Top 7 Compliance Frameworks for Cloud Migration | Hokstad Consulting

Top 7 Compliance Frameworks for Cloud Migration

Top 7 Compliance Frameworks for Cloud Migration

Moving to the cloud? Don't overlook compliance. Failing to meet regulatory standards can lead to hefty fines, data breaches, or loss of customer trust. Here's a quick guide to the top 7 compliance frameworks every UK business should know about for cloud migration:

  • GDPR: Focuses on data protection and privacy for EU citizens. Applies globally to organisations handling EU data.
  • ISO/IEC 27001: An international standard for managing information security, helping businesses protect sensitive data during cloud transitions.
  • PCI DSS: Essential for securing payment card data, especially for e-commerce and payment processors.
  • HIPAA: Safeguards patient health information, critical for healthcare organisations handling U.S. data.
  • SOC 2: Ensures data security, availability, and privacy, often required by SaaS and cloud service providers.
  • SOX: Mandates strong financial reporting controls, crucial for publicly traded companies.
  • FedRAMP: U.S.-specific, for cloud providers working with federal agencies, ensuring high security standards.

Each framework addresses unique challenges, from encryption and access management to industry-specific regulations. Whether you're a healthcare provider, financial institution, or e-commerce business, aligning your cloud migration with these frameworks ensures legal compliance, data security, and customer trust.

Quick Comparison:

Framework Key Focus Applies To Certification Process
GDPR Data privacy Global (EU data) Self-assessment, regulatory audits
ISO 27001 Information security All industries Third-party certification
PCI DSS Payment card data security Payment processors, e-commerce Annual audits or self-assessment
HIPAA Patient health information U.S. healthcare Self-assessment, HHS reviews
SOC 2 Data security and privacy SaaS, cloud providers Type I or Type II audit
SOX Financial reporting controls Public companies External audits
FedRAMP Cloud security for U.S. govt Cloud providers for U.S. agencies 3PAO audit, agency/JAB authorisation

Takeaway: Compliance isn’t optional - it’s your safeguard against legal risks and data breaches. Start your cloud migration with a clear compliance strategy tailored to your industry and region.

Migrating from “Tick Box" Compliance to Automating GRC in a Multi-Cloud World

Cloud Migration Compliance Challenges

Migrating to the cloud brings a maze of compliance hurdles that can easily overwhelm even seasoned IT teams. For instance, 45% of organisations struggle with navigating legal frameworks [1], showcasing how demanding this process can be. To address these challenges, companies need strategies that are not only robust but also continuously updated throughout the migration journey.

One of the biggest concerns is the technical complexity of cloud environments, which introduces significant risks. Since cloud configurations can change rapidly, real-time monitoring becomes critical. This allows organisations to detect risks, unauthorised changes, or policy violations as they happen [4]. Unfortunately, traditional monitoring methods often fall short in these dynamic settings.

Encryption also adds to the complexity. Protecting data both in transit and at rest requires strong encryption protocols like TLS and AES [5]. However, managing encryption keys across multiple cloud platforms is no small feat, especially when trying to stay compliant with various regulatory frameworks.

Identity and access management (IAM) is another major challenge. Organisations must implement multi-factor authentication (MFA) and enforce the principle of least privilege, ensuring users only have the permissions they absolutely need [5]. Despite the fact that 94% of enterprises use cloud services, many still struggle to maintain robust security practices [5].

The cost of non-compliance is steep. On average, penalties can reach £3.6 million, and data breaches have been on the rise [1][2]. In 2024 alone, breaches affected over 300 million records [1], underlining the urgency of strong compliance measures.

Smaller businesses face unique hurdles. Around 60% of small enterprises are unaware of specific regulatory requirements that apply to them [1]. Without the necessary resources or expertise, these organisations are particularly vulnerable to mistakes that could prove costly.

For UK businesses with international operations, data residency requirements create additional complications. Post-Brexit, data transfers from the EU to the UK are now treated as transfers to a third country, requiring businesses to implement extra safeguards [3]. While the UK GDPR shares similarities with the EU GDPR, key differences mean businesses need separate compliance strategies.

Industry-specific regulations further heighten the complexity. For example, healthcare providers must meet HIPAA standards, financial institutions face SOX compliance, and government contractors need to adhere to FedRAMP requirements. Each framework comes with distinct rules for data management, access controls, and audit trails [1].

Audits and reporting requirements can also feel overwhelming. Missing audit protocols can result in severe fines and penalties [1]. However, organisations that conduct regular compliance checks can reduce risks by up to 30% [1].

Cross-functional collaboration is vital during cloud migration. IT teams must work closely with legal experts to ensure security measures align with both technical and legal standards [1]. This is especially important given that 65% of IT and security professionals list cloud security as their top concern [6]. Addressing these issues comprehensively lays the groundwork for exploring structured compliance frameworks in the next steps.

Another challenge is resource allocation. Organisations must juggle the need for thorough compliance strategies with budget limitations and competing priorities. Managing multiple compliance frameworks often requires dedicated teams and specialised tools to ensure nothing falls through the cracks.

Acknowledging these challenges is the first step towards integrating effective compliance measures into your cloud migration plan. The structured frameworks discussed later will offer practical approaches to tackling these requirements, but success hinges on committing to continuous monitoring, allocating sufficient resources, and fostering cross-departmental collaboration.

1. General Data Protection Regulation (GDPR)

The General Data Protection Regulation (GDPR) is Europe's landmark data protection law, setting the standard for how personal data is handled, particularly in cloud migration projects. Its influence extends far beyond Europe, shaping privacy practices worldwide.

Geographic Applicability

GDPR applies to individuals within the European Union (EU) and the European Economic Area (EEA), but its impact doesn't stop there. For instance, a UK-based company handling the personal data of EU citizens must comply with GDPR, even if the data is stored on cloud servers outside the EU. The regulation also places strict controls on cross-border data transfers, making international cloud migration projects more intricate.

Core Requirements

GDPR is built on seven key principles: lawfulness, fairness, and transparency; purpose limitation; data minimisation; accuracy; storage limitation; integrity and confidentiality; and accountability. These principles serve as the foundation for organisations as they manage personal data.

One of the first steps in compliance is securing explicit consent from individuals and ensuring their rights - such as accessing, deleting, or transferring their data - are upheld. These rights must remain enforceable throughout the migration process.

The principle of data minimisation requires organisations to collect only the information they absolutely need. This makes a pre-migration audit essential to identify and eliminate unnecessary data before moving to the cloud.

GDPR compliance means organisations must ensure that personal data is securely handled and protected during the migration process. This involves implementing robust security measures, maintaining transparency about data handling practices, and ensuring data minimisation principles are adhered to.

To safeguard data integrity and privacy in the cloud, organisations must adopt measures like strong encryption, strict access controls, and detailed audit trails.

Certification and Audit Process

While GDPR doesn’t mandate formal certification, organisations are expected to demonstrate accountability by documenting their compliance efforts and conducting regular assessments. Privacy Impact Assessments (PIAs) are particularly important before migrating legacy systems, as they help identify and mitigate potential privacy risks. Ongoing monitoring and audits are also crucial to maintaining compliance over time.

Another critical aspect is establishing clear agreements with cloud service providers. Data Processing Agreements (DPAs) outline responsibilities, data handling protocols, and security measures, ensuring both parties meet GDPR standards.

Non-compliance can be costly. Fines can reach up to 4% of a company’s annual global turnover or €20 million - whichever is higher. For example, the Dutch Data Protection Authority fined Uber €290 million for unlawful data transfers, underscoring the seriousness of violations [7].

For organisations navigating cloud migrations, GDPR compliance requires careful planning. Privacy considerations must be integrated at every stage to ensure not only legal adherence but also the protection of individuals' data.

2. ISO/IEC 27001

ISO/IEC 27001 is an internationally recognised standard designed to protect sensitive information during cloud migrations. It provides a structured framework that addresses security challenges across industries, making it a key tool for organisations navigating the complexities of cloud adoption.

Industry Focus

ISO/IEC 27001 is applicable to organisations of any size and sector, ensuring the protection of information in various forms - whether stored on paper, in digital formats, or within the cloud [15]. While the Information Technology sector leads in certifications, industries like healthcare, finance, manufacturing, and government also benefit from its adaptable framework.

The 2022 update streamlined the standard by introducing 11 new controls and merging 24 existing ones, reducing the total number of controls from 114 in 14 clauses to 93 in 4 clauses [13]. Among these, Annex A Control 5.23 specifically addresses the security of cloud services, offering clear guidance for organisations moving to cloud-based systems [10].

Geographic Applicability

With more than 70,000 certificates issued in 150 countries as of 2022 [8], ISO/IEC 27001 has a truly global reach. For UK businesses, this international recognition is particularly valuable when working with overseas clients or operating in multiple regions. In the US, certifications have seen a 78% year-on-year increase, while globally, the growth rate is 20% [12].

In the UK, ISO/IEC 27001 not only supports compliance with global standards but also aligns with domestic regulations like GDPR [14]. Many organisations now require this certification as part of their vendor assessment processes, opening doors to new contracts and business opportunities [13].

Core Requirements

ISO/IEC 27001 takes a comprehensive approach to information security, integrating people, policies, and technology [8]. It requires organisations to establish and maintain an Information Security Management System (ISMS) through systematic risk management. This ensures cloud security by defining specific controls, setting criteria for cloud services, and establishing clear contractual agreements.

When migrating to the cloud, organisations must outline their security requirements, select appropriate cloud providers, and clearly assign responsibilities for cloud usage [9]. A strategy for handling changes or ending cloud services is also essential. Key steps include conducting risk assessments, drafting cloud-specific security policies, setting clear terms in contracts, and implementing continuous monitoring and staff training [10].

Certification and Audit Process

The certification process typically spans 6–12 months and costs between £40,000 and £160,000 [12]. It starts with detailed planning, defining the ISMS scope, conducting risk assessments and gap analyses, developing policies and controls, training employees, and documenting compliance evidence.

Certification involves a two-stage audit. Stage 1 reviews the ISMS design to ensure it meets ISO/IEC 27001 requirements. Stage 2 is a full audit where the system's practical effectiveness is evaluated. Once certified, organisations undergo regular surveillance audits over three years to maintain compliance, with a recertification audit required at the end of this period. Notably, all ISO/IEC 27001:2013 certifications will expire on 31 October 2025, requiring organisations to transition to the updated 2022 standard [13].

For UK businesses, adopting ISO/IEC 27001:2022 brings tangible benefits. These include enhanced trust from clients and partners, reduced risk of data breaches, access to new business opportunities, a shift towards stronger security awareness, and improved resilience in the face of cyber threats [13]. Success in certification often hinges on appointing a dedicated project manager, securing executive support early on, conducting thorough gap analyses, creating detailed Risk Treatment Plans, and ensuring ongoing security training for staff [11].

3. Payment Card Industry Data Security Standard (PCI DSS)

After GDPR and ISO/IEC 27001, the Payment Card Industry Data Security Standard (PCI DSS) emerges as another crucial framework, focusing on protecting payment data during cloud migration. This mandatory set of guidelines is specifically designed to secure cardholder information during payment processing. For businesses moving to the cloud, adhering to PCI DSS ensures sensitive payment data stays protected throughout the transition and beyond.

Industry Focus

PCI DSS applies to any organisation involved in storing, processing, or transmitting cardholder data for major card brands, regardless of size or industry [23]. This includes merchants, payment processors, banks (both acquiring and issuing), and service providers [16][18]. The framework spans all payment channels, such as in-store point-of-sale systems, mail and telephone orders, and online transactions [24]. As the PCI Security Standards Council puts it:

If you accept or process payment cards, PCI DSS applies to you. [24]

Since its introduction in 2004, PCI DSS has evolved significantly. The latest version, PCI DSS v4.0, became active on 31 March 2024, replacing v3.2.1. This version introduces 51 new requirements, which will become mandatory by 31 March 2025 [16].

Geographic Applicability

PCI DSS is a global compliance standard [24]. Its international relevance is highlighted by past financial losses, such as the £600 million Mastercard and Visa lost to online fraud in the late 1990s [23]. In the UK, acquiring banks enforce compliance, imposing penalties for non-compliance to maintain uniform standards across domestic and international operations.

Core Requirements

PCI DSS is structured around 12 key requirements, grouped into six control objectives. These requirements aim to ensure secure payment processing [17][19]:

  • Build and Maintain a Secure Network and Systems: Implement firewalls and secure configurations to protect networks.
  • Protect Account Data: Secure stored account data and use strong cryptographic methods during transmission.
  • Maintain a Vulnerability Management Programme: Defend against malware and ensure secure development of software and systems.
  • Implement Strong Access Control Measures: Limit access to cardholder data based on necessity, enforce authentication, and secure physical access.
  • Regularly Monitor and Test Networks: Log system access and conduct regular security testing.
  • Maintain an Information Security Policy: Develop and enforce comprehensive security policies and programmes.

These measures focus on three primary goals: protecting data during collection and transmission, ensuring secure storage, and validating security through ongoing monitoring [17]. Meeting these standards involves a rigorous certification process to confirm compliance.

Certification and Audit Process

The certification process varies depending on an organisation's transaction volume and complexity. Costs can range from £4,000 to over £160,000, with completion times spanning from a single day to two weeks [22]. High-volume merchants (Level 1), processing more than six million transactions annually, must work with a Qualified Security Assessor (QSA) to complete a detailed audit and submit an annual Report on Compliance (ROC). Smaller merchants (Levels 2 and 3) can often complete a Self-Assessment Questionnaire (SAQ) instead [22].

The process includes understanding PCI DSS requirements, assessing compliance levels based on transaction volume, documenting payment data flows, conducting risk assessments, implementing security measures, performing vulnerability scans, and maintaining continuous monitoring [22].

Cloud migration adds another layer of complexity. Organisations must ensure their cloud service providers are PCI DSS-compliant, but the responsibility for securing applications ultimately remains with them [20][21]. Michael Aminzade, VP of Compliance & Risk Services at VikingCloud, emphasises the advantages of early preparation:

Being an adopter of the requirements of PCI DSS v4.x is going to help improve your organisation's payment security, will benefit you and your staff from improved processes and additional training, and help you to be ready to meet the new requirements that come into effect on 31 March 2025. [16]

Achieving PCI DSS compliance requires implementing robust security practices, such as encryption, tokenisation, and secure network architecture, alongside regular assessments and monitoring of third-party vendors [17][19].

Hokstad Consulting ensures PCI DSS compliance is seamlessly integrated into cloud migration strategies, keeping payment data secure at every stage.

4. Health Insurance Portability and Accountability Act (HIPAA)

The Health Insurance Portability and Accountability Act (HIPAA) plays a key role in safeguarding patient data, especially during cloud migration. With healthcare data breach costs rising by 53.3% since 2020 and 82% of recent breaches involving cloud data, compliance with HIPAA has become a pressing concern for healthcare organisations adopting cloud technologies [27]. This highlights the urgent need for healthcare providers to prioritise digital compliance.

Industry Focus

HIPAA is designed to protect sensitive patient health information (PHI) across all healthcare-related operations [26]. It applies to healthcare providers, health plans, clearinghouses, and their business associates. Recognised as a cornerstone of the American healthcare system, HIPAA's relevance has only grown with the sector's rapid digital transformation [25].

As healthcare providers increasingly embrace cloud technologies - 88% have accelerated cloud adoption - challenges remain. A significant 62% of cloud projects face difficulties, and healthcare organisations are frequent cyberattack targets [28]. The sector also experiences the second-highest rate of data breaches caused by cloud misconfigurations, responsible for 20% of incidents [27]. For example, Oregon Health & Science University (OHSU) faced penalties after storing over 3,000 individuals' electronic PHI (ePHI) on an unsecured cloud server. These realities emphasise the importance of HIPAA's safeguards in cloud migration efforts.

Geographic Applicability

HIPAA's jurisdiction is limited to healthcare operations within the United States. However, its reach extends to international cloud service providers handling PHI for US-based healthcare organisations. UK healthcare providers serving US patients or partnering with US entities must also comply with HIPAA when processing American patient data in cloud environments. Beyond traditional healthcare entities, the framework applies to any organisation that creates, receives, maintains, or transmits PHI electronically. This includes technology firms, cloud service providers, and third-party vendors working with US healthcare data, regardless of their location.

Core Requirements

HIPAA establishes specific safeguards to protect the confidentiality, integrity, and availability of ePHI, outlined under its Security Rule [30]. These safeguards fall into three main categories:

  • Administrative safeguards: These focus on assigning security officers, conducting regular risk assessments, and implementing detailed policies and procedures. This includes ongoing staff training and establishing clear cybersecurity protocols [31].

  • Technical safeguards: These require measures like encrypting data both at rest and in transit, implementing role-based access controls, and maintaining audit logging capabilities. Multi-factor authentication, firewalls, and intrusion detection systems are also essential for securing cloud environments [29][31].

  • Physical safeguards: These involve securing systems, equipment, and facilities housing ePHI. For cloud environments, this means ensuring that cloud service providers enforce strict physical security measures at their data centres and follow rigorous protocols for equipment disposal and media reuse.

Currently, 70% of healthcare providers have adopted cloud solutions, with an additional 20% planning to migrate by the end of 2025 [31]. This rapid adoption rate underscores the importance of understanding and adhering to HIPAA's requirements for a successful transition to the cloud.

Certification and Audit Process

Unlike some frameworks, HIPAA does not offer formal certification. Instead, organisations must demonstrate compliance through internal audits and be prepared for investigations by the Office for Civil Rights (OCR) [34]. The audit process typically involves appointing a HIPAA security and privacy officer, defining the audit scope, collecting compliance documentation, and performing technical assessments [33].

HIPAA audits evaluate practical implementation - such as training programmes and technical safeguards - rather than just reviewing documented policies [34]. Audits may be triggered by random selection, patient complaints, employee reports, or breach notifications submitted to the OCR. They can take the form of desk audits, requiring electronic submission of compliance documentation, or on-site audits, where investigators assess physical facilities [34].

For cloud migration specifically, organisations must establish Business Associate Agreements (BAAs) with their cloud service providers. As Microsoft explains in its compliance documentation:

By offering a BAA, Microsoft helps support your HIPAA compliance, but using Microsoft services does not on its own achieve it. Your organisation is responsible for ensuring that you have an adequate compliance programme and internal processes in place, and that your particular use of Microsoft services aligns with HIPAA and the HITECH Act. [32]

Addressing audit findings promptly is essential to avoid penalties. By embedding HIPAA requirements into migration strategies, healthcare organisations can secure patient data while maintaining regulatory trust.

Hokstad Consulting ensures HIPAA compliance is seamlessly integrated into cloud migration plans, helping healthcare providers protect sensitive patient data during their digital transformation journey.

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5. Service Organisation Control 2 (SOC 2)

SOC 2 builds on previous frameworks to bolster data protection, particularly during cloud migrations. Developed by the AICPA, Service Organisation Control 2 (SOC 2) focuses on ensuring data security, availability, and processing integrity. While compliance with SOC 2 is voluntary, it has become a standard expectation for organisations looking to assure clients and partners that sensitive information is well-protected.

Industry Focus

SOC 2 is especially relevant for organisations handling sensitive customer data, such as cloud providers and SaaS companies. Many tech firms, hosting providers, data centres, and managed service providers pursue SOC 2 certification to demonstrate their commitment to safeguarding data. Achieving SOC 2 compliance can also align businesses with other frameworks like HIPAA, GDPR, and ISO 27001, enhancing their overall security posture and resilience against cyber threats.

Geographic Applicability

Though SOC 2 originated in the United States, its influence is global. International companies serving U.S.-based clients or operating in American markets often seek SOC 2 certification to meet contractual and client requirements. Many multinational corporations now require their vendors to maintain SOC 2 compliance, making it a valuable credential for companies aiming to expand their reach.

Core Requirements

SOC 2 revolves around five Trust Services Criteria: security, availability, processing integrity, confidentiality, and privacy. Of these, security is the only mandatory criterion. To meet this requirement, organisations must implement robust controls to prevent unauthorised access. Common measures include multi-factor authentication, encryption, access management, and regular security monitoring.

  • Security: Protects systems and data from unauthorised access using controls like encryption and authentication.
  • Availability: Ensures systems and services are operational and accessible as agreed with clients.
  • Processing Integrity: Verifies that system operations are complete, accurate, and authorised.
  • Confidentiality: Safeguards sensitive data from unauthorised access or disclosure.
  • Privacy: Addresses the proper handling of personal information.

Achieving SOC 2 compliance requires clear policies, technical safeguards, ongoing staff training, and regular risk assessments.

Certification and Audit Process

SOC 2 offers two types of reports:

  1. Type I: Evaluates the design of controls at a specific point in time.
  2. Type II: Assesses the operational effectiveness of controls over a period, typically 6 to 12 months.

Type II reports are generally preferred as they provide greater assurance to clients.

The audit process involves hiring an AICPA-accredited CPA firm to verify that internal controls effectively protect customer data. Costs for a Type II audit can range from £15,000 to £60,000, depending on the scope and the chosen auditor.

Phase Key Activities
Preparation & Scoping Identify systems and data in scope, select relevant Trust Services Criteria, and conduct a readiness gap analysis.
Remediation & Implementation Develop security policies, implement safeguards (e.g., encryption, backups), and set up monitoring systems.
Audit Execution Collect evidence, undergo formal testing, and receive the final SOC 2 report.
Maintaining Compliance Conduct regular reviews, update policies, and pursue annual recertification.

The audit should cover both legacy and new systems, with documented reviews of user access before and after migration. Scheduling migrations during off-hours can reduce risks, and having backout plans and reconciliation processes in place ensures issues can be managed effectively.

SOC 2 compliance requires ongoing monitoring and regular audits to maintain standards.

Hokstad Consulting integrates SOC 2 requirements into cloud migration strategies, ensuring that security controls remain effective throughout the process and that all documentation and testing meet auditors' expectations.

6. Sarbanes-Oxley Act (SOX)

The Sarbanes-Oxley Act (SOX), introduced in 2002 after high-profile corporate scandals, was designed to promote financial transparency and accountability. However, moving financial systems to the cloud introduces new challenges in maintaining these controls.

Industry Focus

SOX primarily applies to publicly traded companies in the United States [36]. It extends beyond core financial operations to areas like HR, which must enforce strict payroll controls, and to third-party vendors managing financial tasks [35]. The demand for SOX compliance expertise remains substantial - by April 2025, there were over 34,000 compliance job vacancies in the United States alone, with significant opportunities also reported in India and the European Union [36]. These numbers highlight the complexities of adhering to SOX in global business environments.

Recent corporate failures underscore SOX's ongoing importance. For example, Wirecard's collapse in 2020 exposed weaknesses in financial controls, followed by Silicon Valley Bank's troubles in 2023 [37]. In the UK, Metro Bank's former CEO and CFO faced fines in 2025 for a £900 million accounting error [37].

Geographic Applicability

Although SOX is a U.S. law, its influence spans globally. Any company listed on a U.S. stock exchange must comply, regardless of its home country. Subsidiaries and vendors handling financial data for these companies must also meet SOX requirements. A Protiviti report from 2024 shows that SOX compliance responsibilities have grown significantly over the past two years [37].

Core Requirements

Ensuring SOX compliance during cloud migration hinges on maintaining strong internal controls over financial reporting (ICFR). IT teams must address critical sections of the act - 302, 404, 409, and 802 - which focus on securing financial data, monitoring systems, and accurate reporting [38].

Key requirements include:

  • Internal controls and audit trails: Financial data must be protected from unauthorised access, with detailed records maintained for every transaction [40].
  • Continuous monitoring: Systems should identify risks and report material incidents within four business days [39].
  • Third-party compliance: Vendors must adhere to SOX standards, reflecting a shared responsibility model [40].

The financial burden of SOX compliance is considerable. Over half of companies spend more than £1 million annually on compliance, and in 2024, the average fine for non-compliance reached £4.5 million [37][1].

Certification and Audit Process

SOX audits, particularly under Section 404, assess the effectiveness of internal controls over financial reporting. Cloud adoption adds complexity, especially with virtualisation and multi-tenancy environments [43][41].

To streamline audits:

  • Define audit scope: Clearly outline responsibilities between the organisation and its cloud provider.
  • Maintain centralised logs: Use centralised SIEM logging for at least 90 days to simplify breach detection [42][38][39].
  • Integrate with DevSecOps: Ensure deployed workloads meet security standards.
  • Manage encryption keys independently: This preserves the integrity of audit processes [42].

The Cloud Security Alliance (CSA) offers useful guidelines tailored to cloud environments, though SOX audits focus strictly on financial controls, not overall cloud security.

For private companies planning to go public, starting SOX compliance preparations two to three years in advance is highly recommended [35].

Hokstad Consulting incorporates SOX compliance into its strategic cloud migration plans, ensuring that financial controls remain strong and audit trails meet regulatory standards across hybrid and multi-cloud setups. These efforts safeguard financial data integrity throughout the migration process, laying the groundwork for broader compliance considerations.

7. Federal Risk and Authorisation Management Programme (FedRAMP)

The Federal Risk and Authorisation Management Programme (FedRAMP) is the U.S. government’s standard framework for assessing and authorising cloud security. Its relevance has grown significantly, as federal spending on cloud services increased from £5.7 billion in 2019 to nearly £8.3 billion in fiscal year 2021 [45]. This highlights FedRAMP’s critical role in safeguarding federal data and its potential application across specific industries.

Industry Focus

FedRAMP is tailored for cloud service providers (CSPs) aiming to work with U.S. federal agencies. It’s particularly important for providers serving sectors like law enforcement, finance, and health [46]. To put the stakes into perspective, in 2018 alone, federal agencies reported 13,107 breaches, costing approximately £10.3 billion [46]. As of 31 March 2025, 445 cloud services have achieved FedRAMP authorisation. Among these, Moderate Impact systems represent nearly 80% of approved applications, while the Department of Defense accounted for 33% of high-baseline use cases within the U.S. government as of 2017 [49].

Geographic Applicability

Although FedRAMP was created for U.S. federal agencies, its reach extends globally. International companies looking to sell cloud services to U.S. government agencies must meet FedRAMP certification standards [45]. This has prompted many UK and European firms, including major players like Accenture, SAP, and Siemens, to pursue this certification [51]. In the UK, the Government Cloud (G-Cloud) framework requires suppliers to self-certify compliance with 14 Cloud Security Principles [50]. However, this approach differs from FedRAMP, which focuses more on detailed cybersecurity requirements than organisational ownership considerations [51].

Core Requirements

FedRAMP is built on a robust security framework, drawing from the NIST SP 800-53 Revision 4 catalogue of controls [47]. Any cloud service handling federal data must achieve FedRAMP authorisation, which applies to low-, moderate-, and high-risk impact levels [47]. Key requirements include:

  • Security controls implementation: CSPs must implement specific security measures, including advanced application security, to meet FedRAMP standards [47].
  • Continuous monitoring: Systems are subject to regular checks and vulnerability assessments. The FedRAMP 20x initiative aims to automate validation for over 80% of security controls [48].
  • Documentation and assessment: Providers need to complete detailed documentation, such as the System Security Plan (SSP), aligned with FIPS 199 categorisation [44].

Certification and Audit Process

The FedRAMP certification process follows a methodical path, offering two main routes: agency sponsorship or the Joint Authorization Board (JAB) route [45]. The process involves preparation, a comprehensive security assessment, authorisation, and ongoing monitoring [45]. CSPs must undergo an independent assessment by a FedRAMP-approved Third-Party Assessment Organisation (3PAO), address any identified issues with a Plan of Action and Milestones (POA&M), and maintain monthly vulnerability scans as part of continuous monitoring [44]. As of January 2025, the FedRAMP marketplace lists 357 authorised services, providing a searchable database of approved offerings and assessors [52].

For organisations planning cloud migrations involving U.S. federal data, incorporating FedRAMP requirements into their strategy is crucial. Hokstad Consulting integrates these standards into migration plans, ensuring compliance with federal security protocols while streamlining operational processes.

Framework Comparison Table

Selecting the right compliance framework for your cloud migration hinges on factors like your industry, geographic reach, and specific regulatory needs. Each framework has its own purpose and set of obligations, so understanding these differences is crucial.

Below is a comparison of seven key frameworks across four important dimensions that can shape your cloud migration strategy:

Framework Industry Focus Geographic Applicability Core Requirements Certification/Audit Process
GDPR Any organisation processing EU citizens' data [53] Global reach for EU data processing [53] Data minimisation and consent management Self-assessment with potential regulatory audits
ISO 27001 Information security management across all industries [54] International standard applicable worldwide Risk assessment, security controls implementation, continuous improvement Annual third-party certification audits
PCI DSS E-commerce businesses processing credit card payments [53] Global standard for card payment processing Network security, encryption, access controls, regular vulnerability scans Annual self-attestation or third-party assessment based on transaction volume [57]
HIPAA Healthcare organisations in the U.S. [53] U.S. healthcare sector with global implications for data processors Administrative, physical, and technical safeguards for patient data Self-assessment with HHS compliance reviews
SOC 2 Service organisations handling customer data Primarily U.S.-focused but globally recognised Trust Service Criteria covering security, availability, processing integrity, confidentiality, and privacy Type 1 (point-in-time) or Type 2 (minimum six months of operational effectiveness) audits [58]
SOX Publicly traded companies U.S. public companies and their global subsidiaries Financial reporting controls, executive certification, and audit committee independence Annual external audits with quarterly reviews
FedRAMP U.S. government agencies and contractors [53] U.S. federal requirements with global cloud service provider implications NIST SP 800-53 controls, continuous monitoring, and vulnerability management 3PAO assessment via agency or Joint Authorization Board (JAB) routes

Cloud providers handle infrastructure security, but data, applications, and access remain the customer’s responsibility. This table highlights the importance of aligning your migration strategy with the specific demands of these frameworks.

Framework selection often depends on industry-specific needs. For example, healthcare organisations must prioritise HIPAA compliance, while e-commerce businesses focus on PCI DSS certification. GDPR, on the other hand, applies across all industries, requiring compliance from any organisation that processes data belonging to EU citizens [53].

Certification timelines vary significantly, adding another layer of complexity. For UK businesses, geographic scope can further complicate compliance, especially when operating under UK data protection laws while adhering to multiple international standards. The financial risks of non-compliance are considerable, as highlighted by Former U.S. Deputy Attorney General Paul McNulty:

The cost of non-compliance is great. If you think compliance is expensive, try non-compliance – Former U.S. Deputy Attorney General Paul McNulty [57]

This is why 64% of organisations have increased their compliance assessments, and why 82% of data breaches involve cloud environments [55][56].

For businesses managing overlapping frameworks, this table can help untangle the complexity. Take, for instance, a UK-based healthcare technology company that processes patient data, accepts payments, and serves EU customers. Such a company would need to comply with HIPAA, PCI DSS, and GDPR, each with its own unique requirements and certification processes.

Building Compliance into Your Cloud Migration Plan

Successfully migrating to the cloud isn't just about moving data - it's about ensuring compliance is woven into every stage of the process, from planning to post-migration monitoring. By addressing compliance early, you can avoid costly fixes down the line.

Start with a compliance assessment before transferring any data. This means identifying the regulations that apply to your industry, operations, and data types. For instance, a financial services company based in the UK might need to meet GDPR, PCI DSS, and SOX requirements simultaneously. Pinpointing these obligations upfront helps you avoid surprises later.

Once you've identified the regulatory requirements, the next step is to create a migration roadmap that incorporates these standards. This roadmap should include compliance guardrails for every phase of the project. For example:

  • Plan for data residency and ensure required certifications are in place.
  • Test compliance controls during a pilot phase.
  • Fully implement these controls during the migration process.
  • Post-migration, prioritise ongoing monitoring and validation.

Data encryption and access controls are essential for maintaining compliance. Use strong encryption for data at rest, in transit, and in use. Implement role-based access controls and anonymise personal data wherever possible. These measures not only protect sensitive information but also align with the requirements of many compliance frameworks.

To reduce the risk of human error - responsible for 95% of breaches [60] - establish a dedicated compliance team. This team should include members from IT, legal, and business departments, with clearly defined roles and regular training sessions.

Governance Model Components Description
Roles and Responsibilities Clearly assign roles within the compliance team and across departments.
Compliance Council Create a council with representatives to oversee compliance efforts.
Key Performance Indicators Define metrics to measure how effectively compliance is maintained.
Policy Integration Align your cloud provider’s SLAs with your organisation’s compliance policies.
Training and Awareness Offer ongoing training to ensure compliance obligations are well understood.

Continuous monitoring and documentation are critical after migration. Automated tools can track data movement, access logs, and unusual activities. Organisations with strong monitoring systems can detect breaches 95% faster [60]. Additionally, compliance frameworks often require detailed documentation of where and how data is stored, accessed, and moved. Establishing clear processes to maintain these records from the start will save time and effort later.

Expert advice can also make compliance less daunting. Hokstad Consulting, for example, specialises in cloud migration strategies that balance cost efficiency with regulatory requirements. Their approach integrates security and compliance from the beginning, enabling organisations to deploy up to 75% faster while staying compliant [61].

The financial risks of non-compliance are immense. In 2023, Meta was fined €1.2bn by the EU for GDPR violations tied to its cloud infrastructure [59]. This highlights the importance of getting compliance right.

Architectural resilience is another key factor. Designing your cloud systems to be adaptable allows you to update policies and integrate new compliance frameworks without needing major overhauls. This flexibility, combined with continuous monitoring and well-defined policies, ensures your cloud infrastructure can evolve alongside regulatory changes.

To stay ahead, conduct quarterly policy reviews. Regularly assessing new requirements and updating your controls can help you adapt proactively, rather than reacting to changes after they take effect.

Lastly, remember the shared responsibility model: while cloud providers manage infrastructure security, you’re responsible for data governance, application security, and access management. Your compliance strategy must account for both your provider’s capabilities and your own security measures. This balanced approach ensures a robust and compliant cloud migration.

Conclusion

Moving to the cloud without a solid compliance framework in place exposes your business to serious risks. The seven frameworks we've covered - GDPR, ISO 27001, PCI DSS, HIPAA, SOC 2, SOX, and FedRAMP - are more than just regulatory requirements. They serve as detailed guides to help you achieve secure and legally compliant cloud operations, protecting both your organisation and your customers.

These risks aren't just hypothetical. They have very real consequences. For example, in 2023, Meta was fined €1.2 billion for non-compliance, and a 2019 breach at Capital One resulted in a $190 million settlement. Both cases highlight the financial and reputational damage that can stem from failing to meet compliance standards [59].

On the flip side, prioritising compliance early in your cloud strategy can lead to significant benefits. Take Johnson & Johnson, for instance - their proactive approach to compliance reportedly saved them over $1 million annually, proving that compliance can also improve efficiency [59].

With 80% of businesses now adopting hybrid cloud strategies, aligning your compliance efforts with industry-specific regulations is no longer optional - it’s essential [62]. For example, a financial services firm based in the UK might need to address GDPR for data privacy, PCI DSS for payment security, and SOX for financial reporting - all at the same time. Your compliance strategy should reflect the specific requirements of your industry, the type of data you handle, and the regions where you operate.

As hybrid cloud adoption grows, businesses that treat compliance as a strategic opportunity rather than a regulatory chore will gain a competitive edge. By conducting detailed risk assessments, working with certified cloud providers, implementing strong data governance practices, and continuously monitoring compliance, you’re not just avoiding fines - you’re building trust with your customers and strengthening your market position.

Integrating these frameworks into your migration plan isn’t a one-off task. Compliance is an ongoing process that evolves with new regulations and the changing needs of your business. The frameworks discussed here lay a strong foundation, but your ability to adapt and maintain these standards will ultimately determine your success in the cloud.

For tailored advice on embedding compliance into your cloud migration strategy, visit Hokstad Consulting.

Make compliance a priority from the start of your cloud journey. Neglecting it could lead to regulatory fines, lawsuits, and lasting damage to your reputation. Your business, your customers, and your bottom line depend on a robust and proactive approach to compliance.

FAQs

How can businesses identify the right compliance frameworks for their industry and location when migrating to the cloud?

To figure out which compliance frameworks are needed for cloud migration, businesses need to consider three main factors: the regulations tied to their industry, the legal requirements of their geographic location, and the data protection standards relevant to their operations. Common frameworks like GDPR, ISO 27001, and PCI DSS often come into play, but the exact requirements will vary based on the type of data being managed and the regions where the organisation operates.

Taking the time to review regulatory guidelines and industry standards is a must to ensure compliance. Partnering with cloud migration and compliance experts can make this process smoother, helping businesses meet all the required standards while keeping risks and costs under control.

What challenges do organisations face when integrating compliance frameworks during cloud migration, and how can they address them?

Organisations often face hurdles like ensuring data security, managing application compatibility, controlling migration costs, and keeping up with compliance requirements. If these concerns aren't tackled early, they can make cloud migration far more complicated than it needs to be.

To address these challenges, proactive planning is key. Start by identifying compliance needs right from the beginning. Setting up centralised security controls and maintaining a unified view across your cloud environments can significantly reduce risks. Moreover, aligning your cloud strategy with both IT and business goals can make the transition much smoother while ensuring compliance stays intact.

Why is continuous monitoring essential for ensuring compliance in cloud environments, and what are the best strategies to implement it effectively?

Continuous monitoring plays a key role in keeping cloud environments compliant. It allows organisations to spot security threats as they happen, ensures that regulatory requirements are continuously met, and helps uncover vulnerabilities before they turn into more serious problems. This forward-thinking approach reduces risks and helps businesses stay on top of their compliance responsibilities.

To achieve this, organisations can adopt strategies like using automated compliance controls, setting up real-time activity logging, and performing regular vulnerability assessments. These steps not only strengthen security but also give businesses the visibility they need to prove compliance during audits.