How GRC Leaders Can Prepare for Emerging Federal Data and Privacy Legislation
- Harshil Shah
- Dec 29, 2025
- 3 min read

Federal data and privacy requirements are expanding rapidly as agencies collect, share, and analyze more information than ever before. New legislation, updated OMB guidance, and evolving expectations around data protection are placing increased pressure on GRC leaders to anticipate change rather than react to it. Agencies that prepare early can reduce compliance risk, improve trust, and avoid costly remediation efforts later.
Why Data and Privacy Oversight Is Accelerating
Several forces are driving heightened scrutiny of federal data practices:
Increased data sharing across agencies and with external partners
Expanded use of analytics, AI, and automation
Rising public expectations for transparency and privacy protection
High-profile data breaches and misuse incidents
As a result, lawmakers and oversight bodies are pushing for stronger, more consistent privacy and data governance across the federal enterprise.
What’s Likely Coming Next
While specific legislative timelines vary, federal agencies should expect continued movement in several key areas:
Stronger requirements for data minimization and purpose limitation
Expanded privacy impact assessments for emerging technologies
Clearer accountability for data stewardship and ownership
Increased reporting expectations tied to data sharing and AI use
Greater alignment between cybersecurity, privacy, and enterprise risk oversight
These trends point toward more integrated governance models rather than standalone privacy programs.
Updating Frameworks Before Mandates Arrive
GRC leaders do not need to wait for new laws to begin preparing. Many of the expected requirements are already reflected in existing standards. Agencies should proactively review and update alignment with:
NIST Privacy Framework for managing privacy risk alongside cybersecurity risk
NIST Risk Management Framework (RMF) to integrate data protection into system authorization
NIST Cybersecurity Framework (CSF 2.0), particularly the expanded governance focus
OMB Circular A-108 and related privacy guidance
Harmonizing these frameworks now reduces duplication and positions agencies for smoother compliance transitions.
Strengthening Data Governance as a Compliance Foundation
Emerging legislation is likely to place greater emphasis on how agencies manage data throughout its lifecycle. Modern data governance programs should:
Maintain automated data inventories and catalogs
Standardize metadata and data classifications
Define clear stewardship and ownership roles
Track data sharing agreements and access permissions
These capabilities allow agencies to answer oversight questions quickly and accurately—often the difference between smooth reviews and extended findings.
Integrating Privacy into Enterprise Risk Management
Privacy risk is increasingly viewed as enterprise risk. GRC leaders should ensure privacy considerations are embedded into:
Enterprise risk registers
System-level risk assessments
Technology acquisition and vendor reviews
AI and data analytics governance processes
This integration enables leadership to understand how privacy risks affect mission outcomes—not just regulatory compliance.
Using Automation to Stay Ahead
Manual compliance approaches will not scale as data and privacy requirements grow. Automation helps agencies:
Continuously monitor access to sensitive data
Automate evidence collection for audits and reporting
Identify policy gaps and emerging risks early
Reduce reliance on last-minute compliance efforts
Continuous monitoring and automated reporting align with both current oversight expectations and future legislative direction.
Preparing Leadership and the Workforce
Legislative readiness is not only technical—it is organizational. GRC leaders should brief executives on upcoming trends, clarify accountability for data protection, and ensure staff understand evolving responsibilities.Agencies that invest in awareness and training reduce the likelihood of non-compliance driven by misunderstanding rather than intent.
Looking Ahead
Emerging federal data and privacy legislation will continue to raise the bar for accountability, transparency, and governance. GRC leaders who act now—updating frameworks, strengthening data governance, and integrating privacy into enterprise risk—will position their agencies to adapt with confidence.Preparation today transforms future compliance from a disruption into a managed transition.
For more insights on federal GRC, data governance, and privacy readiness, visitGRCMeet.org.




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