Heavy framework
40 objectives × multiple practices × multiple activities × capability levels:
- Substantial documentation burden.
- Implementation complexity.
- Overhead disproportionate for smaller orgs.
ITIL overlap
ITIL and COBIT both touch IT service management:
- Combined implementations double overhead.
- Some confusion on responsibilities.
- COBIT design factors help but don't fully resolve.
Governance-management distinction in practice
EDM (governance) vs APO/BAI/DSS/MEA (management) distinction:
- Practically often blurred.
- Smaller orgs collapse governance to management.
Procurement signal limited
Compared to ISO 27001 / SOC 2:
- COBIT alignment less commonly procurement-requested.
- Implementation more strategic than procurement-driven.
ISACA certification ecosystem complexity
CISA / CISM / CRISC / CGEIT / CDPSE / COBIT certs:
- Multiple credential paths.
- Continuing education obligations.
- Cost over time accumulates.
Update cadence
COBIT 2019 published 2018. Major revisions infrequent:
- Cloud / DevOps / AI evolution outpaces.
- Focus areas partially address.
Counterpoint
- Genuinely useful governance framework.
- Cross-framework mapping reduces fragmentation.
- ISACA backing legitimate.
- Design factors and focus areas modernize approach.