A proposal, openly published

In-depth continuous assurance over shallow periodic monitoring

Every security compliance framework asks whether a control exists. Almost none of them can tell you whether it has been operating — across a full population, over an entire audit period, against the threats it was built to stop. ALCOVE is a proposed set of assurance levels for closing that gap.

What is ALCOVE?

Assurance Levels for Control Operating Viability & Effectiveness. It is a graduated way to say how much is actually known about a set of security controls — from "someone looked at the design" all the way to "the full population of evidence was assessed, historically, against the threats these controls exist to mitigate."

ALCOVE takes its shape from SLSA, the supply-chain assurance framework: levels give organisations somewhere to start and somewhere to climb, and give the people relying on them a way to ask for a specific rung instead of a yes/no.

  • Assurance
  • Levels for
  • Control
  • Operating
  • Viability &
  • Effectiveness
The ladder
  1. 1Design assessed
  2. 2Samples assessed
  3. 3Full populations, history and state
  4. 4All of the above, threat-informed

Each level is cumulative. Level 4 includes everything below it.

The problem

Three ingredients, three failures

Every security compliance framework is built from the same three parts: a set of requirements controls must meet, an audit methodology for judging how well they meet them, and a reporting artifact that conveys the result. Each part is failing in a way that limits how much assurance the whole thing can possibly provide.

01 · Requirements

Vague solutions for unclear problems

Control requirements are written without explicit reference to the threats they are meant to guard against, so organisations design controls that satisfy the wording without ever being shown to stop anything.

Imagine car safety written this way: “the car implements physical restraint measures to protect passengers against threats from abrupt deceleration events.”
02 · Audit methodology

20th-century methods, 21st-century systems

Transactional controls — access requests, provisioning, change tickets — do get tested historically, because a ticketing system leaves a trail. But stateful technical controls like at-rest encryption, EDR and WAFs are assessed only for their current state.

It doesn’t matter whether the audit period is 1 month or 12. A control tested only at the moment evidence was gathered was never really tested over the period.
03 · Reporting artifact

Static documents, dynamic environments

Modern organisations change their systems dozens to thousands of times a day, and every change can quietly break a control. The report describing those controls is a PDF finalised weeks after the last evidence was reviewed.

Why do we treat a point-in-time report as carrying assurance value more than a week after it was finalised?
Assurance levels

Four levels, one question: how much is actually known?

Levels are a shared vocabulary. An organisation can name the rung it is on; the people relying on it can require a specific rung instead of accepting a pass/fail. Each level is cumulative — every level contains the one below it.

Level 1 1
Requirements

Control designs assessed for viability.

Intended for

Demonstrating commitment to pursuing independent third-party assessment of control operating effectiveness.

Level 2 2
Requirements

Level 1 requirements + samples of control evidence assessed for historical transactions or current state.

Intended for

Providing basic, short-lived assurance about control operating effectiveness.

Level 3 3
Requirements

Level 2 requirements + full populations of control evidence assessed for historical transactions and state.

Intended for

Providing strong, long-lived assurance about control operating effectiveness.

Level 4 4
Requirements

Level 3 requirements, including control implementations based on Common Threat Mitigations (CTM) to guard against Common Threat Criteria (CTC).

Intended for

Providing strong, long-lived, threat-informed assurance about control operating effectiveness.

ALCOVE + SOC 2

Extend the report types rather than replace the framework

SOC 2 Type I and Type II still exist in this world and still carry their (limited) value. Extending the report types to III and IV lets SOC 2 express the higher rungs.

SOC 2 report types extended to align with ALCOVE levels
TypeFocusAligns to
I Suitability of controls to meet Trust Services Criteria (TSC)
II Suitability & effectiveness of controls to meet TSC
III Suitability & comprehensive historical effectiveness of controls to meet TSC ALCOVE Level 3
IV Suitability & comprehensive historical effectiveness of controls to meet TSC & protect against Common Threat Criteria (CTC) via Common Mitigation Criteria (CMC) ALCOVE Level 4

Reproduced from the original proposal. Note the naming: the mitigation half of the threat model appears as Common Threat Mitigations (CTM) in the levels table and the worked example below, and as Common Mitigation Criteria (CMC) here. Settling on one name is an open question for the framework.

Level 4 · Threat-informed criteria

Requirements that name the threat

At Level 4, criteria stop being self-contained assertions and start carrying the threats they exist to stop (CTC) alongside the mitigations known to stop them (CTM). Below is the single worked example from the original proposal: SOC 2’s CC6.6, with the ALCOVE additions marked.

Trust Services Criteria Points of Focus Common Threat Criteria (CTC) Common Threat Mitigations (CTM)
CC6.6
The entity implements logical access security measures to protect against threats from sources outside its system boundaries.
Protects Identification and Authentication Credentials

Identification and authentication credentials are protected during transmission outside its system boundaries and protected from unauthorized transmission outside its system boundaries. Credentials are stored in encrypted forms.
  1. Credential Access
    1. Unsecured Credentials: Credentials In Files
    2. Unsecured Credentials: Chat Messages
    3. Secrets in Config Files
Supporting evidence
  1. EMERALDWHALE: 15k cloud credentials stolen in an operation targeting exposed Git config files
  2. DEV-0537 criminal actor targeting organizations for data exfiltration and destruction
  3. Verizon DBIR 2024: “[Use of stolen credentials] is still our top action at 24% [of breaches]”
  4. Codecov supply chain breach
  5. GitHub Action tj-actions/changed-files supply chain attack
Maturity level 1
  1. Block plaintext credentials from being stored in source code repositories (using pre-commit hooks, push protection, etc.)
  2. Regularly scan source code repositories for plaintext credentials
  3. Disable or rotate all discovered plaintext credentials
Maturity level 2
  1. Regularly scan productivity applications for plaintext credentials (e.g. Slack, Teams, Jira, Google Drive, etc.)
Maturity level 3
  1. Detect plaintext credential exposures and exfiltration attempts in continuous integration (CI) systems
Existing SOC 2 language ALCOVE addition

This is the only worked example the proposal contains. A full CTC and CTM catalogue does not exist yet — building one is the substantive work Level 4 implies, and an open invitation.

The reporting artifact

A PDF cannot describe a system that never stops moving

An audit report still matters — for context about the system, the architecture, the controls and the auditor’s opinion. But alongside it, control operating effectiveness needs metrics that carry current and historical state, the way status pages changed the conversation about uptime.

Trust Center products already publish control indicators. Most of them show only current state, and some remove a control and its green checkmark entirely while it is failing. That is assurance theatre. An honest artifact keeps the failure on the page.

Historical control monitoring metrics

3 of 4 controls operating effectively

Illustrative. The proposal sketches what an ALCOVE reporting artifact could look like; this is that sketch made live. Each cell is one day. Hover or focus a cell for its state. Note the control that is currently degraded — it stays on the page.

Implementations

What it would take to reach Levels 3 and 4

Levels 3 and 4 make demands that no compliance PDF can satisfy: a full population of evidence rather than a sample, a history that cannot be quietly rewritten, and a link from each control back to the threats it exists to stop. Those are infrastructure problems, and open-source infrastructure for them already exists.

Open protocol · Apache-2.0

Corsair

Supports Level 3 Partial path to Level 4

Corsair is an open compliance trust-exchange protocol: it takes what your security tools already found and signs it into a cryptographic proof anyone can verify, without an account. It was not designed against ALCOVE — but several of its primitives are exactly what Level 3 requires.

What it already does
  • Commits a whole evidence population to one signature — an append-only, hash-linked evidence chain reduced to a single Merkle root that is signed into the credential.
  • Proves any single record belongs to that population via Merkle inclusion proofs, so an assessor can spot-check a claimed population without being handed all of it.
  • Binds a proof to its exact source artifact by hashing the original document, so the underlying evidence cannot be swapped after signing.
  • Keeps history append-only through SCITT registration, retaining retired signing keys so old proofs stay verifiable.
  • Detects regressions between periodscorsair diff compares two signed proofs and can fail a build on a regression.
  • Signals drift as it happens using OpenID SSF/CAEP events rather than waiting for the next audit.
What ALCOVE would still need to add
  • Population completeness. Corsair proves a committed set is intact; it does not assert the set is complete. Level 3 turns on exactly that distinction.
  • Transaction-level granularity. The finest signed granularity today is a control with a status, not the individual transactions or state samples behind it.
  • CTC → CTM mappings in the signed artifact. Corsair carries threat-model summaries and has MITRE ATT&CK lineage, but the control-to-threat mapping Level 4 rests on is not in the credential — its own roadmap marks threat-to-evidence as future work.

The CPOE specification defines a namespaced extension mechanism, which is a clean home for exactly these fields — an ext.alcove namespace carrying assurance level, population size and completeness, transaction-versus-state coverage, and CTC → CTM mappings. ALCOVE supplies the assurance semantics; Corsair supplies the verifiable envelope.

Visit grcorsair.com

Created and maintained by Ayoub Fandi. Early-stage and openly developed — capabilities above were read from its public specification and source, not from an ALCOVE conformance claim.

Open invitation

Yours

ALCOVE is a proposal, not a certification scheme. There is no registry, no accreditation body, and nothing to buy. What there is: a set of levels precise enough to argue with, and a lot of unbuilt work.

What is genuinely open
  • The CTC and CTM catalogue. One worked example exists. A usable Level 4 needs a real corpus of threats and the mitigations known to counter them.
  • A definition of population completeness that an auditor could test and a machine could verify.
  • Continuous control monitoring that retains state history for stateful technical controls, which is where the historical evidence for Level 3 has to come from.
  • An honest reporting artifact that leaves failing controls visible.
  • The incentive layer. Assurance this rigorous is unlikely to be bought voluntarily — cyber insurance is the most plausible forcing function.

Discuss it in the GRC Engineering Discord

The obstacle

Incentives, not capability

Nothing above is technically out of reach. The obstacle is that today’s incentives all point the other way. Organisations are rewarded for cheaper, weaker audits. Auditors are rewarded for not upsetting the client. Third-party risk teams have neither the leverage nor the incentive to say no to a vendor with weak controls.

Everyone in the picture is optimising the same thing: spend fewer resources, get more value. Any framework that ignores that will be adopted by nobody.

The most plausible correction is the party with the most leverage and the strongest appetite for reducing uncertainty — cyber insurance.

Instead of a questionnaire once a year, vendors continuously publish control evidence; insurers price against it; auditors consume it instead of screenshots; and customers get assurance at diligence time and continuously afterwards.

Prior art worth studying: AIUC-1’s AI assurance-plus-insurance framework, and usage-based insurance pricing built on continuous telemetry.

Related work

Where this comes from

The original proposal

“SOC 2 is dead, long live SOC 2” — the essay that introduced ALCOVE, its levels, and the SOC 2 Type III/IV extension.

Read it

The GRC Engineering Manifesto

ALCOVE is one attempt at core value #5: in-depth continuous assurance over shallow periodic monitoring.

grc.engineering

Threat-Informed Control Modeling

A GRC Engineering method for modelling a control against the threats it faces and the business it runs inside — the kind of reasoning a CTC/CTM corpus would need.

View TICM

Tell me where this is wrong

ALCOVE is a proposal published in the open so it can be argued with. What would work, what would not, and what would make it more viable?