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Exception Template

Use this template to document approved deviations from a control's expected governance tier. Exceptions should be time-boxed, reviewed, and retained as part of the examination-ready record set.

FSI language rules

This framework is provided for informational purposes only and does not constitute legal, regulatory, or compliance advice. Exceptions do not remove the underlying regulatory obligation; organizations should verify that compensating controls remain sufficient for their specific obligations. See the full disclaimer.


Exception summary

Field Value
Exception ID EX-YYYY-NNN
Control ID e.g. 2.1
Control name
Tier deviated from Baseline / Recommended / Regulated
Requested by name / role
Requested on YYYY-MM-DD
Approved by name / role
Approved on YYYY-MM-DD
Expiry date YYYY-MM-DD
Review cadence quarterly / semi-annual

Business justification

Describe the business need. Note any affected Copilot surface (Chat, Pages, Agents, Teams, Viva, etc.) and user population. Avoid prohibited language — the exception helps meet business needs; it does not "guarantee" an outcome.


Risk assessment

Dimension Assessment
Regulatory exposure e.g. supports compliance with SEC Rule 17a-4 — residual risk to records retention requires compensating archive
Data sensitivity impacted e.g. Highly Confidential; Client PII
Residual risk rating Low / Medium / High
Likelihood of occurrence Low / Medium / High
Impact if realised Low / Medium / High

Compensating controls

  1. Describe the compensating control(s) that help address the residual risk.
  2. Owner and verification cadence for each compensating control.
  3. Evidence trail — where proof of operation is stored.

Monitoring plan

  • Metric(s) reviewed:
  • Frequency:
  • Trigger for early remediation:
  • Reviewer:

Sunset plan

Milestone Target date Owner
Interim review YYYY-MM-DD
Remediation complete YYYY-MM-DD
Exception closed YYYY-MM-DD

Approval trail

Date Actor Action Notes
YYYY-MM-DD Risk committee Approved / Renewed / Closed

This template aids in maintaining a record of exceptions. Organizations are recommended to review exception registers during internal audit cycles and at each regulatory examination to verify that compensating controls remain effective.