Adapting Compliance Programs Amid the Decline of Middle Management

In a Navex article, Matt Kelly, CEO of Radical Compliance, examines how the decline of middle management is reshaping corporate compliance programs. He argues that while leaner management structures promise agility and innovation, they also create significant compliance and cultural challenges. With middle managers often serving as both control points and communication conduits, their absence alters how organizations enforce policies, foster ethics, and assess risk.

Kelly identifies three core issues. First, compliance leaders must ensure that policies, controls, and approval workflows remain practical and functional after restructuring. A reduction in sign-offs or oversight positions could expose approval gaps or new conflicts of interest. To mitigate this, compliance teams must maintain visibility into how policies map to specific managerial roles, working closely with HR to adjust processes or introduce compensating controls.

Second, Kelly warns that fewer managers could weaken the organization’s speak-up culture. Employees typically report concerns to their direct supervisors, but with fewer touchpoints, they may feel less comfortable doing so. Strengthening hotline accessibility, simplifying escalation procedures, and training remaining managers to handle ethics concerns effectively are critical steps to preserve trust and transparency.

Finally, risk assessment and remediation become more complex when fewer managers provide on-the-ground insights. Kelly recommends leveraging data analytics, closer collaboration with audit teams, and even exploring AI-driven analysis to keep risk management grounded in operational reality.

The takeaway? Compliance programs depend on adaptability, transparency, and ability, not headcount, to sustain ethical communication across changing corporate structures.