Saturday, December 20, 2025
Risk and compliance training plan for 2026
2026 is the year risk and compliance training moves from one long annual course to short, role specific practice that people can apply the same day. Budgets are tight, attention spans are short, and regulators are asking for effectiveness evidence, not hours spent. This plan shows how organizations can design a modern compliance program while fitting how people actually learn at work.
Why 2026 training must change
Most employees will not finish a 60 minute compliance module. They will complete a five minute lesson on their phone right before a risky task. The shift is from awareness to application.
- Move from once a year to spaced microlearning, five to seven minutes at a time
- Replace generic lectures with role targeted scenarios tied to your risk map
- Deliver prompts in the flow of work, right when decisions happen
- Measure behavior and outcomes, not only completion and quiz scores
This approach aligns with what auditors ask for, training that is relevant to the risks people face and that can be evidenced as effective.
What regulators will expect to see
Regulators and auditors will not prescribe your format, they will test your effectiveness and documentation.
- Loi Sapin II, Article 17 requires training of exposed personnel, with evidence of frequency and relevance.
- ISO 37001 requires awareness and training appropriate to bribery risks and roles, with records kept.
- UNE 19601 and UNE 19603 require training as part of the compliance management system, proportionate to criminal and antitrust risks and responsibilities.
- AML programs must include ongoing employee training as part of internal controls.
Auditors typically ask for a matrix that maps risks to roles, objectives, frequency, attendance logs, test results, and remediation actions when scores are low. Expect reviewers to sample evidence specifically for anti corruption, antitrust, and criminal compliance (in Spain) training.
A role based training matrix for 2026
Tailor content to the risks each role faces. Start from your risk map, then set objectives and cadence.
Role or audience | Key risks | 2026 learning objectives | Best method | Cadence | Evidence to keep |
|---|---|---|---|---|---|
Executive team and board | Tone at the top, conflicts, third party approvals, sensitive deals | Set and model expectations, challenge red flags, approve risk appetite, oversee investigations | 45 minute live case clinic, quarterly brief | Quarterly | Agenda, attendance, case notes, decisions |
Sales and channel managers | Antitrust RPM and information sharing, gifts and hospitality, third party integrity | Spot and avoid risky conversations, escalate cartel red flags, apply gifts policy in practice | 6 minute microlearning modules, chat based scenarios | Monthly | Completion, 80 percent pass rate, case escalations count |
Procurement and operations | Third party due diligence, facilitation payments, bid rigging | Run proportionate diligence, detect bid patterns, apply contracting clauses | Interactive checklist sprints, 10 minute microlearning modules | Monthly | Diligence records, module results, exception logs |
Finance and accounting | Books and records, AML red flags, payment controls | Maintain accurate records, detect unusual payments, block prohibited vendors | Short video plus quick quiz, 15 minute workshops | Bi monthly | Quiz results, control exceptions resolved |
HR and recruiters | Conflicts, speak up, disciplinary framework | Manage conflicts, protect whistleblowers, apply sanctions fairly | Microlearning and templates, 30 minute yearly workshop | Quarterly micro, annual live | Attendance, case handling metrics |
Marketing and trade teams | Antitrust in associations and events, claims, influencer gifts | Safe conduct at events, avoid sensitive data exchanges, gifts logging | Live role play before events, 5 minute nudges | Before each event | Pre event attendance, post event attestations |
AML and KYC functions | CDD, EDD, sanctions screening | Maintain current procedures, escalate unusual activity, document decisions | Case reviews, risk sprints, 6 minute refreshers | Monthly | Case review logs, training scores |
Product, AI and data teams | AI Act roles and oversight, data ethics, model risk | Identify role under AI Act, apply human oversight, document transparency | 8 minute microlearning modules, live drill on oversight | Quarterly | Oversight roster, drill outcomes, logs |
All employees | Code of conduct, speak up, conflicts | Recognize a concern and report, avoid retaliation, declare conflicts | New hire microlearning series, annual refresher | Onboarding and annual | Completion records, hotline usage trends |
Use a simple three tier approach for depth. Exposed roles get monthly microlearnings plus drills, supporting roles get quarterly refreshers, all staff get onboarding and a yearly update.
A quarterly plan you can execute in 2026
Q1, foundations and high risk refresh
- Publish the annual plan and ownership, align with the updated risk map
- Run two microlearning campaigns for sales and procurement on antitrust and third parties
- Hold a 45 minute executive case clinic, cover conflicts and investigations
- Launch AI Act roles and oversight microlearning series for product and data teams
Q2, simulations and association season
- Before trade shows, run a 15 minute live role play for marketing and sales, issue a one page do and do not
- Conduct an anti corruption scenario drill with procurement and finance
- For AML functions, do a case review sprint using recent alerts, track decisions
Q3, culture and investigations
- Run an all hands speak up and anti retaliation refresh with microlearning scenarios
- Host a 20 minute board briefing on key risk indicators and training outcomes
- For AI teams, drill human oversight on one high risk workflow and document it
Q4, audit readiness and targeted remediation
- Identify low scoring teams, assign targeted microlearnings
- Produce an evidence pack for auditors with logs, content, and outcomes
- Review plan effectiveness with leadership, update 2027 objectives
Modern methods that fit short attention spans
- Spaced microlearning, a five to seven minute module every 2 to 4 weeks beats a single long course
- Scenario cards, one realistic decision per card with immediate feedback and a link to the policy
- Chat based practice, deliver quick dilemmas in the tools people use every day, for example email or chat
- Live case clinics, 25 minutes, 10 minute briefing and three five minute case discussions with decisions recorded
- Event driven nudges, pre populated do and do not reminders before trade shows, audits, and vendor signings
- Role play drills, short supervised simulations for dawn raids, investigations, and third party escalations
- Office hours, monthly 30 minute drop in with compliance for real questions from the field
Avoid long narrated slide decks. Replace them with focused problems people actually encounter, for example a distributor asking for a margin bump and confidential competitor price lists.
Build measurement into the plan
Tracking must go beyond completion to outcomes and behavior. Keep a clean evidence trail.
Metric | Target in 2026 | Why it matters |
|---|---|---|
Coverage by risk role | 95 percent of exposed roles trained within 30 days of plan launch | Sapin II and ISO 37001 expect exposed roles to be prioritized |
Scenario pass rate | 80 percent pass on first try, 95 percent after remediation | Shows understanding, enables targeted follow up |
Time to remediate low scores | Under 15 business days | Demonstrates responsiveness to risk |
Manager acknowledgment rate | 100 percent for teams in high risk markets | Reinforces tone and accountability |
Event nudge adoption | 90 percent of flagged events have a pre event training confirmation | Reduces competition law exposure at meetings |
Evidence completeness | 100 percent of sessions with roster, content, results, and policy link | Supports audits and certifications |
Document how you will respond to results. For example, if sales in country A score below target on RPM scenarios, assign a live clinic within two weeks and pause risky commercial campaigns until after the session.
Governance and accountability
- Assign a single owner per audience, for example sales training owner is the commercial excellence lead, with compliance support
- Agree sign off for content with legal and external counsel when needed, especially for antitrust and criminal compliance
- Establish a quarterly steering review with compliance, HR, business leaders, and internal audit
- Keep a controlled copy of each module and scenario, date stamped, with a link to the policy and risk it supports
The bottom line
If you build a 2026 risk and compliance training plan around short, role specific scenarios that are delivered in the flow of work and tied to your risk map, you will raise real capability and satisfy auditors. Keep the evidence tight, automate the busywork, and use live case clinics to build judgment where it counts.
Ready to connect your training plan to risks, policies, workflows, and evidence, without adding headcount, speak with Naltilia. Our platform helps mid sized teams align risk assessments to training priorities, automate reminders and attestations, and keep audit ready records while you focus on content and culture.