Most SEO failures aren’t caused by bad SEOs. They’re caused by organizations that don’t have the systems to support them.

That’s the argument Ash Nallawalla has been building across five books and over 24 years of enterprise SEO experience in Australia. As a visibility governance consultant based in Melbourne, Ash has worked in-house for some of Australia’s biggest brands, and seen firsthand what happens when no one above the SEO team understands what they do or why it matters.

On IMHO, I spoke with Ash about why he believes visibility needs to be governed at 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. However, the absence of governance is.”

When No One Owns It, Everything Breaks

Most SEO failures are structural. Which means the team didn’t fail, but the system did. And the damage could be disproportionate to the cause. A governance gap of weeks could create months of recovery. And governance is not a constraint on speed. However, the absence of governance is.

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

At one organization, he discovered in Google Search Console 22 million pages as “currently not indexed.” When Australia only has 25 million residents, he knew something has seriously gone wrong.

This was down to someone internally in the past had decided that creating a page for every combination of facet would be a good idea.

“There were 10 quintillion pages. And if you’ve not heard that number before, it is one followed by 18 zeros,” Ash explained. “We calculated that if Googlebot could read a thousand URLs a second, it would take 310 billion years to crawl all of them.”

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

“That place didn’t have governance because no one above the SEO level or the product manager level realized the problem. They just knew someone was doing SEO and yes, we’re getting lots of traffic.”

This kind of structural failure is what drove Ash to write his first book, Accidental SEO Manager, in 2022. As he put it, “In reality most people come into SEO with no background and that applies to the managers who are looking after enterprise SEO.”

A Maturity Model For Visibility Governance

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

“The C-suite gets to know that our visibility governance is at 80% or it’s at 20% or 30% whatever it is, and that corresponds to five levels.”

“Some of these questions are single points of failure. And if you said ‘not in place’ for any of them, it doesn’t matter what your real score is, you are capped at level two.” Ash explained.

A single point of failure (SPOF) might be something as fundamental as whether anyone is responsible for robots.txt. In some companies, Ash noted, they don’t even know what robots.txt is.

Selling Governance To Skeptics

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

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

Second, the rework cost. Fixing a visibility failure after the fact is far more expensive than preventing it, especially when the failure involves AI systems.

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

And third, for the skeptics who worry governance will slow things down: “You will move faster with governance than without it because you might have these big problems and it may take you an unknown amount of time to fix them.”

What To Tell A Board That’s Never Heard Of Visibility Governance

When pitching to a board for the first time, Ash recommends leading with money, then reframing SEO as infrastructure.

“Organic search visibility, which is the traditional SEO, is infrastructure. It’s not just a marketing exercise. It’s a capital asset with a yield.”

He frames AI-mediated discovery as a new category of risk, something boards are already familiar with in other contexts. Brand visibility can erode silently without any alerts firing, and traditional controls aren’t detecting it.

“If their paid costs are slowly creeping up, that’s not always because the search engine is charging more. It’s also because they’re having to advertise more. And that’s one of the early hints that there could be an external system that is brewing and it’s taking customers away and that’s the AI mediated search that their potential customers are beginning to use and they’re being led in other directions.

So the second thing that I say to them is that the risk profile of visibility has changed in the last two years and your traditional controls are not detecting it.”

Ash shared a real example where his CIO once asked why Bing Chat was recommending 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’s also a reputational dimension. If customers are leaving bad reviews on platforms the company doesn’t monitor, large language models are learning from that sentiment, and quietly dropping the brand from their recommendations.

“When you share responsibility without ownership, then governance will fail.”

Ash recommends boards ask four questions:

Who owns accountability for visibility performance at a strategic level?
Is that person senior enough to influence things?
Is visibility reporting reaching the board in a way that distinguishes between performing well today and being structurally sound tomorrow?
Are we treating AI-mediated visibility as a governance matter, or as a technology novelty someone in marketing is keeping an eye on?

The Leadership Test

Ash closed with what he calls the leadership test, a challenge to any organization that relies on individual heroics rather than systems.

“If your SEO depends on individuals pushing uphill against the system, then gradually their capability will vanish when they leave.”

He advocates for internal wikis, documented learnings, and hiring for capability rather than cultural fit. The goal is to reduce dependence on individuals and build structures that survive personnel changes.

“I’m saying to boards, put visibility on the agenda at every meeting, even if it’s a one sentence from the responsible person, “visibility is fine” 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 matters.”

Visibility Governance Isn’t Just For Enterprise

While governance is most obviously an enterprise concern, the principles apply broadly. Smaller companies are just as vulnerable to silent visibility erosion, perhaps more so, because they have fewer resources to detect or recover from it.

Where AI systems are reshaping how brands get discovered, the organizations that treat visibility as a governance matter rather than a marketing task are the ones most likely to survive the shift.

Watch the full interview with Ash Nallawalla here, or on YouTube.

Thank you to Ash Nallawalla for offering his insights and being my guest on IMHO.

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