ISO Survival Kit: Top 100 ISO 22301 Lead Auditor Audit Failures (And How to Avoid Them)

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Written by Matthew Hale

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Achieving ISO 22301 certification is a powerful milestone for any organization serious about business continuity management (BCM). But certification is only the beginning — maintaining it requires deep system understanding, strategic leadership, and airtight audit readiness.

 

To help you navigate the ISO 22301 certification process with confidence, we interviewed over 200 certified ISO 22301 Lead Auditors and reviewed real-world audit findings across industries. The result: a comprehensive breakdown of the most frequent audit non-conformities, their root causes, and practical ways to fix them.

 

The guide provides you with the visibility and insight you need to close gaps before they are flagged- whatever the situation, whether it's an internal review, your first external audit, or making an ISO 22301 audit checklist. 

 

In the ISO Survival Kit series, the blog acts as a practical guide to your undertaking with ISO, aligned with the complete ISO 22301 framework.

What Auditors Look For in ISO 22301:2019 Audits

1. Business Impact Analysis (BIA) Is Missing or Incomplete

📌 Clause: 8.2.2 – Business Impact Analysis

What’s going wrong:

Organizations either skip the BIA or conduct it as a one-off checklist exercise. Impact categories are vague, and recovery time objectives (RTOs) aren’t clearly defined.

Why it matters during an audit:

The BIA is foundational to ISO 22301. Without it, there’s no structured understanding of critical processes, dependencies, or continuity priorities — which weakens the entire BCMS.

How to fix it:

✔ Conduct BIAs for all critical business functions
✔ Include financial, legal, reputational, and operational impact categories
✔ Define RTOs and maximum tolerable downtimes (MTDs)
✔ Update the BIA annually or when major changes occur

Real-world result:

A robust BIA gives auditors confidence that your continuity strategy is based on real priorities — not assumptions.

2. No Documented Business Continuity Strategy

📌 Clause: 8.3.1 – Business Continuity Strategy

What’s going wrong:

Organizations jump straight to response plans without documenting the strategic approach to continuity — including people, premises, technology, and suppliers.

Why it matters during an audit:

ISO 22301 expects strategy before tactics. Without documented strategies, auditors can’t verify the rationale behind your continuity plans.

How to fix it:


✔ Define strategies for each critical process or function
✔ Consider relocation, work-from-home, manual workarounds, cloud recovery, etc.
✔ Include resourcing, responsibility, and dependencies
✔ Review strategy during management reviews

Real-world result:

Documented strategies ensure that response plans are purposeful, realistic, and aligned with risk appetite.

3. Continuity Plans Are Too Generic or Irrelevant

📌 Clause: 8.4.2 – Business Continuity Plans

What’s going wrong:

Plans are templated or outdated. They fail to reflect actual business operations, stakeholder roles, or contact information.

Why it matters during an audit:

Ineffective plans could collapse during a real crisis. Auditors assess whether plans are practical, role-specific, and up to date.

How to fix it:

✔ Tailor plans by department, site, or process
✔ Include step-by-step response actions, communication trees, and escalation paths
✔ Assign responsibilities and include contact details
✔ Review and test plans at least annually

Real-world result:

Clear, actionable plans give staff confidence and ensure real-world effectiveness under stress.

4. No Testing or Exercising of Continuity Plans

📌 Clause: 8.5 – Exercising and Testing

What’s going wrong:

Continuity plans exist but haven’t been tested — or exercises are limited to tabletop discussions without evaluation.

Why it matters during an audit:

Testing is critical for verifying readiness. Auditors expect evidence that plans have been tried, evaluated, and improved.

How to fix it:

✔ Create an annual testing schedule (including different types: tabletop, simulation, technical)
✔ Set clear objectives and scenarios
✔ Record results, gaps identified, and lessons learned
✔ Track improvement actions from test outcomes

Real-world result:

Regular exercises build competence, expose gaps, and satisfy auditors that your BCMS is functional — not theoretical.

5. Lack of Leadership Commitment to Business Continuity

📌 Clause: 5.1 – Leadership and Commitment

What’s going wrong:

Top management delegates continuity to technical teams without providing resources, direction, or review of objectives.

Why it matters during an audit:

ISO 22301 expects leadership to actively support the BCMS — not just sign policies. Weak leadership = poor system credibility.

How to fix it:

✔ Involve leadership in risk acceptance, recovery targets, and policy approvals
✔ Allocate funding and resources for BCMS activities
✔ Include BCMS in strategic planning and governance structures
✔ Require management review participation

Real-world result:

Leadership-driven programs are more resilient, prioritized, and aligned with business goals.

6. Risk Assessments Are Missing or Not Linked to BIA

📌 Clause: 8.2.3 – Risk Assessment

What’s going wrong:

Risks are assessed generically (e.g., "cyberattack," "power failure") without linking them to BIA outputs or recovery planning.

Why it matters during an audit:

Risk and impact must be integrated. A fragmented approach means continuity measures may not address true vulnerabilities.

How to fix it:

✔ Identify risks to business continuity (including internal and external threats)
✔ Link each risk to specific BIA-identified impacts
✔ Evaluate likelihood, impact, and existing controls
✔ Reassess risks after incidents or organizational changes

Real-world result:

Risk-informed planning strengthens your BCMS and aligns prevention with critical operations.

7. Poor Documentation Control Over BCMS Materials

📌 Clause: 7.5 – Documented Information

What’s going wrong:


Critical plans, BIAs, or test reports are stored ad hoc — with no version control, review history, or central repository.

Why it matters during an audit:


Auditors need confidence that continuity documentation is current, reviewed, and available when needed.

How to fix it:


✔ Store BCMS documents in a shared, secured system
✔ Apply version control, approvals, and access permissions
✔ Review documents periodically and after exercises/incidents
✔ Train staff on where to find plans and forms

Real-world result:

Organized documentation improves reliability, audit preparedness, and crisis accessibility.

8. No Evidence of Corrective Action After Tests or Incidents

📌 Clause: 10.2 – Nonconformity and Corrective Action

What’s going wrong:


Gaps are found during tests or real events — but lessons aren’t documented or followed up with action.

Why it matters during an audit:


ISO 22301 is about continual improvement. Auditors expect a closed-loop system for learning and correcting.

How to fix it:

✔ Create a BCMS corrective action log
✔ Record issues found during exercises or incidents
✔ Assign owners and deadlines for each action
✔ Review completion in management meetings

Real-world result:


Following through on findings builds a culture of resilience and responsiveness.

9. Stakeholders Are Unaware of Their Continuity Roles

📌 Clause: 7.3 – Awareness

What’s going wrong:


Key personnel (e.g., process owners, IT, facilities) don’t know what to do in a disruption — or that they’re even part of the BCMS.

Why it matters during an audit:


Auditors often ask staff to explain their role in continuity. Poor awareness = weak engagement and system failure risk.

How to fix it:

✔ Provide role-specific BCMS awareness training
✔ Include responsibilities in job descriptions or induction
✔ Review roles and readiness in test exercises
✔ Post quick-reference guides in critical areas

Real-world result:

Awareness ensures a faster, coordinated, and effective response during disruptions.

10. The Business Continuity Policy Is Too Generic or Inactive

📌 Clause: 5.2 – Business Continuity Policy

What’s going wrong:

Policies are vague, lifted from templates, or not aligned with actual business continuity goals. Staff often haven’t seen them.

Why it matters during an audit:

A strong policy sets the tone for the BCMS. Auditors evaluate how it’s developed, communicated, and implemented.

How to fix it:


✔ Tailor the policy to your organization’s mission, risks, and continuity objectives
✔ Approve it at the executive level
✔ Communicate it via intranet, training, or staff briefings
✔ Review it annually or when your strategy changes

Real-world result:

An active, visible policy reflects leadership commitment and aligns teams on resilience goals.

Strengthening Your ISO 22301 Compliance Journey

It is not only the accomplishment of getting the certifications of the ISO 22301 Lead Auditor Certification but also the establishment of a resilient business continuity management system (BCMS) that prepares an organization to withstand the disaster, protect stakeholders, and recover much faster than the competitors rather than just passing through an audit process.

Understand and respond to these 100 most common ISO 22301 audit failures and then implement this proactive approach to resilience through completing most essential Business Impact Analysis (BIA) updates, exercising your plans, engaging senior management, or even enhancing stakeholder awareness — each little improvement closes another hole in your risk landscape and strengthens your organization's continuity posture farther.

🔁 Continual Improvement is the Backbone of Resilience

Disruptions evolve, and so must your BCMS. Audits and scenario-based testing, reviews by management, and corrective actions all help to ensure that your plan remains in sync with evolving threats, technologies, and operations.

🗂️ Documentation and Testing Build Trust

Demonstration of preparedness through compliance plans with clearly pointed correctives and preventive actions makes a difference between the performance during audits and real events.

🏆 Turn Compliance into a Competitive Advantage

ISO 22301 certification signals to customers, partners, and regulators that your organization is serious about continuity and risk management. It’s not just a standard — it’s a differentiator.

Use this survival kit as a roadmap to smarter, more strategic business continuity. Stay prepared, stay operational — and let compliance drive your confidence, not your fear.

Download the Full List: Top 100 ISO 22301 Lead Auditor Audit Failures

To help you prepare for your next ISO 22301 certification audit, we’ve compiled a clause-by-clause breakdown of the 100 most common non-conformities seen in real audit scenarios.

✅ Understand what causes most audit failures — and how to fix them
✅ Align your BCMS with the ISO 22301:2019 framework clause by clause
✅ Use real-world findings to build stronger policies, strategies, and plans
✅ Prepare confidently for certification, surveillance, or internal audits

What’s inside:

  • 100 of the most frequent non-conformities raised in ISO 22301 audits
  • Clause references with detailed explanations
  • Actionable recommendations to correct each issue
  • Real-world outcomes that show what improvement looks like

This list is an essential companion to your ISO 22301 audit checklist, based on the principles and structure of the ISO 22301:2019 standard and validated against real-world findings.

Download the 100 ISO 22301 Audit Failures Guide Now

Make every audit count — and turn your continuity plan into a competitive edge.



Stay tuned for the next post in our ISO Survival Kit series — where we uncover the top audit failures from another critical ISO standard to help you stay ahead, stay certified, and stay resilient!

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Matthew Hale

Learning Advisor

Matthew is a dedicated learning advisor who is passionate about helping individuals achieve their educational goals. He specializes in personalized learning strategies and fostering lifelong learning habits.

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