Objective 1.1High Priority7 min read

Compensating Controls

Alternative controls that provide equivalent security protection when primary controls cannot be implemented. Compensating controls substitute for standard controls when technical, business, or cost constraints make the original control infeasible.

Understanding Compensating Controls

Compensating controls are Plan B. When you can't implement the standard or recommended control, you substitute something else that provides equivalent protection. The key word is "equivalent"—compensating controls must address the same risk, just differently.

Real-world example: A compliance standard requires disk encryption on all endpoints. But you have legacy systems that can't support modern encryption. A compensating control might be: isolate those systems on a separate network segment, implement strict access controls, enhance monitoring, and ensure the data is encrypted when transmitted. You haven't encrypted the disk, but you've compensated with alternative protections.

Compensating controls require documentation. You must explain why the primary control is infeasible and demonstrate how the compensating control provides equivalent protection.

Why This Matters for the Exam

Compensating controls appear frequently in compliance and audit scenarios. The Security+ exam tests whether you understand that security isn't always about checking boxes—sometimes you need creative solutions that address the underlying risk.

This concept is especially important for Domain 5 (Security Program Management), which covers compliance frameworks. PCI DSS explicitly defines compensating control requirements, and many exam scenarios involve organizations that can't meet a specific standard requirement.

Understanding compensating controls also demonstrates security maturity. Anyone can follow a checklist. Knowing when and how to substitute equivalent protections shows you understand the "why" behind security requirements.

Deep Dive

When Compensating Controls Are Used

Technical Limitations

  • •Legacy systems that can't support modern security features
  • •Hardware constraints preventing software installation
  • •Incompatible applications blocking security updates
  • •Embedded systems with limited processing power

Business Constraints

  • •Systems that can't have downtime for security implementation
  • •Applications that would break with security changes
  • •Third-party systems not under your control
  • •Customer-facing systems with specific requirements

Cost Constraints

  • •Primary control too expensive for the risk level
  • •Budget limitations preventing ideal solutions
  • •Resource constraints on implementation

Temporary Situations

  • •Interim protection while migrating to new systems
  • •Bridge security during transition periods
  • •Emergency measures while primary controls are restored

Compensating Control Requirements

For a compensating control to be valid, it must:

1. Meet the intent of the original requirement 2. Provide similar protection level 3. Be above and beyond other existing controls 4. Be documented with justification 5. Be reviewed regularly for continued validity

Examples of Compensating Controls

Original RequirementBarrierCompensating Control
Encrypt all laptopsLegacy laptops can't run encryptionNetwork isolation + enhanced access controls + data classification to prevent sensitive data storage
MFA for all usersLegacy app doesn't support MFARestricted access hours + enhanced monitoring + IP restrictions + password complexity
Patch within 30 daysCritical system can't be patchedNetwork segmentation + virtual patching via IPS + increased monitoring
Antivirus on all endpointsIoT devices won't support AVNetwork isolation + traffic analysis + device behavior monitoring

Compensating Controls in Compliance

PCI DSS has formal requirements for compensating controls: • Must be "above and beyond" other DSS requirements • Must sufficiently offset the risk • Must be documented with clear justification • Must be reviewed annually at minimum

Other frameworks (HIPAA, SOC 2, ISO 27001) allow similar flexibility but may use different terminology.

How CompTIA Tests This

Example Analysis

Scenario: An organization's point-of-sale (POS) terminals run embedded software that cannot be updated to support current encryption standards. The organization isolates these terminals on a dedicated VLAN, implements strict firewall rules limiting their communication to only required servers, deploys network-based intrusion prevention monitoring their traffic, and ensures all data is encrypted before leaving the network segment.

Analysis: These are compensating controls because: • The primary control (modern encryption on POS) is infeasible • The alternative measures address the same risk (data protection) • Multiple controls work together to provide equivalent protection • The solution goes "above and beyond" with multiple layers

Key point: The organization didn't just skip the requirement—they compensated with alternative protections that address the underlying risk.

Key Terms to Know

compensating controlsalternative controlscontrol substitutionPCI DSSlegacy systemsrisk mitigationcompliance workaround

Common Mistakes to Avoid

Thinking compensating controls mean skipping security—they're not exceptions or exemptions. They're alternative controls that must provide equivalent protection.
Forgetting documentation requirements—compensating controls must be documented, justified, and reviewed. An undocumented workaround isn't a valid compensating control.
Confusing compensating with corrective—compensating controls substitute for other controls. Corrective controls fix problems after incidents. Different purposes entirely.
Assuming any alternative works—compensating controls must meet the INTENT of the original requirement and provide EQUIVALENT protection. "We did something else" isn't sufficient.

Exam Tips

Look for scenarios with constraints: "legacy system," "cannot be updated," "budget limitations," "business requirements prevent." These signal compensating control situations.
Compensating controls often involve multiple measures—since they're substituting for something, they typically need layers to achieve equivalent protection.
PCI DSS questions often involve compensating controls. If a question mentions payment card data and a system that can't meet a standard requirement, think compensating controls.
Remember the documentation requirement. A compensating control isn't just "what we did instead"—it's a formal, documented, justified alternative.

Memory Trick

"Compensating controls COMPENSATE for what you CAN'T do."

They're Plan B when Plan A isn't possible.

  • •The Substitution Test:
  • •Ask yourself: "Is this replacing another control that can't be implemented?"
  • •Yes → Compensating control
  • •No → One of the other types

The Equivalence Rule: Compensating control ≠ Weaker security Compensating control = Different approach, same protection level

The PCI DSS Memory Hook: PCI DSS = Payment Card Industry = Compensating Controls The exam loves PCI scenarios where compensating controls are needed.

  • •The Documentation Requirement:
  • •Real compensating controls are:
  • •Documented
  • •Justified
  • •Reviewed
  • •Equivalent in protection

Test Your Knowledge

Q1.An organization has legacy servers that cannot support modern encryption protocols. To protect sensitive data on these servers, the organization implements network segmentation, enhanced access controls, and continuous monitoring. What type of controls are these additional measures?

Q2.Which of the following is a requirement for a valid compensating control?

Q3.A PCI DSS assessment reveals that a merchant cannot implement the required point-to-point encryption on their payment terminals due to hardware limitations. What is the MOST appropriate response?

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