How to Avoid Top-Down SEO System Failures with the Visibility Governance Maturity Model


Most SEO failures are not caused by bad SEO. They are caused by organizations that do not have the systems to support them.

This is the argument that Ash Nallawalla has developed through five books and over 24 years of experience in business SEO in Australia. As a viewability governance consultant based in Melbourne, Ash has worked in-house for some of Australia’s biggest brands and has seen first-hand what happens when no one above the SEO team understands what they’re doing or why it’s important.

In my humble opinion, I spoke with Ash about why he thinks visibility should be governed at the board level, how his maturity model works, and why the rise of AI-mediated discovery makes this more urgent than ever.

“Governance is not a constraint on speed. On the other hand, the absence of governance is.”

When no one owns it, everything breaks

Most SEO failures are structural. Which means the team did not fail, but the system failed. And the damage could be disproportionate to the cause. A weeks-long gap in governance could create months of recovery. And governance is not a constraint of speed. However, the lack of governance is.

Ash shared an example that illustrates how catastrophic a governance deficit can be.

At one organization, he discovered 22 million pages in Google Search Console as “currently unindexed.” With Australia only having a population of 25 million, he knew something was seriously wrong.

This was due to someone internally in the past deciding that creating a page for each combination of facets would be a good idea.

“There were 10 quintillion pages. And if you’ve never heard that number before, it’s followed by 18 zeros,” Ash explained. “We calculated that if Googlebot could read a thousand URLs per second, it would take 310 billion years to crawl them all.”

Despite this, the site still ranked highly and received 5 million Googlebot visits per day. The problem was invisible to anyone above the SEO or product manager level.

“This place had no governance because no one above the SEO level or the product manager level realized the problem. They just knew that someone was doing SEO and yes, we were getting a lot of traffic.”

This type of structural failure is what pushed Ash to write his first book, “Accidental SEO Manager,” in 2022. As he said: “The reality is, most people go into SEO without any experience and this applies to managers who deal with enterprise SEO.

A maturity model for visibility governance

Ash has since developed what he calls the Visibility Governance Maturity Model (VGMM), borrowing from Carnegie Mellon’s Capability Maturity Framework used in software development. It maps governance across seven areas, SEO (including local and international), content, website performance, accessibility and AI governance, into five levels expressed as a percentage.

“Leaders are learning that our visibility governance is 80% or 20% or 30%, it doesn’t matter, and that corresponds to five levels. »

“Some of these questions constitute single failing points. And if you answered ‘not up’ to any of them, no matter your actual score, you are limited to level two.” » Ash explained.

A single point of failure (SPOF) can be something as fundamental as whether someone is responsible for the robots.txt file. At some companies, Ash noted, they don’t even know what the robots.txt file is.

Selling governance to skeptics

When boards argue against the need for governance, Ash uses three arguments.

First, the system test: “If everything works great this month, are we guaranteed that next month and the month after that everything will work great? And if not, there is a problem we need to investigate.”

Second, the cost of retouching. Fixing a visibility failure after the fact costs much more than preventing it, especially when the failure involves AI systems.

“If ChatGPT suddenly stops recommending your brand, you may not realize it. Your traffic is up. Your rankings are where they were. It’s not effective, but your competitors are doing better than you.”

And third, for skeptics who worry that governance will slow things down: “You will move faster with governance than without it, because you may have big problems and it may take you an indefinite amount of time to resolve them. »

What to say to a board of directors who has never heard of governance by visibility

When first presenting to a boardroom, Ash recommends leading with money, then reframing SEO as infrastructure.

“Organic search visibility, which is traditional SEO, is infrastructure. This is not just a marketing exercise. It is a capital asset with a return.

He sees AI-mediated discovery as a new category of risk, something that boards are already familiar with in other contexts. Brand visibility can silently erode without any alerts going off, and traditional controls don’t detect it.

“If their costs are slowly increasing, it’s not always because the search engine is charging more. It’s also because they have to advertise more. And that’s one of the first clues that there might be an external system brewing that’s taking away customers, and that’s the AI-mediated search that their potential customers are starting to use, and they’re being driven in other directions.

The second thing I tell them is that the visibility risk profile has changed over the last two years and your traditional controls aren’t picking up on it.

Ash shared a real-life example in which his CIO once asked why Bing Chat recommended competitors but not their own brand. The cause turned out to be a blocked Common Crawl bot (CCBot), which Bing Chat had relied on during its learning phase. “We unblocked CCBot, and within a few months it started recommending our brand.”

There is also a reputational dimension. If customers leave bad reviews on platforms the company doesn’t monitor, big language models learn from that sentiment and quietly drop the brand from their recommendations.

“When you share responsibility without ownership, then governance fails. »

Ash recommends boards ask four questions:

  • Who is responsible? for visibility performance at a strategic level?
  • Is this person old enough to influence things?
  • Are visibility reports reaching the board in a way that distinguishes between good performance today and a strong structure tomorrow?
  • Do we treat AI-mediated visibility as a governance issue or as a technological novelty that marketing is closely monitoring?

The leadership test

Ash ended with what he calls the Leadership Test, a challenge for any organization that relies on individual heroism rather than systems.

“If your SEO depends on individuals bucking the system, then gradually their abilities will disappear when they leave.”

He advocates internal wikis, documented learning, and recruiting based on capabilities rather than cultural fit. The goal is to reduce dependence on individuals and build structures that survive personnel changes.

“I tell boards to put visibility on the agenda for every meeting, even if it’s just one sentence from the person in charge, ‘visibility is great’ or whatever they want to report, but it reminds the board at every meeting that SEO and now external visibility are both very important infrastructure issues.

Visibility Governance Isn’t Just for Business

Although governance is clearly a business concern, the principles apply widely. Small businesses are just as vulnerable to the silent erosion of visibility, perhaps even more so, because they have fewer resources to detect or recover from it.

As AI systems reshape how brands are discovered, organizations that treat viewability as a governance issue rather than a marketing task are most likely to survive this shift.

Watch Ash Nallawalla’s full interview here:

Thanks to Ash Nallawalla for offering his ideas and being my guest on IMHO, and learn more about the Visibility Governance Maturity Model in the SEO Management Book Series.

More resources:


This article was originally published on Shelley edits.


Featured image: Shelley Walsh/Search Engine Journal



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