ISO 27001 internal audit: your rehearsal, done properly

The internal audit is where you find your own problems while they are still cheap. It needs a programme covering the whole system, auditors who did not build what they are examining, sampling of real records and interviews, and findings that drive corrective action.

By Alan Hutson, Certified ISO 27001 Lead Implementer, Certified ISO 27001 Lead Auditor, Certified Information Systems Security Professional (CISSP) · Reviewed November 2026

What does ISO 27001 require for internal audit?

Clause 9.2 requires audits at planned intervals, against defined criteria and scope, by auditors selected to be objective and impartial, with results reported to management and evidence retained.

In practice the certification auditor will ask for four things: the programme, who audited and why they were competent to, the reports, and what happened about the findings. Weakness in any one of the four is a recurring Stage 1 and Stage 2 finding.

What does a workable internal audit programme look like?

  • Cover every clause and every applicable control area across the programme cycle; riskier and previously weak areas more often.
  • Schedule audits through the year rather than one annual event, so evidence stays current for surveillance.
  • Name the auditor for each area in advance, and check they do not own what they audit.
  • Record auditor competence: training, experience, or supervised first audits.

What should you sample on the day?

AreaEvidence to sample
Clauses 4–7Scope, policy approvals, objectives, competence and awareness records
Risk (clause 6 and 8)Methodology applied as written, register currency, treatment progress, SoA accuracy
People controlsJoiners, movers and leavers; screening; training completion
Technology controlsAccess reviews, privileged access, backup restore tests, patching and logging records
SuppliersAssessments before go-live, contract clauses, review activity
Incidents and improvementIncident log through to lessons learned; corrective actions closed with root cause
InterviewsControl owners describing their process in their own words

Sample across the whole year. Three access reviews spread over the year prove a working control, while three produced in the same week prove a deadline.

What makes an internal audit finding useful?

Classify findings honestly: nonconformity where a requirement is not met, observation where it is met weakly. Each finding needs evidence, an owner and a date, and closure needs root cause (see my guide to major and minor nonconformities).

Feed the results into management review. An audit programme whose findings go nowhere is a finding in itself.

Who should audit if nobody internal is impartial?

Small organisations often cannot separate builder from auditor, which is the normal case for a standalone external internal audit. An independent Lead Auditor examines the system, reports findings in the format a certification body expects, and leaves your team to fix them without marking its own homework.

It is one of the services set out in my guide to ISO 27001 costs.

Frequently asked questions about ISO 27001 internal audit

Related ISO 27001 guides

ISO 27001 Stage 1 vs Stage 2 audits: what to expect

What each stage of the certification audit examines, what auditors ask for, how findings are graded and how to prepare for both.

Read the guide

Preparing for an ISO 27001 surveillance audit

What a surveillance audit covers, what auditors typically ask for and how to prepare without a last-minute scramble.

Read the guide

Major vs minor nonconformity: meaning and how to respond

How audit findings are graded, what blocks certification, closure timescales, and the four-part corrective response auditors accept.

Read the guide

How much does ISO 27001 certification cost in the UK?

The three costs that make up the total (implementation support, certification-body fees and your own team's time), with published UK market fees and my indicative fees.

Read the guide

Need an independent internal audit?

Arrange a readiness discussion. I audit as I would expect to be audited, and report what I find in a form your certification body will recognise.

Or email info@isosecurity.co.uk