6 Minutes - Read Now 
A question I hear from ethics and compliance leaders more than any other this time of year is some version of: How do I show my leadership what this year cost us? This year, we answered it by counting the work.
The result is “Proof on a Deadline: What 2026’s Regulatory Changes Mean for Your 2027 Planning,” a new research report that features Ethisphere’s 2026 Regulatory Impact Index. It documents something most of you felt all year (regulators passed fewer headline laws, and your programs absorbed more work anyway). It also gives you what you need to make the case that your program requires appropriate support and resourcing to do its job.
What We Counted
Part of our job at Ethisphere is to step back, spot the larger trends reshaping our profession, and hand practitioners something they can use. For this report, that meant measuring the load that new U.S., UK, and EU obligations put on ethics and compliance programs between Jan. 1, 2026, and Jan. 1, 2027.
We began by developing an AI tool that scanned 2026 regulatory activity across U.S. federal agencies, the states, the UK, and the EU. That produced an enormous amount of material, so Ethisphere’s Data & Services team determined which subject areas would matter most to chief ethics and compliance officers. Our subject matter experts then vetted the research obligation by obligation, traced every item to its primary source, and pressure-tested our first conclusions.
We identified 47 core regulatory obligations that took effect, changed, or arrived on the calendar during the year. We sorted each one by topic and by what it asks of your program: a week of work, a standing process, or a new function. Privacy and data rules got a separate tally of 36 obligations, which the report covers in its own sidebar. Then we read all of it against benchmark data from 138 World’s Most Ethical Companies® Honorees.
We partnered with SAI360 on this report because SAI360 sees something we don’t. Its regulatory change management tool helps clients stay on top of the pace and intensity of new regulation, which gives the company a clear view of the alert stream that lands on compliance teams week after week. Chapter 5 draws directly on SAI360’s own platform data, and you’ll find commentary throughout from Damola Ogundipe, SVP and Managing Director, AI and Regulatory Horizon Scanning Products at SAI360, whose closing perspective ends the report. The index, the benchmark, and the planning model are Ethisphere’s. SAI360’s data sits beside them, labeled as its own.
Why We Called It “Proof on a Deadline”
The title comes from two findings. The first is about proof. Regulators now price the quality of your compliance program into enforcement outcomes, and at least eight of this year’s 47 obligations tie a declination, a defense, a penalty discount, or a safe harbor to whether your program can prove it works. In each case, the benefit goes to the program that can produce its record.
The second is about deadlines. Fifteen of the 47 obligations demand evidence on a deadline, and those 15 set the budget. They draw on five underlying capabilities. Three of those evidence deadlines arrive in December 2027: the EU AI Act’s high-risk rules on Dec. 2, the EU Forced Labour Regulation’s product ban on Dec. 14, and California’s privacy risk assessment requirements on Dec. 31. Evidence of that kind takes most of a year to build, so you have to fund it in the 2027 budget your organization is setting right now.
The calendar didn’t help, either. Nineteen of the 20 enforcement-clock dates we tracked in 2026 landed on no fixed schedule, which means no one could have planned for them from the statehouse calendar. The report also follows the nine obligations that slipped during the year and sorts out whether each delay brought relief, shifted the work, or left the outcome uncertain.
The Numbers to Take to Your Board
The numbers I’d point you to first are our full-time equivalent (FTE) calculations. Ethisphere’s planning model puts the new work from 2026 at about 3.5 FTEs in year one for an illustrative U.S.-headquartered multinational, and about two FTEs every year after. For a median Honoree team, that’s roughly 10% of its hours in year one. The cost follows your organization’s footprint, not the size of your compliance team, so a lean team operating in the same markets takes on the same work as a large one.
Who on your team absorbed those hours? What got pushed aside to make room? And does your board know? Even among Honorees, only 66% put the resources their program needs in front of their board last year. Resourcing decisions require information, and this is information most boards haven’t seen, so we have presented it in a way you can easily share with your leadership.
How to Use the Report
If you have 15 minutes, start with the executive summary at the top of the report page. It walks through six findings, five actions for 2027, and the board case, and it closes with a Go Deeper table that points each common question to the chapter and exhibit that answers it. If you have more time (and I hope you’ll make it), the full report takes each finding apart across six chapters and 35 exhibits, with every counting rule laid out in Appendix A. Exhibit 34 lists every obligation by name, along with its domain, its cost tier, and the capability it depends on, and Appendix B2 links each one to its primary source. Together they let you find the obligations that likely apply to your organization, check each one against the regulation itself, and bring the matches to your counsel for review.
And don’t skip Chapter 6. It closes with three board slides and a talk track for your 2027 budget conversation, which I strongly encourage you to borrow. When you download the report, we’ll also email you a 2027 board meeting pack with those slides and the talk track the next morning.
Your program’s workload grew in 2026, and this report gives you the numbers to show it. Download “Proof on a Deadline” here. If you haven’t started that conversation with your CFO yet, now is the time.
Author Bio
Erica Salmon Byrne, J.D. | Chief Strategy Officer and Executive Chair, Ethisphere
As Chief Strategy Officer and Executive Chair, Erica Salmon Byrne is responsible for ensuring continuous and strong growth for the company while maintaining Ethisphere’s founding ethos that good businesses do better.
