What is the most common gap auditors find on COM-04?

Review held less often than once a year or skipped in a busy period

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

`COM-04` Information on information security performance and management assessment of the ISMS

Q: What evidence do auditors commonly ask for on COM-04 Information on information security performance and management assessment of the ISMS?

Management review minutes addressing security performance; Performance reporting pack presented to top management; Attendance record evidencing top management presence at the review; Decisions and resource allocations arising out of the review.

Report information security performance within the scope of the management system to top management on a regular basis, and carry that information into a management review of the system held at least once a year.

Source: BSI C5 (121-criteria catalogue), COM-04. 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

Document repository

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

Management review minutes addressing security performance · Policy repository / GRC workspace
Attendance record evidencing top management presence at the review · HR system / LMS
Decisions and resource allocations arising out of the review · Document repository

governing documentDocuments that govern the control

Performance reporting pack presented to top management · Document repository

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

Review held less often than once a year or skipped in a busy period
Reporting shows activity counts with no judgement on suitability or effectiveness
Review conducted by the security function alone without top management
Decisions taken but never assigned an owner or a deadline

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-03 Internal audits of the information security management system · COS-01 Technical safeguards