Our recommendation is to close immediate obligation and evidence gaps first, then implement reusable platform capabilities. Do not make a new platform’s go-live date the prerequisite for meeting a nearer obligation.
Immediate triage
- Assign legal, compliance and operational owners to the near-term dates above.
- Identify which dates in the existing register are obsolete, proposed or suspended.
- Obtain an approved applicability decision for each priority item.
- Record a controlled interim process where a platform change cannot be delivered in time.
- Preserve the evidence supporting current decisions before migration.
Before year-end
- Prepare January 2027 privacy and automated-decision workflows where applicable.
- Establish evidence collection for applicable audit periods starting in January.
- Update internal audit templates for effective topical requirements.
- Test at least one complete workflow, including an exception, failed integration and export.
- Confirm who will maintain regulatory mappings after implementation partners leave.
During the next procurement or renewal decision
Use the Requirements Scorecard to select the first workflow, the Migration Checklist to protect history, and the Demo Script to make supplier claims testable. The three-year TCO comparison should separately request prices for regulatory content, specialist modules, APIs, sandboxes, implementation, administrator training and update services.
Ask explicitly:
- Who decides whether a regulatory update applies: the buyer, supplier or content provider?
- What is included when a rule is delayed, replaced or withdrawn?
- Can the buyer reject an automated mapping while preserving the proposed mapping and rationale?
- What requires paid professional services?
- Can historical content still be exported after a content subscription ends?
- Who owns ongoing data quality, integrations and testing?
The purchase decision should follow an evidenced operating model. If the incumbent can support the required controls and change process with manageable repair work, regulation alone is not a sufficient reason to replace it.