What evidence do auditors commonly ask for on SP-03 Exceptions from Existing Policies and Instructions?

Exception register with unique identifiers, expiry dates and links to the corresponding risk entries; Approval evidence signed by the accountable risk owner for a sample of granted deviations; Records of the annual reconfirmation showing which deviations were closed, renewed or extended; Request workflow or form design that blocks a grant without a linked risk reference.

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

Deviations granted open ended and quietly become the permanent operating state

BSI C5 (121-criteria catalogue) · C5: Security Policies and Instructions

`SP-03` Exceptions from Existing Policies and Instructions

Route every deviation from security policies, instructions and the related controls through the risk management process, secure risk owner approval and residual risk acceptance, record each deviation with a defined expiry, and have risk owners reconfirm its appropriateness at least annually.

Source: BSI C5 (121-criteria catalogue), SP-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

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

Approval evidence signed by the accountable risk owner for a sample of granted deviations · Document repository
Records of the annual reconfirmation showing which deviations were closed, renewed or extended · Document repository

governing documentDocuments that govern the control

Exception register with unique identifiers, expiry dates and links to the corresponding risk entries · Policy repository / GRC workspace
Request workflow or form design that blocks a grant without a linked risk reference · 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

Deviations granted open ended and quietly become the permanent operating state
Expired entries left open while the underlying deviation continues in production
Approval given by the requesting team instead of the risk owner
Informal workarounds tolerated in operations and never registered as deviations

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

SP-02 Review and Approval of Policies and Instructions · SSO-01 Policies and instructions for controlling and monitoring third parties