The 100 Most Common ISO 27001 Audit Failures (And How to Fix Them)

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Written by Matthew Hale

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Achieving ISO 27001 certification is a rigorous process that requires a strong Information Security Management System (ISMS) and adherence to strict compliance measures. 

 

Yet, many organizations struggle with common non-conformities that auditors frequently encounter. These gaps in compliance can cause delays, increase security risks, and, in some cases, prevent certification altogether.

 

To help businesses navigate this challenge, we interviewed over 200 experienced ISO 27001 auditors and spent countless hours analyzing real-world audit reports. 

 

This research has resulted in an ultimate guide covering the 100 most common ISO 27001 non-conformities and how to fix them.

 

In this blog, we will explore the most common non-conformities organizations face during ISO 27001 audits, explaining why they happen, their impact, and actionable steps to resolve them.

1. No Clearly Defined Overall Risk Management Procedure

📌 ISO 27001 Clause: 6.1.2 – Information Security Risk Assessment

What happens?

Many organizations lack a structured risk management process, meaning they do not properly identify, assess, and mitigate security risks.

This often results in reactive, uncoordinated security decisions instead of a proactive, well-documented approach.

Why is this a problem?

Without a clear risk management procedure, organizations fail to prioritize security threats, leaving themselves vulnerable to cyberattacks, data breaches, and regulatory fines.

Auditors will see this as a major compliance gap.

How to fix it?

✔ Develop a formal risk assessment framework detailing how risks are identified, evaluated, and treated.
✔ Use a risk register to document risks, their impact, and assigned mitigation measures.
✔ Conduct regular risk assessments to adapt to evolving threats.
✔ Involve top management in risk reviews to ensure strategic alignment.

2. Weak Evidence of Risk Treatment

📌 ISO 27001 Clause: 6.1.3 – Information Security Risk Treatment

What happens?

Security risks are acknowledged by many organizations; however, treatment plans are rarely written.

This is to say, verbal confirmations and incomplete spreadsheets cannot form enough evidence for auditors.

Why is this a problem?

Auditors need to be able to provide proof that these risks are not only registered but are also being managed.

Indeed, the lack of documentation raises compliance concerns, which weaken security governance.

Auditors need documentary evidence that the risks are not only established but controlled as well. The lack of documentation raises questions about compliance and compromises the integrity of security governance.

How to fix it?

✔ Establish a Risk Treatment Plan (RTP) detailing how each risk is addressed.
✔ Assign clear ownership and deadlines for risk mitigation actions.
✔ Maintain audit logs of all security measures implemented.
✔ Regularly review and update the risk treatment plan as new threats emerge.

3. No Scheduled Internal Audits or Management Reviews

📌 ISO 27001 Clauses: 9.2 – Internal Audit & 9.3 – Management Review

What happens?

Some organizations do not conduct internal audits or management reviews as required by ISO 27001. Others perform them inconsistently or fail to keep records of findings and corrective actions.

Why is this a problem?

Internal audits are crucial for identifying compliance gaps before external audits. Without them, non-conformities remain undetected, increasing the risk of audit failure and security incidents.

How to fix it?

✔ Schedule internal audits annually and ensure findings are well-documented.
✔ Conduct management reviews regularly to assess ISMS performance.
✔ Implement corrective action plans for audit findings.
✔ Use audit management tools to streamline tracking and reporting.

4. Missing or Weakly Defined Statement of Applicability (SoA)

📌 ISO 27001 Clause: 6.1.3(d) – Statement of Applicability

What happens?

The SoA outlines what security controls apply to a given organization, being another key ISO 27001 document.

Many companies do not justify why a particular control has been included or excluded, creating a misalignment with the risk assessment.

Why is this a problem?

A weak SoA raises red flags during an audit because it reflects poor risk governance and a lack of alignment with ISO 27001 requirements.

How to fix it?

✔ Ensure the SoA clearly defines applicable Annex A controls and provides justifications for any exclusions.
✔ Regularly update the SoA to reflect organizational and regulatory changes.
✔ Maintain cross-references between the SoA, risk treatment plan, and ISMS documentation.
✔ Use automated ISMS tools to manage and track control implementation.

5. No Defined Metrics for ISMS Performance

📌 ISO 27001 Clause: 9.1 – Monitoring, Measurement, Analysis, and Evaluation

What happens?

Most organizations are without clear Key Performance Indicators (KPIs) to measure the effectiveness of ISMS programs.

When this is the case, then the performance of a security program is often evaluated subjectively rather than through measurable data.

Why is this a problem?

Without quantifiable security objectives, organizations struggle to demonstrate compliance, leading to poor decision-making and a lack of accountability.

How to fix it?

✔ Define security KPIs, such as incident response times, compliance scores, and security training completion rates.
✔ Conduct quarterly ISMS performance reviews with management.
✔ Align security metrics with business risk strategies.
✔ Use automated dashboards to track and visualize security performance.

Get the Full List of 100 Common Non-Conformities!

These few non-conformities happen to be the just start. Being ISO 27001 compliant calls for a well-elaborated process and an organization has to work at closing all security gaps to guarantee a smooth audit experience.

📥 Download our full guide featuring 100 detailed non-conformities, real-world examples, and step-by-step solutions to ensure a successful ISO 27001 certification!

Why Download This Guide?

✅ Created with insights from 200+ auditors to reflect real-world ISO 27001 challenges.
✅ Covers the most frequently found ISO 27001 audit issues to help you prepare.
✅ Includes practical solutions you can implement immediately.
✅ Saves time and effort by guiding you through a structured compliance approach.

Don’t leave your ISO 27001 audit to chance—download the full guide now and take control of your compliance journey!

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Strengthening Your ISO 27001 Compliance Journey

ISO 27001 compliance is not just an audit element; it is about IT security improvement in a continual manner.

For each of these common non-conformities, addressing them will help not only compliance but also enhance the organization's overall security.

Threats evolve, so active risk management, periodic audits, and clear documentation of security controls are the ongoing imperatives to maintain an effective ISMS.

Those organizations treating ISO 27001 as a continual process instead of a one-time certification will be in a better position to safeguard their data, reputation, and business continuity.

Addressing the solutions in this guide will enhance audit preparedness, mitigate the risks of compliance, and fortify long-term security strength

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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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