Building an enterprise capability model can be challenging, but using accelerators like APQC, it's possibile to come up with a reasonable straw model quite quickly. The intent of this post is to provide what I've learned about building out the model at the enterprise level. I will complement this post with one tomorrow about how capability models should look at the line-of-business level.
For Level 1 capabilities), I think that using the APQC description of levels works just fine. Level 1 is an organizing structure and are not capabilities unto themselves. The purpose of L1 is to give your fellow architects an easy way to find the capabilities that they're looking for.
Level 2 capabilities, in my view, are also organizing structures and not capabilities. They provide much greater precision than the L1 but can also generally be used to communicate with high level executives.
At L2 is also when your design choices begin to matter. The APQC - which is more of a process model - creates several layers of organization and classification. In this example, they've created a level for "3.3 Develop Sales Strategy." I don't find this abstraction particularly useful especially given how specific the L3 capabilities are such as 3.3.1 Develop Sales Forecast. Develop Sales Forecast provides far more clarity - I would dispense altogether with Develop Sales Strategy and make Develop Sales Forecast and its siblings my L2 capabilities. By removing the original 3.3, we're flattening the hierarchy so that we can enable a more modular taxonomy of L3 capabilities. (More on that tomorrow).
One note on how you define and place your capabilities. Generally, the L1 models follow function, i.e. R&D, Marketing, Sales, etc. Don't confuse the functions with the organizations that you may be supporting. For example, our sales people are involved in getting agreements signed and managed. We have a capability to manage that called "Agreement Management." Although this is a capability that's needed in the sales organization, we don't classify it for the purposes of the model in the Sales capabilities. Instead, we group Agreement Management with other like capabilities - in the Legal capability grouping. This makes the capability easier to find for other architects and also ensures that we're not duplicating capability taxonomy in our framework.
I think that the right number of capabilities for an enterprise (at L3) is between 500-700 capabilities. This provides enough precision without having a taxonomy that is too unwieldy to steward and manage. L3 is usually a capability - that is, a business outcome unconstrained by how it's implemented by people, process, information, or technology. The APQC ones (L4 in their model) are generally written to sound more like processes.

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