capability.
By focusing on alignment, clarity, and proportionality, CCM becomes a scalable and sustainable part of the control environment, rather than an additional burden.
In summary: Making CCM a sustainable success
Continuous controls monitoring reflects the way modern SAP environments now operate. When it is implemented with clear scope, aligned ownership, and well-designed rules, it becomes part of day-to-day operations rather than something layered on purely for audit purposes.
For organizations managing complex system landscapes, growing transaction volumes, and overlapping regulatory requirements, CCM provides a structured and scalable way to maintain control without slowing the business down.
To find out more about implementing CCM effectively, or to access specialist support on your journey, contact the Turnkey team today.
Frequently asked questions: Continuous controls monitoring in SAP GRC
1: What types of controls are best suited to continuous controls monitoring?
CCM works best for high-volume, transactional controls that are based on system logic and data, rather than human judgment, and where rules can clearly be defined. Typical examples include financial postings (such as duplicate invoices or postings outside tolerance), Segregation of Duties (SoD) violations, sensitive configuration changes, user access changes, and emergency access duties.
The key is to automate appropriately, instead of just automating everything; judgment-based controls should remain manual.
2: Does continuous controls monitoring replace internal audit or manual controls?
No. CCM is a complement to auditing, rather than a replacement for it. The primary purpose of CCM is to ensure controls remain effective and right-sized, better protecting the organization from risk in the process
Audits still have a role in validating design effectiveness, while CCM improves control operation visibility and readiness between audits. As CCM provides continuous evidence and reduces reliance on sample-based testing, it helps reduce the risk of surprises when audits emerge and enables more confident conversations with auditors.
3: What are the most common reasons CCM initiatives fail or stall?
CCM programs are often let down by automating too many controls too early, poor-quality rules that generate false positives, and a general lack of ownership across business, IT, and risk.
These issues lead to alert fatigue, low stakeholder confidence, and unclear ownership that leads to unresolved expectations. CCM should not be aligned solely to system capability — it needs to work for the reality of the business concerned.
4: What are the main benefits of continuous controls monitoring for SAP environments?
CCM enables organizations to move from periodic, sample-based testing to continuous, system-driven oversight across their SAP landscape. In practice, this means faster detection of control breaches, reduced reliance on manual reconciliations, and greater visibility across high-volume processes such as financial postings, access management, and configuration changes.
By automating rule execution and focusing teams on genuine exceptions rather than routine checks, CCM improves productivity and strengthens accountability. It also provides consistent, system-generated evidence of control effectiveness, helping leadership manage operational, regulatory, and reputational risk with greater confidence.
