How to Build a Risk Register from Scratch: A Practical Guide for 2026

Every risk management program starts with the same artifact: a risk register. Whether you're a startup preparing for SOC 2, a mid-size company formalizing operations, or an enterprise consolidating scattered risk data, the risk register is where it all lives.

The problem is that most organizations build their first risk register wrong — they either make it too complex to maintain or too simple to be useful.

What a Risk Register Actually Is

A risk register is a structured record of identified risks, their assessed severity, who owns them, and what's being done about them. It's the single source of truth for your risk posture.

At minimum, each entry captures:

• What the risk is (title and description)
• How bad it could be (likelihood and impact scores)
• Who is responsible (owner)
• What you're doing about it (treatment decision)
• When it gets reviewed next

That's it. Everything else — categories, controls, KRIs, residual scoring — is layered on as your program matures.

Step 1: Define Your Risk Categories and Scoring

Before you identify a single risk, establish two things: how you'll categorize risks and how you'll score them.

Risk Categories

Categories group risks by domain. A practical starting set:

Category	What It Covers
Cybersecurity	Data breaches, ransomware, access control failures
Operational	Process failures, system outages, human error
Financial	Revenue loss, cost overruns, fraud
Compliance	Regulatory violations, audit failures, contractual breaches
Reputational	Brand damage, customer trust erosion, public incidents
Strategic	Market changes, competitive threats, failed initiatives

You can always add categories later. Don't overthink this — 5-8 categories cover most organizations.

Scoring Methodology

The 5x5 likelihood-by-impact matrix is the industry default for good reason: it's simple enough for non-specialists to use but granular enough for meaningful differentiation.

Likelihood Scale:

Score	Label	Definition
1	Rare	Less than 5% chance in 12 months
2	Unlikely	5-20% chance in 12 months
3	Possible	20-50% chance in 12 months
4	Likely	50-80% chance in 12 months
5	Almost Certain	Greater than 80% chance in 12 months

Impact Scale:

Score	Label	Definition
1	Negligible	Minimal disruption, less than $10K loss
2	Minor	Limited disruption, $10K-$100K loss
3	Moderate	Significant disruption, $100K-$500K loss
4	Major	Severe disruption, $500K-$2M loss
5	Catastrophic	Existential threat, greater than $2M loss

The risk score is simply Likelihood × Impact, producing a range of 1-25. Map these to levels:

• 1-5: Low (green)
• 6-12: Medium (yellow)
• 15-20: High (orange)
• 21-25: Critical (red)

Customize the definitions to fit your organization's context. A $10K loss might be negligible for a large enterprise but significant for a startup.

Step 2: Identify Your Risks

This is where most teams stall. They either try to boil the ocean or sit in a conference room guessing. Use multiple identification methods:

Workshop Approach

Bring together 5-8 people across departments. For each category, ask:

• "What could go wrong that would significantly affect our objectives?"
• "What has gone wrong in the past 2 years?"
• "What keeps you up at night?"

Timebox each category to 15 minutes. Capture everything, then consolidate duplicates.

Document Review

Pull from existing sources:

• Past incident reports and post-mortems
• Audit findings (internal and external)
• Compliance gap analyses
• Insurance claims
• Customer complaints

Industry Intelligence

Use industry-specific risk libraries as a checklist. Frameworks like NIST CSF, ISO 27001 Annex A, and COSO ERM provide structured risk catalogs you can filter for relevance.

Writing Good Risk Descriptions

A well-written risk has three parts: cause, event, and consequence.

Bad: "Cybersecurity risk"

Good: "Due to insufficient access controls on cloud infrastructure, an unauthorized party could access customer data, resulting in regulatory fines, breach notification costs, and customer churn."

The formula: "Due to [cause/vulnerability], [threat event] could occur, resulting in [business impact]."

Step 3: Score Each Risk and Assign Owners

With risks identified, assess each one:

1. Rate likelihood — how probable is this in the next 12 months?
2. Rate impact — if it happens, how severe is the consequence?
3. Calculate the inherent risk score — Likelihood × Impact
4. Assign an owner — who is accountable for this risk?

On Risk Ownership

Every risk must have exactly one owner. This is the person who:

• Monitors the risk and its indicators
• Ensures treatment plans are progressing
• Reports on the risk at review meetings
• Escalates when the risk exceeds tolerance

Risk owners are typically department heads or senior managers with the authority to allocate resources. Assigning risk ownership to someone without decision-making power guarantees the risk will be neglected.

Step 4: Define Treatment Decisions

For each risk, choose a treatment strategy:

Treatment	When to Use	Example
Mitigate	You can reduce likelihood or impact through controls	Implement MFA to reduce unauthorized access risk
Accept	The risk is within appetite and the cost of treatment exceeds the benefit	Accept the risk of minor website downtime during maintenance
Transfer	Another party can absorb the risk more efficiently	Purchase cyber insurance, outsource to a specialist
Avoid	The risk is unacceptable and no treatment is sufficient	Discontinue a product line that creates regulatory exposure

For mitigated risks, document the specific controls and actions:

• What controls are in place or planned?
• What actions need to be completed?
• Who is responsible for each action?
• What is the target completion date?

After controls are applied, score the residual risk — the remaining risk level after treatment. Residual risk should never exceed inherent risk. If it does, your controls aren't doing what you think.

Step 5: Set Review Schedules and Operationalize

A risk register that isn't reviewed regularly is just documentation theater. Set review cadences based on risk level:

• Critical risks: Monthly review
• High risks: Monthly review
• Medium risks: Quarterly review
• Low risks: Semi-annual review

Beyond individual risk reviews, schedule a quarterly risk committee meeting where owners present their top risks, treatment progress, and any emerging threats.

When to Move Beyond Spreadsheets

Spreadsheets work for the first iteration of a risk register. They stop working when:

• Multiple people need to update risks concurrently
• You need an audit trail of who changed what and when
• Risk scoring should calculate automatically based on your methodology
• Review reminders need to fire without someone manually checking dates
• Leadership expects real-time dashboards instead of quarterly slide decks
• You're mapping risks to controls and compliance frameworks

At that point, a GRC platform eliminates the manual overhead and provides the workflow, automation, and reporting that spreadsheets can't.

Common Risk Register Mistakes

Listing risks too vaguely. "Cybersecurity" is not a risk — it's a category. Risks need specificity to be actionable.

No ownership. If every risk is "owned by the risk team," no one is really accountable. Distribute ownership to the people closest to each risk.

Scoring without definitions. If your team doesn't share a common understanding of what "Likelihood 4" means, your scores will be inconsistent. Define each level clearly and reference the definitions during assessments.

Set and forget. The biggest failure mode is building a risk register for an audit and never looking at it again. A risk register is a living tool, not a compliance artifact.

Too many risks too soon. Starting with 100+ risks guarantees that most will be poorly defined and never reviewed. Start with 15-20, manage them well, and expand deliberately.

Getting Started Today

You don't need a perfect risk register to start managing risk effectively. You need a register that's good enough to use, owned by people who will maintain it, and reviewed on a regular cadence.

Start with your top 10-15 risks. Score them honestly. Assign real owners. Set review dates. Iterate.

The organizations that manage risk well aren't the ones with the longest risk registers — they're the ones that actually use them.