What evidence do auditors commonly ask for on COM-03 Internal audits of the information security management system?

Internal audit programme covering the full management system scope; Internal audit reports issued within the last twelve months; Independence and competence records for the auditors used; Corrective action tracker showing findings through to verified closure.

What is the most common gap auditors find on COM-03?

Programme repeats the same familiar areas and leaves parts of scope unaudited

BSI C5 (121-criteria catalogue) · C5: Compliance

`COM-03` Internal audits of the information security management system

Have subject matter experts run internal audits at least annually to test whether the information security management system meets the identified legal, regulatory, self imposed and contractual requirements and internal policies, with findings risk assessed and corrective measures defined and tracked.

Source: BSI C5 (121-criteria catalogue), COM-03. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open BSI C5 (121-criteria catalogue) in the compliance library.

The edition of the catalogue is not stamped here; check the edition your attestation is issued against.

artefacts

held by a system

at each review

hard

to go live

Policy repository / GRC workspace

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

Independence and competence records for the auditors used · HR system / LMS

governing documentDocuments that govern the control

Internal audit programme covering the full management system scope · Policy repository / GRC workspace
Internal audit reports issued within the last twelve months · Policy repository / GRC workspace
Corrective action tracker showing findings through to verified closure · Policy repository / GRC workspace

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

Programme repeats the same familiar areas and leaves parts of scope unaudited
Auditors review processes they operate themselves
Findings logged without risk assessment or a due date
Actions marked complete with no evidence that they worked

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

COM-02 Policy for planning and conducting audits · COM-04 Information on information security performance and management assessment of the ISMS