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Audit template

Internal Audit Plan

Annual internal audit plan template with scope and schedule.

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DOCX
Category
Audit
Pages
14
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Internal audit

Planning an internal audit program that finds problems before your auditor does

Internal audit is the ISMS checking itself. Done well, it is the cheapest source of findings you will ever get: problems surface on your own schedule, with time to fix them before a certification or surveillance audit. Done as a box-ticking exercise, it produces a clean report that the external auditor promptly contradicts. This template gives you a starting structure for an annual plan with scope and schedule. The guidance below covers what the plan must contain, how to prioritize, and how to stay independent when your team is small.

What ISO 27001 clause 9.2 requires

ISO/IEC 27001:2022 clause 9.2 requires internal audits at planned intervals to determine whether the ISMS conforms to the organization's own requirements and to the standard, and whether it is effectively implemented and maintained. The organization must plan, establish, implement, and maintain an audit programme covering frequency, methods, responsibilities, planning requirements, and reporting, taking into account the importance of the processes concerned and the results of previous audits.

  • Define audit criteria and scope for each audit.
  • Select auditors and conduct audits so the process is objective and impartial.
  • Report results to relevant management.
  • Retain documented information as evidence of the programme and the audit results.

Certification bodies generally expect at least one completed internal audit and a management review of the ISMS before the Stage 2 certification audit. ISO 19011 provides general guidance on auditing management systems, and ISO/IEC 27007 applies that guidance to information security management systems.

Build the plan from risk, not from the clause list

Start with an audit universe: every ISMS clause (4 through 10) and every applicable control from your statement of applicability. Then prioritize. Areas with high risk ratings, recent incidents, previous findings, significant change, or immature processes get audited earlier and more deeply. Stable, low-risk areas can be covered more lightly, as long as the full scope is covered across the certification cycle. Pull the risk ratings directly from your risk register so the rationale is traceable.

Illustrative annual schedule

Illustrative annual schedule
Q1Access control and identity lifecycle (Annex A 5.15 to 5.18, 8.2)High-risk area; leaver findings in prior yearSample-based testing against HR records
Q1Risk assessment and treatment (clauses 6.1.2, 6.1.3, 8.2, 8.3)Annual risk assessment just completedDocument review and re-performance of scoring
Q2Supplier security (Annex A 5.19 to 5.22)New critical vendors onboardedSample vendor files against tiering requirements
Q2Change management and secure developmentMajor platform migration in progressSample changes and pull requests
Q3Incident management and business continuity (5.24 to 5.30)Follows the annual tabletop exerciseReview exercise output and incident records
Q3Physical and people controlsLower risk; office move completedWalkthrough and interviews
Q4Leadership, objectives, competence, documented information (clauses 5, 6.2, 7)Feeds management reviewInterviews and document review
Q4Follow-up of all open findingsVerify corrective actions before surveillance auditRe-test

Independence when the team is small

Auditors must not audit their own work. In a small company where one person built most of the ISMS, that takes deliberate arrangement. Workable options include:

  • Cross-auditing: a trained colleague from another function audits security processes, with the security lead auditing areas they do not operate.
  • Outsourcing: an external consultant or vCISO performs some or all internal audits. The organization still owns the programme and the follow-up.
  • Hybrid: outsource audits of areas the security lead owns and perform the rest internally.

Grading and reporting findings

Grade, Meaning, Expected response comparison
Major nonconformityA requirement is not met at all, or a failure casts serious doubt on the ISMS achieving its outcomesRoot cause analysis and corrective action, prioritized for closure well before the external audit
Minor nonconformityAn isolated lapse that does not undermine the requirement overallCorrective action with owner and date
ObservationNot a nonconformity yet, but a weakness likely to become oneConsider action; track
Opportunity for improvementA suggestion to strengthen an already conforming areaOptional, recorded for management review

Each audit report should state scope, criteria, auditor, dates, what was sampled, findings with evidence, and a conclusion. Nonconformities flow into corrective action under clause 10.2, and a summary of audit results is an input to management review under clause 9.3. A CAPA process keeps each finding tied to a root cause, an action, and verification of effectiveness.

Beyond ISO 27001

SOC 2 CC4.1 expects ongoing or separate evaluations to confirm controls are present and functioning, and CC4.2 expects deficiencies to be communicated to those responsible for corrective action. The HIPAA Security Rule requires periodic technical and nontechnical evaluation under §164.308(a)(8). An internal audit plan built on a shared control set can test controls once and report against several frameworks.

Evidence of a functioning programme

  • Approved audit programme showing scope, frequency, methods, and responsibilities
  • Rationale linking schedule priorities to risk and previous results
  • Record of auditor selection addressing objectivity and impartiality
  • Audit reports with working papers or sample lists
  • Corrective action records with verification of effectiveness
  • Management review minutes showing audit results were considered

Asurvo's Audit product supports internal as well as external audit workflows, with requests, evidence, findings, and remediation in one place. The internal auditor role page describes how that looks day to day.

FAQ

Frequently asked questions

How often should ISO 27001 internal audits be performed?

ISO 27001 requires audits at planned intervals without fixing a frequency. Most organizations run an annual programme that covers higher-risk areas every year and the full ISMS scope across the three-year certification cycle, with many choosing to cover everything annually. Certification bodies expect an internal audit to be completed before the Stage 2 audit.

Can the internal audit be outsourced?

Yes. ISO 27001 requires objectivity and impartiality, not that auditors be employees. Many small and mid-sized organizations use external consultants. The organization still owns the audit programme, must retain the results, and remains responsible for corrective actions and reporting to management.

What should an internal audit plan include?

The audit universe and scope, audit criteria, a schedule with rationale based on risk and previous results, methods, assigned auditors and how independence is ensured, reporting lines, finding classification, and how corrective actions are followed up. Each individual audit then gets its own scope, criteria, and report.

What is the difference between a major and minor nonconformity?

A major nonconformity is a failure to meet a requirement that raises serious doubt about the management system achieving its intended outcomes, such as no risk assessment at all. A minor nonconformity is a limited or isolated lapse, such as one missed access review. Certification bodies define these terms in their own procedures, so check yours.

Who receives internal audit results?

Clause 9.2 requires results to be reported to relevant management, typically the owners of audited areas and the ISMS lead. Results are also a required input to management review under clause 9.3, where top management considers them alongside other performance information and decides on actions.

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