Four Ways Technology Can Ease the MAR Compliance Process
-
September 10, 2026
-
Most insurers struggle with Model Audit Rule (“MAR”) certification – not because of its complexity, but because they rely on traditional approaches that are no longer effective.
Crossing the $500 million premium threshold triggers MAR requirements that mandate stronger controls, formal accountability, and executive certification.1 Many organizations layer new requirements onto existing manual processes such as spreadsheets, emails, and disconnected control frameworks.
This approach leads to inefficiency, fragmented data, duplicated effort, and uncertainty about control effectiveness. MAR compliance becomes a resource-intensive process focused on tracking, validation and reconciliation, rather than reliable governance.
While MAR is a compliance hurdle, insurers quickly learn that it’s also an operational test, revealing an organization’s ability to administratively manage such a project across functions and at scale.
Technology can ease compliance burdens, but its value goes beyond increased efficiency. For organizations struggling with compliance structure and traceability, integrated Governance, Risk and Compliance (“GRC”) systems can be a game-changer.
The Accountability Test Behind MAR Certification
MAR certification requires management to answer four questions:
- Who owns the control?
- How do we know it was performed?
- What happened when it failed?
- What evidence supports management’s assertion?
Without visibility, ownership, evidence, and traceability, management cannot confidently answer these questions. While these questions center on accountability, technology is needed to answer them at scale.
How Technology Eases MAR Compliance
MAR compliance is more complex without the proper resources or technology the program truly requires. For many insurers, responsibility falls to internal audit or MAR compliance teams that are already stretched across multiple priorities. Even with the right expertise, managing the program and testing requirements can be difficult without dedicated technology.
The real value of a GRC platform is its ability to create a single source of truth across a platform that unites risks, controls, testing activities, deficiencies, and certifications. Many insurers already use GRC solutions to support existing programs, including Enterprise Risk Management and Cybersecurity Risk Management. By leveraging a shared data model across functions, organizations can improve visibility, reduce duplication of effort, and create stronger linkages between risk, controls, testing, and compliance activities.
Since MAR compliance involves finance, internal audit, compliance, IT, underwriting, claims, and executive leadership, organizations need a centralized platform to connect control ownership, testing, remediation, and certification activities across the enterprise.
Here are four key challenges with MAR readiness and how GRC platforms can help:
One: Accountability Begins With Evidence
Without a GRC platform, teams rely on email and manual follow-up to gather testing evidence from multiple stakeholders. As controls and stakeholders increase, these processes become more resource-intensive and harder to monitor, leading to delays, inconsistent documentation, and accountability gaps.
How GRC helps: MAR readiness evaluates an organization’s ability to consistently demonstrate control effectiveness. Technology supports this by centralizing evidence, strengthening accountability, and creating a defensible record of control performance. Additionally, finance departments could have their own controls that support both MAR and operational objectives. A GRC platform provides a consolidated view of controls, test results, and policies and procedures, enabling organizations to leverage existing compliance investments and minimize duplication.
Two: Accountability Requires a Single Source of Truth
When risks are maintained across spreadsheets and e-mails, no one has a complete picture of the organization’s risk profile or real-time visibility into MAR activities. This prevents the company from identifying interconnected risks, potentially creating compliance risk blind spots. Without ownership, accountability remains fragmented and compliance reactive. Teams spend more time gathering or reconciling information than managing risk.
How GRC helps: The platform centralizes risks, controls, processes, and systems into a single inventory, linking related documentation and evidence. More importantly, updates can be centralized to single point where updates are linked and automatically flow through to risk and control matrices, process narratives, flowcharts, and other documentation. This can reduce evidence duplication, inconsistency, and compliance resource efforts. MAR teams can focus on tasks that remain outstanding instead of chasing down control owners for updates on testing activities.
Three: Limited Risk Visibility Delays Remediation and Increases Risk
Control failures are inevitable, but the ability to respond effectively is what matters. Without a GRC system, organizations commonly rely on manual processes to log issues, assign accountability, manage remediation plans, monitor progress, and chase updates. This makes timely resolution difficult and onerous.
How GRC helps: Effective remediation requires visibility, accountability and timely escalation. A GRC platform can provide real-time insight into issue status, remediation progress, and ownership. By addressing deficiencies early, organizations can proactively manage risk.
Four: Executive Accountability Requires Defensible Evidence
MAR requires executive management, typically the CEO and CFO, to acknowledge their responsibility for establishing, maintaining, and designing effective internal controls over financial reporting (“ICFR”). This attestation must be supported by detailed documentation that is readily available upon a regulatory examination. Management must document how they evaluated ICFR effectiveness and disclose any unremediated weaknesses. CEOs and CFOs are held accountable when they sign the management reports. False or misleading statements could result in regulatory actions, civil actions, and penalties.
How GRC helps: Executive certifications are only as reliable as the evidence supporting them. A GRC platform creates structured certification workflows, captures sub-certifications from control and process owners, maintains supporting evidence, and provides executives with a defensible audit trail for management’s attestation.
The fundamental challenge of MAR extends beyond controls design, testing methodology, and documentation: it is accountability. Regulators expect organizations to demonstrate who was responsible, what was tested, what exceptions were identified, how those exceptions were resolved, and what evidence supports management’s conclusions. Organizations that rely on manual processes often struggle to answer these questions consistently. Integrated GRC platforms create the transparency and accountability needed to support executive certification.
Footnotes:
1: “NAIC Model Laws, Regulations, Guidelines, and other Resources: Annual Financial Reporting Model Regulation” NAIC Accounting, MO-205-16 (Q3 2015).
Related Insights
Related Information
Published
September 10, 2026
Key Contacts
Senior Managing Director
Managing Director
Senior Director