DORA
Risk Management
Continuous Vendor Monitoring: The Only Way to Manage Real Risk
Annual vendor assessments made sense when technology changed slowly and vendor ecosystems were small. But in today's world of rapid change and deep dependencies, point-in-time reviews create a dangerous illusion of control while leaving organizations blind to the risks that matter most.
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Tony DiPadova
October 2, 2025

Continuous Vendor Monitoring: The Only Way to Manage Real Risk

Most organizations conduct annual vendor risk assessments. They have a structured process: send questionnaires, review responses, analyze security documentation, assign risk scores, document everything in your GRC platform. At the end, you have a clean assessment report showing that Vendor X passed their annual review with acceptable risk levels.

Three months later, that same vendor experiences a major data breach. Or gets acquired by a company with questionable security practices. Or suffers a critical outage that takes down your customer-facing services for hours. Or quietly degrades performance until your SLAs are violated daily.

None of this appeared in your annual assessment because none of it had happened yet. Your risk evaluation was accurate on the day you completed it. But risk doesn't wait for your annual review cycle.

This is the fundamental problem with point-in-time assessments. They measure vendor risk at a single moment, then assume that measurement remains valid for the next 364 days. In a world where vendor risk can change overnight, this approach doesn't just create gaps in visibility. It creates a dangerous illusion of control.

How We Got Here

Point-in-time vendor assessments weren't always inadequate. They emerged in an era when technology changed slowly, vendor ecosystems were smaller, and the pace of business allowed for periodic reviews. An annual or biannual assessment made sense when vendors were relatively stable and major changes happened infrequently.

But three fundamental shifts have made this model obsolete.

  1. The velocity of change has accelerated. Vendors now ship updates weekly or daily. Infrastructure changes constantly. Security vulnerabilities emerge and must be patched immediately. Waiting twelve months between assessments means you're always operating on stale information.
  2. Vendor ecosystems have exploded. The average enterprise now manages hundreds or thousands of vendor relationships. The idea that risk teams can conduct meaningful annual reviews at this scale is simply math that doesn't work.
  3. Dependency has deepened. Modern organizations don't just use vendors. They're architecturally dependent on them. Your core systems run on vendor infrastructure. Your customer experience relies on vendor APIs. A vendor failure isn't an inconvenience. It's a business continuity event.

Yet despite these changes, most TPRM programs still operate on an annual assessment cadence because that's what's always been done.

The Five Fatal Flaws of Point-in-Time Assessments

1. They're Obsolete Before You Finish Them

By the time you complete an annual assessment, review the documentation, assign risk scores, and get sign-off from stakeholders, weeks or months have passed. The vendor has shipped multiple updates. Their security posture has changed. Their business situation has evolved.

You're making decisions based on information that describes how the vendor was, not how they are.

2. They Miss the Incidents That Actually Matter

Point-in-time assessments excel at identifying theoretical risks. "Does the vendor have adequate backup procedures?" Sure, but they're terrible at catching actual incidents.

The questionnaire shows the vendor has a documented incident response plan. What it doesn't show is that they failed to notify you of a security incident for two weeks, or that their actual response time during a real incident was dramatically longer than their documented procedures suggested.

3. They Create Perverse Incentives

When assessments happen annually, vendors know they have 364 days when nobody's watching closely. The incentive isn't to maintain consistent performance. It's to look good for the assessment.

This creates a dynamic where vendors are most responsive and transparent during the weeks surrounding your review, then revert to normal, less attentive behavior once the assessment is complete.

4. They Don't Scale

If you have 500 vendors and conduct meaningful annual assessments of each one, your risk team spends their entire year on assessments with no time for actual risk management, strategic work, or responding to real issues.

The typical response is to tier vendors and only assess "critical" ones annually, with others reviewed less frequently. But this just means you have even less visibility into the majority of your vendor ecosystem.

5. They Measure the Wrong Thing

Point-in-time assessments measure vendor capability at a moment in time. "Is the vendor capable of meeting our requirements?" But what organizations actually need to know is "Is the vendor consistently meeting our requirements?"

A vendor can have excellent documented procedures, impressive security certifications, and strong financial health and still deliver poor service quality, miss SLA commitments, or experience frequent operational issues.

What does good Continuous Monitoring look like?

Continuous monitoring isn't just "more frequent assessments." It's a fundamentally different approach that treats vendor risk as a dynamic, ongoing condition rather than a periodic checkpoint.

Real continuous monitoring includes several key components.

  • Automated performance tracking measures whether vendors are actually meeting their SLA commitments on an ongoing basis, not just whether they have an SLA on paper.
  • Real-time incident detection alerts you when vendors experience outages, security issues, or performance degradation. Ideally before they officially report it.
  • Change monitoring tracks significant vendor changes. Acquisitions, leadership changes, financial status shifts, new security vulnerabilities, regulatory actions.
  • Trend analysis identifies patterns over time. Is vendor performance gradually degrading? Are incident frequencies increasing? Are resolution times getting slower?
  • Integrated risk signals combine multiple data sources to provide a comprehensive, current view of vendor health rather than a single point-in-time score.

How can we get there?

The most common objection to continuous monitoring is practical. "We can barely complete annual assessments. How are we supposed to monitor vendors continuously?"

The answer is that continuous monitoring works precisely because it's continuous. It relies on automation and real-time data rather than labor-intensive manual reviews.

What should be automated:

  • Service availability and performance monitoring
  • Status page tracking and incident aggregation
  • News monitoring for vendor-related security incidents or business changes
  • SLA compliance tracking against contractual commitments
  • Financial health monitoring through credit rating services and public filings
  • Security posture changes through integrations with threat intelligence feeds

What still requires human judgment:

  • Interpreting the significance of changes in vendor context
  • Deciding when automated signals warrant investigation
  • Conducting targeted deep-dive reviews when risk signals escalate
  • Making decisions about contract renewals, terminations, or renegotiations
  • Engaging with vendors when issues are identified

The goal isn't to eliminate human judgment. It's to focus that judgment on actual risk events rather than consuming it with routine information gathering.

The Hybrid Model: Continuous Monitoring Plus Targeted Assessments

The future of TPRM isn't abandoning assessments entirely. It's using continuous monitoring to inform when and where deep-dive assessments are needed.

Instead of blindly conducting annual reviews of all critical vendors, organizations with mature continuous monitoring programs do several things differently.

  • Conduct targeted assessments triggered by risk signals. When continuous monitoring detects significant changes or incidents, that triggers a focused review.
  • Perform periodic validation reviews. Annual or biannual reviews that validate the accuracy of continuous monitoring and assess areas that can't be automated.
  • Prioritize assessment resources dynamically. Spend time on vendors showing concerning trends rather than evenly distributing effort across all vendors regardless of current risk profile.
  • Reduce assessment burden on stable vendors. Vendors with consistently strong performance and no concerning signals can be reviewed less frequently and less intensively.

This approach is more efficient, by focusing human effort where it matters, and more effective, by catching problems when they happen rather than months later.

The Regulatory Tailwind

Regulatory bodies are increasingly recognizing the inadequacy of point-in-time assessments. DORA explicitly requires financial institutions to implement continuous monitoring of critical vendors, not just periodic reviews. Similar language is appearing in regulatory guidance globally.

This isn't regulators being arbitrarily demanding. It's recognition that operational resilience requires real-time visibility. When a critical vendor fails, "we reviewed them last year and they were fine" isn't an adequate explanation to customers, stakeholders, or regulators.

The Real Barrier Isn't Technology

The technology for continuous monitoring exists and is increasingly accessible. The real barrier is organizational. Shifting from a mindset that treats vendor risk management as a periodic compliance exercise to one that treats it as an ongoing operational discipline.

This requires several things:

  • Executive buy-in that continuous monitoring is strategic investment, not just another tool.
  • Process changes that integrate continuous signals into daily risk management.
  • Skill development to help teams interpret automated signals and act on them.
  • Cultural shift from "we did the assessment" to "we understand the current risk."

Organizations that make this shift discover something interesting. Continuous monitoring is actually less burdensome than intensive periodic assessments because it distributes effort over time and focuses attention where it's genuinely needed.

The Point-in-Time Assessment Is Already Dead

Here's the uncomfortable truth: many TPRM teams have already lost confidence in manual annual assessments, yet most organizations still conduct them. They provide incomplete information, and vendors can change dramatically between reviews. Everyone knows that when something goes wrong with a vendor, the annual assessment isn't where you look for answers.

The point-in-time assessment model persists not because it's effective, but because it's familiar and because organizations haven't yet committed to an alternative.

But the math is clear. You can't manage hundreds of dynamic vendor relationships with a process designed for dozens of stable ones. You can't catch real-time operational issues with annual paperwork reviews. You can't build genuine operational resilience on top of information that's months out of date.

The only question is whether your organization will proactively adopt continuous monitoring or wait until a vendor incident forces the conversation.

Ready to move beyond the limitations of point-in-time assessments? Contact Clarative to learn how continuous vendor monitoring can give you real-time visibility into the vendor risks that matter most without overwhelming your team.

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