CISO Reporting line: Does it really matter?

The Chief Information Security Officer (CISO) plays a pivotal role in safeguarding organisations against cyber threats. But one question often sparks debate: Where should the CISO report into within the organisational structure?

This is a question / debate I see regularly on LinkedIn and within CISO circles. This seems to originate from the perspective that there is a single right answer - well, I believe there is, but it's not the one most expect or want!

Reporting Lines for CISOs

Let's start by looking at some of the possible reporting lines within an organisation.

Reporting to the CEO

Advantages:

• Board-Level Visibility: Elevates cyber security to a strategic priority, ensuring it gets the attention and resources required at the highest level.

• Independence: Allows the CISO to operate independently, free from IT or operational biases, which is critical for objective risk reporting and escalation.

• Direct Influence: The CISO can directly influence business decisions and strategy, embedding security into organisational culture and governance.

Challenges:

• Technical Understanding: CEOs may lack the technical expertise or bandwidth to fully grasp complex security risks, potentially leading to gaps in understanding or support.

• Communication Skills: Requires the CISO to translate technical risks into clear, business-focused language to ensure buy-in and effective decision-making.

• Potential Overload: CEOs already oversee numerous functions, so cyber security risks being one of many competing priorities.

Reporting to the COO

Advantages:

• Operational Integration: Aligns security with operational resilience, business continuity, and overall organisational risk management.

• Holistic Risk View: Provides a broader perspective on risks, ensuring that security is considered alongside other operational threats, such as supply chain or physical security.

Challenges:

• Competing Priorities: Security may be overshadowed by pressing operational concerns, especially in fast-paced or resource-constrained environments.

• Diluted Focus: Risk of diluting the strategic focus on cyber security, with the CISO’s agenda being subsumed under broader operational goals.

Reporting to the CIO

Advantages:

• IT Alignment: Enables seamless collaboration with IT teams, making it easier to influence technical security controls and respond to technical incidents.

• Integration: Security becomes an integrated part of IT operations, potentially streamlining processes and leveraging existing resources and expertise.

Challenges:

• Conflict of Interest: The CIO may prioritise IT performance, project delivery, or budgets over security, leading to potential conflicts.

• Narrow Focus: Security risks being seen as a subset of IT, rather than a broader organisational concern, which can limit its strategic impact.

• Budget Constraints: Security investments may be deprioritised in favour of other IT initiatives.

Reporting to the CTO

Advantages:

• Technology Focus: Close alignment with technology strategy, ensuring security is embedded into the organisation’s technology stack and product development lifecycle.

• Agility: Facilitates faster decision-making on technology-related security measures, especially in tech-driven organisations.

Challenges:

• Technical Bias: Security risks being perceived as purely a technical issue, rather than an organisational imperative.

• Limited Independence: The CISO may have less authority to challenge technology decisions that could compromise security.

• Potential for Overlap: CTOs may focus more on innovation and delivery, rather than risk management and compliance.

Reporting to the CFO

Advantages:

• Risk & Compliance Synergy: CFOs are increasingly responsible for enterprise risk and regulatory compliance, making this a logical fit in some organisations.

• Budget Influence: Direct access to financial decision-making can help secure funding for security initiatives.

Challenges:

• Limited Technical Insight: CFOs may lack the technical background necessary for nuanced security oversight.

• Financial Focus: Security may be viewed through a cost-control lens, potentially limiting investment in proactive measures.

Reporting to the Chief Risk Officer (CRO)

Advantages:

• Risk Management Alignment: Positions cyber security as part of the broader risk management framework.

• Regulatory Focus: Particularly beneficial for organisations in highly regulated industries, where legal and compliance risks are significant.

Challenges:

• Potential Siloing: Security may become too focused on oversight, rather than holistic risk management or proactive threat mitigation.

• Distance from Operations: May reduce the CISO’s influence over day-to-day technology and operational decisions.

Matrix or Dual Reporting

Some organisations use a matrix reporting structure, where the CISO reports functionally to one executive (e.g., CEO, CRO) and operationally to another (e.g., CIO, COO). This can help balance independence with integration, though it can also introduce complexity and ambiguity.

Anyone want to pick out the commonality of the challenges of the placements?

Well, if you had not noticed, it's priorities. Wherever the CISO reports into within an organisation, their reporting line may have priorities that are not, or do not include security.

Placement of a CISO Based on Business Type

Does the type of business you operate significantly influence where the CISO should report? Possibly - let's consider three examples. 1) Technical Product Business, 2) Retail Business and 3) Financial Services business.

Technical Product Businesses (e.g., SaaS, Technology Startups)

Common Reporting Line: CTO (sometimes CEO in security-driven startups)

Why?

• Security must be embedded from the ground up in the product lifecycle—this includes secure software development, DevSecOps, and rapid vulnerability remediation.

• The CTO and CISO need to collaborate closely to balance innovation with risk management, ensuring features aren’t shipped at the expense of security.

• Customer trust and compliance (e.g., SOC 2, ISO 27001) are often key differentiators, so the CISO’s influence on product strategy is critical.

Consideration: In rapidly scaling startups, reporting lines may evolve—early on, the CISO might report to the CTO, but as the business matures and faces more regulatory pressure, a shift to CEO or COO reporting may become necessary.

Retail Businesses

Common Reporting Line: CIO or COO

Why?

• Retailers process large volumes of personal and payment data, making data protection and PCI DSS compliance critical.

• The CIO ensures the CISO is tightly integrated with IT operations, covering e-commerce platforms, POS systems, and digital transformation initiatives.

• The COO perspective becomes vital for operational resilience—minimising downtime from cyber incidents and ensuring continuity across logistics and supply chains.

Consideration: For retailers with a significant online presence or omnichannel strategy, the reporting line may flex to reflect where the majority of risk sits—IT, operations, or even marketing (for customer data/privacy).

Financial Services (FS)

Common Reporting Line: COO or CEO (sometimes CRO in risk-driven organisations)

Why?

• FS organisations face intense regulatory scrutiny (e.g., DORA, GDPR, PCI DSS, FCA regulations) and high-value cyber threats.

• The CISO needs direct access to the board or executive committee to escalate risks, influence governance, and drive a culture of compliance.

• Reporting to the COO aligns cyber security with business resilience, operational risk, and incident response. Reporting to the CEO signals security’s strategic importance.

Consideration: In some FS firms, the CISO may report to the Chief Risk Officer (CRO), especially where cyber risk is managed as part of an integrated risk framework.

Additional Considerations

• Company Size and Maturity: In smaller organisations, the CISO may wear multiple hats and report to whoever owns the most risk (often the CTO or CIO). As the company grows, a shift to CEO/COO/CRO reporting is common.

• Regulatory Landscape: Highly regulated sectors may require the CISO to have direct board access, regardless of business type.

• Geography: In multinational organisations, reporting lines may differ by region, depending on local regulatory expectations.

1st vs 2nd Line Placement: The Three Lines of Defence Debate

In Financial Services and other regulated industries, the “Three Lines of Defence” model is often used to structure risk management. This model is also being adopted, in part, by less regulated businesses.

• 1st Line: Operational management, responsible for owning and managing risks.

• 2nd Line: Risk and compliance functions, providing oversight and guidance.

• 3rd Line: Internal audit, offering independent assurance.

With regard to the CISO role, the debate centres on whether the CISO belongs in the 1st line (operational) or 2nd line (oversight).

1st Line Placement

• Advantages: Positions the CISO closer to operational teams, enabling faster responses to threats. Encourages hands-on involvement in day-to-day security operations.

• Challenges: Creates potential conflicts of interest, as the CISO is both implementing and overseeing security measures. May limit the CISO’s ability to challenge operational decisions objectively.

2nd Line Placement

• Advantages: Reinforces independence, ensuring security oversight is unbiased. Aligns with governance and compliance requirements in regulated industries.

• Challenges: Risks creating a disconnect from operational realities. Slower response times to emerging threats due to the oversight focus.

In practice, and in my personal experience, many organisations adopt a hybrid approach, where the CISO operates across both 1st and 2nd line to balance operational agility with strategic oversight.

In other organisations, I have seen the split of Governance (often considered the Information Security aspects, such as policy) and technical implementation (cyber) split between 1st and 2nd line respectively.

The Human Element: Influence and Relationships

Let’s be honest, regardless of where a CISO sits on the org chart, their real impact comes down to their ability to influence, collaborate, and build trust across the business.

Foster Cross-Departmental Collaboration

Security isn’t just an IT issue; it’s a business-wide responsibility. A CISO who proactively engages with HR, legal, finance, operations, and even marketing can embed security into the DNA of the organisation.

• Example: By partnering with HR, the CISO can ensure security objectives are included in staff onboarding, annual reviews, and awareness programmes, making security a shared goal rather than a siloed function.

• Practical Tip: Regular cross-functional workshops or “security champions” networks can help break down silos and keep security top-of-mind.

Communicate in Business Terms

Not everyone speaks “security.” The most effective CISOs are those who translate technical risks into language that resonates at the boardroom table.

• Example: Instead of warning about a “critical vulnerability,” explain that it could lead to a “£2M operational loss” or “serious reputational damage.”

• Practical Tip: Use real-world scenarios, analogies, and impact-driven metrics to make risks relatable and actionable for non-technical stakeholders.

Position Security as a Business Enabler

Security shouldn’t be seen as a necessary evil or a cost centre. The CISO’s role is to show how good security can:

• Build customer trust and brand reputation

• Protect intellectual property and sensitive data

• Enable new business opportunities (e.g., winning deals that require high security standards)

• Strengthen operational resilience

Organisational Culture Matters

Of course, the organisation’s culture and hierarchy play a role. In highly hierarchical or traditional environments, the reporting line may still influence the CISO’s effectiveness. But in practice, a CISO who can build strong relationships and influence decision-makers will find ways to drive security forward—whether they report to the CEO, CIO, or anyone else.

Bottom line: If a CISO is respected, trusted, and able to influence all corners of the business, the reporting line becomes largely a formality. It’s the relationships, not the reporting, that make the difference.

So, What is the Best Placement for a CISO?

The single right answer is, in my opinion: Wherever your CISO can be most effective based on your business and culture, and their capabilities.

You need to consider your organisation’s structure, culture, and risk appetite, alongside your CISO's ability to influence stakeholders. Your CISO must be able to develop strong and well-maintained relationships.

To help, you can follow some of these guiding principles:

• Independence: Avoid as many conflicts of interest as possible, but accept there will always be some, by ensuring the CISO has the autonomy to challenge decisions.

• Visibility: Place the CISO close to decision-makers, relevant to your business model, to elevate security as a strategic priority.

• Integration: Enable the CISO to work across the organisation to embed security into its DNA.

Getting the placement of your CISO right is not just an organisational decision, or a strategic one, it is a decision that needs to be made based on a variety of factors, and the CISO you hire for that role should possess the right attributes to make that work.